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Responding department: Group Corporate Social Responsibility

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

Yes.  Zain has references to its human rights commitments within the following documents that are publically accessible:

  • Its Code of Conduct: [link]
  • Its Supplier Code of Conduct: [link]  
  • Its Sustainability Report: [link]

How are human rights governed in your company?

Human rights are ingrained in the Zain business model. Zain takes an ethical approach to its product and service offerings, and emphasizes accessibility, affordability and the maximization of utility in its product and service portfolio. Products and services are adapted to local customs and needs, and incorporate cultural sensitivity and respect for local traditions and heritage.

The company often subsidizes the rollout of coverage into economically under-developed areas as a means to enable and facilitate socio-economic development.

In addition, the company is now focused on investing time and resources on capacity-building efforts to develop entrepreneurship and innovation for the betterment of society by establishing and supporting startup incubators, accelerators and public competitions.

Internally, Zain’s HR policies ensure equal opportunities based on non-discrimination. The obligation to develop local talent is also enshrined in Zain’s HR Policy.

As a pillar of corporate governance (CG), social responsibility is embedded in our corporate culture and is reflected in all our internal policies and charters.

One element of corporate social responsibility is to emphasize on the importance of human rights. At Zain we strive to make the environment a healthy one for our stakeholders through the implementation of policies such as, related party transactions, stakeholders’ rights protection, shareholders’ rights protection, conflict of interest, and whistleblowing.

Our Code of Conduct emphasizes on the equal opportunity for all employees which caters for a healthy work environment and inspires teams to bring out their full potential. In addition our articles of association highlights the equal opportunity principle for all classes of investors. And lastly, our Board of Directors is committed to the highest levels of corporate governance compliance. Our corporate governance board committee met seven times during 2014 to discuss items relating to the protection of stakeholders, company’s ethics, policies and Corporate Sustainability and Social Responsibility (CSSR) related matters, being one of the pillars of CG. Zain’s board is committed to fulfilling the principles and ethics outlined in our BoD code of conduct.

At Zain, our continuous efforts to establish a strong foundation for ethics and social responsibility guides our attention to the details of human rights values. From protecting our stakeholders, to building a strong corporate family, and finally giving back to society through our charitable programs and social events.

How are human rights managed within your company?

Human rights issues are identified within the value chain through the supplier selection process. Zain’s supplier selection process ensures that for significant spend suppliers, major consideration is given to those with established and reputable policies regarding social responsibility, environmental considerations, sound labor practices and human rights records. Furthermore, Zain requires the abidance of its Supplier Code of Conduct as a precondition to establishing relationships with its suppliers and as a condition for ongoing relationship with Zain, which includes policies requiring the adherence to specific criteria regarding human rights, labor practices and environmental performance.

If violations by existing suppliers of the Supplier Code of Conduct are detected, Zain takes appropriate action accordingly, including termination of the contract or blacklisting of the supplier. Zain also reserves the right to audit its suppliers to ensure suppliers’ adherence to the Supplier Code of Conduct.

Included within Zain’s Environmental and Social Management Plan (ESMP) are policies regarding 1) the protection of indigenous peoples, 2) the protection of workers and the general public from electro-magnetic field (EMF) exposure, and 3) other health and safety considerations for workers and the general public.

The Zain Group’s annually published sustainability reports track and measure the organization’s internal and external activities that often relate to human rights issues, particularly those that impact the wider community. These include activities that promote: public health, capacity-building for the poor or other marginalized groups (women, the disabled, etc…), relief for people living in conflict zones, awareness about product misuse, and youth development.

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?

Internally, Zain notifies its employees about human rights issues by referring them to the Code of Conduct and the Human Resource (HR) Policy manual, both of which cover human rights issues.

Externally, ESMP guidelines specify policies for consulting with the general public for construction projects that may adversely affect those communities. Also, the Supplier Code of Conduct is shared with all suppliers and specifies their adherence to certain human rights principles as a condition for conducting business activities with Zain. Lastly, the Sustainability Report, which announced to stakeholders and the wider public, details Zain’s position on human rights issues.  

Actions on health

Health (including workplace health & safety, prevention of pollution)

Examples include:

  • Public health awareness initiatives.
  • Activities to mitigate pollution by the company (such as the installation of battery and solar hybrid solutions)
  • The ESMP guidelines, which outline health and safety policies for workers and the general public.

Actions on workplace diversity / non-discrimination

Zain’s HR Policy clearly forbids discrimination based on race, nationality, marital status, age, religion, gender, political belief, physical handicap or disability.

Actions on forced labour and human trafficking

Zain’s Supplier Code of Conduct forbids forced labor in its supply chain.

Actions on sexual harassment

Zain’s HR Policy forbids all forms of verbal and physical harassment between employees.

Actions on freedom of expression and privacy

Zain complies with the GSMA Mobile Privacy Principles; ensuring best practices are followed on matters related to the privacy and confidentiality of customer data. Zain takes the protection of customer data extremely seriously and takes all prudent measures to avoid data leaks, theft and/or loss. The company also aims to respond to such issues with the utmost precaution and diligence. Zain complies with all laws and regulations related to the protection of customer privacy and data and takes steps to align with ISO certifications related to the matter.

Actions on operations in conflict zones

Zain maintains business activities in several conflict zones including Iraq and South Sudan. In addition, Zain’s directs CSR outreach activities towards promoting reconciliation and peace-building, as is the case with the Youth Peacemaker Network, an initiative in South Sudan that is ongoing since 2012 and is undertaken in collaboration with Ericsson, UNESCO and UNESCO Goodwill Ambassador Forest Whitaker.

Actions on tax avoidance & revenue transparency

Zain maintains transparency by complying with local governance bodies such as the Capital Markets Authority.

Zain also maintains transparency through the disclosure and publication of financial reports in regular intervals that are readily available through the Investor Relations section of the Zain website: [link] .

Clearly stated in the Zain website is the company’s position regarding corporate governance, available at the Corporate Governance section of the Zain website: [link]

Actions on product misuse

One key example is the Drive Zain campaign, an ongoing activity undertaken to raise awareness among the general public about the responsible use of mobile phones.

Actions on women

Several of Zain’s CSR outreach activities specifically target socio-economic development and inclusivity for women. These include: sponsorship of the Widows Development Center in Iraq which in 2014 trained 1,500 women, and the support by Zain KSA of the Hadafi Program in Saudi Arabia which provides a forum for Saudi women to develop and present their entrepreneurial ideas to a professional panel.

Actions on children (including child labour)

Zain supports youth development initiatives across its footprint through its CSR outreach activities. These include skill development and capacity-building for children through activities such as: the Future University Network (FUN) program whereby students are given job training within Zain’s offices, and support for job shadowing programs. They also include the promotion of children’s health, as is the case with Zain Jordan’s Mobile Health Clinic for Children, which has provided free health care to 165,000 children since 2002. Other activities include poverty relief for children, such as Touch Lebanon’s meal provisions to needy children during the month of Ramadan.

In 2014, in response to the conflict between Israel and the Palestinians in Gaza, Zain dispatched several humanitarian convoys amounting to USD $500,000 worth of food and medical supplies to assist the beleaguered residents of Gaza overcome their plight. Several Zain operations also took up independent support initiatives as well. Zain Jordan donated 50% of the revenues generated from international calls towards the reconstruction of Gaza and the provision of health care and treatment for children. Zain also organized a Group-wide initiative through which employees and the wider public are able to donate their used children’s books to youth in Gaza.

Actions on migrant workers

Zain targets the plight of migrant workers by developing service packages specifically catering to their needs, such as preferred rates to contact their home countries.

Actions on 'other' issues


Connectivity is viewed as a human right by Zain due to its potential to empower individuals and facilitate their socio-economic development. Zain undertakes many initiatives that enable connectivity for those that are unconnected. In South Sudan, Zain partnered with Huawei to divert energy from its base station to connect 3,000 students to computer stations. In Lebanon, Touch offers a unique ‘Dary’ package offering special rates to customers located in remote areas with limited access to connectivity.

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

Internally, Zain shares its HR Policy with its employees.

Externally, Zain reports on various human rights issues in its annually published Sustainability Report, which available online to the general public. The Sustainability Report follows the GRI G4 reporting guidelines and reports on human rights related aspects within the 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?

Grievances are addressed internally through a formal mechanism outlined in the HR Policy.

Externally, grievances can be addressed to the Complaints Department, available in each of Zain’s operating countries. Major grievances about breaches of legal issues are referred to the company’s legal departments.

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

Zain participates in the GSMA Alliance and the GSMA Mobile Privacy Principles. Zain also collaborates with partners within its industry and in other sectors in order to promote human rights issues, as is the case with the following:

  • Collaboration with Ericsson and Refugees United to enable displaced people that are separated from their loved ones to reconnect with one another by using mobile technology. The project is currently in its pilot phase in Jordan and will be subsequently launched in South Sudan and Iraq.
  • Collaboration with UNESCO to enable Syrian refugees in Jordan connect to UNESCO.
  • Collaboration with the Vodafone Foundation to provide connectivity to 70,000 people in the Yida refugee camp in South Sudan.

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 2011, Zain has codified its position on human rights through its Code of Conduct, HR Policy and Supplier Code of Conduct.

Zain has also developed its governance model to emphasize transparency through its reporting mechanisms, which it undertakes in its Sustainability Report and through constant communication with relevant stakeholders. The annually published Sustainability Report is assured by a third party through Limited Assurance, validating the accuracy of its contents.

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

One key challenge that exists is due to the lack of prioritization and awareness of human rights within the region amongst a majority of stakeholders. Another major challenge is the regional geopolitical situation of conflict and instability that gives rise to difficulties regarding the enforcement of human rights principles in Zain’s markets.