Slavery and Human Trafficking Statement 2015-16 Group Plc Vodafone Group Slavery and Human Trafficking Statement

Forced, bonded or compulsory labour, Vodafone Group is one of the world’s largest broadband operations in 26 countries: Beliefs and principles human trafficking and other kinds of communications companies. We provide Australia (our joint venture), Albania, Czech We fully acknowledge our responsibility slavery and servitude represent some mobile services in 26 countries and fixed Republic, Egypt, , Ghana, Greece, to respect human rights as set out in the services in 17 local markets and we partner Hungary, India, Ireland, , Kenya (our International Bill of Human Rights. The IBHR of the gravest forms of human rights with mobile networks in a further 57 associate ), Malta, the Netherlands, abuse in any society. informs all of our policies related to the rights countries. As of 31 March 2016, we have 462 New Zealand, Portugal, Qatar, Romania, , and freedoms of every individual who works We will not tolerate any such activities within million mobile customers, 13.4 million fixed Turkey, the UK, in South Africa and for us, either as a direct Vodafone employee our own operations or within our supply chain customers and 9 million TV customers. We Vodacom’s subsidiaries in the Democratic or indirectly through our supply chain. We are and are committed to taking appropriate have more than 107,000 direct employees Republic of Congo, Lesotho, Mozambique also committed to implementing the United steps to ensure that everyone who works for worldwide and are an important source of and Tanzania. It does not include our partner Nations Guiding Principles on Business and Vodafone – in any capacity, anywhere in the indirect employment – through our supply networks, where we hold no equity interest. Human Rights throughout our operations. world – benefits from a working environment chain and through franchising and affiliate Our business is connectivity: we build and Respect for the dignity of the individual – and in which their fundamental rights and relationships – in every country in which we operate mobile and fixed networks which the importance of each individual’s human freedoms are respected. have an operating business. our customers rely on to manage their daily rights – form the basis of the behaviours we While this is our first public statement The Group is domiciled in the UK with lives and businesses. While we are neither expect in every workplace worldwide. We addressing these issues in line with the headquarters in London. Our UK operating a manufacturer (so do not own or operate will not accept any form of discrimination, requirements of the new UK Modern Slavery company has over 18 million consumer and factories or other production plant beyond a harassment or bullying and we require all of Act (2015), we have been focused on the enterprise customers as of 31 March 2016; it small and specialised automotive technology our managers to implement policies designed 1 rights and well-being of the people who also directly employs around 12,500 people facility in Italy ) nor a handler of raw materials to increase equality of opportunity and work for Vodafone – and for our suppliers – and has a retail presence on most High or commodities (and therefore do not own or inclusion for all Vodafone employees. for many years. We have also published an Streets in the country. operate processing facilities), our business is We have also developed and implemented overview of our guiding principles, policies nevertheless complex, with a wide range of The information in this Statement relates policies and processes which are intended and compliance processes in these areas suppliers and other commercial third-party to the financial year ended 31 March 2016 to extend these commitments through in successive public documents, the most relationships. and the scope of markets included in this our supply chain. These include requiring salient of which we refer to below. Statement covers our mobile and fixed suppliers to take measures to avoid any form of forced, bonded or compulsory labour (or any other kind of slavery or human trafficking) 1 During the financial year 2015-16, Vodafone Automotive also owned a small assembly facility (approximately 50 employees) in . within their own operations. This was outsourced to a third party in February 2016.

Vodafone Group Plc | Slavery and Human Trafficking Statement 2015-16 1 Codes and policies The Code of Conduct was updated during Every supplier who works for us is required The Code of Ethical Purchasing directly Vodafone’s Code of Conduct underpins the 2015-16 financial year to expand the to sign up to – and then abide by – our addresses the labour rights issues associated everything we do. The Code is mandatory references to human rights: Code of Ethical Purchasing. These with modern slavery. The specific requirements and extends to every individual working for or We respect all internationally commitments extend down through the regarding forced labour risks were updated in on behalf of Vodafone. The Code requires all proclaimed human rights, including the supply chain, so that a supplier with whom 2014 to make explicit reference to slavery and of us to act ethically and comply with legal International Bill of Human Rights and we have a direct contractual relationship (a human trafficking: requirements at all times, putting our principles the principles concerning fundamental Tier 1 supplier) in turn bears the responsibility • the Supplier shall not use any form of into practice in everything we do. rights set out in the International for ensuring compliance across their own forced, bonded, compulsory labour, slavery direct supply chain (a Tier 2 supplier from We require everyone who works for Vodafone Labour Organization’s Declaration on or human trafficking; Vodafone’s perspective) and so on. The Code to report suspected breaches of the Code, Fundamental Principles and Rights at • the Supplier’s employees shall be was established more than 10 years ago and including via our anonymous confidential Work. We strive to ensure that we are entitled to leave work or terminate their is based on international standards including hotline Speak Up reporting service – a not complicit in human rights abuses. employment with reasonable notice. the Universal Declaration of Human Rights local-language, online and phone reporting We shall, in all contexts, seek ways to Employees shall be free to leave work after and the International Labour Organization’s hotline which is prominently communicated honour the principles of internationally such reasonable notice period expires. All Core Conventions on Labour Standards. to all employees and contractors on a regular recognised human rights, even when employment shall be voluntary; It stipulates a range of ethical, labour and basis. Speak Up is overseen by our Group faced with conflicting requirements. We environmental standards that we expect to • the Supplier shall provide each of its Risk and Compliance Committee and every are also committed to implementing the be followed across our supply chain including employees with an employment contract report submitted is assessed and investigated. United Nations Guiding Principles on areas such as child labour, health and safety, which contains such a reasonable notice Further details of Speak Up are set out in our Business and Human Rights throughout working hours, discrimination and disciplinary period; and Sustainable Business Report. our business operations. processes. Those requirements are backed up • the Supplier shall not require employees by a risk assessment, audit and operational to lodge deposits of money or withhold improvement process, which we summarise payment or place debt upon employees below and which are also underpinned by or require employees to surrender binding contractual commitments. any government-issued identification, passports, or work permits as a condition of employment.

Vodafone Group Plc | Slavery and Human Trafficking Statement 2015-16 2 Risk assessment across our operating business and our global Supply chain leadership based approach to determine the extent When the UN Guiding Principles of Business supply chain. That analysis is informed by: The Code of Ethical Purchasing is overseen of scrutiny and challenge required when and Human Rights were first published in • the risk profile of individual countries based by the Vodafone Group Board through the considering whether or not to appoint a 2011, we analysed the approach to human on the Global Slavery Index; Group’s Chief Financial Officer, who is an new supplier and in response to an existing supplier’s declaration of conformity with rights then in place across the Group, to • the extent to which specific demographic Executive Director of the Group and also our Code, prioritising locations, industries assess the extent to which our policies and groups or types of employees or sits on the Group Executive Committee. or activities with a history of poor labour practices were aligned to those Principles. contractors may be more vulnerable Development and implementation of the standards for more detailed evaluation. That analysis helped to sharpen our focus than others for cultural, economic or Code is led by the Group Supply Chain Management Director, who is a member of on the most salient human rights risks of operational reasons; Conflict minerals Vodafone’s Global Senior Leadership team. relevance to an international communications • the disclosures of peer companies and There are specific human rights risks The majority of Vodafone’s procurement operator, including matters related to labour vendors; and associated with so-called conflict minerals rights among our employees and in our activity is centralised; the Group Supply • the insights of labour and human rights – the term used to describe some of the supply chain. Chain Management team directly control groups and other stakeholders with raw materials (tin, tantalum, tungsten and over £18 billion per year of spending at both We continue to review and enhance how specialist expertise in this area. gold) used throughout the global electronics Group and local market level, including for we manage these issues. During 2015-16, industry. There are significant mineral This analysis will in turn determine whether example in our UK local operating company. we established a steering group – chaired deposits in certain areas affected by conflict, or not there are any changes required to We are therefore able to ensure a good by the Vodafone Group Head of Sustainable particularly in Africa, leading to widespread the programme and associated compliance degree of consistency and cohesion in the Business and with senior expertise from the concern that the electronics industry’s mechanisms. management of our relationships with our legal, supply chain and compliance functions constant demand for those raw materials has suppliers worldwide, which in turn underpins in Vodafone Group and Vodafone UK – the effect of fuelling conflict and entrenching our ability to monitor performance and focused on developing and implementing further the corruption and risk of poor labour evaluate compliance with a reasonably high programmes to address modern slavery risks conditions, including forced labour, endemic degree of confidence. within our operations and supplier base. to those countries. Those concerns are also During 2016-17, the modern slavery steering Labour rights are a key aspect of the due reflected in legislation; our views on this group will continue to lead an ongoing diligence process applied to new suppliers issue are set out in our separate statutory assessment of the Group’s potential exposure and a core factor evaluated on an ongoing disclosure. basis with existing suppliers. We use a risk-

Vodafone Group Plc | Slavery and Human Trafficking Statement 2015-16 3 Monitoring and compliance In 2015-16, our on-site audits (together We also require everyone in our global supply Joint Audit Cooperation: Potential new suppliers rated as higher risk with those conducted through the JAC) chain organisation – as well as other people are required to provide evidence that they identified 15 issues related to forced labour who work closely with suppliers – to complete improving standards in operate ethically and responsibly in line with activities prohibited under our Code of Ethical training in our Code of Ethical Purchasing on the supply chain our Code requirements; this may include a Purchasing. Those issues arose within a range an annual basis. The programme includes third-party audit by a credible independent of suppliers from Tier 1 to Tier 3 and involved: specific guidance on how to identify and Vodafone is a member of the source. The supporting data provided is then • employees requiring approval from factory report non-compliance issues when visiting Joint Audit Cooperation (JAC), an reviewed by the relevant policy and operational management in order to resign; supplier sites and on how to communicate association of 12 telecommunications expectations to suppliers effectively. experts within Vodafone who will reject a • camera surveillance being in use without operators established with a shared supplier from being on-boarded if they do not appropriate signage and usage policies Evaluating our progress desire to improve ethical, labour and meet our requirements and, in the Group’s in place; During 2015-16: environmental standards in the ICT view, have no prospect of doing so even with • supervisors unreasonably limiting the time support and remediation. If the information •  we carried out 24 on-site audits of the supply chain. Other members are that employees could leave their work highest-risk suppliers; Deutsche Telekom, KPN, Orange, provided is found to be unsatisfactory, further stations during a shift; and on-site assessment may be required to verify • JAC conducted 612 on-site audits; Proximus, Rogers, , Telecom • employees not receiving copies of their compliance with the standards set out in the Italia, Telefonica, Telenor, Telia employment contract or not being aware of • we received 374 reports to our external Code. If a new supplier is found to be non- their leave entitlements. Speak Up hotline, none of which concerned Company and Verizon. compliant, where feasible we try to work with matters related to modern slavery issues; and them to help enhance their capabilities and Actions to address 13 of these issues have • 100% of Vodafone employees in global The JAC guidelines incorporate the same address the issues of concern. now been completed; two remain open with elements designed to address modern ongoing monitoring of the suppliers involved supply chain roles completed their annual Where we have identified that a particular slavery risks that are included in Vodafone’s until fully remediated. refresher training (or new joiner induction supplier is high risk and requires monitoring, training) on the Code of Ethical Purchasing. own Code of Ethical Purchasing. we evaluate that vendor’s compliance with our Training JAC members collaborate closely, sharing Code through a detailed assessment which The Vodafone Doing What’s Right mandatory resources to develop the appropriate may involve on-site audit. Some of these we training course is designed to help employees supply chain standards and best practice conduct ourselves, sending the appropriately across the organisation understand the and working together to assess and qualified and experienced Vodafone supply underlying principles, objectives and practical Group Chief Executive verify operational compliance. Audits are chain manager into the supplier’s operations implications of Vodafone’s Code of Conduct Vodafone Group Plc conducted by independent specialists to examine working conditions on the ground and, in turn, reflect upon their personal and speak directly to employees on the based on internationally recognised responsibilities and behaviours. Training is social and environmental standards, factory floor or relevant worksite. Other on-site delivered through e-learning courses, face- audits are conducted under the Joint Audit such as the SA 8000 social accountability to-face line manager events, webinars and standard, with results shared between JAC Cooperation (JAC) initiative as explained to induction programmes for new employees. the right. member companies. The JAC approach ensures suppliers are audited once rather than multiple times by different vendors and are assessed for compliance with a single set of rules under 2 This data is for the calendar year 2015. a standardised methodology.

Vodafone Group Plc | Slavery and Human Trafficking Statement 2015-16 4 Labor Link: voices from the workplace

Monitoring the compliance of a company’s direct suppliers can be challenging given the number of vendors, related subsidiaries, operating locations and employees involved. Assessing the extent to which a Tier 1 supplier is mandating compliance across the companies that in turn supply it with goods and services – the Tier 2 suppliers, from Vodafone’s perspective – can be even more difficult.

We now use the core service we provide to other labour rights issues. The Labor Link our customers – mobile – to gain insights into survey asked employees how many times a the views and experience of Tier 2 suppliers’ week their working day extended beyond employees. We are the first telecoms operator 10 hours. in the world to work with the not-for-profit Of the 2,161 who responded: social enterprise Good World Solutions to • 64% said never; enable employees to use their personal mobile phones to provide anonymous feedback on • 25% said one to three days; key aspects of their working conditions. • 8% said four to six days; and The Labor Link service provides employees • 4% said seven days a week. with a simple, local-language questionnaire We also asked if overtime was voluntary: delivered via an interactive voice response 87% responded yes, and 13% no. When (IVR) menu with pre-recorded questions we asked how the respondents felt about which is accessed by dialling a local phone overtime, 43% said they wanted to work as number, with a call-back facility, at any time. many hours as possible, 50% said they were We require participating suppliers to allow sometimes willing to work overtime and 7% their employees to respond to the Labor Link said they did not want to work overtime. questions freely and all responses received These are important insights which enabled are fully anonymised. We began using Labor us to focus directly on specific areas of poor Link during 2014 and, on the basis of the management performance – in this example, initial phase, believe it will make a meaningful excessive hours reported by respondents – contribution to ensuring compliance across and highlight the changes required to bring the supply chain. the workplace in question back in line with During 2015-16, over 2,500 employees the requirements set out in our Code. If a across eight Tier 2 suppliers have used the supplier is found to be non-compliant, where service. We have initially focused on working feasible we try to work with them to help hours and enforced overtime as these are enhance their capabilities and address the often a proxy indicator for a broad range of issues of concern.

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