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 take a two-pronged approach to human rights due diligence by conducting risk and impact assessments. This means we proactively monitor our operating environment to identify potential human rights risks before they materialise, and we assess actual or emerging impacts to ensure we respond effectively when issues do arise. By integrating a forward-looking risk analysis and responsive impact evaluation, we create a comprehensive framework that helps us safeguard human rights across our operations and value chain. We follow up assessments with remedial and mitigating actions. 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 rights impact assessment. The assessment confirmed the following human rights as being most salient to Vodacom:

The human rights programme is led by the Principal Human Rights Specialist and overseen by the Group Executive Head of ESG and Sustainable Business and the Group Chief Officer: Regulatory and External Affairs.

At group-level, the human rights specialist is support by a cross-functional internal Human rights advisory group (HRAG) comprising senior leaders 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 referenced within the human rights policy and collaborating with our operating companies to integrate policy controls. Within our local operating companies, we have a network of human rights leads and champions.

All our employees receive training on the Vodacom code of conduct which encompasses many aspects of our human rights approach. This is supplemented with training on specific human rights impacts for relevant employees, contractors, and suppliers.

We report on our progress to the Group Executive ESG and Reputation Committee, and the Group Social and Ethics Committee.

We are committed to transparency and report externally on our performance, where legally permitted. Our disclosures include the number of law enforcement demands we receive in each of the countries in which we operate as well as the number and categories of human rights-related grievances received and investigated.

We maintain a grievance mechanism accessible to all rights holders through Speak Up which is accessible online or by telephone. Speak Up is available to our customers, our suppliers and the public. For suppliers who maintain their own grievance mechanisms, we require that they inform us of any grievances raised relating to direct work for Vodacom.

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. Other than Speak Up, employees can raise concerns with their line manager, or with human resources.

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.