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Responding department: Group Sustainability

Stock Exchange Symbol: (MTN:SJ)

Does your company have a publicly available commitment to respect human rights?

Yes, a stand-alone policy is maintained. The Group's publicly available commitment is available at [link].

How are human rights governed in your company?

The Group Board has delegated responsibility for sustainability to the Group Social and Ethics Committee. ICT Human Rights matters are overseen by this Committee, which comprises both members of the Group Board, and the Group Executive Committee. Within country operations, responsibility ultimately rests with the operations Executive Committee. Depending on the nature of the issue, different committees and business functions are responsible for resolution e.g. IT security and network functions, corporate services, etc.

How are human rights managed within your company?

Group level, country-specific, and business continuity risks and mitigation/ management and compliance processes in all MTN countries of operation are addressed and managed through the Group’s Business Risk Management process, which includes a list of the Group’s Principle Risks, a set of 23 risks of most relevance to MTN. These risks are reviewed, monitored and managed by the relevant executive for each risk, on an ongoing basis, within all MTN countries of operation. As the profile/ probability/ impact of risks will vary for the macro operating conditions specific to each country, each country’s management team develops context-specific mitigation and management responses. For example, in some countries, the business risk management team is complemented by executive level emergency response teams, comprising senior level management, to ensure that political, social and human rights risks, amongst others, are managed and addressed on an ongoing basis. In other countries where the risk is less prominent, human rights risks and impacts are managed by legal, corporate affairs or other functions more operationally. ICT Human Rights is a material sustainability issue for the Group, and work is underway to ensure existing/ new processes are adequately structured for appropriate management. As this imperative is work-in-progress, some process matters related elements of PR17-21 including training, grievance mechanisms effectiveness tracking require further development and implementation time.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

The Group's stakeholder engagement process is detailed in the annual Integrated Business Report, the most recent version of which is located at [link] (see page 10). The updated version will be published at the end of March 2015. On human rights issues, the Group hold regular discussions with a number of civil society organisations, ESG investor groups, and to a lesser degree media and business associations on an ongoing basis.

Priority human rights issues: What are some of the priority human rights issues for your company?

  • Health (including environmental health, workplace health & safety)
  • Workplace diversity / non-discrimination
  • Operations in conflict zones
  • Freedom of expression and/or right to privacy / digital rights
  • Transparency in payments to governments /responsible tax practices

Actions on 'other' issues

Please see these links for more information. Updated information will also be published at the end of March 2015.

  • Freedom of expression/ privacy: [link]

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

The annual Sustainability Report (including UN Global Compact and UN GRI reporting) provides a formal means of communicating to all stakeholders, and is available at [link] (last updated March 2014; next update March 2015). We engage in discussions on a regular and ongoing basis with civil rights organisations and a number of MTN's mainstream and ESG-focused investors. To a lesser degree, we also respond to queries from media, business associations, and general members of the public (as received).

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

Grievance procedures and access to remedy processes are still under development.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

UN Global Compact and GSMA.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

  • The challenge to all ICT sector operators in balancing the broader socio-political implications of offerings which, while enabling positive societal benefit, may inadvertently also create risk to both the operators and users of their communication services
  • Balancing the challenges faced by telecommunication service providers who may only operate by way of regulatory licences globally, and are therefore subject to local legislation, which may sometimes be at odds with global standards and expectations.
  • The lack of a globally defined and generally understood and accepted digital laws and regulations governing digital rights.