Responding department: Group Sustainability, External Affairs (also with input from Group Legal including privacy and compliance teams, External Communications, Public Policy)
Stock exchange symbol: (VOD:LN)
Does your company have a publicly available commitment to respect human rights?
Yes. Vodafone’s responsibility to respect human rights, is embodied in its Business Principles and Code of Conduct which are publicly available at [link]
Vodafone’s approach to human rights is available publicly at [link] and states that “Wherever we operate, we work to ensure that we do not infringe human rights through our operations or business relationships…We recognise that Vodafone has a responsibility to respect human rights, as articulated in the Universal Declaration of Human Rights, and align our approach with the UN Guiding Principles on Business and Human Rights.”
Vodafone policies that relate to its human rights responsibilities and are publicly available include the:
Law Enforcement Assistance Policy Standard available at [link]
Code of Ethical Purchasing available at [link]
Conflict Minerals Policy Standard available at [link]
Health, Safety and Wellbeing policy available at [link]
Tax risk management strategy [link]
How are human rights governed in your company?
Human rights are governed as an integral part of Vodafone’s governance of sustainability performance. The Group Executive Committee (ExCo) is responsible for Vodafone’s sustainability performance. An explanation of the governance model is included in Vodafone’s Sustainability reporting and is available at [link].
All Vodafone policy standards operate within the following policy governance framework:
• Vodafone’s Audit and Risk Committee, along with its Executive Committee, are ultimately accountable for compliance at Vodafone. Please note that Vodafone’s Executive Committee is the highest operational committee within Vodafone, chaired by Vodafone’s CEO.
• The Policy and Compliance Committee is a sub-committee of the Executive Committee and assists in fulfilling their policy compliance obligations.
• Every global policy standard - such as law enforcement assistance and ethical purchasing -has an executive committee “policy owner” (executive committee member responsible for policy implementation across the group) and a “policy champion” (subject matter expert who own and set the requirements in the policies).
• Vodafone’s Group Compliance Team also acts as a gatekeeper for global policies and are responsible for monitoring and coordinating compliance centrally and reporting to the above referenced committees.
How are human rights managed within your company?
In 2012, we worked with the sustainability organisation Business for Social Responsibility to conduct a gap analysis of our Group-level approach to human rights against the UN Guiding Principles on Business and Human Rights.
This identified the categories of human rights most relevant to Vodafone’s business as: labour rights; civil and political rights; rights of the child; economic, social and cultural rights; land and property acquisition; and the environment. Each of these categories is managed through well-established policies and programmes, described in detail in the relevant sections of Vodafone’s sustainability reporting. Vodafone’s approach to human rights provides a summary and is available at [link]
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?
Vodafone’s approach to stakeholder engagement is described at [link]
Priority human rights issues: What are some of the priority human rights issues for your company?
In 2012, we worked with the sustainability organisation Business for Social Responsibility to conduct a gap analysis of our Group-level approach to human rights against the UN Guiding Principles on Business and Human Rights. This identified the categories of human rights most relevant to Vodafone’s business as: labour rights; civil and political rights; rights of the child; economic, social and cultural rights; land and property acquisition; and the environment. Each of these categories is managed through well-established policies and programmes, described in detail in the relevant sections of Vodafone’s sustainability reporting.
Descriptions follow in sub-questions below.
Actions on health
Economic, Social and Cultural Rights: More information on how Vodafone manages Transformational solutions, Ethics and Mobiles, masts and health are available in Vodafone’s sustainability reporting
Actions on freedom of association and trade union rights
Labour Rights: We are committed to respecting the human rights of everyone working for Vodafone either directly as an employee, or indirectly as someone employed by one of our suppliers. More information on how labour rights are managed in Vodafone is available in the Our people and Responsible supply chain sections of Vodafone’s reporting. [link] [link]
Actions on displacement and community relocation
Land and property acquisition: We consult communities in the selection of our sites, as part of the applicable planning permissions in each market for installing antennas or other equipment. See Network deployment.
Actions on freedom of expression and privacy
Civil and Political Rights: We believe that access to communications technology can support greater freedom of expression, which in turn depends upon the right to privacy if it is to be exercised effectively. More information on how privacy and freedom of expression are managed within Vodafone are available in the Law Enforcement Disclosure report and Privacy and security section of Vodafone’s reporting.
Actions on children (including child labour)
Rights of the Child: We support a common industry approach to child safety online. More information on how Vodafone manages child safety online is available at Child safety online.
Actions on 'other' issues
Environment: We have strong processes in place to manage the environmental impacts of our operations including our carbon footprint and disposal of electronic waste. See Environment.
How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?
Information about how Vodafone addresses its human rights impacts is reported in:
- Vodafone’s Annual Report and Accounts available at [link]
- Vodafone Group’s Sustainability reporting available at [link]
- Many Vodafone operating companies also report at the country level. Local market reports are available at [link]
- Vodafone’s approach to stakeholder engagement is described at [link]. This includes examples of how Vodafone engages and communicates with different stakeholders including investors, NGOs, customers, communities, suppliers and employees
- We frequently engage with or respond to civil society organisations in response to specific concerns that they may raise, including through responses we provide to requests from the Business and Human Rights Resource Centre
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?
Vodafone has a number of mechanisms whereby grievances can be raised. Examples include:
- Whistleblowing mechanism
Vodafone has a global whistleblowing mechanism – called Speak Up - which is closely linked to our Code of Conduct ([link]) The details are provided within the public Code of Conduct document.
All employees and contractors have a duty to report any breaches of our Code of Conduct. Employees and contractors can report breaches of our Code through line management and HR, but if this is not possible for whatever reason, there is a global external reporting scheme through a third party.
- Customer service channels
The main mechanism by which customers can raise any kind of complaint or concern would be through Vodafone’s customer contact channels including, for example, stores, a customer services number, live chat or writing to customer complaint teams.
- Privacy / Data Protection Officers
Some of the markets in which we operate have mechanisms in place for customers to submit queries directly to data protection / privacy officers. For example, Vodafone Germany maintains a portion of its website dedicated to privacy and data protection. A dedicated email address – [email protected] – is available for all data protection and privacy-related queries.
- Third party mechanisms
For example, all of the UK mobile operators use the British Board of Film Classification (BBFC) to define which content is unsuitable for customers under the age of 18. There is an appeals process available on their website if members of the public or website owners believe a classification error has been made [link] . Vodafone UK uses a third party to provide automated technology to block sites which are unsuitable under that rating system but when appropriately challenged we take immediate steps to unblock any affected sites. A recent example in December 2014 resulted in a website that could not be accessed from the UK being investigated by Vodafone and subsequently unblocked.
Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?
Vodafone participates in a number of human rights related initiatives. These include:
- Vodafone is a member of the Telecommunications Industry Dialogue on Freedom of Expression and Privacy ([link]) a group of telecommunications operators and vendors who jointly address freedom of expression and privacy rights in the telecommunications sector and work in collaboration with the Global Network Initiative.
- Vodafone participates in the Conflict Free Sourcing Initiative which aims to tackle conflict minerals by increasing transparency and traceability in the supply chain. [link]
- Vodafone is also a member of the Joint Audit Collaboration - a collaboration with other telecoms companies to assess and improve the social and environmental performance of common suppliers.
- Vodafone is one of 22 companies that have signed up to the guiding principles of the ICT Coalition for a Safer Internet for Children and Young People, which we helped to develop. [link] The principles set out a common code of conduct for the development of products and services that promote child safety online. We submitted a self-declaration report [link] of our status in September 2013, and an independent assessment [link] of all the companies’ declarations was published in May 2014.
- Vodafone is also a signatory to the European Commission’s CEO Coalition on Child Safety Online, which commits us to making it easier for users to report harmful content, ensure that privacy settings are age-appropriate and offer parental controls. In January 2014, we delivered our status report to the EU outlining our progress against our commitments to online safety. [link]
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.
The most significant actions since June 2011 are detailed below. Progress and activities across a wide range of human rights issues are reported in detail in Vodafone’s sustainability reporting.
1. In 2012, we worked with the sustainability organisation Business for Social Responsibility to conduct a gap analysis of our Group-level approach to human rights against the UN Guiding Principles on Business and Human Rights. This was conducted in direct response to the UN Guiding Principles
2. In 2013/14, we strengthened our human rights impact assessment process for potential new markets identified as high risk. The findings are considered in the decision-making process before entering a new market.
3. In June 2014, Vodafone published its first Law Enforcement Disclosure report which provides a detailed insight into the legal frameworks, governance principles and operating procedures associated with responding to demands for assistance from law enforcement and intelligence agencies across 29 countries.
What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?
Practical examples addressing the ‘access to remedy pillar’ of the UN Guiding Principles.