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Responding department: Global Directorate for Corporate Identity and Sustainability

Stock exchange symbol: (TEF:SM)

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

Specific human rights policy: [link]  [link]

How are human rights governed in your company?

The Institutional Affairs Committee, as the top governing body of Reputation and Corporate Social Responsibility, where the implementation and development of our sustainability strategy is consolidated and reinforced. The Global Directorate for Corporate Identity and Sustainability oversees all human rights issues. As set out in our commitment, our Human Rights strategy is built around five core components covering our sphere of influence: our people, our technologies, our business partners, our role in communities and our role in change.

How are human rights managed within your company?

For the implementation of the Guiding Principles, we have defined a formal process to simplify the proactive management of risks and to make the most of opportunities, involving our principal stakeholders. To this end, and with the external support of BSR, Business for Social Responsibility, we carried out a global assessment of our impact as regards human rights, taking into account the following objectives:

1. To raise awareness and develop internal expertise and experience within the organisation, based on interdisciplinary teams.

2. To obtain an overall vision of the impact of our activity in human rights, identifying the risks and opportunities, both at corporate and local level. This assessment allowed us, in 2012, to prioritise the most important aspects and to define a road map for the Company for 2013-2015, in this area. We identified 71 human rights and 15 priority topics. We conducted an assessment at local level (16 countries) using more than 300 relevant documents, involving 200 people and assessing 200 topics. The outcome was a total of 16 reports and presentations for each country, a corporate report and 9 cross-disciplinary reports with the consolidation of all countries for each topic.

Based on our Business Principles, we require that our suppliers carry out their activity applying similar principles and that they comply with the law and regulations in force in the countries in which they operate. Our Business Principles include the minimum requirements on social, occupational, environmental and ethical matters with which all our suppliers must comply. For this, we have made an online course available to them, accessible at our supplier portal: [link]. Human rights are one of the aspects covered. It is a priority for Telefónica that our employees are aware of the spirit and letter of our Code of Ethics. This is the basis for building a culture where employees understand what is required of them and their own responsibility in the observance of the Business Principles. An online training course on Our Business Principles has been included within the employees’ professional training plans. In this activity, by means of varied scenarios, the importance to the Company of having ethical directives, their responsibility as professionals to abide by them and the channels of assistance to resolve doubts or handle allegations are all explained.

By December 2013, more than 73,000(1) employees (63% of the workforce) had passed the Business Principles course. Likewise, it should be noted that Telefónica Colombia has developed various initiatives and action plans resulting from diagnoses made locally in 2011 and 2012 as part of the overall assessment of the impact of Telefónica on human rights. They include: Training Course on Human Rights. As part of the due diligence process and in order to strengthen capacity and awareness in relation to certain specific risks within the company, in 2013 they worked on the design and usability of the Human Rights training course for employees through the A+ training platform. They have set themselves the challenge of training 80% of the employees in Colombia during 2014 (pending verification in the 2014 Sustainability Report). At Telefónica, monitoring is undertaken by means of a structured plan to develop and strengthen several different projects on a global and local basis, adapting them to the different contexts in the 16 countries where the assessment was carried out. The main lines of action of the plan were as follows: - Share the findings with the areas involved at local level. - Integrate the findings, identifying the existing policies, strategies and management systems. - Arrange internal and global working groups to manage key aspects that appeared after the assessment, such as the Working Group on Privacy and Freedom of Expression and the Working Group on Business and Children’s Rights. - Start building a map of stakeholders and multistakeholder platforms.

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?

More than 200 Telefónica employees were involved in the Human Rights impact assessment and, in the interviews with stakeholders, questions were asked about each of the issues identified. [link]   

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
  • Forced labour and human trafficking (including in supply chains)
  • Sexual harassment
  • Freedom of association and trade union rights
  • Freedom of expression and right to privacy
  • Conflict minerals
  • Access to Health
  • Access to Education
  • Indigenous Peoples
  • Corruption and Bribery

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

Sustainability Report: [link]. Online Corporate Responsibility and Sustainability channels:  [link]. Social Responsible SRI indices: DJSI, etc.

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?

Business Principles Office: [link]. In 2013, The Business Principles Office recorded a total of 77 communications through the Business Principles channel. Of the 63 whose investigation has concluded, 14 turned out to be well-founded, one of them being for corruption (considered non-material) and none for discrimination.

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

  • Global Network Initiative (GNI), as a member of the Telecom Industry Dialogue on Freedom of Expression and Privacy: [link]  
  • The Global Compact in Spain
  • Working Group on Business and Human Rights to guide the implementation of the Guiding Principles
  • International Organisation of Employers (IOE)
  • Participation in Human Rights conferences: [link]
  • European Telecommunications Network Operators' Association (ETNO) - As members of the Sustainability Working Group
  • UNICEF - Telefónica is the only Spanish company to have taken part in the pilot project
  • to eradicate child labour from the supply chain. Through our “Aquí estoy y Actúo” (I’m here and I’m acting) app, the company has signed up to the Children’s Rights and Business Principles initiative developed by UNICEF, the United Nations Global Compact and Save the Children. [link] -
  • CSR EUROPE [link].

As members:

  • European Commission - Comments on ICT Sector Guide on Implementing the UN Guiding Principles on Business and Human Rights.
  • Spanish National Business and Human Rights Plan. Members of the working group for its development.

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.

  • It is fundamental for Telefónica to perform an a priori risk evaluation of our providers. Because of the size of our supply chain, this has to be carried out by an external and independent source. For this reason, in 2012 we decided on the solution offered by EcoVadis and we incorporated Human Rights aspects.
  • Freedom of Expression and Privacy – in March 2013 we signed a memorandum of understanding (MoU) with the Telecom Industry Dialogue and a service agreement with the GNI. In addition, we signed up to the Guiding Principles on Freedom of Expression and Privacy.

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

Local legislation. The local context of different countries often hinders the implementation of self-regulation policies on human rights issues.