Managing human rights
Alignment with UN Guiding principles
We align with the UN Guiding Principles. This means we work to make sure our policies, governance and due diligence processes take account of human rights risks so that we can properly manage and mitigate them.
Our approach to managing human rights:
Assessing our impact
We focus on the most salient human rights issues in our operations. We take action first on the most severe risks, based on how they could affect people rather than just the risk to our business.
We collaborate with the tech sector on current and emerging risks for us all, keeping pace with changes. We keep a close watch on the markets where we operate by keeping in touch with civil society on the ground and contributing to multi-stakeholder forums.
In 2023 we reviewed our salient human rights risks with the support of an external adviser.
We conduct due diligence to help make sure that we respect human rights. Due diligence comes in various forms and at different moments in our operations: it may be an independent human rights risk assessment for a new market entry as we did for Ethiopia or a thematic impact assessment such the child rights assessment.
- Developing new products, services, technologies or making substantial changes to existing ones.
- Entering new markets or in anticipation of changes in our existing operating environments.
- Considering new partnerships and acquisitions.
- Engaging with our suppliers.
Embedding respect
The Chief External and Corporate Affairs Officer oversees Vodafone’s human rights programme and is a member of the Executive Committee. The Human Rights Lead manages our programme, with the support of a cross-functional internal Human Rights Advisory Group (HRAG) comprising senior managers responsible for privacy, security, responsible sourcing, and diversity and inclusion amongst others.
Each HRAG member is responsible for implementing the relevant internal policies that are covered by the Human Rights Policy and collaborating with our operating markets to integrate policy controls. In 2023 we established a network of human rights champions in all our local operating companies.
We regularly report on our progress to the ESG and Reputation Committee, which assists the Executive Committee in fulfilling duties with regards to our purpose, sustainability strategy, reputation management and policy. We raise any concerns regarding how our operations – or business partners’ operations – could result in a negative human rights impact.
All our employees receive training on the Code of Conduct. This is supplemented with training on specific human rights impacts for relevant employees, contractors and suppliers. For example, our corporate security teams receive ‘Challenging Demands’ training in the context of law enforcement demands, and our supply chain teams receive training on modern slavery. In 2023 we made UN Global Compact training on human rights available to all our employees.
Tracking and communicating performance
Our cross-functional Human Rights Advisory Group (HRAG) meets regularly to review our performance, challenges and external trends.
Compliance with each policy relevant to human rights is reviewed periodically across the Group.
We are committed to transparency and externally report on our performance, such as the number of law enforcement demands we receive in each of the countries where we operate, the number of issues and remedial actions related to forced labour identified in supplier audits, and how many grievances have been raised through our anonymous Speak Up mechanism and remedial action taken.
Access to remedy
We believe that transparency is essential to help put things right when they go wrong. Some of our most salient impacts arise because of our links with the actions taken by others. For example, in our section on Law Enforcement Demands we describe how we have to take action when governments direct us. In those situations, governments are accountable for remedies.
However, we try and play our part by raising awareness and being transparent about the position. Our collaboration with others through organisations such as GSMA, UN Global Compact and UN B-Tech means we can collectively advocate for respect for human rights.
Everyone who works for or on behalf of Vodafone must report any behaviour at work that may be unlawful or criminal or could amount to an abuse of our policies, systems and processes. Employees are able to raise concerns with a line manager, with a colleague from human resources or through our confidential third-party hotline – Speak Up – accessible online or by telephone.
Speak Up is also made available to the public and our suppliers, communicated through our Code of Ethical Purchasing. For suppliers that decide to maintain their own grievance mechanisms, we require that they inform us of any grievances raised relating to direct work for Vodafone.
We also give customers in each of our markets access to channels to raise concerns.