We align with the United Nations Guiding Principles on business and human rights (UNGPs). 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 due diligence process is committed to identifying risks in our own operations, value chain, and business-related activities. This includes risk identification in new business relations such as mergers and acquisitions and joint ventures, as well as systematic periodic review and risk mapping.

In line with the UNGPs, our approach involves having a comprehensive human rights policy, assessing impacts, embedding respect for human rights across our corporation and collaborations, providing remedies, and systematically tracking and communicating our performance.

Our operations have potential to impact various groups, including our employees, women, children, indigenous people and migrant workers and refugees. Our approach includes robust accountability measures, ensuring meaningful access to effective remedies for adverse impacts.

We conduct human rights risk and impact assessments as part of our ongoing due diligence. This dual-pronged approach allows us to proactively monitor our risk environment and effectively address any possible impact or incidents. We follow up assessments with mitigating actions such as contractual commitments to respect human rights. We are committed to providing redress wherever possible for identified human rights violations.

In partnership with Vodafone, we engaged Linklaters and Webber Wetzel to conduct an independent human right impact assessment of our operations and OpCos. The assessment identified the following salient human rights:

The principal human rights specialist reports to the group executive head of ESG and sustainable business who reports to the accountable executive and manages and oversees human rights programmes daily. They provide regular status reports to the Group Chief Officer: Regulatory and External Affairs, and updates to the Group Social and Ethics Committee.

The human rights specialist oversees our programme, with the support of a cross-functional internal Human Rights Advisory Group (HRAG) comprising senior managers responsible for privacy, corporate 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.

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.

We maintain a grievance mechanism accessible to all rights holders through Speak Up. 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 Vodacom 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 Vodacom. We also give customers in each of our markets access to channels to raise concerns.

We work with others to better understand what businesses should do to respect human rights. This is achieved through our participation in initiatives such as United Nations Global Compact Network (UNGC) and UN B-Tech Project. Vodacom is a participant in the UNGC – both internationally and through a few UNGC country networks. As part of this, Vodacom supports the Ten Principles of the UNGC on human rights, labour, environment, and anti-corruption. We are committed to making the UNGC and its principles part of the strategy, culture, and day-to-day operations of our company, and to engaging in collaborative projects that advance the broader development goals of the United Nations, particularly the Sustainable Development Goals. Vodacom works closely with UNICEF to ensure that it takes adequate step to protect children’s rights.