Vodafone Modern Slavery Statement 2020/21 Instructions
- June 7, 2024
- Vodafone
Table of Contents
Modern Slavery Statement 2020/21
Modern Slavery Statement 2020/21
Vodafone Group Plc
Vodafone Group Plc Modern Slavery Statement 2020/21
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Vodafone Group Plc Modern Slavery Statement 2020/21
Forced, bonded or compulsory labour, human trafficking and other kinds of
slavery and servitude represent some of the gravest forms of human rights
abuse in any society.
We will not tolerate any such activities within our own operations or within
our supply chain and are committed to taking appropriate steps to ensure that
everyone who works for Vodafone in any capacity, anywhere in the world
benefits from a working environment in which their fundamental rights and
freedoms are respected.
In this sixth Statement, which relates to the financial year ended 31 March
2021, we report on our efforts to prevent modern slavery in line with the
requirements of the UK Modern Slavery Act 2015. We have been focused on the
rights and wellbeing of our employees and for our suppliers for many
years. This Statement provides details of our policies, our approach and the
actions we have taken in the financial year 2020/21 to further strengthen our
programmes and commitments to respect and uphold people’s fundamental rights
and freedoms. This Statement is published by Vodafone Group Plc (Vodafone’) and its relevant subsidiaries (seeScope of report and review’ on page 17) in
compliance with the UK Modern Slavery Act 2015.
Highlights in 2020/21
Introduced programmes to counter the heightened risk of child and forced
labour as a result of COVID-19
Page 3
Collaborated with industry peers to investigate allegations of forced labour
Page 9
Included cobalt in our Conflict Minerals due diligence and reporting to
enhance our approach to the responsible sourcing of minerals
Page 10
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COVID-19 and the heightened risk of child and forced labour
In November 2020, the International Labour Organization (ILO) highlighted the
link between increased socio-economic vulnerability as a result of COVID-19
and the risk of child and forced labour. Recognised root causes, such as
limited employment opportunities, inadequate access to quality education and
poverty, have been exacerbated by the crisis.
The ILO states that the fundamental principles and rights at work, including
freedom from forced labour and child labour, are not only at heightened risk
but are also key to global recovery.
Vodafone has played its part in addressing these root causes: in addition to
our 5-point plan introduced in response to the pandemic, we introduced
everyone.connected, bringing together various programmes to counter the
impacts of COVID-19 for our customers, colleagues and the communities where we
operate.
Education
The impact of school closures around the world highlighted the need for
digital-enabled education to be more widespread. We recognise the potential of
technology to make education accessible for all. See the graphic on the right
for more information on how we are supporting students.
Jobseekers
Recognising the increased financial pressures faced by jobseekers, Vodafone
launched a comprehensive support package in Europe, Turkey, Egypt and South
Africa, which combined price discounts and data offers, zero-rating access to
job portals and continued access to free learning and skills through the
e-learning marketplace Udemy and Vodafone’s Future Jobs Finder tool. For more
information please visit www.vodafone.com/covid19.
Small and medium-sized enterprises
Vodafone addressed the concern about the liquidity problems that many
businesses, especially micro and small enterprises, faced when the COVID-19
crisis started.
To assist businesses most at risk within our supply chain, Vodafone ensured
that all new orders issued to our micro and small suppliers providing goods
and services to Vodafone’s European operations between 1 April and 1 October
2020 were paid in 15 days, instead of the customary 30 to 60 days. From 1
October 2020, payments for small suppliers reverted to customary terms, with
micro suppliers being paid in 29 days.
Over 1,200 micro and small suppliers have benefited from Vodafone’s COVID-19
payment term relief policy.
Vodafone UK will continue to abide by the Prompt Payment Code because we know
that cash flow is vitally important in these difficult times.
We know that the economic crisis precipitated by COVID-19 is dialling back
progress, creating an even greater need for society to focus on inclusion as
we recover and rebuild for the future.
Vodafone Foundation Instant Network Schools
Before the pandemic, refugees were twice as likely to be out of school as
other children, with only 63% enrolled in primary education and 24% in
secondary education. Ensuring that the most vulnerable are also part of the
shift to digital education is essential.
Since 2013, Vodafone Foundation and the United Nations High Commissioner for
Refugees have established 47 Instant Network Schools across eight refugee
camps in Africa, benefiting 100,000 refugee students and 1,000 teachers to
date. The programme provides access to digital learning content and the
internet, improving the quality of education in some of the most marginalised
communities in Africa.
The programme has been shown to increase digital skills for 61% of students
and 125% of teachers, improving student confidence, motivation and academic
performance. It has also led to higher levels of school attendance, with
examples of young people accessing tertiary education from within refugee
camps for the first time.
Instant Network Schools is a prime example of how investments in digital
technology can help accelerate the number of students able to access
education. The programme is now expanding through a 26 million joint
investment by Vodafone Foundation and UNHCR to reach 500,000 young refugees
and their communities by 2025.
1 www.ilo.org/wcmsp5/groups/public/—ed_norm/—ipec/documents/publication/wcms_761110.pdf
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Our business and supply chain
Vodafone Group is one of the world’s leading telecoms and technology service
providers. We have extensive experience in connectivity, convergence and the
Internet of Things (IoT), as well as championing mobile financial services and
digital transformation in emerging markets.
Vodafone Group operates mobile and fixed networks in 21 countries and partners
with mobile networks in 48 more. As of 31 December 2020, we had over 300
million mobile customers, more than 27 million fixed broadband customers and
over 22 million TV customers, and we connected more than 118 million IoT
devices.
Our company is large, with a wide range of suppliers and other commercial
third-party relationships, and relies on an international supply chain with
suppliers that range in size from small and medium-sized enterprises to large
multinationals that spans multiple tiers. We spend more than 24 billion a
year with more than 11,000 direct suppliers around the world to meet our
customers’ needs. As we illustrate later, our direct suppliers can have a very
large number of their own suppliers that, in turn, rely on a large number of
their own suppliers and so on, down through several tiers in the supply chain.
The majority of our external spend is with suppliers that provide us with
network infrastructure, information technology and services related to fixed
lines, mobile masts and data centres that run our networks. Our nextlargest
area of spend is on the products we sell
to our customers, including mobile phones, tablets, SIM cards, broadband
routers, TV set-top boxes and IoT devices. The remaining expenditure is made
up of a wide variety of goods and services procured to support our general
business and administrative functions, including marketing, travel,
professional advisory support, catering and cleaning.
We are not a mass-market manufacturer and do not directly own or operate large
factories or other production facilities, with the exception of a small plant
based in Italy that manufactures specialist automotive IoT components. We do
offer our customers a range of smartphones and tablets that carry the Vodafone
logo; however, those devices are designed and manufactured on our behalf by
suppliers known as original design manufacturers that are contracted to
design and make products according to our specifications. We do not own,
operate or control the manufacturing plants that make those Vodafone-branded
devices, nor are we a handler of raw materials or commodities.
Procurement is a highly centralised function within the business. The
procurement process is designed to ensure fair treatment of suppliers during
the competitive tender process. The majority of our external spend is managed
by our Vodafone Procurement Company (VPC) and the Vodafone Shared Services
Centres that are based in Budapest, Hungary and Ahmedabad, India. Globally,
procurement is carried out using a single Enterprise Resource Planning System
that
helps to ensure that we maintain a consistent approach to supplier management across Vodafone, from on-boarding and vetting a supplier to raising orders and paying for delivered goods and services. This makes it easier to monitor and improve supplier performance across our markets.
Further information on the structure of our supply chain can be found online at www.vodafone.com/ supplychain
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A typical electronics supply chain for Vodafone
Tier 1: direct suppliers
Vodafone buys products and services from approximately 10,500 suppliers. The
majority of our spend is with large multinational companies supplying finished
products.
We have a direct contractual relationship and work closely with our Tier 1
suppliers to develop innovative new products and services, engage their
leadership and assess how they assure compliance across their operations.
Tier 2: such as electronics manufacturers and sub-assemblers
Electronics manufacturers and suppliers of electronic equipment have many
suppliers of their own.
We work with our Tier 1 suppliers to gain insights into their suppliers Tier
2 companies particularly where we believe a supplier is high risk.
Tier 3: such as component suppliers
Components are sourced from a significant number of suppliers to form parts
for the products being manufactured.
Tier 4+:
These products are made from materials sourced from many different commodity
and raw material suppliers that can be found many layers further down the
supply chain.
Our supplier base is dynamic: the network of suppliers and sub-suppliers is changing continually. We work through industry initiatives to enhance transparency throughout the supply chain. Where we have influence over the design or manufacture of products, we seek to ensure that those products do not contain metals that fund conflict in the Democratic Republic of Congo. We provide further details of our approach to this issue in our statutory Conflict Minerals Report available at the Vodafone Sustainable Business Reporting Centre.
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Vodafone’s commitment to human rights and combatting modern slavery
We fully acknowledge our responsibility to respect human rights as set out in
the United Nations Guiding Principles on Business and Human Rights and the
International Bill of Human Rights (IBHR). The IBHR informs all of our
policies related to the rights and freedoms of every individual who works for
us, either as a direct Vodafone employee or indirectly through our supply
chain.
Respect for the dignity of the individual and the importance of each
individual’s human rights forms the basis of the behaviours we expect in
every workplace worldwide, which are communicated through our Code of Conduct.
We will not accept any form of discrimination, harassment or bullying and
require all of our managers to implement policies designed to ensure equality
of opportunity and inclusion for all Vodafone employees.
We have also developed and implemented policies and processes that are
intended to extend these commitments throughout our supply chain, which are
embedded in our Code of Ethical Purchasing (see below). These include
requiring our suppliers to take measures to avoid any form of forced, bonded
or compulsory labour (or any other kind of slavery or human trafficking)
within their own operations.
Our policies are implemented in all our mobile and fixed broadband operations
in 19 countries where we have operational control: Albania, Czech Republic,
Egypt, Germany, Ghana, Greece, Hungary, Ireland, Italy, Portugal, Romania,
Spain, Turkey, the UK, Vodacom (South Africa) and Vodacom’s subsidiaries in
the Democratic Republic of Congo, Lesotho, Mozambique and Tanzania.
Codes and policies
i. Code of Conduct Vodafone’s Code of Conduct underpins everything we do. The
Code is mandatory and extends to everyone working for, or on behalf of
Vodafone, including employees, directors, contractors, subsidiaries, joint
ventures and suppliers. We expect our suppliers and business partners to
uphold the same standards and to act ethically, putting our principles into
practice in everything they do.
Specifically, with regard to human rights, the Code of Conduct states the
following:
“We respect all internationally proclaimed human rights, including the
International Bill of Human Rights and the principles concerning fundamental
rights set out in the International Labour Organization’s Declaration on
Fundamental Principles and Rights at Work. We strive to ensure that we are not
complicit in human rights abuses. We shall, in all contexts, seek ways to
honour the principles of internationally recognised human rights, even when
faced with conflicting requirements. We are also committed to implementing the
United Nations Guiding Principles on Business and Human Rights throughout our
business operations.”
ii. Vodafone Human Rights Policy Vodafone’s Group Human Rights Policy
Statement sets out the minimum requirements that every single person working
for and with Vodafone must comply with to uphold the rights of our customers,
colleagues, business partners and communities.
Existing policies relating to specific human rights topics were mapped and
reviewed and expert internal stakeholders were consulted to collate our Group-
wide commitments into one policy document. The policy was reviewed and
approved by the Vodafone Group Executive Committee (ExCo) and signed by our
Group CEO.
The prevention of slavery and human trafficking is included as an explicit
commitment in the Human Rights Policy given the potential risk exposure
related to the global scale of our business and supply chains spanning
multiple tiers.
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iii. Supply chain and Code of
Ethical Purchasing Every supplier that works for us is required to sign up to
and then abide by our Code of Ethical Purchasing. These commitments extend
down through the supply chain so that a supplier with which we have a direct
contractual relationship (Tier 1 supplier) is required to ensure compliance
across its own direct supply chain (Tier 2 supplier from Vodafone’s
perspective) and so on.
The Code of Ethical Purchasing was established more than 10 years ago and is
based on international standards including the Universal Declaration of Human
Rights and ILO’s Fundamental Conventions on Labour Standards. It stipulates a
range of ethical, labour and environmental standards that we expect to be
followed across our supply chain, including areas such as child labour, health
and safety, working hours, discrimination and disciplinary processes. Those
requirements are backed up by risk assessments, audits and operational
improvement processes, which we summarise below, and are underpinned by
binding contractual commitments.
The Code of Ethical Purchasing was developed in consultation with employees,
suppliers, investors and non-governmental organisations and directly addresses
the labour rights issues associated with modern slavery. The specific
requirements regarding forced labour risks were updated in 2014 to make
explicit reference to slavery and human trafficking:
The Supplier shall not use any form of
forced, bonded or compulsory labour, slavery or human trafficking.
The Supplier’s employees shall be entitled to leave work or terminate their
employment with reasonable notice. Employees shall be free to leave work after
such reasonable notice period expires. All employment shall be voluntary.
The Supplier shall provide each of its employees with an employment contract
that contains such a reasonable notice period.
The Supplier shall not require employees to lodge deposits of money or
withhold
payment or place debt upon employees or require employees to surrender any
government-issued identification, passports or work permits as a condition of
employment.
The Code of Ethical Purchasing is overseen by the CEO of the VPC, who reports
to the Group’s Chief Financial Officer who sits on the Vodafone Group ExCo.
Development and implementation of the Code is led by the Global Supply Chain
Management Director, who is also the CEO of the VPC and a member of Vodafone’s
global senior leadership team. The Code is reviewed annually, in line with
Vodafone’s risk profile,
and there were no further amendments necessary in the reporting period.
For information about how we communicate our Codes to our employees and
suppliers see the Other training and capacity-building initiatives’ section on page 15. We encourage our employees to report suspected breaches of our Codes confidentially by using our Speak Up process, which can also be used to report a wide range of unethical or unlawful activities and can be used by employees and suppliers alike. For more information about this process and how we respond to any findings of non-compliance, see theGrievance mechanisms’ section on page 14.
iv. Global Resourcing Policy and Fair
Pay Principles Vodafone has a Global Resourcing Policy that is updated
annually. It sets out the overarching principles and controls to be followed
and applied in each of our local operating companies to ensure that employee
resourcing is conducted in a fair, open and transparent manner. The policy is
owned by the Global Resourcing Centre of Excellence and training is provided
on induction to the resourcing teams.
There is also a clear culture in our business of ensuring we offer competitive
and fair pay to our employees. Our approach to Reward at Vodafone is
underpinned by our Fair Pay Principles, which we apply to all employees
regardless of level, location or role. One of our principles is Ensure a good standard of living’ we work with an independent organisation, Fair Wage Network, to assess how our pay compares to theliving wage’ in each of our
markets as we are committed to providing a good standard of living for our
people and their families. We monitor our position across our principles
annually and agree on local action plans for any required adjustments.
v. Conflict Minerals Policy Vodafone has a Conflict Minerals Policy that was
updated in 2021. It sets out the approach to supporting the responsible
sourcing of conflict minerals: tin, tungsten, tantalum and gold. The policy
explicitly makes reference to forced labour, stating that:
“Vodafone has a responsibility to respect human rights and not contribute to
conflict, nor by any means profit from, or contribute
to, by any party of any forms of torture, inhumane treatment, forced labour,
worst forms of child labour, gross human rights violations, or other serious
violations of international humanitarian law, crimes against humanity or
genocide related to the sourcing of tin, tantalum, tungsten or gold.”
More information on our work on Conflict Minerals can be found online
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Governance and accountability
Vodafone has an established Human Rights team that has a comprehensive
understanding of modern slavery and supply chain issues. The team sits within
our Sustainable Business function and our Group External Affairs Director, who
sits on the Group ExCo and is responsible for Vodafone’s approach to human
rights issues.
The Human Rights team works in close collaboration with other teams in the
business at both the Group and local markets level. To further strengthen our
global governance on human rights issues, we have established a cross-
functional Human Rights Advisory Group consisting of expert internal
stakeholders accountable for the management of Vodafone’s material human
rights impacts such as responsible sourcing, freedom of expression and the
right to privacy.
Collaboration in 2020-21
i. UK Home Office Business Against
Slavery Forum Vodafone continues to actively participate with the UK Home
Office Business Against Slavery Forum and the Transparency in Supply Chains
Advisory Group, one of six groups that will feed into the Home Office’s Modern
Slavery Strategy and Implementation Group.
ii. United Nations Global Compact Modern
Slavery Working Group In 2019, Vodafone was also invited to join the Modern
Slavery Working Group hosted by the United Nations Global Compact Network UK.
Vodafone contributes to discussions and shared experience in the working
group.
iii. Joint Audit Cooperation (JAC)
Human Rights Workstream Vodafone is Chair of the JAC initiative, an
association of telecoms operators established to improve ethical, labour and
environmental standards in the information and communications technology (ICT)
supply chain. Other members include AT&T, Deutsche Telekom, Elisa, KPN, MTS,
Orange, Proximus, Swisscom, Telecom Italia, Telefónica, Telenor, Telia
Company, Telstra and Verizon.
Vodafone is a member of JAC’s industry task force on human rights. The task
force tackles risks in the downstream supply chains of the telecoms industry
and addresses topics such as human trafficking. The task force is monitoring
the situation in relation to allegations of forced labour of Uyghur and other
ethnic minority citizens in China. It meets to understand the actions needed
to engage suppliers and review JAC’s approach to due diligence.
iv. Trust Your Supplier Vodafone is a founding member of Trust Your Supplier.
The platform enables organisations to use a common industry approach to review
risks, including human rights, when on-boarding suppliers. This platform
provides access to supplier information that is verified by third parties
using blockchain technology. This initiative is at the early stages, with
several large international companies, including Vodafone, on-boarding their
suppliers onto the platform for verification.
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Management of modern slavery risk
i. Assessing risk
We continue to use the approach defined based on the results of our Group-wide
modern slavery risk assessment, which mapped our business and supply chain
activities against recognised indicators of modern slavery risk, including:
potential employment of vulnerable groups (such as low-skilled, seasonal or
migrant workers);
likely involvement of labour recruiters and other third-party agencies in
the recruitment of workers;
consideration of how many workers are involved in the business or supply
chain activity; and
the country-by-country risk of modern slavery (based on the Global Slavery
Index).
This assessment enabled Vodafone to better understand where to prioritise our
efforts across our operations and supply chain. The resulting indicators were
fed into our supplier on-boarding process to ensure that our areas of greatest
potential exposure are identified and assessed for risk.
Our greatest areas of potential exposure are linked to our procurement of
manufactured electronic products, the construction services for our mobile and
fixed assets, maintenance and support services at our offices, and the
warehousing of products. Customer support and telesales activities carried out
in higher-risk geographies some of which are outsourced and some of which we
carry out directly may also carry a level of risk.
Internal subject matter experts evaluate the likely risk exposure for new
products and services that Vodafone procures, and this information is fed into
a supplier risk-screening tool. Labour rights are a key consideration in this
process and all new suppliers are screened using this tool to determine an
appropriate due diligence approach.
As part of our ongoing due diligence, Vodafone reviews human rights
allegations against our direct suppliers to assess the risk of their potential
involvement in human rights violations. We will not work with suppliers that
fail to engage with us on addressing any issues that have been found.
ii. Conflict minerals and cobalt
Our approach to managing the so-called conflict minerals the term used to
describe some of the raw materials (tin, tantalum, tungsten and gold) used
throughout the global electronics industry is set out in our Conflict
Minerals Report, our separate statutory disclosure.
Human rights risks, including forced labour, have been linked to artisanal
cobalt mining in the Democratic Republic of Congo. Vodafone published its
first public Statement on Human Rights and Artisanal Cobalt Mining in the
Democratic Republic of Congo at the end of 2017. We have since included cobalt
into of our formal responsible minerals programme in conformance with the OECD
Due Diligence Guidance for Responsible Supply Chains of Minerals from
Conflict-Affected and HighRisk Areas. We continue to support industry
initiatives trying to address this issue and are part of the Responsible
Minerals Initiative sub-group on cobalt.
Supply chain due diligence
i. Selecting new suppliers
Labour rights are a key aspect of the due diligence process applied to new
suppliers and are a core factor evaluated on an ongoing basis with existing
suppliers. We use a risk-based approach to determine the extent of scrutiny
and challenge required when considering whether to appoint a new supplier.
Factors such as locations, industries and activities with a history of poor
labour standards are considered when determining whether a more detailed
evaluation of the supplier is required.
Potential new suppliers rated as higher-risk through the outcome of our
initial riskscreening process (see the `Management of modern slavery risk’
section on page 10) are required to complete a self-assessment questionnaire
and provide evidence that they operate ethically and responsibly in line with
our Code of Ethical Purchasing requirements.
A supplier providing an incomplete response triggers a review in which
relevant Vodafone policy owners review the supporting data provided along with
the self-assessment questionnaire, which is supplemented by a review of any
adverse media coverage. These policy owners, who are independent of the
business functions, will then determine whether to reject a supplier from
being permitted to work with us. They will do so if that supplier does not
meet our requirements
and, in the view of those policy owners, has no prospect of doing so even with
support and remediation. If the information provided is found to be
unsatisfactory, further onsite assessment may be required to verify compliance
with the standards set out in the Code of Ethical Purchasing, and this may
include a third-party audit by a credible independent source.
If a potential new supplier is found to be non-compliant, where feasible, we
try to work with them to help enhance their capabilities and address the
issues of concern, using corrective action plans and training. We share our
free online modern slavery training with all suppliers and encourage them to
use it and to cascade it with their suppliers (see the Publicly available modern slavery training for suppliers’ section on page 15) to build awareness and understanding about the risk of modern slavery in their supply chains. If we receive sufficient assurance of compliance on completion of our due diligence processes, the supplier will be qualified. Our suppliers are then required to sign up to and abide by our Code of Ethical Purchasing, which includes explicit provisions related to modern slavery. We also require that our suppliers cascade the Code to their own supply chains (see theCodes and
policies’ section on page 6).
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Mechanisms for ensuring our suppliers operate responsibly to our standards
Vodafone Code of Conduct Vodafone Code of Ethical Purchasing
Qualification process Qualified Vodafone
supply base Risk profiling
Monitoring compliance
· Contractual commitment to Code of Ethical Purchasing
· Due diligence
· Based on country, industry and type of activity
· Screening for reputational issues · Validated questionnaires · On-site
audits · Direct worker feedback
Improvements and capability building
· Improvement plans · Events and forums · Sharing best practices · Capability building
Recognition
· Offer further work · Supplier awards
Consequences
· Reduce business · Terminate contract
ii. Ongoing monitoring
Where we have identified that a particular supplier is high-risk and requires
monitoring, we evaluate that supplier’s compliance with our Code of Ethical
Purchasing through a detailed assessment that may involve an on-site audit. We
conduct some of these audits ourselves, sending appropriately qualified
auditors from recognised audit firms or Vodafone auditors into the supplier’s
operations to examine working conditions on the ground and speak directly to
employees on the factory floor or relevant worksite. Other site audits are
conducted under the JAC initiative.
Suppliers that do not comply with our standards as set out in our Code of
Ethical Purchasing are provided with a corrective action plan to address any
areas for improvement and are required to submit evidence that this has been
completed. Corrective action plans through JAC are uploaded to a platform and
reviewed quarterly by an independent provider, and ongoing monitoring occurs
if and when grievances are raised (see the `Grievance mechanisms’ section on
page 14 for more information).
We also monitor our strategic suppliers through our Supplier Performance
Management programme, which measures whether our suppliers have a responsible
supply chain as well as other factors such as delivery, quality and commercial
performance. Strategic suppliers are required to submit responses to our
questionnaire with evidence related to their compliance annually. This
evidence is then validated and assessed internally and each supplier is given
a scorecard highlighting areas for improvement.
iii. Beyond Tier 1
We have various measures to encourage and assess the compliance of suppliers
in Tier 2 and beyond, where we do not have direct control. For example, we
require that our suppliers cascade our Code of Ethical Purchasing to their own
supply chains (See the `Codes and policies’ section on page 6). As part of our
Supplier Performance Management programme, strategic suppliers are also
evaluated on how they assess the social and ethical risks in their supply
chains and how they measure their effectiveness in ensuring compliance.
Through our membership in JAC, we also have access to audit reports of
suppliers that we share in common.
Audit findings in 2020/21 In the financial year 2020/21, our on-site audits
(together with those conducted through JAC) identified 20 incidents relating
to forced labour activities prohibited under our Code of Ethical
Purchasing.These incidents, which are similar to issues uncovered last year,
are related to:
non-compliance with China’s labour laws regarding having more than 10% of
agency workers (called `dispatch workers’ suppliers that had failed to
comply with local labour requirements by exceeding the percentage of agency
workers permissible as part of the overall workforce) as part of the
workforce;
employees paid late to dates defined in contracts;
contracts not having key terms, such as working hours or wages, defined; and
copies of contracts not given to employees.
Most of the cases related to workers who had highlighted these issues during
confidential worker interviews. In the cases where contracts were not given to
employees, those suppliers have subsequently been assigned corrective actions
to issue workers with a copy of their contracts and remuneration. The
suppliers in these cases have since committed to a plan to achieve compliance,
which will be periodically reviewed by the JAC industry association member
companies to ensure progress and timely closure.
There were also two cases that were followed up and rectified by the supplier:
in one, a worker had been required to pay a fee to get a job; in the other,
the worker had paid a financial penalty when their contract was terminated.
Worker surveys We also use mobile devices to gain insights into the views and
experiences of some of our Tier 2 suppliers’ employees to understand the
extent to which Tier 1 suppliers are mandating compliance of their suppliers.
We were the first telecoms operator in the world to use worker surveys to
enable employees to use their personal mobile phones to provide anonymous
feedback on key aspects of their working conditions through the use of
locallanguage surveys. Following Vodafone, other industry members from JAC
have also adopted this solution and, collectively, we surveyed 13 common
factories employing over 25,000 workers during 2020.
Anonymous worker surveys using mobile devices are now integrated into part of
the on-site audits programme results as a means to include workers’ voices.
The survey sections related to modern slavery risks focus on working hours and
overtime, as these are often proxy indicators for a broad range of other
labour rights issues. The results of these surveys are integrated into our on-
site audit reports, and findings that require action are incorporated into the
relevant suppliers’ corrective action plans.
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Grievance
mechanisms
We encourage everyone who works for
Vodafone to report suspected breaches of our Code of Ethical Purchasing as
soon as possible via our Speak Up process. There are a number of ways people
can do this, including via our anonymous external confidential reporting
service: a local-language, online and phone reporting hotline that is
prominently communicated to all employees, suppliers and contractors on a
regular basis. Speak Up operates under a non-retaliatory policy; everyone who
raises a concern in good faith is treated fairly, regardless of the outcome of
any subsequent investigation.
Speak Up is also made available to all of our suppliers and is 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 work done on behalf of Vodafone directly.
The Speak Up programme is overseen by our Group Risk and Compliance Committee, and senior executives review each individual complaint reported via Speak Up. Each grievance raised is formally and robustly investigated and is monitored to verify that any corrective action plan or remediation has been conducted.
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Other training and capacity-building initiatives
The Vodafone Doing What’s Right’ mandatory training course is designed to help employees across the organisation understand the underlying principles, objectives and practical implications of Vodafone’s Code of Conduct (See the Codes and policies’ section on page 6 for more information) and, in turn,
reflect upon their personal responsibilities and required behaviours. Training
is delivered through e-learning courses, face-to-face line manager events,
webinars and induction programmes for new employees. To date, over 90% of
active employees around the world have completed the e-learning training (this
rate excludes employees in Germany due to local works councils’ restrictions).
In addition, tailored face-to-face training programmes are used to cover
relevant scenarios for higher-risk employees, such as those working in
procurement, network operations, Vodafone Business sales and government
relations.
We also require everyone in our global supply chain organisation, VPC as
well as other people who work closely with suppliers to complete training on
our Code of Ethical Purchasing on an annual basis. The programme includes
specific guidance on how to identify and report non-compliance issues when
visiting supplier sites and how to communicate expectations to suppliers
effectively. This training includes a module on human rights, in addition to
modules on ethics, health and safety, and the environment. The training
explicitly refers to the withholding of documentation, illegal recruitment
fees and freedom of movement. See the Codes and policies’ section on page 6 for more information. Publicly available modern slavery training for suppliers We have previously developed and launched a freely accessible and interactive modern slavery online training module to help build awareness and understanding of modern slavery among suppliers and other partners across our supply chain. The training is available in English, Mandarin Chinese and Hindi and was promoted across our supply chain during the year. The 20-minute module is tailored to the challenges of the ICT supply chain and follows an avatar through the different modern slavery risks that exist in the work cycle (recruitment, working, leaving). It was designed to provide an introduction to the subject matter and enable suppliers to spotred flags’
within their business operations and supply chain. The course uses in-depth
examples from a range of high-risk sectors, such as recruitment fees in the
construction sector and passport retention in electronics manufacturing, and
highlights both Vodafone’s expectations and international standards in
relation to these issues.
Since its launch in 2018, Vodafone’s modern slavery online training has been
distributed to over 11,000 suppliers. We encourage all our stakeholders to
register and access the free training on their desktop or mobile device via
http://modernslavery.vflearning.com.
Vodafone Group Plc Modern Slavery Statement 2020/21
15
Vodafone Group Plc Modern Slavery Statement 2020/21
16
Evaluating our progress
Modern slavery is a hidden risk, making the evaluation of progress complex. We
use the following key performance indicators (KPIs) to monitor and report on
the effectiveness of our policies and procedures in this area.
KPIs
Number of site assessments conducted (either by Vodafone or through JAC3)
Reason for KPI
2018-20192
We explicitly investigate practices that could result in modern slavery conditions through 85 our various engagements with our suppliers, e.g. audits, frequent supplier visits and JAC assessments.
2019-2020 74
Number of issues related to forced
By monitoring the number of issues identified, we can better adapt our policies
9
16
labour identified
and procedures.
For example, if the numbers significantly decrease, we would investigate greater awarenessraising activities and improved grievance mechanisms to gain confidence that issues are not going unreported. If the numbers significantly increase, we would review our due diligence processes to gain confidence that such activity is investigated and eliminated.
Number of remedial actions taken
By monitoring the number of remedial actions taken, we gain greater confidence that our 9
16
in response to forced labour
corrective plans are being actioned and any activity is investigated and eliminated.
issues identified
Number of reports to our external Speak Up hotline related to modern slavery concerns
By monitoring the number of issues identified, we can better adapt our policies
1
0
and procedures.
(See Slavery and Human
For example, if the numbers significantly decrease, we would investigate greater awareness- Trafficking Statement 2018-19
raising activities and improved grievance mechanisms to gain confidence that issues are not for more information)
going unreported. If the numbers significantly increase, we would review our due diligence
processes to gain confidence that such activity is investigated and eliminated.
Number of sites where we have
The increased provision of an anonymised, local-language, confidential survey will enable
12
20
conducted a confidential survey of
greater transparency of specific worker concerns and indicators that may point to potential
supplier employees via their personal modern slavery conditions.
mobile phones
2 For data on previous years, please refer to Vodafone Group Sustainable Business Reporting Centre. 3 JAC assessments are reported on a calendar-year basis.
2020-2021 76
20 (See `Beyond Tier 1′ section on page 12 for more information) 20 0
13
Scope of report and review
This Statement describes the activities that Vodafone Group Plc is undertaking
to prevent slavery and human trafficking in its business operations and supply
chains. This Statement is published by Vodafone Group Plc (`Vodafone’) and its
relevant subsidiaries (see below) in compliance with the UK Modern Slavery Act
2015.
The Act requires all large UK businesses (with a turnover of £36 million or
more) to publish such a statement. The following UK-registered entities, which
are part of Vodafone, are covered by the content of this Statement:
Vodafone Group Services Limited (VGSL), including Vodafone Group Plc which
supports our local operating companies;
Vodafone Sales and Services Limited which supports our commercial,
marketing and brand functions;
Vodafone Limited (also known as Vodafone UK) our local UK operating
company;
Talkmobile Limited our online-only UK mobile brand;
Vodafone Global Enterprise Limited which supports our multinational
customers;
Vodafone Enterprise Global Limited which provides off-footprint services
and support to multinational business customers; and
Vodafone Global Network Limited which is responsible for carrier services
globally, including ownership of subsea cables and associated assets.
The Boards of each of these entities have reviewed and approved this Modern
Slavery Statement. Separately, this Statement has also been reviewed and
approved by the Vodafone Group Plc Board, as required, and has been signed on
its behalf by the Vodafone Group CEO.
Nick Read, Chief Executive Officer, Vodafone Group Plc
Vodafone Group Plc Modern Slavery Statement 2020/21
17
View our previous Modern Slavery Statements here.
© 2021 Vodafone Group Plc Registered Office: Vodafone House The Connection
Newbury Berkshire RG14 2FN
Registered in England No. 1833679
References
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