Responding department: Corporate Social Responsibility
Stock Exchange Symbol: (ORA:FP)
Does your company have a publicly available commitment to respect human rights?
Yes, Orange was one of the first companies to join the United Nations Global Compact in 2000, asserting its commitment to respecting and promoting basic human rights in its activities and sphere of influence. The commitment to respect and promote human rights is explicitly included in the Group’s Code of Ethics created in 2003. See the link: [link]
The Group commitments concerning human rights are implemented through three big themes: human resources, freedom of expression and purchasing.
1. human resources
In December 2006 France Telecom and the Worldwide Trade Union Alliance UNI have signed a worldwide agreement on fundamental labour rights in the France Telecom Group and committed itself to apply fundamental ILO agreements, particularly :
- prevent the use of forced labour,
- prohibit child labour and exploitation,
- combat unfair discrimination,
- seek to ensure health and safety at work,
- uphold the principle of freedom of association and the effective recognition of the right to collective bargaining.
See the link: [link]
- In 2010 Orange Launched the New Social Contract in France to define Company’s professional practices and management culture. See: 2014 Orange registration Document p.35
- Since the end of 2011 Orange has implemented the Orange People Charter, rolling it out globally across 23 different countries. See the link: [link]
- In November 2014 Orange signs a global Group agreement in the health and safety field. See the link: [link]
-For more commitments concerning HR, see the link: [link]
2. freedom of expression and privacy:
- In March 2013, as a member of Industry Dialogue (see question 8) , Orange signed principles that provide a common frame of reference for the elaboration of policies and processes relative to protection of privacy and freedom of expression. These principles are available on orange.com: [link] or on the Industry Dialogue website: www.telecomindustrydialogue.org
- The Group has also signed a two-year partnership with the Global Network Initiative (www.globalnetworkinitiative.org) for collective reflection and to exchange good practices with regard to the challenges posed by freedom of expression and protection of privacy within the telecommunications sector.
- At the Group level, the CEO Stéphane Richard signed the personal data charter in 2013 which outlines the Group’s four commitments on privacy: 1) Security of customers' personal data through its reliable processing and secure storage. 2) Control for customers over their own personal data and how it is used, including a personal dashboard. 3) Transparency in terms of the handling of data for its customers and users at all stages throughout the relationship and 4) Support for all its customers and users to help them protect their privacy and manager their personal data better. See the link: [link]
- In 2013 Orange updated its sustainable procurement policy , which is structured around two themes:
- act as a responsible company, implementing Corporate Social Responsibility concerns into its governance and internal processes of purchasing and logistics and contributing to country development and the local employment by means of its purchasing
- ask its suppliers and subcontractors to reach its CSR standards and to implement them within their own supply chain. See the link: [link]
As a member of the Joint Audit Cooperation ( JAC) Orange drew up guidelines in 2013 to facilitate understanding of shared CSR expectations bysuppliers and to support implementation throughout the audit and monitoring process. See the link: [link]
- Orange ensures that human rights are respected throughout the entire subcontracting chain. That is why Group contractors and suppliers sign a contractual agreement to respect a Supplier Code. See the link: [link]
How are human rights governed in your company?
The responsibility for human rights is shared by several bodies in the highest level in the organization. Human rights, being a part of Orange’s CSR approach are underpinned by a dedicated organisation, involving all employees in every business and country in which the Group operates:
- the Governance and Corporate Social Responsibility Committee, formed by the Board of Directors, ratifies strategic CSR approach and procedures. The Committee reports directly to the Board of Directors and provides Orange with the organisational structure to guarantee that CSR challenges inform policy at the highest decision-making level.
- the CSR Department: headed up by a member of the senior management team, the department ensures that guidelines is deployed throughout the Company’s operations by providing technical and methodological support to subsidiaries and reporting on projects to the Group Executive Committee;
Furthermore, as part of the implementation of its new Social Contract, in 2012 Orange established a new Group Policy on Occupational Health, Safety and Quality of Life, with specific targets and indicators. Orange has set up a dedicated structure within the organization to steer the implementation of this policy in each Group entity:
- a Strategic Health and Safety Committee, chaired by a member of the Executive Committee;
- an Occupational Health, Safety and Quality of Life Department.
To support international development of social dialogue, the Group has implemented social dialogue bodies covering all activities at all levels:
- at global level: Global Group Committee: including 31 members elected for 4 years representing 22 countries with more than 400 employees in each one;
- in Europe: European Works Council comprising 28 employee representatives from 19 European countries;
- at national level: employee representation bodies have been set up in 27 of the Group’s countries.
Externally, Orange is a founding member of the Telecommunications Industry Dialogue (ID) since 2011, the ID sets out to address freedom of expression and privacy rights issues for the sector. Yves Nissim, VP, Head of Transformation and Operation in CSR, was chair of this organization from September 2013 to April 2014.
How are human rights managed within your company?
The human rights management theme is very broad and complex, so that Orange has been undertaking many measures to ensure proper approach to this extensive issue. Some of them (e.g. grievance procedures, stakeholder engagement, cooperation with external bodies) are described in more details in different sections of this questionnaire. In this section we will concentrate on the crucial points related to human rights management in Orange.
Human rights impacts identification and assessment
In 2013 Orange launched a human rights impact study with the aim of prioritising impacts in each country in which the Group operates. We used the human rights risk atlas services of Maplecroft to rank the risk potential for its operations in each of the countries where the company is present. The Group level preliminary human rights impact assessment framework includes an examination of laws affecting privacy and freedom of expression in jurisdictions where the company operates to inform company policies and practices for mitigating risks to users’ rights.
Prevention of negative human rights impacts
To manage and prevent negative human rights impact, Orange is analysing its internal processes focusing at human rights as well as engaging stakeholders and cooperating with external partners.
- Example 1: Orange is a founding member of the Telecommunications Industry Dialogue since 2011, the ID sets out to address freedom of expression and privacy rights issues for the sector. As a member of the ID, Orange has agreed to abide by the joint action principles (signature of the ID principles in March 2013), one of which is to conduct human rights impact assessments.
- Example 2: To improve the incorporation of CSR aspects by suppliers, the Group initiated a cooperation agreement in 2009 (Joint Audit Cooperation – JAC) with Deutsche Telekom and Telecom Italia to combine their CSR audits of suppliers according to a common methodology based on the social responsibility and environmental standards, SA 8000.
Promotion of human rights among business partners
Orange ensures that human rights are respected throughout the entire subcontracting chain. That is why Group contractors and suppliers, like their subcontractors, sign a contractual agreement to respect a Supplier Code, alongside CSR contractual clauses, the principles of which are as follows:
- combating any and all forms of compulsory or forced labour;
- combating child labour;
- working conditions must be safe;
- respecting the environment in the manufacturing processes.
These principles are applied within Buyln, the partnership with Deutsche Telekom to share purchases between the two Groups (in particular for devices, mobile communication networks or landline equipment).
Every supplier is assessed once or twice a year on CSR issues either through the QREDIC® tool, created by the Group, or by specialist contractors such EcoVadis, or on site, in partnership with other telecommunications operators, within the framework of the Joint Audit Cooperation (JAC). This involves 9 European and 1 American operators for the purposes of assessing their shared suppliers in relation to social responsibility as defined by the SA 8000 standard and environmental responsibility defined by ISO 140001. All these audits are used to produce plans of action to correct the risks or weaknesses which have been identified.
Furthermore in 2013, the Compliance Officer was appointed in the Purchasing Department.
Training on human rights
Human Rights is a section of our CSR and ethical trainings, some of the trainings are compulsory for managers and employees. We are working to reinforce the knowledge about human rights among different functions in the company.Example: Preparation of a comprehensive CSR training program by the Sourcing University, created in 2013, structured on three levels:
- generic Group modules to raise awareness (CSR, ethics, and more);
- “responsible supplier relations and responsible purchasing” module
- new CSR workshops to encourage transposition of CSR principlesinto the purchasing process;
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 engagement of stakeholders is a crucial element of Orange approach to human rights which is based on constant dialogue with different groups of stakeholders. We believe that in the challenging areas of human rights, working together with our stakeholders can bring the most efficient solutions and the best results in a long run. We include topics related to fundamental human rights (e.g. privacy, human rights in supply chain) to our Group Stakeholder Dialogue. In November 2013 we engaged our stakeholders in a dialogue on freedom of expression and privacy during an Internet governance forum, with considerable participation on the part of NGOs.
Orange cooperate with operators and manufacturers in the telecommunications sector to establish a joint dialogue with stakeholders on human rights issues. More specifically, the Industry Dialogue addresses two key issues for the sector, namely freedom of expression and customer privacy (see Industry Dialogue, question 8). To influence more effectively the behavior of suppliers and combine CSR audits, Orange initiated an agreement with other operators (Joint Audit Cooperation – JAC). The process of drawing up JAC guidelines in 2013 is a very good example of stakeholder engagement.
Based on the findings of audits by JAC members over a number of years, the guidelines were established following dialogue with the stakeholders concerned: the draft text was sent for ratification to a number of specialist external firms (with expertise in environment, work organization, occupational health and safety, human rights and other specific areas). A total of 52 opinions and comments on the draft were received during the process. The third JAC forum on 16 January 2014 in Chengdu (China) was attended by 137 participants, including operators, suppliers, NGOs and audit fi rms. Discussions were lively and included a very extensive debate on the Guidelines during the plenary session, which were then sent to the participants following the forum.
Priority human rights issues: What are some of the priority human rights issues for your company?
The company selected the following from a check list:
- Health (including workplace health & safety, prevention of pollution)
- Workplace diversity / non-discrimination
- Forced labour and human trafficking (including in supply chains)
- Freedom of association and trade union rights
- Freedom of expression and/or right to privacy / digital rights
- Conflict minerals
- Children (including child labour)
- Other issue(s): human rights in supply chain
Actions on health
E.g. new Group agreement in the health and safety field. See the link: [link]
Actions on workplace diversity / non-discrimination
E.g. encouraging women’s access to positions of responsibility, with the aim of having, between now and 2015, 35% female representation in its management bodies. See 2013 Orange CSR report p. 43-45.
Actions on freedom of association and trade union rights
E.g. Group has implemented social dialogue bodies covering all activities at all levels:
- at global level: Global Group Committee: including 31 members elected for 4 years representing 22 countries with more than 400 employees in each one;
- in Europe: European Works Council comprising 28 employee representatives from 19 European countries
See Orange 2013 CSR Report p. 34.
Actions on freedom of expression and privacy
E.g. participation in Industry Dialogue (see question 8 and Orange 2013 CSR Report p. 14-15)
Actions on conflict minerals
E.g. update of Group processes to collect and escalate information from suppliers and take steps to encourage them to limit use of rare materials and those originating from conflict areas in the world, substituting them with recycled resources etc. See Orange 2013 CSR Report p. 97.
Actions on 'other' issues
Human rights in supply chain e.g. participation in Joint Audit Cooperation. See Orange 2013 CSR Report p. 27.
How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?
To communicate about our approach and actions regarding human rights we use different kinds of tools:
- In Orange registration document there is a section about Governance and CSR (including human rights) See 2013 registration Document p. 313-381;
- In Orange 2013 CSR Report. See p. 9-25; 33-43; 57;
- Through our website: [link]
- Internally, through CSR section in the intranet
- Internally, Human Rights is a section of our CSR and ethical trainings, some of the trainings are compulsory for managers and employees
- We are addressing specific CSR issues by participating in working groups and initiatives focused at specific topics e.g. Industry Dialogue [link]
- We are members and partners of many initiatives focused on Human Rights (see question)
- We are responding to public concerns through our public commitments e.g. Privacy Charter Signed by CEO in 2013: [link]
- We answer on questionnaires and investors’ questions regarding human rights
- In 2015 we are planning to publish Orange Transparency Report
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?
We use several measures:
- Company training programs containing sections on human rights for managers and employees
- Whistle blowing procedure for employees
- Official company pro-active measures to respect fundamental human rights e.g. industry dialogue
- audits of suppliers: 112 audits were conducted in 15 countries on five continents since 2010. 374 corrective actions were completed, out of a total of 638, covering 83 plants and 400,000 or more workers.
Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?
Orange was one of the first companies to join the United Nations Global Compact in 2000, asserting its commitment to respecting and promoting basic human rights in its activities and sphere of influence. In 2006, Orange signed with the UNI Global Union an agreement on basic social rights within the Group.
The Group also takes part in the “Industry Dialogue”, which is a union of operators and manufacturers in the telecommunications sector with the aim of establishing a common dialogue with stakeholders with respect to human rights. It focuses on two key challenges for the telecommunications sector: freedom of expression and protection of privacy. It is primarily based on the international framework of the UN: “Protect, Respect & Remedy”. In 2012, the participating companies jointly developed guiding principles that address the issues of privacy and freedom of expression as they relate to the telecommunications sector, specifically exploring the interaction and boundaries between a government’s duty to protect human rights and the corporate responsibility of telecommunications companies to respect human rights.
As a founding member of Industry Dialogue, the Group actively participated in 2012 in defining these guiding principles. Similarly, the Industry Dialogue has reached a services agreement with the Global Network Initiative (GNI) to facilitate dissemination of the principles and develop new tools to support their implementation.
Orange is also involved in a working group on the broader human rights program established by the Global e- Sustainability Initiative (GeSI), a sector organization which aims to share best practices in this area. To improve the incorporation of CSR aspects by suppliers, Orange is convinced that all companies in the sector should pull together: cooperation between competitors creates the opportunity to more effectively infl uence supplier behaviour. To further this aim, the Group initiated a cooperation agreement in 2009 (Joint Audit Cooperation – JAC) with Deutsche Telekom and Telecom Italia to combine their CSR audits of suppliers according to a common methodology based on the social responsibility and environmental standards, SA 8000. See: Registration Document 2013, section 184.108.40.206, p.371
Complete CSR Report 2013, p. 14-15
Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.
Since June 2011 our approach to human rights has significantly developed in following areas:
- Freedom of expression and privacy (especially through creation of Industry Dialogue, that is primarily based on the international framework of the UN: “Protect, Respect & Remedy” and signature of the ID principles in March 2013.
- Human Rights in supply chain (As a member of the Joint Audit Cooperation ( JAC) Orange drew up guidelines in 2013 to facilitate understanding of shared CSR expectations by suppliers and to support implementation throughout the audit and monitoring process).
- Support for human rights by encouraging access to sustainable technologies, and supporting ICT-enabled transformation across all industries and sectors around the globe (through our participation in the Global e-Sustainability Initiative (GeSI).
What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?
The main constraints concerning the implementation of commitments are related to the limited role of companies/ business to be a lever of transparency. This topic is managed mostly by governments and we are obliged to follow the national legislation on different markets. For that reason, sometimes it can be very difficult to respond to demand for greater transparency. Another challenge is related to the human rights in supply chain, where we cooperate with our competitors to create the opportunity to more effectively influence supplier behavior ( cooperation agreement initiated in 2009 (Joint Audit Cooperation – JAC).
Internally, we are focused on continuous improvement of our employees’ well-being by putting through our six commitments:
- act as a responsible employer;
- offer career and development opportunities;
- provide a work environment for outstanding customer satisfaction;
- empower managers and hold them accountable for progress and success;
- provide a positive quality of life at work;
- recognize and reward employees for their individual and collective contributions to our success.