Vodafone Group Plc
Sustainable 
Business Report 
2019

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, as well as championing mobile 
financial services and digital transformation in emerging markets.
INTRODUCTION
Our year at a glance	
3
Chief Executive introduction 	
5
How we connect for a better future	
6
Our sustainable business strategy	
7
TRANSFORMATION
Women’s empowerment	
9
The global context	
10
Empowering women in 
emerging markets	
11
Gender equality in our workplace	
16
Youth skills and jobs	
19
The global context	
20
Our future jobs strategy 	
21
Digital workplace experience	
23
Energy innovation	
25
The global context 	
26
Vodafone, energy and climate change 	
27
Our greenhouse gas emissions	
28
Optimising our energy consumption	
30
Increasing renewable energy 	
32
Scope 3 emissions	
33
Enabling customers to 
reduce emissions 	
34
Our business
650 million
mobile customers*
85 million
IoT connections
37.1 million
mobile money customers
5.4 million
TB of data transmitted
€43.7 billion 
turnover
92,005
employees
OPERATING RESPONSIBLY
Supply chain integrity 	
37
Safety	
42
Managing key safety risks	
43
Human rights	
46
Anti-bribery and corruption	
48
Our approach to political engagement 	
51
Privacy and cyber security	
53
Mobiles, masts and health	
56
OUR PEOPLE 	
Developing skills and capability	
61
Building a diverse and inclusive business	 62
Employee wellbeing	
64
Managing change and reorganisations	
65
APPENDIX 
Managing and reporting on 
sustainable business	
67
Materiality	
69
Environmental management	
70
Scope of reporting	
71
How we report our key 	
performance indicators	
72
Independent Limited Assurance 
Report to Vodafone Group Plc	
80
In this report
* Including all of the customers in Vodafone’s joint ventures and associates.
Our people
Appendix
Introduction
Transformation
Operating responsibly
2
Vodafone Group Plc Sustainable Business Report 2019

Youth skills
and jobs
Progress towards 
our 2022 goals 
Support 10 million young people 
to access digital skills, learning and 
employment opportunities
478,986 
users have completed our Future Jobs 
Finder tool to understand their strengths 
and skills and view job opportunities in 
the digital economy
Provide 100,000 opportunities for young 
people to receive a digital learning 
experience at Vodafone
54,712 
young people provided with workplace 
experience during the year
Our year at a glance
Women’s 
empowerment
By empowering women 
and promoting gender 
equality, we can help 
communities, economies 
and businesses – including 
our own – to prosper.
With a growing digital 
skills gap, we believe 
there is a need to help 
young people develop the 
skills they need to thrive 
in the digital economy.
Progress towards 
our 2025 goals 
We aim to connect an additional 
50 million women living in emerging 
markets to mobile
19.4 million 
more female customers in 
our emerging markets since 2016
Our ambition is 
for Vodafone to become the 
world’s best employer for women
31% 
of our management and
 leadership roles held by women
Energy 
innovation
Progress towards 
our 2025 goals
To reduce our greenhouse 
gas emissions by 50% 
3%
reduction in our total greenhouse 
gas emissions in the last year
Our ambition is to purchase 
100% of the electricity  we use 
from renewable sources 
15%  
of purchased electricity was 
from renewable sources
9
19
Urgent action is needed to 
address climate change. We 
are committed to achieving 
a significant reduction in the 
greenhouse gas emissions 
associated with our operations.
25
3
Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix

We work with our suppliers, partners 
and peers to drive high standards 
across our supply chain and do our 
utmost to keep everyone working in 
our operations safe from harm.
Key highlights of the year
Supplier Academy
Launched a common industry 
Supplier Academy to help build 
capability of suppliers
85 
on-site assessments conducted 
within Vodafone’s supply chain
Supply chain integrity and safety
Our business performance and our 
customers’ experience of Vodafone depend 
on our ability to attract, develop and retain 
talented individuals at all levels.
Our people
* Employees 
who responded
to our Global 
People Survey
Key highlights of the year
€60m
invested in employee 
training and development
85% 
of our employees* believe that 
Vodafone is socially responsible 
450 employees
have joined our Multicultural 
network, which was launched 
this year in the UK
58
Vodafone has strict governance processes 
and controls in place to protect our 
customers’ personal data, respect their 
privacy and proactively manage the cyber 
security risks that face businesses today.
Privacy and cyber security
Key highlights of the year
10 Privacy 
‘commandments’ 
established to help drive how we 
develop and operate our products 
and services
Vodafone Cyber Code 
launched to simplify and 
explain our basic security controls 
to all employees
53
Our reporting does not stop here
Reporting our contribution
to the UN SDGs 
Vodafone is committed to leveraging 
the power of its technology, networks 
and services to contribute to the United 
Nations Sustainable 
Development Goals. 
Find out how in 
our report. 
Taxation and our total 
economic contribution 
As a major investor, taxpayer and employer, 
we make a significant contribution to the 
economies of all the countries in which we 
operate. Our tax 
report sets out our 
total contribution to 
public finances on a 
cash-paid basis. Find 
the report online. 
Digital Rights and 
Freedoms Reporting Centre
Our transparency disclosures on matters related 
to digital human rights include our policies, 
approach and principles regarding government 
access to customer data, as well as our 
approach to managing issues such as freedom 
of expression, censorship and the digital rights 
of the child. We present our approach on these 
issues online in our Digital Rights and Freedoms 
Reporting centre.
vodafone.com/sdgs
vodafone.com/tax
vodafone.com/drf
vodafone.com/sustainability
Mobiles, masts and health 
The health and safety of our customers and 
the wider public is a priority for Vodafone. 
We endeavour to address any concerns 
regarding the electromagnetic frequency 
(EMF) emissions from mobile devices and 
base stations by providing up-to-date, open, 
transparent information on our website and 
by engaging with local communities.
56
vodafone.com/mmh
Our contribution  
to the UN SDGs
Vodafone Group Plc 
May 2019
Our contribution  
to the UN SDGs
Human rights
Key highlights of the year
GNI assessment
completed to ensure we have 
measures in place to protect and 
advance freedom of expression 
and the right to privacy
Tech Against 
Trafficking
Joined a new multistakeholder 
coalition, Tech Against 
Trafficking, which is focused on 
modern slavery issues
46
Respect for human rights, together with 
established processes to reduce the risk 
of human rights abuses, is critical to 
our long-term success.
Our year at a glance
4
Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix
Supply chain 37
Safety 42

society. In the first year, we have made good 
progress through our Future Jobs Finder 
platform, with 500,000 young people, across 
20 different countries, learning more about 
their skills and abilities and how they can use 
those to find a career in the digital economy. 
–	 Climate change remains one of the most 
critical global challenges facing humanity. 
We have committed to reducing our 
greenhouse gas emissions by 50% and to 
purchasing 100% of the electricity we use 
from renewable sources by 2025. These are 
ambitious targets for our business, as business 
growth and our customers’ growing data 
usage is resulting in increased energy demand. 
While there is no simple global solution, I am 
pleased with the progress we have made this 
year to ensure that we will meet our targets in 
a credible and sustainable way.
Vodafone is also committed to operating 
responsibly and with integrity. This report 
outlines the policies, approach and controls 
we put in place to manage key risks such as 
digital human rights, ensuring integrity in our 
supply chain, health and safety, protecting 
our customers’ data and respecting their right 
to privacy. 
Vodafone’s purpose is to connect for a better 
future and is supported by our commitment to 
improve one billion lives through an inclusive 
digital society while halving our environmental 
impact by 2025. 
We have an important role to play in helping 
to create a digital society. Digital services, like 
the ones we provide, are quickly becoming 
the new engines of growth in the global race 
for economic prosperity and sustainable 
development. As digitisation dramatically 
increases the rate of change and pace of 
innovation, it can however, also widen existing 
divides in our societies. In this fast-paced 
journey to an exciting digital age, our goal must 
therefore be to democratise digitisation, making 
technology truly accessible to everyone while 
being more mindful of its impact on our planet.
As Vodafone’s CEO, I am pleased to share our 
Sustainable Business Report 2019 with you, which 
outlines our progress against our sustainable 
business strategy and targets. It is clear that 
our focus on women’s empowerment, youth 
skills and jobs and energy innovation is having a 
positive impact on our customers, our colleagues 
and the communities in which we work. 
Chief Executive introduction
Vodafone’s purpose is 
to connect for a better 
future and is supported by 
our commitment to improve 
one billion lives through an 
inclusive digital society while 
halving our environmental 
impact by 2025.
Our strategy continues to 
help drive impact against 
the UN Sustainable 
Development Goals (SDGs)
Inspired by our purpose and supported by our 
networks and technologies, we are working 
to ensure that our services, programmes and 
initiatives are helping to accelerate gender 
diversity and women’s empowerment, and are 
improving young people’s digital skills across our 
footprint, while we reduce our environmental 
impact. I am pleased with our progress and 
would particularly highlight some of the 
programmes and initiatives that are driving that 
success, including:
–	 In 2016, Vodafone set a target to connect 
an additional 50 million women living in 
emerging markets to mobile by 2025. To 
date, we estimate that we have connected 
an additional 19.4 million women, providing 
opportunities for them to enhance the 
quality of their lives and reach their full 
potential. Vodacom’s Mum & Baby service 
in South Africa is one example of the 
programmes we are developing in pursuit 
of our goal. It is a platform that provides 
subscribers with maternal, neonatal and child 
health and wellbeing information, with 98% 
of those completing a recent independent 
survey saying they had taken action to 
improve their child’s health as a result of 
using this service.
–	 In March 2018, we committed to our target 
to support 10 million young people to access 
digital skills, learning and employment 
opportunities by 2022.  This goal was 
developed to address the concern that, 
while younger people are generally more 
savvy digitally, many find themselves lacking 
the necessary digital skills to capture new 
employment opportunities in a digital 
Our strategy continues to help drive impact 
against the UN Sustainable Development Goals 
(SDGs), and specifically those that relate to 
quality education, gender equality, decent work 
and economic growth, industry, innovation and 
infrastructure, and climate action.
Vodafone is optimistic about the benefits of 
a digital society. High speed networks are 
accelerating the availability of new technologies 
and innovative products and services that 
will help our customers and wider society to 
improve their lives and livelihoods. Using those 
new technologies, we intend to continue to 
help to build prosperous economies, strong 
communities and a sustainable planet, as we 
work to create a more inclusive digital society.
Nick Read
Group Chief Executive, Vodafone Group Plc
5
Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix

Our employees
Our business performance and 
our customers’ experience 
depend on our ability to attract, 
develop and retain talented 
individuals at all levels.
Working across our business
Every day, our products and services play a 
central role in the daily lives and livelihoods 
of more than half a billion people, across 
25 countries. We work to embed our 
sustainable business strategy across all our 
operations and are committed to building 
positive relations with all our stakeholders. 
Working with our suppliers
We work with more than 10,800 
direct suppliers around the 
world. We have collaborated with 
peer companies to develop an 
academy to support suppliers to 
improve their social, ethical and 
environmental performance.
In our operations
Keeping the people who work 
for us safe is one of our most 
fundamental responsibilities. 
We are also committed to 
responding openly and 
transparently to public concerns 
about mobiles, masts and health.
For our customers
Our customers trust us with 
their personal information and 
their privacy. Protecting that 
information and respecting 
their privacy is fundamental. 
Across our network
Our networks account for 94% of our 
total energy use. Through a number 
of different initiatives, we are working 
to improve energy efficiency across 
our networks and purchase 100% 
renewable electricity by 2025.
42	 Safety
56	 Mobiles, masts and health
13	 Increasing access to health 
advice in South Africa
23	 Providing free coding training 
in Turkey
16	 Gender equality 
in our workplace
58	 Our people
6
Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix
How we connect for a better future
For communities
Through targeted commercial 
propositions, we are helping 
women in emerging markets 
overcome the barriers they face 
in reaching their full potential, 
benefiting both themselves and 
their local communities.
30	 Our network – optimising our 
energy consumption
32	 Increasing renewable energy
53	  Privacy and cyber security
37	  Our suppliers

We believe that Vodafone has a significant 
role to play in contributing to the societies in 
which we operate. Our sustainable business 
strategy articulates our intention to deliver 
significant positive impact in three areas, 
each of which has the potential to improve 
the lives of our customers and wider society. 
We have established long-term targets to 
drive change in the areas of:
–	 women’s empowerment;
–	 youth skills and jobs; and
–	 energy innovation.
In parallel, we remain committed to ensuring 
that Vodafone operates responsibly and 
ethically, supported by our corporate 
transparency programme. Four areas form 
the focus of our efforts as we ensure detailed 
policies, practices and disclosures help 
to hold our businesses to account while 
contributing to the broader debate. 
Our operating responsibly focus areas are:
–	 taxation and total economic contribution;
–	 supply chain integrity and safety;
–	 mobiles, masts and health; and
–	 digital rights and freedoms.
Our sustainable business strategy
Supply chain 
and safety
Principles and practice
Mobiles, masts 
and health
Digital rights 
and freedoms
Our transformation areas
Operating responsibly
Tax and total 
economic 
contribution
Women’s  
empowerment
Energy 
innovation
Youth skills 
and jobs
We connect for a better future
7
Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix

8
Introduction
Transformation
Operating responsibly
Our people
Appendix
Vodafone Group Plc Sustainable Business Report 2019
Women’s empowerment
Energy innovation
Youth skills and jobs
Women’s empowement
By empowering women and 
promoting gender equality, we can 
enable communities, economies 
and businesses – including our 
own – to prosper. Communications 
technology plays a critical role in 
helping women to improve their 
lives and livelihoods. By improving 
the diversity of our global workforce 
we will better reflect our customer 
base and wider society.
Youth skills and jobs 
In many of the countries where 
we operate, youth unemployment 
remains at very high levels. Together 
with a growing digital skills gap, 
this creates a significant social 
and economic challenge. Working 
together, governments, educators 
and companies need to find ways 
to address future workplace needs 
and enhance the skills of people 
entering the workforce, to enable 
them to be better equipped to 
contribute to a prosperous and 
inclusive digital society.
Energy innovation 
Our industry faces a growing 
greenhouse gas (GHG) emissions 
challenge and we have an important 
role to mitigate the consequences 
of the growth in demand for our 
services. We will continue to reduce 
the GHG emissions associated 
with our operations by purchasing 
more of the electricity we use from 
renewable sources. We will also 
continue to help our customers 
to reduce their emissions through 
the use of our Internet of Things 
products and services.

Transformation
Our sustainable business strategy articulates our intention to deliver 
significant positive impact in three areas, each of which has the 
potential to improve the lives of our customers and wider society. We 
have established long-term targets to drive change that focuses on 
women’s empowerment, youth skills and jobs, and energy innovation.
9
25
19

Women’s empowerment 
The equality of women remains a significant global challenge. By 
empowering women and promoting gender equality, we can enable 
communities, economies and businesses – including our own – to prosper. 
For society
We are changing women’s lives 
through mobile.
Within our business
Our strong commitment to diversity 
is a source of  business strength.
Our 2025 goal
We aim to connect an additional 
50 million women living in 
emerging markets to mobile.
Progress towards our goal
19.4 million 
more female customers in our 
emerging markets since 2016.
Our 2025 goal
Our ambition is for Vodafone 
to become the world’s best 
employer for women.
Progress towards our goal
This year, the 2019 Bloomberg 
Gender-Equality Index 
recognised Vodafone as one 
of the top companies globally 
leading the way towards more 
equal, inclusive workplaces.
See page 11
See page 16
9
Transformation
Women’s  empowerment
Vodafone Group Plc Sustainable Business Report 2019
Energy innovation
Youth skills and jobs
Introduction
Operating responsibly
Our people
Appendix

The global context
Women are disadvantaged 
economically across all cultures, 
societies and economies. Globally, 
around 50% of women aged 15 or 
over are in paid employment, 
compared with around 75% of men1. 
According to the World Economic Forum, it will 
take another 202 years to close the economic 
‘gender gap’ if significant changes are not made. 
Also, the comparative lack of women in senior, 
better-paid roles means that the global average 
for women’s earnings is half that for men2. 
In emerging economies, the gender gap often 
affects women at an earlier age than it does in 
more developed economies, and barriers exist 
in all areas of life, including access to education, 
healthcare and finance. An estimated 132 
million girls around the world are currently out 
of school, and girls are more likely to remain 
excluded from education than boys3. Evidence 
also suggests that women in emerging markets 
are more likely to live in poverty than men4. 
Estimates state that every day approximately 
830 women die from preventable causes related 
to pregnancy and childbirth5.
In more developed economies, young women 
and men enter the workplace with equivalent 
skills and in broadly equal numbers, but a 
much greater proportion of men reach middle 
and senior-level roles. A significant proportion 
of women leave the workforce or continue 
working in more junior roles than their male 
peers. A lack of support during pregnancy and 
the challenge of balancing childcare with work 
account for many women deciding to leave 
paid employment. Some women experience 
difficulties in returning to work after a career 
break. Those who return to work find fewer 
opportunities for promotion and progression 
than their male counterparts6. 
Our alignment to the UN Sustainable 
Development Goals (SDGs)
It is estimated that giving women and girls equal rights 
and opportunities could improve public health, increase 
productivity and grow prosperity, adding US$12 trillion to 
global GDP by 20257.
Communications technology can play a critical role in 
empowering women to improve their lives and livelihoods. 
Providing women with access to life-enhancing services 
can help unlock socio-economic opportunities and 
champion the inclusion of women in the workplace. 
Vodafone is committed to SDG Goal 5, which is focused 
on achieving gender equality.
Our approach also aligns with Goals 4 (quality education) 
and 8 (decent work and economic growth), as our mobile 
technologies also support improved education outcomes 
and drive financial inclusion.
Key SDGs and targets
4.3 By 2030, ensure equal access 
for all women and men to affordable 
and quality technical, vocational and 
tertiary education, including university.
5.1 End all forms of discrimination 
against all women and girls everywhere.
5.5 Ensure women’s full and effective 
participation and equal opportunities for 
leadership at all levels of decision-making 
in political, economic and public life.
5.B Enhance the use of enabling 
technology, in particular information 
and communications technology, to 
promote the empowerment of women.
8.5 By 2030, achieve full and productive 
employment and decent work for all 
women and men, including for young 
people and persons with disabilities, and 
equal pay for work of equal value.
8.10 Strengthen the capacity of domestic 
financial institutions to encourage and 
expand access to banking, insurance and 
financial services for all.
132 million girls
are currently out of school and 
are more likely to remain excluded 
from education than boys.
The global gender gap
Women 
are 10% 
less likely
to own a mobile phone 
than men. 
One-third 
fewer women
Around 50% of women 
aged 15 or over are in paid 
employment, compared
 with around 75% of men.
10
Transformation
Women’s  empowerment
Vodafone Group Plc Sustainable Business Report 2019
Energy innovation
Youth skills and jobs
Introduction
Operating responsibly
Our people
Appendix

Empowering women in emerging markets
In low and middle-income countries, women 
are 10% less likely to own a mobile phone than 
men. This equates to a ‘mobile gender gap’ of 
approximately 200 million women deprived of 
the benefits of mobile ownership8. In addition, it 
is estimated that over 300 million fewer women 
than men access the mobile internet. 
Closing the gender gap in mobile ownership 
and usage by 2023 would provide an estimated 
additional US$140 billion in revenue for the 
mobile industry over five years9. 
Owning even the most basic mobile enables a 
woman to communicate, access information, 
learn, manage her finances, set up and run a 
business and even get help if feeling threatened. 
Mobile technology also enhances many public 
and commercial services of value to women 
and girls in emerging markets, from accessing 
vaccinations and maternal healthcare, to 
mobile banking and online support for 
smallholder farmers.
Changing women’s lives through mobile
We estimate that 119.8 million of the 
334.5 million active customers we serve in 
emerging markets are women10. However, this 
only represents 36% of our customer base, and 
a disproportionate number of women in these 
markets still do not own a mobile phone.
We want to bring the benefits of mobile to 
women through a series of targeted commercial 
programmes. In 2016, we set a goal to connect 
an additional 50 million women in emerging 
markets to mobile. To reach this target, we are 
committed to use our mobile technologies to 
enhance the quality of women’s lives through 
programmes that:
Our 2025 goal
We aim to connect an additional 
50 million women living in 
emerging markets to mobile
Progress towards our goal
We have made progress towards
our goal and now have an estimated 
119.8 million active female 
customers, 6.1 million more 
than last year (and an increase 
of 19.4 million since 2016).
Estimated number of female customers 
in emerging markets (millions)
See page 71 for how we report our 
key performance indicators
2017
2018
2019
Goal
Baseline
0
25
50
75
100
125
150
109.7
113.7
+9.4
2016
100.3
+3.9
119.8
+6.1
–	 support education and skills;
–	 improve health and wellbeing; and
–	 enable economic empowerment.
To contribute towards our goal, we have 
launched new commercial propositions for 
customers focused on helping women in 
emerging markets overcome the barriers they 
face in reaching their full potential. These 
include Vodacom’s Mum & Baby initiative in 
South Africa, Vodafone Idea’s Sakhi safety plan 
and our Business Women Connect programme 
in Tanzania and Mozambique.
Supporting education and skills
Enabling girls and women to access a good 
education can enhance their chances of thriving 
in life, yet many girls in emerging markets enter 
adulthood lacking basic literacy and numeracy 
skills. An estimated 132 million girls worldwide 
are out of school, including over 34 million girls 
of primary school age11.
Mobile technology increases access to quality 
education, especially for people living in remote 
areas. Vodafone Foundation has pioneered the 
development of innovative digital teaching and 
remote learning technologies for deployment 
among some of the most vulnerable and 
disadvantaged communities in the world, 
including people living in refugee camps in 
sub-Saharan Africa. Its Instant Network Schools 
programme connects classrooms to the internet, 
providing remote and isolated communities 
with solar power, tablet computers and teacher 
training resources, together with access to 
educational content. Run in partnership with the 
United Nations High Commission for Refugees, 
the Instant Network Schools programme has 
given over 83,500 young refugee students 
access to a quality digital education.
Across our networks
6.1 million
more female customers 
than last year
37.1 million
customers using M-Pesa, 
16.9 million are women
1.5 million
subscribers to Mum & Baby 
service in South Africa
11
Transformation
Women’s  empowerment
Vodafone Group Plc Sustainable Business Report 2019
Energy innovation
Youth skills and jobs
Introduction
Operating responsibly
Our people
Appendix

Improving health and wellbeing
Estimates show that at least half the world’s 
population lacks access to essential health 
services13. Most of those people live in low to middle-
income countries where access to services for 
screening, prevention and treatment is often limited 
or non-existent. Rural poor, especially women, are 
particularly deprived of such essential services.
Through Vodafone and Vodafone Foundation, we 
have developed a range of mobile technologies that 
enhance primary healthcare and prevention services 
in emerging markets. Many of these programmes 
are particularly important for women and young 
children. They include Vodacom’s Mum & Baby 
service in South Africa, which provides subscribers 
with maternal, neonatal and child health and 
wellbeing information. This year we commissioned 
KPMG to conduct a socio-economic assessment of 
this service to understand its impact and identify 
areas where it could be enhanced in the future (see 
the case study on page 13 for more information).
In Tanzania, Vodafone Foundation has 
collaborated with the United States Agency for 
International Development and other partners 
to develop its Mobilising Maternal Health 
programme. This uses mobile technology to 
connect mothers to healthcare with the aim 
of reducing rates of maternal death and injury, 
indirectly reducing the number of neonatal 
deaths. Since the launch of the programme, 
over 900,000 women have been connected 
to treatment or free transport in emergencies. 
Known as M-Mama, the emergency transport 
works with a network of local drivers to act as 
‘taxi ambulances’ in areas where ambulances 
are rarely available. When the patient makes a
free call to a 24/7 dispatch centre, the call 
handler assesses the patient’s condition using
the M-Mama app, which indicates whether the 
patient needs transferring to a health facility.
If so, the nearest taxi ambulance driver identified 
on the M-Mama app is sent to take the woman to 
the closest health facility. On arrival, the driver 
is paid for the journey via M-Pesa. M-Mama has 
helped achieve a 27% reduction in maternal 
mortality in the northern Lake Zones of 
Tanzania where it is operational.
Empowering girls through mobile
Across the world, millions of girls lack the 
information, connections, tools and services 
they need. Many of the everyday issues that 
affect them – relationships, contraception 
and gender-based violence – are often too 
sensitive to talk about openly, if at all. Boys 
are also one and a half times more likely to 
own a mobile phone than girls12.
Vodafone Foundation, which focuses 
on using connectivity to drive social change, 
launched a partnership this year with Girl 
Effect, a non-governmental organisation 
(NGO) with expertise in using media and 
mobile technology to empower girls to 
change their lives. The partnership aims
to empower 7 million vulnerable girls 
across eight countries, connecting them 
to information, support and services they 
need, through mobile.
The partnership will increase the reach of mobile 
platforms such as Springster, a mobile platform 
designed for and created by girls. The content on 
Springster helps girls understand and navigate 
the key social issues they face in their local area, 
from health and education, to financial security 
and personal safety. Through informal learning 
and by connecting girls with a supportive group 
of peers, the Springster platform aims to break 
the cycle of poverty by giving girls the tools, 
knowledge, networks and confidence they 
need to reach their full potential.
Vodafone Foundation has contributed US$5 
million to the project, which will be used to 
generate a total of US$25 million over five 
years. The partnership aims to reach girls across 
India, Tanzania, South Africa, Lesotho, Ghana, 
the Democratic Republic of Congo, Kenya and 
Mozambique.
12
Transformation
Women’s  empowerment
Vodafone Group Plc Sustainable Business Report 2019
Energy innovation
Youth skills and jobs
Introduction
Operating responsibly
Our people
Appendix

Increasing access to health advice for mums, dads and carers
According to UNICEF South Africa14, each 
year 4,300 mothers die due to complications 
during pregnancy and childbirth, 20,000 
babies are stillborn and another 23,000 
die in their first month of life. Research 
shows that good access to reliable health 
information plays a crucial role in reducing 
maternal and infancy illness and mortality. 
In addition, many people in South Africa 
face long queues to receive health advice 
for themselves and their families and often 
have to travel long distances to reach a clinic, 
especially in rural areas. 
To help address this problem, Vodacom 
developed Mum & Baby. This free-to-use 
(no data charges) mobile health (‘mHealth’) 
intervention gives customers maternal, 
neonatal and child health information. 
The information is shared through weekly 
stage-based SMS messages. Additional 
health-related content, such as articles, 
videos and tutorials, is available through a 
mobile-optimised website. Mum & Baby is 
available in English, Zulu, Sesotho, Xhosa 
and Afrikaans. The service has helped over 
1.5 million parents and caregivers to take 
positive actions to improve their children’s 
health since its  launch in 2017.
This year we commissioned KPMG to 
conduct an independent study to assess 
the socio-economic contribution of 
Vodacom’s Mum & Baby service.
The study found:
–	 98% of the mothers and pregnant women 
surveyed said they had taken action to 
improve their child’s health because of 
access to the information provided by 
the service;
–	 95% of the mothers and pregnant women 
surveyed said that the information 
received influenced their decision to 
breastfeed, and across the focus groups 
a small number of participants indicated 
that the information received had resulted 
in them breastfeeding for longer than 
six months;
–	 97% of mothers and pregnant women 
surveyed said the service influenced 
their decision to visit a health centre for 
check-ups; and
–	 96% agreed that the information received 
helped with their decision to vaccinate 
their child. If this were representative of all 
Mum & Baby subscribers, it would suggest 
that the service may have influenced the 
vaccination decisions for the children of 
approximately 650,000 individuals in 
South Africa.
The findings of the study will be 
used to help shape future plans 
for the service and how its social 
impact can be enhanced. 
  Read the report: 
Vodacom’s Mum & Baby 
service in South Africa
Tackling domestic violence and abuse 
Vodafone Foundation has more than a decade 
of experience developing mobile services 
to support victims of domestic violence and 
abuse. This includes the TecSOS technology, 
which has supported more than 100,000 
high-risk survivors of domestic violence in five 
countries, along with Easy Rescue, which has 
supported over 300,000 women in Turkey, and 
gender-based violence hotlines in South Africa 
and Kenya, which have connected over 300,000 
women to help during crises.
This year, Vodafone Foundation commissioned 
research to explore the impact of domestic 
violence and abuse in the workplace (see page 17 
for more information on the findings). In response 
to the issues highlighted by the research, 
Vodafone Foundation announced the international 
expansion of Bright Sky, a free app that provides 
information and advice to those affected by 
domestic abuse. Created in partnership with the 
UK-based crisis support charity Hestia, the app 
enables users to locate their nearest support 
centre. A short questionnaire also helps users 
assess the safety of a relationship and provides 
information about different forms of abuse and
the types of support available.
In conjunction with this, Vodafone has launched 
a global domestic violence and abuse policy
(see page 17 for more information).
13
Transformation
Women’s  empowerment
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Energy innovation
Youth skills and jobs
Introduction
Operating responsibly
Our people
Appendix

Helping women to feel safer in India
In India, there are over a billion mobile connections and while almost half of the population is 
female, only 59% of them own a mobile phone15. This year, Vodafone Idea (our joint venture in 
India) launched a new mobile service for female customers called Sakhi that includes a special 
set of security and safety features, including:
Emergency Alerts
Location alerts that can be sent to ten pre-registered contacts in an emergency.
Emergency Balance
Ten free minutes of call time that can be used during emergencies, even with zero credit.
Private Number Recharge
Provides a dummy ten-digit number to ensure the privacy of customers when they recharge 
at retail outlets, avoiding the need for them to have to reveal their mobile number to an 
unknown retailer.
Female customers using Vodafone Idea prepaid or postpaid services can sign up to Sakhi for free, 
and can use the service on any type of phone, even without credit or access to mobile internet.
To date, millions of women from both rural and urban areas have subscribed to Sakhi, giving 
them the confidence to travel further from home to pursue education and employment 
opportunities, while feeling safer and less at risk of harassment.
Enabling economic empowerment
More than 2 billion people in the world, most 
of them women, still have no access to banking 
facilities16, and women have less access to 
financial services than men in 40% of the world’s 
countries17. Finding ways to improve their access 
to financial services will bring significant social 
benefits and economic opportunities.
In 2007, together with our Kenyan associate, 
Safaricom, we developed the first mobile 
money transfer service, M-Pesa. This is a 
simple, secure, cheap and convenient solution 
now offered to customers across eight markets: 
the Democratic Republic of Congo, Egypt, 
Ghana, India, Kenya, Lesotho, Mozambique
and Tanzania. The service enables customers 
to safely and securely send, receive and 
store money via a basic mobile phone and, 
more recently in some markets, using a 
smartphone app.
As of March 2019, 37.1 million customers 
were using M-Pesa18, with over 11 billion 
transactions having been made through 
a network of more than 395,000 agents. 
With a mobile phone and an M-Pesa account, 
people on low incomes have more control 
over their financial affairs. It also reduces the 
associated risks of robbery and corruption in a 
cash-based society. Thanks to the development 
of additional services such as M-Shwari, 
M-Pawa and KCB M-Pesa, our customers can 
also save money through interest-bearing 
accounts and arrange micro-loans to help fund 
their businesses. M-Pesa is also widely used 
to manage business transactions and to pay 
salaries, pensions, agricultural subsidies and 
government grants. 
With M-Pesa, women can take greater control 
over their own and their family’s finances. For 
example, in Kenya, research estimated that 
with mobile money access through M-Pesa, 
185,000 women have been able to switch from 
subsistence farming to business or sales as their 
primary occupation19. In addition, the research 
also found that M-Pesa has helped lift 194,000 
households, or 2% of Kenyan households, out of 
poverty. We estimate that 16.9 million women 
were actively using M-Pesa in 2018, accounting 
for 46% of our M-Pesa customer base.
Goal 10 of the UN SDGs is to ‘reduce inequality 
within and among countries’. Within this, 
target 10.c is to reduce the cost of sending 
remittances to less than 3% of transaction costs 
by 2030. This has already been met by M-Pesa in 
those markets where it has regulatory approval 
to offer outbound remittances. In Kenya this 
year, in partnership with Western Union, we 
launched M-Pesa Global. This service allows 
M-Pesa customers to send and receive money 
across 200 countries and territories. M-Pesa 
also continues to expand its partnerships across 
the globe for inward remittances, helping 
migrants and their families receive their money 
in a fast, secure and convenient manner.
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Women’s  empowerment
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Energy innovation
Youth skills and jobs
Introduction
Operating responsibly
Our people
Appendix

Supporting female entrepreneurs 
In addition to financial services, 
Vodafone’s networks and technologies 
support businesses of all sizes, including 
entrepreneurs. For example, research 
commissioned in Ghana by Vodafone found 
that 70% of micro-entrepreneurs would face 
difficulties continuing their business without 
a smartphone20. This constant connectivity 
allows entrepreneurs to connect with 
customers, search for new business ideas 
and track competitors’ prices. 
Through Vodafone Business in our local markets, 
we provide products and services for small and 
medium-sized (SME) and small-office home-
office (SOHO) businesses. Our aim is to be a 
digital solutions provider for this market and 
help guide small businesses through technology 
choices that are moving at an unprecedented 
pace. For example, this year Vodafone Ireland 
launched Open Conversations, an initiative to 
help our SME customers gain insights on the 
future of business. 
Vodafone also supports female entrepreneurs 
through local Vodafone Foundation 
programmes. The Vodafone Institute in 
Germany developed F-LANE, a seven-week 
acceleration programme for high-potential 
digital impact ventures and the first 
accelerator in Europe aimed exclusively at 
women. The programme’s mission is to foster 
the participation of women in technological 
development and to empower women of all 
ages around the world through technology. In 
the most recent round, 180 start-ups from 57 
countries were identified for consideration and 
review. The final five applicants took part in 
the full programme of support, which included 
mentorship, training, networking and funding.
Supporting businesswomen in Tanzania and Mozambique
Since 2016, we have built on the success of our M-Pesa money transfer and M-Pawa money 
saving services. We are a partner in Business Women Connect (BWC), a service specifically 
designed for women who run micro-businesses. Created in partnership with the ExxonMobil 
Foundation, World Bank and Centre for Global Development, BWC enables women to save and 
access useful business skills training, delivered by the NGO TechnoServe. 
Since its launch, nearly 6,000 Tanzanian women have benefited from BWC’s business skills 
training and learned how to use M-Pawa. The World Bank has analysed the results, which show 
that women who are introduced to M-Pawa and have business skills training are statistically 
more likely to move their savings into their phones and improve their business practices.
Building on this success, we supported a pilot involving 500 businesswomen in Mozambique 
in 2017. After the training, women’s savings by phone increased from 56% to 93%, and the 
number keeping business records increased from 25% to 60%. The pilot also found a high use 
of phones among urban businesswomen and a growing interest in mobile payments.
Over the coming year, TechnoServe and Vodacom plan to explore a new partnership in 
Mozambique to support female agents who run kiosks where M-Pesa customers can deposit 
and withdraw money. One of the main objectives will be to provide financial literacy, business 
and agent skills so that more women can become successful entrepreneurs. 
Women First in Entrepreneurship
Through Vodafone Turkey Foundation’s 
Women First in Entrepreneurship 
programme, more than 36,000 
women have received training on 
entrepreneurship, communications and 
finance. Once trained, they can use their 
new skills to make and sell handmade 
items on a bespoke website. Launched in 
2015, the programme is run in partnership 
with the Ministry of National Education 
and the Turkish Informatics Foundation. 
This year, a new mobile application was 
launched to enable women to access 
e-learning content and manage their 
products. The application has been 
downloaded over 21,000 times, with over 
50% of the users completing the e-learning.
15
Transformation
Women’s  empowerment
Vodafone Group Plc Sustainable Business Report 2019
Energy innovation
Youth skills and jobs
Introduction
Operating responsibly
Our people
Appendix

Gender equality in our workplace
Vodafone employs over 36,500 women directly 
and provides employment opportunities for 
hundreds of thousands more across our global 
supplier base. We believe that achieving greater 
gender equality strengthens our company 
significantly, giving us a better understanding 
of the needs of the women, men, families 
and businesses who rely on our networks 
and services.
Achieving gender equality in the workplace, 
at all levels, remains a significant challenge for 
most businesses, especially those of a global 
nature. To address this issue, Vodafone has a 
long-term ambition to become the world’s 
best employer for women by 2025. 
Our commitment to gender equality
We have embedded our commitment to 
diversity and gender balance into how we work 
at Vodafone. In our induction programme for 
senior leaders, they are required to complete 
unconscious bias training to help them 
recognise the assumptions and beliefs that can 
skew their decision making. A number of our 
training programmes focus on making sure our 
recruitment processes are balanced and help to 
develop the skills required to manage diverse 
teams. This year, we piloted a global female 
development programme, ConnectedSheCan, 
providing in-depth coaching and training to 
15 senior leaders from across the business.
The programme forms part of the succession 
plan for employees destined for more senior roles. 
Our new Group Chief Executive, Nick Read, 
continues the commitment to act as a corporate 
champion for the UN Women’s global solidarity 
movement for gender equality, HeforShe. On 
a quarterly basis, we assess our progress to 
Our 2025 goal
Our ambition is for Vodafone to 
become the world’s best employer 
for women
Progress towards our goal
This year, the 2019 Bloomberg 
Gender-Equality Index recognised 
Vodafone as one of the top 
companies globally leading 
the way towards more equal, 
inclusive workplaces. 
The Index scored Vodafone 
between 82% and 100% 
across several categories, 
including gender 
employment statistics, 
employer policies, company 
products and company 
community engagement. 
Vodafone was also recently  
named in The Times Top 50 
Employers for Women 2018, 
recognising our leadership 
on workplace gender 
equality in the UK.
increase the global proportion of women in 
management and leadership. HR directors in 
our local markets and professional functions 
use quarterly analysis to identify and address 
challenges. Twice a year, our Group Executive 
Committee (ExCo) reviews Vodafone’s gender 
balance and discusses key initiatives to increase 
the proportion of female employees. The 
Vodafone Group Board is updated regularly 
on progress.
We have active women’s networks in many of the 
countries in which we operate. These networks 
are founded and managed by employees. They 
offer women at all levels a supportive and 
informative environment in which to network, 
share and learn. 
This year, Vodafone Business created a forum 
to bring together global female senior leaders, 
with 70 invited to a specific event in December 
2018. During the forum, participants shared best 
practices on how to create an inclusive business 
environment and discussed challenges facing 
women in the workplace.
We also celebrate women’s achievements with 
visible support from our senior leaders. We 
hold a week-long celebration to coincide with 
International Women’s Day. On March 8, 2019 
more than 6,300 employees watched a global 
webinar led by our Group Chief Executive. Our 
global programme saw over 60 events being held 
worldwide, including roundtable discussions, 
networking events, training, and role-modelling 
and mentoring sessions.
Across our business
We employ over
36,500
women directly.
Women hold
31%
of our management 
and leadership roles.
Our Women in 
Technology Network 
now has more than  
1,300 
members
and we now have active 
women’s networks in 
many of the countries 
in which we operate.
40%
of our total workforce 
are women, which 
enables us to have 
a stronger gender 
equality base.
16
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Women’s  empowerment
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Energy innovation
Youth skills and jobs
Introduction
Operating responsibly
Our people
Appendix

Supporting employees suffering 
from domestic violence and abuse
During the year, Vodafone Foundation 
commissioned research to assess the 
impact of domestic violence and abuse on 
people’s work-life and career. The study 
surveyed 4,715 women and men in the 
workplace across nine countries (the UK, 
Germany, Ireland, Turkey, South Africa, 
Kenya, India, Italy and Spain). The research 
found that more than one in three workers 
had experienced domestic violence and 
abuse, and 67% of those said that the 
abuse affected their career progression. 
Furthermore, 51% felt too ashamed to 
discuss their abuse at work. 
Using these insights, Vodafone designed 
and introduced a new global HR policy 
specifically for victims of domestic 
violence and abuse in all our markets. 
Employees now have access to support 
and specialist counselling, as well as up 
to 10 days’ additional paid ‘safe leave’. The 
extra safe leave gives them time to manage 
their situation, which can be used for 
seeking professional help and counselling, 
attending police or court appointments, 
making arrangements to move house 
and supporting their children. In addition, 
specialist training is provided for HR 
managers to help them support employees 
experiencing domestic violence or abuse.
Flexibility and support for working parents
Research by KPMG estimates that the cost to the 
global economy of replacing women who do not 
stay in the workforce after having a baby could 
be as much as US$47 billion every year21. We 
encourage and support our employees to return to 
work with us after the birth or adoption of a child.
Bringing our gender equality 
strategy to life in Portugal
Since 2017, Vodafone Portugal has 
implemented a number of different 
initiatives to support gender equality. 
For example, in the last two years, 
33 female employees have been 
recruited through ReConnect in 
Portugal. In addition, the business 
has strengthened its recruiting 
procedures to ensure that there 
are at least two credible females 
in every shortlist. These initiatives, 
along with working closely with third 
party labour providers, have helped 
increase the number of females hired 
in front line positions (such as within 
call centres and retail stores) by 154% 
in the last year.
Vodafone Portugal has also focused 
on training leaders to promote gender 
equality through incorporating 
unconscious bias workshops as 
part of its leadership learning and 
development curricula.
Finally, the business has worked to 
create a pipeline for female graduates 
through its internship programme, 
which has helped lead to over 60% of 
female graduates recruited in the last 
two years. As part of the internship 
programme, the students with the 
most potential are invited to become 
Vodafone Campus Ambassadors, 
64% of which are currently female. 
This provides the interns with an 
opportunity to become advocates 
of Vodafone through organising and 
participating at university job fairs and 
open days across the country.
In 2015, we introduced a global minimum 
maternity policy covering all Vodafone employees. 
Over the past four years, more than 7,000 women 
working for Vodafone have gone on maternity 
leave. All of them were eligible to benefit from at 
least 16 weeks’ fully paid maternity leave, plus full 
pay for a 30-hour week for the first six months of 
their return. Last year, we also launched a global 
paternity policy that set a minimum standard 
for all men and secondary carers who work 
for Vodafone to be entitled to two weeks’ paid 
paternity leave. 
Launched in 2016 across all our markets, our 
ReConnect initiative aims to bring talented women 
back into the workplace after a career break. 
The programme includes training, coaching and 
a specially designed induction to help those 
returning to refresh and enhance the professional 
skills they need to return to work and progress their 
careers. ReConnect joiners are also offered flexible 
working options and a phased return to work.
Our target is to hire 1,000 ReConnect women 
across our markets by 2020. To date, 310 women 
have been recruited through the programme. 
While there are a significant number of vacancies 
on offer at Vodafone at all times, it is important to 
ensure we match the skills the roles require with 
those of the candidates who have applied. We do 
not always find the appropriate skills mix in the 
ReConnect candidates who apply. This year we 
will be launching a new, more targeted campaign 
to attract women with the skills we need for the 
future, with a particular focus on digital talent. 
We also have flexible working, part-time and 
homeworking policies in place across a large 
number of our local markets, and many employees 
are using our remote working technologies. These 
include opportunities such as working from home 
one day a week, allowing for earlier or later start or 
finish times and, in some markets, having on-site 
childcare services for employees.
Our programmes in action: ReConnect
“I know many women like me, who 
are attempting to support their family 
and further their professional career 
at the same time. When I heard about 
ReConnect, I thought how refreshing 
to find a business that sees value 
in attracting talent back into the 
workplace! ReConnect has helped me 
rebuild my confidence, achieve my 
aspirations and relaunch my career.”
Alison Davies – Senior 
Customer Experience 
Manager, Vodafone UK
17
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Women’s  empowerment
Vodafone Group Plc Sustainable Business Report 2019
Energy innovation
Youth skills and jobs
Introduction
Operating responsibly
Our people
Appendix

1	 Leave No One Behind, UNHLP, 2016
2	 The Global Gender Gap Report, WEF, 2018
3	 Fact Sheet No. 48, UNESCO Institute for 
Statistics, 2018
4	 The Full Participation Report, Clinton 
Foundation and Bill & Melinda Gates 
Foundation, 2015
5	 Maternal mortality factsheet, WHO, 2016
6	 KPMG research for Vodafone, 2017
7	 Delivering the Power of Parity, McKinsey 
Global Institute, 2016
8	 GSMA Mobile Gender Gap Report, 2019
9	 GSMA Mobile Gender Gap Report, 2019
10	 Based on 30-day active customer figures 
for the nine emerging markets in the 50 
million women goal. 2019 annual data 
only includes data from Vodafone India 
up to August 2018, prior to the merger of 
this business with Idea Cellular to create 
Vodafone Idea.
11	 Fact Sheet No. 48, UNESCO Institute for 
Statistics, 2018
12	 ‘Real girls, real lives, connected’, Girl Effect 
and Vodafone Foundation, 2018
13	 Tracking Universal Health Coverage: 2017 
Global Monitoring Report, WHO and World 
Bank
14	 UNICEF, 2019
15	 GSMA Mobile Gender Gap Report, 2019
16	 Powering Potential, BNY Mellon and UN 
Foundation, 2018
17	 The Global Gender Gap Report, WEF, 2018
18	 30-day active customers (financial 
transaction within last 30 days)
19 	‘The long-run poverty and gender impacts 
of mobile money’,
 Suri and Jack, Science, 2016
20	 ‘Smartphones and micro-
entrepreneurship: evidence from Ghana’, 
Vodafone, 2016
21	 KPMG research for Vodafone, 2017
22	 Defined as management and leadership 
roles in our Technology function and 
Vodafone Shared Services Technology
23	 This includes women in senior leadership, 
senior management and middle 
management
24	 Our most senior employees (approx.
 200 employees in total), including 
ExCo members
Women in management 
and leadership23
2017
2018
2019
29%
30%
31%
Women in senior 
leadership24 
2017
2018
2019
26%
26%
28%
Women in senior 
management 
2017
2018
2019
27%
28%
28%
Women in middle 
management 
2017
2018
2019
30%
31%
31%
Women (all non-
management employees)
2017
2018
2019
40%
40%
40%
Female employees at Vodafone*
Women in technology 
Vodafone has placed specific focus on increasing 
the proportion of women in technology roles, 
particularly within senior roles. Initiatives such as 
ensuring that female candidates are included in 
interview shortlists and setting internal targets 
have helped increase the proportion of females 
working in technology. During the year, 21% of 
our technology management and leadership 
roles were held by women22. Though this 
represents progress compared to previous years, 
we know that there is more we can do to increase 
this proportion.
Through our Women in Technology network, 
we are working to better support women in 
technology roles. This now has more than 1,300 
members and holds quarterly webinars and 
local face-to-face meetings. Programmes such 
as #Codelikeagirl (see page 23), and our work 
with schools and universities to promote women 
in technology, underpin our wider strategy to 
have a positive impact on women taking up 
technology careers. 
Our performance
We have met our target of 30% of management 
and leadership roles being held by women across 
our local markets and professional functions 
ahead of our deadline of 2020. As of 31 March 
2019, women held 31% of our management 
and leadership roles, and we have now set a 
revised target for women to hold 40% of our 
management and leadership roles by 2030. 
In four of our local markets (Ireland, Romania, 
Albania and Tanzania), women already hold more 
than 40% of all management roles. In addition, 
women make up 40% of our total workforce, 
which gives us a stronger base from which to 
drive our gender equality initiatives.
The percentage of women in Vodafone’s 
global senior leadership – including ExCo 
members – increased from 26% in 2018 to 
28% in 2019. Women’s representation in our 
senior management community remained the 
same, also at 28%.
This year, the ExCo team female representation 
increased significantly, from 14% to 25%, with four 
roles now occupied by women (General Counsel, 
HR Director, CFO and EU Cluster Director). 
This year, 52% of the places on our Discover 
graduate development programme were held 
by women, along with 46% of the places on our 
Columbus fast-track graduate scheme. Increasing 
the proportion of women on these schemes 
gives us confidence that women are playing an 
increasingly important part in leading Vodafone. 
As of 31 March 2019, 42% of the directors of 
the Vodafone Group Plc Board were women. 
Twice yearly, senior management reviews the 
proportion of women serving as directors on our 
subsidiary company boards. As part of this review, 
opportunities for increasing gender diversity 
are identified and progress is tracked. We also 
encourage greater female participation in non-
executive and advisory roles outside Vodafone.
* 2017 and 2018 data has been restated to exclude employees from our joint ventures in the 
Netherlands and India, and Vodafone Qatar, which was sold in March 2018.
18
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Women’s  empowerment
Vodafone Group Plc Sustainable Business Report 2019
Energy innovation
Youth skills and jobs
Introduction
Operating responsibly
Our people
Appendix

Youth skills and jobs 
High levels of youth unemployment and a growing digital 
skills gap are significant social and economic challenges. 
Our What will you be? programme aims to help young people 
develop their digital skills and access learning and employment 
opportunities so they can thrive in the digital economy. 
For society
We are supporting young people 
to thrive in the digital economy.
Within our business
Providing young people with 
a digital learning experience.
Our 2022 goal
Support 10 million young people 
to access digital skills, learning 
and employment opportunities.
Progress towards our goal
533,698 
young people supported to date.
Our 2022 goal
Provide 100,000 opportunities for 
young people to receive a digital 
learning experience at Vodafone.
Progress towards our goal
54,712
opportunities provided for 
young people to receive a digital 
learning experience this year.
See page 21
See page 23
Women’s empowerment
19
Vodafone Group Plc Sustainable Business Report 2019
Energy innovation
Youth skills and jobs
Transformation
Introduction
Operating responsibly
Our people
Appendix

The global context
The International Labour Organization 
(ILO) estimates that 209 million young 
people either are unemployed or work 
but live in poverty1. In many of the 
countries where we operate, youth 
unemployment continues to remain 
at very high levels: 53% in South Africa, 
40% in Greece, 34% in Spain and 32% 
in Italy2.
Unemployment can have a negative impact on 
young people’s wellbeing; even a short period 
of unemployment can have a long-term effect 
on self-esteem and confidence3. By tackling this 
issue and reducing the number of youth out of 
work or in vulnerable work, societies have much 
to gain in terms of growth and reducing costs 
associated with supporting unemployed young 
people, while ensuring better inclusion and more 
shared prosperity in the long run.
The impact and opportunity 
of technology
Mobile communications and digital technology 
are transforming every aspect of our lives. For 
many, this is positive, bringing increased access 
to information and services as well as the ability 
to share and learn. Businesses benefit too, 
as they are able to achieve productivity and 
efficiency gains.
However, some advances in technology may 
lead to disruption: automation, robotics 
and artificial intelligence (AI) may increase 
productivity, but they are also likely to 
shift labour needs and potentially reduce 
employment opportunities. These changes in 
technology are having an impact on the skills 
required by businesses from their employees 
and altering the nature of work itself. 
While digital technology is disrupting traditional 
work patterns, this same disruption is also 
creating new employment opportunities.
In a future where AI and robotics are 
commonplace, certain skills and abilities will 
be highly valued. The European Commission has 
stated that around 90% of all jobs – from nursing 
to engineering to accountancy – already require 
some form of digital skills4.
Working together, governments, educators 
and companies need to find ways to address 
future workplace needs and develop the skills 
of current workers and the younger generation, 
enabling them to be better equipped for a 
prosperous and inclusive digital society.
Our alignment to the UN Sustainable 
Development Goals (SDGs)
Youth unemployment is a significant social and 
economic challenge in many of our markets. We 
believe urgent action is needed to help young people 
develop their digital skills and access learning and 
employment opportunities that will help them thrive 
in the digital economy. 
Our commitment to help young people to address these 
dual challenges supports Goal 8, which aims to promote 
sustained, inclusive and sustainable economic growth, 
full and productive employment and decent work for all.
Key SDGs and targets
4.4 By 2030, substantially increase the 
number of youth and adults who have 
relevant skills, including technical 
and vocational skills, for employment, 
decent jobs and entrepreneurship.
4.5 By 2030, eliminate gender dispar­
ities in education and ensure equal 
access to all levels of education and 
vocational training for the vulnerable, 
including persons with disabilities, 
indigenous peoples and children in 
vulnerable situations.
8.3 Promote development-oriented 
policies that support productive 
activities, decent job creation, 
entrepreneurship, creativity and 
innovation, and encourage the 
formalisation and growth of micro-, 
small- and medium-sized enterprises, 
including through access to 
financial services.
8.5 By 2030, achieve full and productive 
employment and decent work for all 
women and men, including for young 
people and persons with disabilities, 
and equal pay for work of equal value.
8.6 By 2020, substantially reduce the 
proportion of youth not in employment, 
education or training.
Around 90% 
of all jobs – from nursing to 
engineering to accountancy 
– already require some form 
of digital skills.
209 million
young people are either 
unemployed or work but 
live in poverty.
Global youth employment
In many of the countries where we operate, 
youth unemployment remains at high levels.
40%
Greece
32%
Italy
34%
Spain
53%
South Africa
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Our future jobs strategy
Our role in closing the digital skills gap
Despite high levels of youth unemployment, 
demand for digital skills already outstrips the 
supply of available talent. While many young 
people are ‘digital natives’, most do not leave 
education with the depth of technical skills to 
create and run the technologies our economies 
are increasingly reliant on, such as writing code, 
mitigating cyber security risks or designing, 
configuring and maintaining electronic devices 
and wireless or fixed-line networks. The EU 
Digital Skills and Jobs Coalition reports that 
37% of EU workers have insufficient digital 
skills5 and there are clear signs that the digital 
skills gap is widening. By the end of next year, 
there could be almost 500,000 unfilled digital 
technology jobs in Europe6.
We believe that there is a need for training 
for young people to be ready for a digital 
society. This view is supported by the European 
Commission in its Skills Agenda for Europe7, 
which calls on governments, industry NGOs 
and educators to work together towards this 
objective. Vodafone is committed to doing 
our part to support digital learning and 
digital skills for youth. 
What will you be?
Vodafone’s What will you be?  programme has 
been designed to respond to the digital skills gap 
challenge. This programme has two objectives: 
deepening the understanding of youth on how 
they can contribute to the digital economy and 
identifying how we can provide workplace 
digital experiences. 
By 2022, our targets are:
–	 to support 10 million young people to access 
digital skills, learning and employment 
opportunities; and
–	 to provide 100,000 opportunities for young 
people to receive a digital learning experience 
at Vodafone. 
We have developed a new platform, Future Jobs 
Finder, which offers young people a simple 
but comprehensive gateway to new skills and 
opportunities for employment in the digital 
economy. Using the platform, young people 
are able to identify their strengths and skills 
and are then matched to available digital jobs 
and training opportunities in their region and 
beyond. This platform is free to use for young 
people regardless of their mobile provider.
Future Jobs Finder
Last year, we launched a free smartphone-
based platform called Future Jobs Finder, 
designed to inspire and help young people
 to understand their strengths and skills and 
to find the right job opportunity in the 
digital economy. 
Available in 12 languages, the platform 
identifies young people’s skills and interests 
through a series of short tests developed with 
psychologists, careers experts and training 
providers. By responding to these questions, 
young people can better understand where 
their potential lies and find live local job 
opportunities in multiple digital industries 
that are matched to their skills.
If a user is not quite ready to apply, the 
Future Jobs Finder also offers the ability to 
match training needs to online digital skill 
providers and access specific courses, many 
of which are free (including edX, Coursera, 
Udacity, Cognitive Class, Udemy and the 
Khan Academy).
This year, we collaborated with Sony Pictures 
to use the release of Spider-Man: Into the 
Spider-Verse to introduce young people to 
the Future Jobs Finder service. A global digital 
campaign drew on the film’s central theme 
that anyone can achieve their full potential 
with the right skills and support. As part of 
the campaign, we ran a global competition 
asking young people to share their career 
superpower. Over 28,000 people entered the 
competition. The two winners were given the 
opportunity to visit and learn from the team 
who created the film and to discover how 
digital skills are applied in animation and 
film making.
Since launching in March 2018, 478,986 
unique users have completed the tool 
(including 369,495 from this year), 
introducing each of them to the top five 
jobs that match their individual test results. 
Our 2022 goal
Support 10 million young people 
to access digital skills, learning and 
employment opportunities.
Progress towards our goal
Through our Future Jobs Finder 
and provision of digital learning 
experiences, we have supported 
533,698 young people to date.
478,986 
completions of Future Jobs Finder
54,712 
digital learning experiences provided
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Kenya
In Kenya, the M-Pesa Foundation Academy is a state-of-the-art, 
mixed boarding high school aimed at providing an education 
for talented but economically disadvantaged students with 
leadership potential. Since 2003, through its two charitable arms, 
the Safaricom and M-Pesa Foundations, Safaricom has impacted 
over 1.2 million learners by supporting primary, secondary and 
vocational training institutions across the country.
Egypt
The Vodafone Egypt Foundation has launched Knowledge is Power 
Schools, building on its adult literacy programme, Knowledge 
is Power. This programme is focused on helping public primary 
schools support students, teachers and parents through e-learning 
modules for the classroom. This includes literacy ICT activities to 
build students’ confidence. The programme also provides teacher 
training and supports parents with literacy and vocational training 
classes. The project is now active in 100 schools. It has reached 
50,000 students, 2,500 teachers and 7,000 parents.
South Africa
Vodacom’s flagship mobile education (‘mEducation’) programme, 
developed in partnership with the South African Department of 
Basic Education, has provided information and communications 
technology (ICT) equipment and free internet access to 3,000 
schools and 92 teacher centres across South Africa. In addition, 
over 251,000 teachers have been trained on the use of ICT in the 
classroom. Vodacom has also entered into partnerships with 19 
universities to provide free access to curriculum content they 
provide. More than 619,000 learners have had free access to quality 
digital educational content through the Vodacom e-School.
Vodafone Foundation’s Instant Schools is a free-to-access online 
platform that hosts educational resources in local languages in 
the Democratic Republic of Congo, Ghana, Lesotho, Tanzania, 
Mozambique and South Africa (as e-School). There is no charge for 
the content or for the data to access the platform. Instant Schools 
has been developed in conjunction with Learning Equality – a not-
for-profit provider of open-source educational technology solutions 
– and with educational partners, ministries of education and local 
education experts in each country.
Supporting education and building skills
Through our local operating companies and foundations, 
Vodafone has also launched a number of programmes 
that help young adults develop their skills, including 
digital ones, and support the development of young 
entrepreneurs. The following provides some examples
of the programmes we have around the world. 
Italy
Vodafone Italy has worked with the Ministry of Education to design a 
work experience programme, Alternanza Scuola-Lavoro, to reach 2,000 
students in 25 schools across the country. Employee volunteers go 
to the schools for a day, where they guide and support students aged 
15–16 on their possible future careers. The Future Jobs Finder tool is 
introduced to students so they can discover their digital opportunities 
and participate in workshops to help them find the right career. 
Ghana
In August 2018, the Vodafone Ghana Foundation launched a national 
coding programme to provide training for young people on coding 
basics. Since launch, 400 people have participated in the programme, 
which has an ambition to reach 10,000 young people by 2023.
Spain
Through its Campus Lab initiative, Vodafone Spain has developed 
an online innovation platform where young people from different 
disciplines can work together to solve different challenges. The winners 
receive a €20,000 prize alongside mentoring to develop their idea.
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Digital workplace experience
Coding Tomorrow
In Turkey, the Vodafone Turkey Foundation launched its Coding Tomorrow project in 2016 
with the aim of tackling the digital divide by providing children aged 7–14 with free training in 
coding and robotics, along with other essential skills for future employment.
Run in partnership with the Habitat Foundation, the project focuses on helping children gain 
new digital skills and become active producers of technology rather than just being passive 
consumers of it. In addition, besides building coding capabilities, participants also develop 
skills such as problem solving, teamwork, creativity and algorithmic thinking.
Scratch, the free programming language developed for children by the Massachusetts 
Institute of Technology, is used in the training. Children learn how to use Scratch to help them 
think creatively and design their own interactive stories, games and creations. They are also 
provided with introductory training on robotics programs and learn the basics of electronics 
and circuit systems.
To expand the reach of the project to more remote rural areas, the Vodafone Turkey 
Foundation delivers some of the training using a specially customised truck, which travelled 
over 6,000 km in 2018. Since the launch of the project in 2016, more than 43,400 children 
across 60 cities have participated, including 30,992 during the last year. 
Our 2022 goal
Provide 100,000 opportunities for 
young people to receive a digital 
learning experience at Vodafone.
Progress towards our goal
We are over halfway towards 
meeting our goal, with 54,712 
opportunities provided for young 
people to receive a digital learning 
experience at Vodafone this year.
This year, 5,710 new recruits aged 26 or under 
joined Vodafone across our global footprint. We 
also indirectly create employment opportunities 
for many young people in our supply chain 
and retail distribution networks. We run well-
established apprenticeship, internship and 
graduate schemes across our business and offer 
a wide range of work experience opportunities. 
Last year, we committed to providing 100,000 
opportunities for young people to receive a 
digital learning experience at Vodafone by 20228.
Digital work experience
In 2019, we provided opportunities for 46,833 
young people through digital work experience 
programmes. This encompassed a number of 
different programmes, including one-week 
placements, job shadowing and insight-into-
work days, alongside innovative experiences 
such as our Coding Tomorrow programme in 
Turkey and #Codelikeagirl, which offers 14 
to 18-year-old girls immersive digital training 
during the school holidays. 
Since its launch in 2017, Vodafone’s 
#Codelikeagirl programme has reached over 
3,000 girls in 23 markets. The programme, 
launched in partnership with Code First: Girls, 
has the mission to tackle the disproportion of 
girls in STEM (science, technology, engineering 
and mathematics) education. Through the 
programme, we offer girls aged 14–18 an 
immersive one-week digital experience where 
they learn to code a website. The training 
the girls receive provides basic knowledge 
of computer languages and development 
programs, allowing them to gain skills for 
the future.
Direct hires (5,710)
Digital work 
experience (46,833)
Internships (974)
Apprenticeships  
(518)
Graduates (677)
Opportunities for young people to receive 
a digital learning experience at vodafone 
during 2019
See page 72 for how we report our 
key performance indicators
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Internships
Our internship programmes provide opportunities 
for undergraduate students to work with us 
for up to six months while they complete their 
degree. These opportunities expose students 
to challenging business-critical activities and 
projects, enabling them to gain relevant business 
experience to support their studies. Participants 
can apply to return to Vodafone once they have 
graduated and can participate in our Discover 
graduate programme. During the year, 974 young 
people gained an experience of Vodafone’s digital 
workplace through our internship programmes 
around the world.
This year, Vodafone Group piloted its Explore 
Industrial Placement intern programme with 
a small group of students currently studying 
in the UK. The placement year is for students in 
their third year of studies who need to complete 
a placement in business as part of their course. 
The students join a team in Vodafone for the year 
with the aim of joining the Discover graduate 
programme after graduation. Following the 
completion of the pilot, we hope to attract 60 
students to the placement programme next year. 
In Spain, the Vodafone yu New Talent internships 
programme is aimed at students in the final 
year of their bachelor’s or master’s degree. 
Participants combine part-time work at Vodafone 
with their academic studies. This year, 76 interns 
participated in the programme.
Apprenticeships
We continue to expand our vocational training 
and apprenticeships across our business. These 
programmes enable young people who have 
chosen not to go to university to join Vodafone in 
permanent roles while being supported through 
continuous learning in order to gain a formal 
qualification in their chosen fields. 
1	
ILO, 2019
2	
OECD, 2018
3	
Long-term effects of youth unemployment on mental health, Journal of Epidemiology and Community Health, 2017
4	
EU Commission, 2018
5	
The Digital Skills and Jobs Coalition, 2018
6	
European Commission, 2018
7	
New Skills Agenda for Europe, European Commission, 2016
8	
Starting from the 2019 financial year
Digital Degree Apprenticeship
In the UK, we offer advanced, higher and degree apprenticeships to students aged over 
16 in a range of areas across the business. For example, technology apprentices are given 
the opportunity to work in cyber security, software testing and network engineering, while 
our customer service apprentices support our customer-facing activities.
This year, Vodafone UK partnered with the University of Birmingham to design a Digital 
Degree Apprenticeship, providing opportunities for students to be at the forefront of digital 
innovation. Students study a BSc in Computer Science full time at the University and, as a 
Vodafone employee, also receive a competitive salary across the four years, fully funded 
tuition fees and access to all employee benefits. They gain valuable work placement 
experience and obtain a role in one of Vodafone’s digital teams once they graduate. 
We currently have 16 students on the programme, with a commitment to bring in more 
students in the future.
During 2019, 518 young people joined one of our 
apprenticeship schemes. We offer opportunities 
at the heart of our operations with our Technology 
and Customer care divisions.
Graduates 
Our Discover graduate programme, which has 
been running for over 10 years, offers young 
people with a bachelor’s or master’s degree a 
series of assignments across our business areas 
and local markets. Over 5,300 graduates have 
been through our structured development 
schemes over the last 10 years, with 677 
recruited this year, helping to provide us 
with a strong pipeline of future talent. 
Our Discover programme is highly diverse; 
more than 52% of new entrants are female, and 
recruits are drawn from 23 different countries. 
Those who do not progress into a full-time role 
with Vodafone at the end of their training are 
well placed to secure good job opportunities 
elsewhere. 
With the aim of attracting more talented 
youth, increasing eligibility and achieving even 
higher diversity and social mobility across the 
Discover programme, this year we lowered the 
academic entry requirement to a 2:2 degree 
classification (or equivalent) across all operating 
markets. 
In addition to Discover, we run Columbus, a 
leadership fast-track graduate scheme that this 
year welcomed 13 graduates. This programme 
offers graduates who have completed the 
Discover scheme an additional two-year 
international assignment that aims to equip 
them with the knowledge and insights that 
will prepare them for the next stage of their 
Vodafone career.
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Energy innovation
There is clear evidence that man-made greenhouse 
gases (GHGs) are having a direct impact on climate. 
We support the view that urgent action is needed 
to address climate change.
Within our business
In recognition of our need to contribute to international 
efforts to tackle climate change, we have two targets which 
focus on achieving a significant reduction in GHG emissions.
Our 2025 goal
To reduce our GHG emissions 
by 50%.
Progress towards our goal
1% 
reduction in our GHG emissions, 
against a 2017 baseline.
Our 2025 goal
To purchase 100% of the 
electricity we use from 
renewable sources. 
Progress towards our goal
15% 
of our purchased electricity 
was from renewable sources.
See pages 30 to 32 to read how we are achieving our goals
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The global context
There is clear evidence that global 
temperatures are rising rapidly, with the 
last four years being the four hottest on 
record1, and that man-made GHGs are 
having a direct impact on climate2. We 
support the view that urgent action is 
needed to address climate change.
The Paris Agreement on climate change commits 
world leaders to act to limit global temperature rise 
to below 2°C above pre-industrial levels and calls 
for efforts to pursue a more challenging target of 
a maximum 1.5°C increase. Climate scientists now 
recommend keeping below 1.5°C to avoid some 
of the worst impacts, as highlighted in the recent 
International Panel on Climate Change Special 
Report on Global Warming.
While good progress has been made in many 
countries, the pledges made to date are insufficient 
to achieve the goals of the Agreement. Current 
predictions imply temperature rises of 3°C by 
2100, with warming continuing with potentially 
catastrophic consequences3. The repercussions 
of climate change will be felt everywhere but with 
particularly damaging effect in low and middle-
income countries, which are least able to adapt.  
Achieving the required reductions in GHG 
emissions will be particularly challenging in the 
context of continuous economic and population 
growth. Most analysts predict that global energy 
needs will be 25% higher than at present by 20404. 
With over 80% of the world’s current energy 
requirements met from carbon-intensive fuel 
sources5, there is a pressing need to phase out
the use of fossil fuels and move to lower-carbon 
energy sources. 
ICT and climate change 
Providing communications services requires 
significant amounts of electricity. Every 
additional connected device and gigabyte 
of data transmitted or stored represents 
a potential increase in energy needs. The 
telecommunications and information and 
communications technology (ICT) industry 
faces a growing GHG emissions challenge as 
the sector’s carbon and energy footprint 
increases: a recent study estimates that 
worldwide ICT energy consumption is 
increasing by around 9% per year6. 
While the emissions from ICT companies are 
growing, the services that communications 
companies provide can make a significant 
contribution to the reduction of emissions arising 
from their customers’ operations. Through the 
Internet of Things (IoT), products and processes 
in the workplace and in the home can become 
significantly more efficient and reliable. This has 
a positive impact on energy and GHG emissions, 
as well as other environmental issues.
Our alignment to the UN Sustainable 
Development Goals (SDGs)
Our commitments to reduce our GHG emissions, 
though our move to purchase renewable electricity 
and improve our energy efficiency, particularly support 
Goal 13, which is focused on climate action, and Goal 7, 
which includes a focus on clean energy. 
Key SDGs and targets
7.2 By 2030, increase substantially the 
share of renewable energy in the global 
energy mix.
13.2 Integrate climate change measures 
into national policies, strategies and 
planning.
100x
By 2022, global mobile 
data traffic will be over 100 
times the volume in 20127.
3x
By 2022, the number of 
devices connected to IP 
networks will be more 
than three times the 
global population7.
+25 billion
IoT connections will 
reach over 25 billion by 
2025, up from 9 billion 
in 20188.
Data and mobile growth predictions
20%
By 2022, global mobile 
data traffic will account for 
20% of global total IP (fixed 
and mobile data) traffic, up 
from 9% in 20177.
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We are focusing on increasing the 
energy efficiency of our network 
and services and are moving towards 
purchasing electricity from 
renewable sources.
This year, as part of Vodafone’s purpose, we have 
committed to halve our environmental impact by 
2025. In order to reflect this in our goals, we have 
increased our GHG emissions target to achieve a 
50% reduction by 2025 (previously 40%), against 
a 2017 baseline. We will deliver against this 
target by improving the energy efficiency of our 
network and purchasing 100% of the electricity 
we use from renewable sources. 
Across our networks we have more than: 
164,000 mobile base station sites; 89,000 
servers; and 3,200 buildings (including 400 
technology centres).
We spend over €700 million a year on energy, and 
with a significant risk of energy cost inflation in 
the future, setting energy efficiency targets and 
switching to more sustainable energy sources 
makes business and environmental sense. 
In August 2018, we established a Green Bond 
Framework, under which Vodafone can issue 
green bonds to be able to finance or refinance 
projects to help us meet our environmental 
objectives. The framework defines which 
projects are eligible under the use of proceeds 
and how they are selected. 
Climate-related financial reporting
As highlighted by the Bank of England 
Governor, Mark Carney, the ‘tragedy of the 
horizon’ is that by the time climate change 
becomes a defining issue for financial 
stability, it will very likely be too late to 
do anything about it. The Task Force on 
Climate-related Financial Disclosures 
(TCFD) was established in 2015 to address 
this misalignment and provide a voluntary 
reporting framework for companies to 
consistently report climate risk to investors.  
We welcome the development of the TCFD 
recommendations and have updated our risk 
management process this year to strengthen 
our consideration of the potential business 
implications and impacts of climate change. 
In addition, we undertook an independent 
gap analysis of our reporting against the 
TCFD recommendations. 
Although climate change is not currently 
seen as a principal risk for Vodafone, 
due to the nature of our business and 
the contingencies that are built into our 
networks, a number of potential risks have 
been identified from a physical (e.g. storms 
or higher average operating temperatures) 
and regulatory (e.g. carbon reduction 
commitments) perspective. These potential 
risks continue to be monitored and measured 
as part of our ongoing risk management 
process to ensure that the appropriate 
management and mitigation actions are 
taken as we work towards full alignment with 
the TCFD recommendations.
The recent devastating Cyclone Idai, which 
struck Mozambique, is an example of the 
type of extreme weather events that are 
predicted to occur more frequently and at 
a higher intensity due to climate change. 
This cyclone had a widespread impact on 
our network, with damage caused to base 
stations, fibre cabling and retail stores. In 
response, Vodacom Mozambique deployed 
support for our staff as soon as was possible 
and engineers to repair and re-establish 
critical network connections and equipment. 
Pop-up shops and recharging points were 
established to allow people without access to 
power to charge their devices. 
In addition, a number of employee volunteers 
were deployed by Vodafone Foundation to 
establish its Instant Network to the most 
severely affected areas, in order to provide 
emergency network communications, WiFi 
and charging capabilities, services that are 
critically important for initial international 
and local aid efforts.
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Vodafone, energy and climate change

Our 2025 goal
To reduce our greenhouse 
gas emissions by 50%.
Progress towards our goal
We have reduced our GHG emissions 
by 1%, against the 2017 baseline. 
Our total GHG emissions decreased 
slightly from last year, predominantly 
due to a reduction in the carbon emissions 
associated with purchased electricity.
Our greenhouse gas emissions
Our GHG emissions reduction target 
is to cut our emissions by 50% across 
our network and operations by 2025, 
against a baseline of our emissions for 
the 2017 financial year. 
Meeting this absolute GHG emissions reduction 
target is challenging in the context of our 
business growth. The amount of data carried 
across our networks has grown exponentially 
over the last decade, and this growth in global 
digital communications is predicted to continue 
for the foreseeable future. With the continued 
demand for mobile data, we are increasingly 
focused on energy efficiency to mitigate the 
cost and environmental impact of this growth.  
We have started work towards our GHG 
reduction target through increasing focus on a 
series of energy efficiency programmes across 
our networks and servers, particularly in power 
supply and cooling. We are also working with 
our local operating companies to plan the 
move to purchase 100% of our electricity from 
renewable sources by 2025. 
Our total global Scope 1 and Scope 2 GHG 
emissions were 2.00 million tonnes CO2e in 2019. 
Our Scope 1 emissions include those arising 
from fuel consumption, such as from diesel and 
gas and fugitive emissions of refrigerant gases, 
and our Scope 2 emissions include our indirect 
emissions from power consumption through 
purchased grid electricity.
Volume of Vodafone mobile data traffic 
(petabytes)
Vodafone GHG emissions (million tonnes 
CO2e) (market-based method)
2017
2018
2019
1.77
2.06
2.00
1.74
1.72
2.02
Baseline
2025 goal
0
0.5
1.0
1.5
2.0
2.5
0.29
0.26
0.30
Scope 1
Scope 2
See page 73 for how we report our 
key performance indicators
6,000
2,000
3,000
4,000
5,000
1,000
500
2014
2015
2016
2017
2018
2019
1,000%
increase in Vodafone 
mobile data traffic over the 
last five years
Our total GHG emissions have decreased by 3% 
from last year (2018) predominantly due to the 
purchasing of more electricity from renewable 
sources and the use of less carbon-intensive 
power sources.
The numbers quoted in the chart on the left 
use the market-based method of calculating 
GHG emissions, which uses supplier emissions 
factors. Using the location-based method (using 
average emissions factors for the national grid), 
our Scope 2 emissions were 1.91 million tonnes 
CO2e and total Scope 1 and 2 emissions were 
2.17 million tonnes CO2e. Further details of the 
methodology used and the relevant emissions 
factors applied are on page 74 of the Appendix.
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Our key measure for GHG emissions intensity 
improved again this year, with a reduction in 
emissions per petabyte of mobile traffic data 
of 36%9. This was achieved due to continued 
mobile data traffic growth, while maintaining 
a relatively flat energy consumption through 
efficiency measures and a shift towards 
purchasing renewable electricity. 
Emissions over which we do not have direct 
control (Scope 3) but which we may be able to 
influence are reported separately on page 33.
As a consequence of the merger of Vodafone 
India and Idea Cellular to become Vodafone Idea 
in August 2018, the GHG emissions for India in 
this financial year are now estimated as part 
of our Scope 3 emissions. In addition, in July 
2018, Vodafone Greece acquired CYTA Hellas, a 
provider of fixed and mobile telecommunications 
services in Greece; the GHG emissions from 
CYTA Hellas will be incorporated into our 2020 
reporting after its first full year of ownership.
GHG emissions (tonnes CO2e) per petabyte of 
mobile data traffic on Vodafone’s networks 
2017
2018
2019
577
371
926
0
300
600
900
1,200
Employee engagement  on energy 
innovation 
In order to meet our GHG emission reduction 
targets, we need to engage our employees to gain 
their support. As a result, we have established 
an employee engagement programme, 
#RedLovesGreen. This programme raises awareness 
of the individual actions that employees can take 
to reduce our energy use, both as a business and as 
individuals, and encourages changes in behaviour 
that collectively could have a significant impact. 
The #RedLovesGreen programme regularly 
engages employees via an internal social media 
channel to catalyse their support and raise 
awareness of the ongoing energy efficiency 
programmes that will help us to meet our targets. 
The #RedLovesGreen channel also provides 
a central space to share success stories, news 
updates, tools and information. Since launching this 
global programme in June 2018, we have reached 
over 5,000 employees who engage regularly on this 
topic, and an energy awareness e-learning module 
has been completed by over 7,000 employees. 
Recently, we created an ‘energy guru’ community 
to create energy efficiency advocates across the 
business to inspire other employees to take action. 
Energy gurus receive a quarterly communications 
pack to support them in their role. They also directly 
help to shape our programmes by sharing ideas 
across our different markets and submitting ideas
to help us improve what we are doing.
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Optimising our energy consumption
We are committed to improving the 
energy efficiency of our base station 
sites and in our technology (data and 
switching) centres, which together 
account for 94% of our total global 
energy consumption.
Unlike most ICT companies, which tend to 
have a small number of large data centres, 
Vodafone has a larger number of smaller 
technology and base station sites spread across 
different countries and locations. This means 
that much of the energy consumed across 
our businesses is split between multiple sites 
that consume relatively small amounts of 
energy. Consequently, optimising our energy 
consumption is a complex challenge. 
Our energy consumption has remained largely 
static this year despite the significant growth 
in customer numbers and data traffic across 
the network. 
Improving energy efficiency across 
our network operations
In 2017, Vodafone started a specific programme 
to prioritise energy efficiency within the 
business’s technology strategy and to invest 
in energy projects. We expect this three-year 
programme to deliver energy reductions and 
savings of approximately 10% of our energy cost. 
During 2019, we invested €57 million capital 
expenditure in energy efficiency projects across 
our business, which has led to annual energy 
savings of 164 GWh. 
We use large numbers of servers and other 
network equipment, which generate significant 
amounts of heat during their operation. Cooling 
technologies are therefore an essential part 
of our strategy, as too much heat can harm 
components and lead to network failure. This 
year we have met our forecast for energy savings 
for upgrading power and cooling systems across 
our networks. We delivered savings of 116 GWh, 
equating to 2% of our total energy consumption. 
Vodafone energy use (GWh)
The amount of energy our business uses varies across our operations
2017
2018
2019
2019
(%)
3,637
3,684
3,651
1,569
1,571
1,510
308
282
350
55
5,569
45
5,582
51
5,561
Our base station sites
Our technology centres
Our offices
Our retail stores
Total
66%
28%
5%
1%
Our energy efficiency initiatives are focused on 
three key areas:
–	 sourcing and implementing more efficient 
network equipment; 
–	 reducing energy demand by installing lower-
energy power and cooling technologies; and
–	 cutting energy use by decommissioning and 
upgrading legacy equipment. 
We have continued to improve the energy 
performance of our radio access network 
equipment by: 
–	 installing energy-efficient single radio 
access network equipment, which 
enables a single item of radio hardware to 
run multiple technologies (e.g. 2G, 3G and 
4G) and now makes up the majority of the 
deployed radio hardware in 98% (161,000) 
of our base station sites and is fully 
operational in 97% (159,000) of them; 
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Operating responsibly
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Appendix

Improving energy efficiency and reducing carbon emissions in the UK 
Vodafone UK operates networks and services 
relied upon by more than 17.8 million mobile 
and fixed broadband customers. However, 
providing these communications services 
requires a significant amount of energy. 
To minimise these impacts Vodafone UK has 
implemented a GHG reduction strategy. Since 
2013, this focus has resulted in a 35% GHG 
emission reduction, despite network growth 
and increased customer demand over the 
same period. 
The strategy includes:
–	 implementing ISO 14001 and ISO 50001 
certified management systems;
–	 investing in energy efficiency projects 
- £11.8m was invested in efficient 
technologies this year, such as new 
power and cooling systems, delivering 
total savings of over 63 GWh. A facilities 
management Energy Performance 
Contract, delivered over 27 GWh of those 
savings and decommissioning legacy 
network switches saved around 15 GWh; 
and  
–	 switching to renewable energy through 
exclusive power purchase agreements 
with two wind farms. 
In addition, 150 environment ambassadors 
have been established across the business 
to promote energy efficiency and champion 
positive behaviours. Electric hybrid vans are 
being trialled and 20 vehicle charging points 
have been installed. In June 2018, all Vodafone 
UK employees were given a ‘Keep Cup’, which 
has already saved over 90,000 disposable 
coffee cups.
–	 activating energy-saving software features 
that optimise radio resources and energy 
consumption to reflect actual voice and data 
traffic requirements in real time. To date, we 
have deployed energy-saving features across 
2G, 3G and 4G technologies in all of our major 
markets; and
–	 deploying active antennas – a technology 
that boosts energy performance by 
integrating radio equipment inside the 
antenna to eliminate power attenuation over 
cable runs – as part of the introduction of 
Massive MIMO technology in all our planned 
5G sites in Europe and also for 4G in more 
than 150 sites in Turkey and India.
Energy efficiency initiatives in our technology 
(data and switching) centres this year included: 
–	 upgrading to more efficient power conversion 
equipment; for example, at our main 
technology centre in Germany we improved 
energy efficiency by 8% by upgrading to a 
state-of-the-art power supply system;
–	 continuing the installation of the dynamic 
thermal management control systems to 
reduce energy consumption from cooling. 
Using machine learning algorithms, the 
system ensures that servers receive the 
optimal amount of cooled air based on 
server load and external environmental 
conditions. Italy completed deployment to 
all its 29 main technology sites this year; and
–	 cutting energy use by decommissioning 
legacy assets, including data storage 
systems and servers.
The overall energy efficiency of technology 
centres is often assessed in terms of their 
power usage effectiveness (PUE) – an industry-
standard metric that compares the amount of 
electricity used to operate computer equipment 
with the amount used for all other functions. 
This year, we made further improvements to 
our centres’ PUE, reaching an average of 1.60 
(2018: 1.61). 
In five local markets – Germany, Greece, Ireland, 
Turkey and the UK – we have also achieved ISO 
50001 certification. The ISO 50001 standard 
provides a management framework with the 
aim of reducing energy consumption, costs 
and GHG emissions.
Energy efficiency in network 
procurement 
We work with our equipment vendors to ensure 
that increased demand and business growth 
do not result in a similar percentage increase in 
electricity usage. This year we:
–	 made energy efficiency a mandatory 
requirement in the procurement process for 
all energy-intensive network and IT products;
–	 developed more sustainable network 
technology, including the introduction of 
machine learning algorithms to optimise 
the usage of radio resources with minimum 
energy consumption; and
–	 evaluated emerging technology, including 
development of an innovation hub (Green 
Island) to showcase different technologies 
that promote sustainability and energy 
efficiency in radio access sites.
We incorporate power optimisation in design 
specifications for new infrastructure to ensure 
that each successive generation of equipment 
is more energy efficient. 
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Operating responsibly
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Appendix

Over 95% of the energy we consume to run our 
operations comes from grid electricity. To date, 
the proportion of our electricity from renewable 
sources has been low, accounting for just 15% 
of the electricity purchased. This is currently 
delivered through green electricity sourcing 
in the Czech Republic, Ireland and Italy, where 
we purchase renewable electricity contracts, 
and two wind farm power purchase agreements 
(PPAs) in the UK. 
This year we conducted an assessment of the 
maturity of renewable electricity markets across 
our local operating companies to develop an 
appropriate phased approach. In some of our 
local markets there is no renewable supply, or 
the sources available are not certified through 
recognised schemes. We will therefore first 
look for opportunities to purchase renewable 
electricity in the countries where renewable 
electricity markets are well developed, followed 
by those in which the renewables market is 
currently developing and will be feasible in a 
few years and finally those markets that we 
expect to be available before 2025. 
We are also a member of RE100 – a collaborative 
initiative led by The Climate Group in partnership 
with CDP that brings together major businesses 
committed to switching to 100% renewable power.
Our 2025 goal
To purchase 100% of the electricity 
we use from renewable sources.
Progress towards our goal
We are working towards our target 
by increasing the procurement 
of energy from renewable power 
generation sources via national 
electricity grids, selecting tariffs 
with renewable attributes and 
purchasing renewable energy 
certificates (RECs).
This year, 15% of our purchased electricity 
was from renewable sources.
Grid renewable energy purchased 
(% of total electricity use)
2017
2018
2019
15.3
15.4
13.2
2025 goal
0
20
40
60
80
100
See page 73 for how we report our 
key performance indicators
2019 Vodafone energy use by source 
(GWh)
Grid electricity 
(4,516)
Grid renewable 
energy (821)
On-site renewable 
energy (5)
Diesel and petrol 
(165)
Other (74)
Expanding renewable electricity in our 
local markets
When selecting renewable electricity in our local 
markets we apply the following hierarchy:  
–	 the signing of corporate PPAs with developers 
and suppliers of renewable energy assets to 
procure longer-term energy contracts. This 
can help stimulate new renewable electricity 
generation, as well as providing excellent 
traceability and avoiding the double-
counting of renewable electricity; and
–	 the purchasing of renewable electricity 
backed by RECs – market-based instruments 
issued to power generators to track renewable 
electricity production and consumption.
This year we opened a tender for the 
construction and operation of utility-scale solar 
parks in Egypt. Minimising energy consumption 
at Vodafone Egypt is a particular challenge due 
to the hot climate, which requires additional 
equipment cooling and the rapid roll-out of 
mobile networks to regions with poor or no 
electricity grid. The aim is for the solar arrays to 
come online before the start of 2025 and power 
a substantial proportion of Vodafone Egypt’s 
electricity requirements.  
In the UK, we have two operational wind farms, 
for which we receive the renewable energy 
guarantees of origin certificates; this has 
increased the overall proportion of renewable 
electricity in the UK operating company to over 
12%, saving over 20,000 tCO2e.  
In South Africa, Vodacom successfully signed 
a PPA this year for renewable energy for one 
municipality and is in the process of exploring 
the feasibility of signing further PPAs for other 
municipalities. 
On-site renewables
We develop on-site renewable sources when it 
is commercially and technically feasible to do 
so, primarily by installing solar photovoltaic (PV) 
systems at base station sites and technology 
centres. We have over 1,200 solar PV systems 
across our base station sites, technology centres 
and offices, contributing 4 GWh of renewable 
power. Our aim is to replace our use of diesel 
by increasing solar generation and deploying 
diesel-battery hybrids, although this can be 
limited at remote locations prone to vandalism 
or at sites with limited space or shading in 
urban areas.
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Operating responsibly
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Appendix
Increasing renewable energy

Scope 3 emissions
Their answers form part of the overall 
performance score that we use to assess their 
performance. We also ask selected suppliers 
to provide details of their GHG emissions 
and management programmes through CDP 
(formerly the Carbon Disclosure Project). This 
year, 139 (or 90%) of those suppliers responded, 
with 81% reporting that they had set a target for 
GHG emissions, while 76% had implemented 
GHG emissions reduction programmes. This 
year we also noted an increase in the number 
of suppliers setting renewable energy targets.
 
Scope 3 emissions sources 
(thousand tonnes CO2e)
Most material
Joint ventures and 
associates (6,000)
Purchased goods and 
services (4,000)
Use of sold products  
(2,100)
Other
Fuel and energy-related 
activities (700)
Business travel  (60)
Upstream leased assets  
(50)
Waste generated in our 
operations (1)
Scope 3 emissions are indirect 
GHG emissions over which we have 
no direct control but may be able 
to influence. 
This year our estimated Scope 3 emissions 
were 12.9 million tonnes CO2e. We have worked 
with the Carbon Trust to analyse our Scope 3 
emissions in order to identify where emissions 
are highest and prioritise where we have the 
greatest opportunity to influence third-party 
GHG emissions. This analysis considered all 
of the categories defined in the international 
guidance for Scope 3 emissions published by 
the GHG Protocol.
Of the Scope 3 emission categories, those most 
material to our business are:
	 our joint ventures Vodafone Hutchinson in 
Australia, Vodafone Idea and Indus Towers in 
India, Vodafone Ziggo in the Netherlands and 
our associate company Safaricom in Kenya 
– with emissions estimated to be 6 million 
tonnes CO2e;
	 our suppliers’ emissions in producing the 
goods and services that we procure from 
them, particularly in our networks, IT 
equipment, handsets and other devices 
estimated to be 4 million tonnes CO2e; and
	 customer use of our products and services, 
which includes emissions arising from the 
electricity used by network connection 
devices (such as routers) and when charging 
mobile device batteries – with our emissions 
for the devices we sold this year estimated to 
be 2 million tonnes CO2e.
Some other categories included in our Scope 
3 reporting are less significant in terms of 
volume but are reported because we have 
more control of them than for those deemed 
most material. These are:
	 business travel (predominantly air but also 
train, bus and taxi travel) – estimated to 
have generated 0.06 million tonnes CO2e 
this year of which air travel accounts for 
the majority;   
	 emissions that arise from the operation of 
base stations owned by third-party tower 
companies in Ghana and Tanzania where 
we lease space for our radio network 
equipment – which we estimate to be 0.05 
million tonnes CO2e ; and
	 treatment and disposal of waste from our 
operations, with emissions arising from the 
transportation, recycling and disposal of 
network and office waste estimated to be 
0.001 million tonnes CO2e.
We do not report on the other non-material 
Scope 3 categories.
Our supplier performance management 
programme covers environmental factors, 
and suppliers’ GHG performance is one of the 
factors evaluated in our annual assessment 
process. We ask suppliers whether they have 
publicly reported their GHG emissions, have set 
targets to reduce emissions and have identified 
the risks and opportunities associated with 
managing their GHG emissions. 
See page 75 for how we calculate 
our Scope 3 emissions
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Vodafone Group Plc Sustainable Business Report 2019
Energy innovation
Youth skills and jobs
Transformation
Introduction
Operating responsibly
Our people
Appendix

Enabling customers to reduce emissions
Increasing energy efficiency with 
Narrowband-IoT smart metering
With the evolution of new IoT 
technologies there is a need to develop 
low-power methods of connecting 
devices out in the field for applications 
such as smart meters, connected 
agriculture, smart cities or asset tracking. 
Narrowband-IoT (NB-IoT) is a new low-
power method of long-range wireless data 
transmission between devices that can be 
deployed in rural areas where there is no 
reliable access to power or where devices 
are underground or within buildings. NB-
IoT technology delivers many benefits, 
including great power efficiency, so that 
devices can run on batteries for 10 years 
or more without a charge. 
Techem, a market leader in remote radio 
metering of energy consumption in 
homes and commercial buildings, is using 
NB-IoT from Vodafone to track energy 
consumption reliably and cost-effectively 
and help customers improve their 
energy efficiency.
“Having a better understanding of 
energy flows and consumption opens 
up new opportunities for improving 
energy efficiency in the field of smart 
buildings and smart homes.”  
Dr Daniel Ghebru, 
Innovation Management, Techem
IoT applications that help our customers reduce 
emissions include: 
Smart energy meters that enable 
businesses, municipal authorities and 
households to monitor, manage and reduce 
their energy use. Worldwide we have over 9 
million smart meter connections using our IoT 
technology, saving an estimated 1.4 million 
tonnes CO2e.
Smart cities – networked intelligently to 
improve the efficiency of energy-intensive 
services such as public transport, public road 
networks and street lighting. For example 
in the city of Guadalajara, Spain, 13,500 
LED lights were connected to a central 
management system, reducing street 
lighting energy consumption by 68%. 
Smart logistics – IoT technologies 
embedded in vehicles to optimise route 
management, vehicle maintenance and 
driver behaviour, delivering cuts in fuel 
consumption of up to 30%; saving an 
estimated 4.0 million tonnes CO2e.
Through our IoT mobile services, 
we are helping our customers to 
manage energy more efficiently 
and reduce their emissions. Over 
time, IoT technologies have the 
potential to transform industry, 
public services and many aspects 
of people’s daily lives.
Our progress
This year we enabled our customers 
to avoid 2.9 tonnes of CO2e for every 
one tonne generated from our 
operations.
Ratio of GHG emission savings for 
customers to our own GHG footprint 
2017
2018
2019
2.6
2.4
0.0
0.5
1.0
1.5
2.0
2.5
3.0
2.9
We estimate that over 31% of the more than 
85 million IoT connections we operate directly 
enable customers to reduce their emissions, and 
we expect these connections to increase over time. 
We calculate that in 2019, the total GHG 
emissions avoided as a consequence of our 
IoT technologies and services were 5.9 million 
tonnes CO2e, which is nearly three times the 
emissions generated from our own operations. 
The greatest CO2e savings enabled were in smart 
metering and improvements in logistics and 
fleet management.
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Transformation
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Operating responsibly
Our people
Appendix

Monitoring air quality in Albania
Road traffic volumes have increased 
significantly in Albania since the early 1990s, 
which has caused environmental challenges 
from traffic congestion and air pollution in 
the capital city Tirana: the annual average 
concentrations of PM10 and PM2.5 for Tirana 
are above the limit values of the EU Air Quality 
Standard and the World Health Organization10. 
Working in collaboration with the 
Municipality of Tirana, Vodafone Albania 
has implemented a system to monitor and 
transmit air quality in the capital city to 
the public. Using our IoT technology, smart 
air quality monitoring devices have been 
installed in the city and integrated into 
a system to monitor real-time air quality 
through the ‘Tirana Ime’ application. By 
monitoring air pollution in this way the 
municipality is better able to understand 
traffic-related air pollution factors and 
identify appropriate measures for tackling 
such pollution.
Improving fleet efficiency using IoT
For all fleet operators, the cost of fuel is critical to the bottom line and any 
improvement in fuel efficiency, however small, can help reduce costs and 
consequently overall emissions. 
We have been providing Dako, a company specialising in telematics, with the IoT 
connectivity it needs to support its networked logistics solutions for commercial 
fleets. One Dako customer, Schmalkalden Stadtreinigung GmbH (SSR), a waste 
management services company in Germany, has installed telematics devices 
into its collection vehicles. Using Vodafone IoT GPS tracking of the vehicles, 
connected to the Vodafone Managed IoT Connectivity Platform, the system is 
able to monitor, analyse and archive driving times, routes, driver activity and rest 
periods. This data is being used by SSR to optimise the vehicle rounds.
The next stage of the project will see the launch of a pilot to also monitor 
selected bins and recycling containers and alert SSR when they require emptying. 
1	 WMO Provisional Statement on the State of the Global Climate, 2018
2	 Fifth Assessment Report, IPCC, 2014
3	 Special Report: Global Warming of 1.5°C, IPCC, 2018 
4	 World Energy Outlook 2018, IEA
5	 Global Energy and CO2 Status Report, IEA, 2018
6	 Lean ICT Report, The Shift Project, 2019
7	 Cisco Visual Networking Index, 2019
8	 The Mobile Economy, GSMA, 2019
9	 Please note this intensity metric takes into account our total CO2e 
emissions but only our mobile data traffic (not our fixed-line data traffic).
10	 WHO air quality database, 2018
Women’s empowerment
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Energy innovation
Youth skills and jobs
Transformation
Introduction
Operating responsibly
Our people
Appendix

Operating responsibly
We are committed to ensuring that our business operates ethically, lawfully and 
with integrity wherever we operate as this is critical to our long-term success.
This chapter contains sections relating to some of the key risks we face and details the controls 
we put in place to ensure our operating practices meet our and our stakeholders’ expectations:
Supply chain integrity
We work to ensure integrity in our supply 
chains by managing many different legal, 
social, ethical and environmental risks. We also 
encourage those who work with us, directly or 
indirectly, to adopt sustainable business practices.
37
Safety 
Keeping the people who work for us safe is one 
of our most fundamental responsibilities. We 
promote our approach across our industry with 
leading safety standards by insisting on high 
safety practices from our employees, contractors 
and suppliers and by engaging with customers 
and peers.
42
Human rights 
Respect for human rights, including those 
that extend into the digital realm, is critical
to the long-term success of our business.
46
Anti-bribery and corruption 
and political engagement
Vodafone does not tolerate bribery or corruption 
in any form. We would rather walk away from 
a business opportunity than engage in actual 
or even perceived corruption. Interaction with 
governments, political parties and political 
commentators, civil servants, regulators and 
independent statutory bodies is an essential 
aspect of managing our businesses around 
the world.
48
Privacy and cyber security 
Vodafone has strict governance controls worldwide 
to ensure the protection of our customers’ personal 
data and communications, respecting their privacy 
and proactively managing security risks. 
53
Mobiles, masts and health 
We are committed to responding openly and 
transparently to public concerns about mobiles, 
masts and health and comply with all applicable 
laws in every jurisdiction in which we operate. 
56
36
Introduction
Transformation
Operating responsibly
Supply chain integrity
Safety
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Our people
Appendix
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement
Supply chain integrity
Safety
Human rights
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

Supply chain integrity
We spend approximately €22 billion 
a year with more than 10,800 direct 
suppliers around the world to meet 
our businesses’ and customers’ needs.
Our businesses rely on complex and multilayer 
global supply chains. For example, our direct 
suppliers often have many suppliers of their own, 
who in turn rely on a large number of suppliers, 
and this dependency continues through several 
tiers. Intermediaries such as distributors and 
wholesalers are also involved at various points 
in our chains.
We work to ensure integrity in our supply chains 
by managing many different legal, social, ethical 
and environmental risks. We also encourage those 
who work with us, directly or indirectly, to adopt 
sustainable business practices. 
Safety in our supply chain is also critically 
important. Vodafone has comprehensive 
measures in place in our own businesses 
designed to make sure everyone who works
 for us goes home safely. We reinforce this 
across our supply chains. 
  Further information on the structure of 
our supply chain can be found online at 
www.vodafone.com/supplychain.
Supply chain risks
Some of the most material risks in the 
information and communications technology 
(ICT) supply chains include injury to people 
working in field operations, the harmful effects 
of working long hours in electronics factories, 
corruption and human rights abuses in the 
mining of cobalt or other metals and minerals.
Safety is a critical priority throughout our supply 
chain and in particular during the installation, 
management and maintenance of our mobile 
and fixed-line networks. There are grave risks 
for our employees and suppliers when carrying 
out this work, including those related to 
driving, working at height or dealing with 
high-voltage equipment. 
We have developed robust systems to seek to 
ensure that our suppliers meet our mandatory 
ethical, labour and environmental standards. 
We expect all our suppliers to follow our Code 
of Ethical Purchasing and uphold the Business 
Principles in our Code of Conduct. We expect 
our suppliers to be accountable for managing 
risk in their operations and to understand that 
we expect them to hold their own suppliers 
accountable to the same high standards.
When choosing a new supplier, or choosing 
to continue to work with one, we assess the 
supplier’s compliance with our rules on health, 
safety and responsible behaviour, just as we 
assess commercial factors such as quality, cost 
and the supplier’s ability to deliver on time.
Levels of influence
The Vodafone Procurement Company (VPC) 
leads purchasing and supplier management. 
The VPC manages most of our spending with 
suppliers worldwide and supports the needs of 
our operating companies and group functions. 
This approach is designed to ensure objective 
and consistent supplier management across 
Vodafone’s businesses and makes it easier to 
monitor and improve supplier performance.
We also have relationships with local suppliers 
that work on behalf of our local country 
businesses, particularly those involved 
in service-related procurement, such as 
merchandising or field operations. Our support 
for these local businesses has a positive impact 
on communities through providing employment 
in our local operating countries.
Monitoring our suppliers’ compliance with 
our rules can be challenging because of the 
complexity of our supply chain, which includes 
many businesses in different locations and at 
different tiers or levels. Therefore, the level of 
influence we can exert over businesses in our 
supply chain varies significantly. The greatest 
level of influence usually exists with our Tier 1 
suppliers where we have direct contractual 
agreements. Many of these are substantial 
brands and businesses with proven processes in 
place to ensure high standards and sustainable 
business practices. Where a supplier is dominant 
in the marketplace with a particular product or 
service, or where Vodafone is not a significant 
purchaser, we have less influence.
Our Code of Ethical Purchasing requires all our 
Tier 1 suppliers to ensure that their suppliers 
also have equivalent policies, processes and 
verification systems in place to manage risks and 
ensure compliance in their own supply chains. 
We collaborate with some of our Tier 1 suppliers 
to monitor their supplier bases directly and help 
them to improve standards. We also work with 
our peers and suppliers to share best practice 
and to strengthen compliance at the top tier of 
our supply chain. 
We also have influence over the infrastructure 
suppliers who supply, install and maintain our 
networks, as well as over suppliers that provide 
branded products and services. We have less 
influence over Tier 21 and other sub-suppliers 
operating further down our supply chains, where 
the risks of non-compliance are higher. We work 
with our direct suppliers to monitor and manage 
the risks at this level.
  Further information on the process 
to qualify as a Vodafone supplier and 
our policies can be found online at 
vodafone.com/supplychain.
37
Introduction
Transformation
Operating responsibly
Supply chain integrity
Safety
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Our people
Appendix
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

Minerals in the supply chain
Vodafone does not directly own or operate 
factories or production plants, with the 
exception of a technology operation in Italy 
that is part of our Vodafone Automotive Internet 
of Things (IoT) business. We do not directly 
purchase raw minerals, ores or metals. The 
majority of the smartphones and tablets that 
we resell to customers are produced by major 
companies with internationally recognised 
brands that report on sustainability efforts in 
their own right. We also offer our customers a 
range of smartphones and tablets that carry the 
Vodafone logo. These devices are designed and 
manufactured on our behalf by suppliers known 
as original design manufacturers.
Electronic products contain numerous 
components that may contain one or more of 
the 3TG metals (tin, tantalum, tungsten and 
gold). For example, tin is used often as a 
soldering material for electronic components. 
Gold and tantalum are typically used in 
components such as connectors or capacitors. 
In addition, some electronic products contain 
cobalt within their lithium-ion batteries. 
Smelters and refiners mine and process cobalt. 
It is then supplied to component manufacturers, 
assemblers and sellers. 
These minerals come from many different 
smelters and refiners in a complex and often 
opaque supply chain. Both the smelters and 
refiners, and the mines from which minerals are 
sourced, are many steps away from Vodafone in 
the supply chain. If we can influence the design 
or manufacture of products, we try to ensure that 
they do not contain metals or minerals that fund 
conflict in the Democratic Republic of Congo. 
We are members of, and involved in, industry 
initiatives such as the Responsible Minerals 
Initiative to improve transparency in supply 
chains. Vodafone also investigates the potential 
human rights risks relating to both cobalt and 
3TG metals mining in our supply chain. We 
have focused on identifying products likely to 
contain these minerals and the locations of 
suppliers who manufacture or are employed as 
contractors to manufacture those products. 
We provide further details of our approach to this 
issue in our statutory Conflict Minerals Report 
and Artisanal Cobalt Statement.
Monitoring compliance
We expect our suppliers to continuously monitor 
their compliance with the standards set out 
in our Code of Ethical Purchasing. Any failures 
must be immediately addressed. We also require 
them to report serious breaches to Vodafone 
immediately so we may ensure that they take 
corrective action.
The Vodafone approach to monitoring 
compliance with the Code of Ethical Purchasing 
is determined by the nature of the risks and the 
kind of activity involved. High-risk suppliers, 
including those operating in industries, sectors 
or countries with a history of poor standards, 
are required to undergo a detailed evaluation 
process. Suppliers who work in lower-risk areas 
may be required to complete self-assessment 
questionnaires. 
Supplier questionnaires
Through our Supplier Performance Management 
Programme Vodafone monitors our key 
suppliers’ health and safety and sustainable 
business performance standards, as well as their 
commercial, product and service performance. 
We define key suppliers in terms of the nature 
of their contribution to our business and the 
significance of our expenditure with them. 
We require suppliers to complete an ethical, 
labour and environmental risk questionnaire and 
to provide evidence to validate their responses. 
Suppliers can use the questionnaire to highlight 
ways in which they have shared best practice in 
their own business or their supply chains. This 
year we evaluated 43 key suppliers through this 
approach. Our supply chain team then validates 
and uses the information provided to assign 
each supplier an overall sustainability score and 
grade. These scores are also used to grant two 
Vodafone Supplier Awards, one for health and 
safety and the other for sustainability.
38
Introduction
Transformation
Operating responsibly
Supply chain integrity
Safety
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Our people
Appendix
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

Detecting and tackling modern slavery
During 2017, we asked more than 8,000 
supplier businesses to cascade our modern 
slavery e-learning training through their 
supply chains. The training, which is available 
in English, Hindi and Mandarin Chinese, 
is designed to increase workers’ and line 
managers’ awareness and understanding 
of modern slavery risk. It also promotes 
Vodafone’s Speak Up process as a way for 
workers to raise issues directly with Vodafone.
As a direct result of this training, during the 
year, we had one report of a modern slavery-
related issue through Speak Up, from a 
worker at a supplier site in one of our African 
markets. The individual raised a concern that 
they did not have an employment contract 
and had yet to be paid.
Working with an independent auditor, 
Vodafone observers visited the site to review 
the supplier’s contracting and payment 
procedures. This included document checks, 
confidential employee interviews and taking 
a sample of the supplier’s workers’ contracts, 
in job roles likely to be at risk of modern 
slavery practices.
After a thorough investigation, using an 
independent audit firm specialising in 
detecting modern slavery to carry out 
an on-site audit, no wrongdoing was 
found. However, we identified some areas 
for improvement to avoid any similar 
concerns occurring in the future. The 
supplier has since implemented the 
recommendations that resulted from the 
audit with respect to communicating pay 
in advance of remuneration and ensuring 
that employment contracts are both 
kept on file and shared with employees. 
The confidentiality of the individual was 
maintained through the process.
On-site audits
We regularly undertake intensive on-site supplier 
audits, which include an examination of written 
policies and procedures, site inspections and 
discussions with managers and employees. 
This provides us with a detailed insight into 
how suppliers’ policies translate into action.
Vodafone is one of 17 telecoms operators 
who belong to the Joint Audit Cooperation 
(JAC) initiative, where we share our on-site 
assessments, given that our industry peers 
share the same suppliers and supply chain 
risks. Through the JAC process, each supplier 
undergoes a single audit. The results of these 
audits are shared between JAC members and 
one member leads any required follow-up 
with the supplier.
Between January and December 2018, there 
were 79 JAC audits, of which 87% were within 
Vodafone’s supply chain. Of the audits in 
Vodafone’s supply chain, 24 were Tier 1 direct 
suppliers, 39 were Tier 2 suppliers, five were 
Tier 32 suppliers and one was a Tier 43 supplier. 
In parallel, we conduct our own on-site 
assessments for specific Tier 1 and Tier 2 suppliers 
that we have identified as high risk but that are not 
covered by the JAC initiative assessments. This 
year, we conducted six on-site assessments: four 
Tier 1 suppliers and two Tier 2 suppliers.
Direct employee feedback
While the assessment of the working hours and 
working conditions of our suppliers is important, 
it can be difficult because supervisors and 
managers may attempt to falsify timesheets 
and other workplace records. This year, we 
continued to obtain direct feedback from our 
suppliers’ employees in order to identify 
modern slavery risks and areas for improvement.
We use an independent third-party company 
to gather confidential and unbiased feedback 
directly from our suppliers’ employees. 
Anonymous and simple mobile phone-based 
worker surveys enable employees to reply to 
pre-recorded questions in their local language 
at any time and from any location. We require 
participating suppliers to allow their employees 
to respond to questions freely and privately. The 
responses provide us with important insights 
into our suppliers’ employees’ working hours and 
conditions so we can work with suppliers to put in 
place appropriate remedial measures if required. 
During 2019, our approach to using worker 
surveys was adopted by JAC member companies. 
This year JAC members collectively surveyed 
common factories employing 16,800 workers 
across 12 factories in China and India. Where 
Vodafone also conducted on-site audits and 
verification of supplier factories in China and 
India with the same workforce population, 
10% responded to our anonymous survey. 
Recommendations for improvement 
from combined JAC audits* and Vodafone 
audits in 2019 (Number of cases)
 
 
 
466 Health and safety 
139 Working hours
106 Business ethics
101 Environment
51 Payment 
 
17 Discrimination
16 Young workers
11 Freedom of association
9 Forced labour
8 Disciplinary practices
* JAC audits are reported on a calendar-year basis.
Improving performance and 
building capability
Engaging directly with suppliers through follow-
up discussions and briefings using our monitoring 
processes is one of the most effective ways of 
improving performance in our supply chain.  If there 
is evidence of non-compliance through JAC audits, 
our own on-site assessments or worker surveys, we 
work with suppliers to develop corrective actions, 
to improve their policies and/or strengthen the 
processes they use to manage key risks.
This year, most of the recommendations made 
following Vodafone or JAC audits related to 
health and safety, excessive working hours and 
business ethics. Regarding health and safety, 
there was an increase in recommendations 
related to fire evacuation signage, evacuation 
lighting and fire exits. There was also an increase 
in environmental recommendations, mainly 
regarding unsatisfactory management systems 
or emissions monitoring. We work directly and 
through the JAC governance process to ensure all 
recommendations are implemented.
2019*
2017
2016
2018
Number of site assessments conducted by JAC*
Number of supplier site assessments conducted 
by Vodafone
 
0
20
40
60
80
100
61
24
26
69
81
17
79
6
* JAC assessments are reported on a calendar-year basis.
** 12 sites were assessed both on-site and via mobile surveys.
Number of assessments conducted 
39
Introduction
Transformation
Operating responsibly
Supply chain integrity
Safety
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Our people
Appendix
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

Health and safety
–	 Emergency preparedness (e.g. missing 
building safety plans or missing equipment).
–	 Lack of safety management policies 
and processes.
–	 Inadequate safeguards to prevent exposure 
to hazardous substances.
Working hours
–	 Poor resource planning and forecasting,
which leads to excessive working hours 
by supplier employees.
Business ethics
–	 Lack of effective ethics policies.
–	 Lack of ethics requirements towards 
their suppliers.
–	 Lack of whistle-blowing mechanism.
Environment
–	 Lack of environmental performance targets.
–	 Missing environmental permits to 
conduct certain activities.
–	 Poor control on disposal of hazardous 
substances.
Payment
–	 Improper or unclear overtime payments.
–	 Failure to comply with minimum wage 
requirements.
–	 Failure to keep accurate records on 
social insurance payments.
Discrimination
–	 Inadequate policies to ensure equality.
Young workers
–	 Instances of young workers aged 16–18 
found to be doing dangerous or night work.
–	 Inadequate records kept on verifying 
worker age.
Freedom of association
–	 Workers denied the opportunity 
to join representative bodies. 
–	 Worker representatives not elected freely. 
Forced labour
–	 Excessive use of agency or temporary labour.  
–	 Employees not receiving copies of their 
employment contract. 
Disciplinary practices
–	 Wage deductions used as a disciplinary 
measure.
30 out of the 60 critical performance issues 
identified from JAC on-site audits were resolved 
and signed off. The remaining 30 issues, 
which relate to working hours and emergency 
preparedness, require additional time and 
investment to monitor the effectiveness 
of actions before they can be signed off as 
completed. Vodafone will terminate a contract 
if any supplier persistently fails to resolve 
compliance failures or if issues of gross 
misconduct occur. 
Supporting LGBT+ communities in our supply chain
This year we began to measure the progress 
our suppliers are making towards support for 
diverse groups such as LGBT+. Approximately 
half our suppliers declared that they have 
LGBT+ supportive practices, such as support 
networks, or LGBT+ inclusive policies and 
practices in place. 
In March 2019, Vodafone hosted ‘Partners 
with Pride’ at our Group Headquarters in 
Paddington. This event brought together 
leaders from more than 25 of our global 
suppliers to explore how to make a positive 
difference in the treatment of LGBT+ 
people worldwide. Through our ecosystem 
of suppliers and partners, many of which 
are technology companies, we shared 
approaches on our collective successes and 
challenges in LGBT+. We also explored how 
we could collaborate to advance greater 
levels of belonging and inclusion across the 
three key areas of youth, community and 
cultural change. 
Participants at the event included Vodafone’s 
LGBT+ Global Executive Sponsor (who is also 
the Group Supply Chain Director and CEO of 
the VPC), the Group Chief Technology Officer 
and a former UN Head of Human Rights and 
Anti-discrimination.
The key factors underlying recommendations (ranked by frequency)
40
Introduction
Transformation
Operating responsibly
Supply chain integrity
Safety
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Our people
Appendix
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

Our payment practices
Our payment terms take into consideration the 
size of the supplier in question, the contract, 
the nature of service or type of goods provided 
and the supplier’s relationship with the wider 
Vodafone Group, along with any other relevant 
commercial factors. As a global organisation, 
many of our suppliers are large multinational 
companies, which may provide network 
equipment or devices for customers. Vodafone 
also has many suppliers that are small and 
medium-sized enterprises.
As a general principle, our supplier payment 
terms are a maximum of 60 days from the date 
of receipt of invoice. To help suppliers improve 
their cash flow, we offer our suppliers supply 
chain financing facilities and free e-invoicing 
tools. As of 31 March, over 3,500 suppliers had 
taken up early invoice payments on a completely 
voluntary basis, where payment can be taken in 
advance under agreed terms at much lower rates 
than they are likely to receive under traditional 
factoring or borrowing arrangements.
We recognise that small, innovative technology 
start-ups are particularly sensitive to cash 
flow, and to support them we introduced an 
‘Innovation Fast Lane’ scheme, which has 
simplified contracting and enables lower 
payment terms, capped at a maximum of 21 days 
from date of receipt of invoice. We also ensure 
that our invoices are paid on time (2019: 99%) 
and we cap maximum payment terms.
In order to ensure that our policies and practices 
are appropriate for smaller suppliers, we work 
to improve our understanding of our supplier 
base and to introduce a range of initiatives 
designed to benefit those smaller suppliers. 
This year in the UK, we committed to pay all our 
small suppliers (as defined by the Companies 
Act) within 30 days of receipt of their invoice. 
We asked our suppliers to confirm whether they 
fall into the category of smaller suppliers. We 
have also amended our systems to enable this 
information to be captured on an ongoing basis.

In South Africa, last year Vodacom increased 
the value paid under preferential payment 
terms to qualifying small, medium and micro-
sized enterprises by 55%. In addition, the 
business offers preferential payment terms 
to businesses which are over 51% Black-owned, 
assisting them with their cash flows and to 
reduce financial constraints. 
Providing our suppliers with direct support and building capability
As part of the JAC initiative, Vodafone 
worked with three other operators this 
year to launch a Supplier Academy to build 
supplier capability. The Academy focuses 
on developing training to help suppliers 
assess and improve the social, ethical and 
environmental performance issues that may 
arise within their own supply chains.
Following a week of classroom training 
delivered by an internationally recognised 
audit and verification company, five 
participating suppliers were on-boarded 
into the Academy. They were then given an 
opportunity to gain practical experience of 
performing an audit under the supervision 
of an independent third-party auditor. Once 
completed, suppliers were then able to 
complete 25 audits of their own, or of their 
suppliers’, facilities and shared the results 
with Vodafone.
  Read Vodafone’s latest 
UK payment practices report. 
41
Introduction
Transformation
Operating responsibly
Supply chain integrity
Safety
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Our people
Appendix
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

Safety 
We take safety extremely seriously in 
our operations. Keeping the people 
who work for us safe is one of our 
most fundamental responsibilities. 
We promote our approach across our 
industry with leading safety standards 
by insisting on high safety practices 
from our employees, contractors 
and suppliers and by engaging with 
customers and peers.
Our commitment to safety does not 
differentiate between our own employees, 
our contractors and our suppliers’ employees 
and contractors. 
We want everyone working with Vodafone 
to return home safely every day. Any injury 
or any loss of life related to our operations is 
unacceptable. It is therefore with great regret 
that we report two recordable fatalities4 this 
year. We provide the context for those deaths 
in this section on page 45.
Policy
Our Code of Conduct makes it clear that 
everyone working for or on behalf of Vodafone 
must behave in a safe and responsible manner 
at all times. Our Group Health, Safety and 
Wellbeing Policy expands on the Code of 
Conduct, setting out our commitment to 
establish a robust and durable health, safety 
and wellbeing culture. Detailed standards with 
this policy establish the specific steps that must 
be taken to manage our greatest risks.
Our Absolute Rules on safety 
The Vodafone Absolute Rules on safety focus 
on risks that present the greatest potential 
for harm for anyone working for or on behalf 
of Vodafone. The Absolute Rules are clear and 
underpinned by a zero-tolerance approach to 
unsafe behaviours in all of our businesses.
Vodafone employees and contractors, 
and our suppliers’ employees and 
contractors, must:
–	 always wear seatbelts when travelling 
in or operating vehicles;
–	 always use suitable personal protective 
equipment, a safety harness and fall 
protection when working at height;
–	 never carry out electrical work on 
electrical equipment, circuits and gear 
if they are not qualified;
–	 never work under the influence of 
substances (alcohol or drugs) that are 
illegal or in excess of legal levels or where 
this impairs the individual’s ability to 
perform tasks;
–	 never exceed speed limits or travel at 
speeds that are dangerous for the type 
of vehicle or conditions;
–	 never use a hand-held phone while driving 
and only make calls by pulling over or 
using hands-free devices, when it is safe 
to do so; and
–	 never undertake any street or 
underground work activities unless 
competent to do so.
Work Safe Home Safe
We continue to develop our health and safety 
messaging around Work Safe Home Safe, which 
promotes the importance of adhering to the 
Vodafone Absolute Rules as good practice in our 
employees’ personal lives and workplace. The 
intention is to encourage commitment to safe 
practice rather than merely compliance with the 
Vodafone safety requirements. 
Over the next year, we will introduce our 
Vodafone Safety Values, which encourage 
employees to consider the benefits of safe 
practice, not only for themselves but also for 
the safety of others. For example, the Values 
include a commitment to intervene wherever 
someone’s safety may be at risk. They also 
encourage the reporting of incidents and 
hazards to prevent a reoccurrence. 
Our global Code of Conduct training, completed 
by 90%5 of active employees, includes a 
mandatory e-learning safety module designed 
to ensure that employees know how to keep 
themselves and others safe at work. It also 
includes details of our Speak Up programme, 
which enables anyone to report safety concerns 
anonymously if they prefer. 
In addition to the Absolute Rules, our Supplier 
Group Policy on Health, Safety and Wellbeing 
sets out additional safety requirements at 
an operating level, particularly for high-risk 
activities. The policy emphasises the need for 
suppliers to monitor compliance on a continuous 
basis, report about their safety performance 
to us and have in place robust mechanisms to 
manage safety in their own supply chain. It also 
requires suppliers to put in place a safety plan 
before they undertake a number of specified 
high-risk activities.
  Further information on how we ensure 
compliance with our policy, including 
how it is governed, can be found online 
at www.vodafone.com/safety.
42
Supply chain integrity
Safety
Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix
Human rights
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

Managing key safety risks 
Our safety strategy focuses on the most 
significant risks for people working in operational 
roles in our businesses. These risks are:
–	 road risk when driving for work;
–	 working with electricity;
–	 working at height;
–	 laying cables in the ground; and
–	 management and control of suppliers.
Historically, these risks have accounted for 
the majority of serious incidents and fatalities 
that have occurred in Vodafone and in our 
supply chain. This reflects the general trend 
across the global telecommunications industry. 
Traffic-related incidents remain the greatest 
threat of harm on a daily basis, particularly in 
emerging markets.
We consider the management and control of 
suppliers to be a significant risk because much 
of the work relating to the risks identified is 
undertaken by our Tier 1 suppliers or Tier 2 
sub-suppliers.
Road safety 
Road safety remains our primary safety concern 
and continues to be the primary cause of serious 
injuries and fatalities associated with Vodafone 
activities. This echoes the growing awareness 
and focus on improving road safety across the 
globe, including UN Sustainable Development 
Goal target 3.6 on road safety, which aims to 
halve the number of road traffic deaths and 
injuries by 2020. 
Safe driving techniques training is mandatory for 
anyone who drives a road vehicle while working 
on our behalf. However, mitigating road risk 
remains challenging because we have no 
direct ability to control external factors such as 
unsafe driving conditions, the lack of a safety-
first culture or the actions of third parties on 
public roads.
We have historically experienced challenges with 
employee data privacy when using telematics 
in company vehicles. However, with improved 
technology we are starting to introduce devices 
with improved functionality that enables the 
driver to identify the difference between using 
their vehicle for business and private use. This 
ensures privacy around their personal driving 
behaviour. These privacy improvements have 
seen the introduction of telematics in a number 
of markets, most notably Hungary and Ireland. 
This year in Egypt, Vodafone Egypt created 
an app that uses telematics data to identify 
adherence to road speed limits, driver fatigue 
and journey management violations and then 
send instant notifications in cases of non-
compliance. This proactive approach has 
the potential to help reduce the number of 
future incidents. 
Working with electricity 
Our Absolute Rules stipulate that anyone 
working with electrical equipment must be 
qualified and authorised to do so. Our training 
module on working with electricity provides 
guidance to employees on how to recognise 
risks and implement appropriate safety controls. 
There was one fatal electrocution and one 
major incident involving electricity this year. 
The fatal electrocution occurred in Vodacom 
Mozambique when a contractor installing fibre 
on an electrical distribution line suffered an 
electric shock when using an aluminium ladder 
to free a cable caught in a tree. In addition, a 
major incident occurred in our joint venture 
Vodafone Hutchinson Australia where two 
employees from a sub-contractor working on 
a distribution panel suffered severe burns. We 
continue to ensure that electrical risk is a focus 
for all suppliers. We took the following actions 
to strengthen controls:
–	 distributed a Group-wide safety alert; 
–	 emphasised electrical risk at our global 
supplier forum;
–	 conducted monitoring checks during 
market visits; and
–	 revised our electrical safety standard.
In addition, we have continued to work with 
suppliers to ensure that:
–	 they have a documented risk management 
process for working with electricity;
–	 those working with electricity are certified, 
competent and medically fit;
–	 electrical equipment is fit for its 
intended purpose;
–	 appropriate safety controls such as 
‘lockout-tagout’ are in place; and
–	 work on live electrical systems is 
prohibited (with the exception of extra-low-
voltage systems, where additional controls 
are specified).
Working at height
Mobile communications services rely on 
connectivity provided by antennas placed
on towers, masts and rooftops. We work to 
ensure the training of Vodafone employees 
and contractors and our suppliers’ employees 
and contractors who work at height so that
 they understand the risks and take steps to 
control them. 
Our network site design principles stipulate the 
need for safe access for people working at height 
and include guidance on the control measures 
required to manage the risks involved effectively. 
Fall-arrest equipment is inspected regularly as 
part of each of our local businesses’ preventative 
maintenance programmes.
There were eight working-at-height major 
incidents during the year, six of which involved 
engineers falling from ladders while installing 
fibre cables. To mitigate the risks of working at 
height and safe site access we have:
–	 maintained investment in fall-arrest 
equipment and strengthened maintenance 
and recertification activities in all markets;
–	 assessed suppliers who provide training on 
working at height in India, Egypt, Turkey, 
Greece, Albania, Romania, the Czech 
Republic and Hungary;
–	 reviewed our key global suppliers and their 
compliance to our working-at-height and 
safe site access procedures; and
–	 strengthened safe site access controls 
with the introduction of a new standard 
and guidelines.
43
Supply chain integrity
Safety
Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix
Human rights
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

During the year, we have also continued to work 
with third-party suppliers to ensure effective 
controls are implemented and monitored, with 
a specific focus on ladder work.
Laying cables in the ground 
Expanding our fixed-line business has increased 
the amount of work undertaken to lay or 
maintain cables at street level or underground. 
At street level, this work is hazardous, with the 
risk of injury or death posed by penetrating 
electricity or gas lines, trenches collapsing 
during excavation and nearby road traffic.
Fibre-to-the-premises and cable broadband 
installations require employees and contractors 
to work on private residential and business 
property as well as in the street. Doing so also 
poses risks such as not knowing the location 
of buried utilities. We are working with our 
local businesses to ensure that they have the 
necessary safety plans and controls in place 
to mitigate these risks.
Control of suppliers
Suppliers’ employees and contractors working 
on masts, towers and other equipment 
undertake most of the highest-risk activities 
related to the deployment and maintenance 
of our networks. In addition to our policies and 
Absolute Rules, we operate a consequence 
management system. This means we will 
terminate contracts if our suppliers or their sub-
suppliers persistently fail to meet our standards.
Effective risk management starts at the top of 
any organisation, so we are clear about our safety 
expectations to the chief executives and senior 
leadership teams of our supplier businesses. 
We expect them to focus on the operational 
challenges our safety experts identify. 
Four times a year, we host a supplier safety 
forum, first established in 2016, for our major 
network suppliers, focusing on best practice 
and critical risks. 
High-risk supplier reviews
The majority of fatalities continue to involve 
our suppliers, where unsafe behaviour is a 
contributing factor. This year we completed 
a review of high-risk suppliers across our Africa, 
Middle East and Asia-Pacific markets, focusing 
on Tier 1 and Tier 2 suppliers. This review helped 
us better understand how local markets monitor 
suppliers’ adherence to our requirements. 
The review confirmed strong engagement with 
suppliers through local market supplier forums. 
However, it also found that further action was 
required to address under-reporting by suppliers. 
Markets were subsequently instructed to 
reiterate expectations to all suppliers on the 
requirements when reporting incidents. These 
include reporting timescales and the definition 
of what should be reported.
We continue to influence global suppliers at 
Group level and will continue to include high-risk 
supplier reviews as part of quarterly reporting. 
In addition, we plan to further investigate how to 
improve the speed and ease of supplier reporting 
using technology.
Performance 
Monitoring and reporting on our safety 
performance is essential to ensure the safety 
of everyone working with us – our employees, 
contractors and suppliers and those suppliers’ 
own employees and contractors. It also helps 
us to focus on and address the risks that are 
inherent to our industry.
We want our own teams, our suppliers, our 
stakeholders and others in our industry to 
learn from the performance data we share. 
In the case of fatalities, we set a wide boundary 
for our in-scope reporting. In contrast with 
many businesses, which only report employee 
fatalities on their own premises, we report 
fatalities involving any of our suppliers’ 
Equipping commercial vendors with safety training
Vodafone celebrated 10 years in Ghana in June 2018. Over that time, the health and safety 
agenda has seen a significant improvement, from a ‘no safety’ regime in 2008 to the point 
where health, safety and wellbeing has been embraced as part of the core values and culture 
in the organisation. 
To date, the main safety emphasis has been on installing technology, due to the high-risk nature 
of these projects. However, this had meant there was less of a focus on our non-technology 
suppliers meeting our health and safety standards. In response, the business organised working-
at-height training this year for its two main Tier 1 commercial suppliers and their sub-contractors. 
This comprised both theory and practical courses, which included working at height to assemble 
advertising banners, fall arrest and rescue, secure rope lifeline use, radio frequency awareness 
and safe ladder use.
This training and associated certification will help our suppliers to work safely as Vodafone Ghana 
introduces 4G LTE services, which will require vendors to advertise our 4G network countrywide. 
employees and contractors (across all tiers) and 
members of the public, regardless of whether 
these fatalities occur on Vodafone premises or 
at other locations such as on public roads. We 
investigate and report openly on our findings 
in the case of fatalities within our reporting 
boundary (see page 70), including instances 
where we conclude that our safety controls did 
not function as intended or that they could have 
been enhanced.
44
Supply chain integrity
Safety
Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix
Human rights
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

2
6
3
10
1
Total recordable fatalities 
2019*
2017
2018
Suppliers’ employees/contractors
Members of the public
 
0
2
4
6
8
10
12
14
Recordable fatalities by cause
2019*
2017
2018
0
2
4
6
8
10
12
14
Vehicle accident
Electrocution
Falling object
Criminal activity
 
10
4
3
1
1
1
1
1
2019*
2017
2018
India
Vodacom**
Egypt
Turkey
Ghana
 
Recordable fatalities by country
8
3
4
2
1
1
1
1
1
0
2
4
6
8
10
12
14
* There are three fatal incidents which include a 
number of fatalities that are still under investigation 
and cannot be included in our figures until the 
investigations are complete; a fatal incident in Italy 
from FY 2017/18 that happened on 29 March 2018 
is still under investigation by national authorities; a 
fatal incident in Turkey on 18 April 2018 is currently 
under investigation by national authorities; and 
a fatal incident in Turkey on 5 October 2018 is 
currently under investigation by national authorities. 
Data includes fatalities from India up until 1 
September 2018.
** Vodacom markets include South Africa, the 
Democratic Republic of Congo, Lesotho, 
Mozambique and Tanzania.
Fatalities 
It is with deep regret that we report two 
fatalities during the past year. Both occurred 
under circumstances in which, after 
investigation, we concluded that our supplier 
controls were breached or were not operating 
effectively. Specifically:
–	 A contractor died in a vehicle-related incident 
in Egypt. His vehicle was in a collision with 
a heavy goods vehicle. The contractor was 
speeding at the time.
–	 A contractor died while trying to free a 
trapped fibre cable during a fibre-laying 
operation in Mozambique. The fibre was 
being run up electricity poles when it 
became caught in a tree. The contractor 
used a metal ladder to try to free the cable 
and was electrocuted.
We thoroughly investigated the causes of 
each fatal incident and defined actions to help 
prevent a recurrence of a similar incident. These 
investigations are overseen by the respective 
local market Chief Executive, who is responsible 
for ensuring that the causes of the incident 
are widely understood and that any necessary 
corrective actions are implemented. We also 
share the lessons learned from each fatality 
across the relevant Group functions. These 
discussions take place at the most senior levels 
and at Group-wide safety conferences, held six 
times a year.
High-potential incidents (HPIs)
We track and investigate HPIs – incidents that 
do not necessarily result in injury but have the 
potential to do significant harm. We investigate 
each HPI as an indicator of the potential for a 
more serious accident. We seek to identify the 
root cause and take suitable corrective action, 
where necessary. An investigation is undertaken 
into an HPI at a scale proportionate to the 
indicative level of risk.
During the year we recorded 999 HPIs, of which 
146 involved employees, 174 involved suppliers’ 
employees or contractors, 13 involved members 
of the public and 666 were infrastructure related. 
Lost-time incidents (LTIs)
LTI is the term we use when a Vodafone 
employee is injured while carrying out a work-
related task and is consequently unable to 
perform his or her regular duties for a complete 
shift or period of time after the incident. We do 
not track LTIs for our suppliers’ employees and 
contractors.
In recent years, we have stepped up our 
efforts to capture and analyse all incidents 
of potential or actual harm to our employees. 
Greater compliance with mandatory rules on 
LTI reporting enables us to identify emerging 
trends in operating risks, increasing our scope 
to intervene and put the necessary controls in 
place. This year, our overall reported LTI rate 
remained at 0.62 per 1,000 employees.
Lost-time incidents (employees only)
2017
2018
2019*
Number of lost-time 
incidents
86
64
64
Lost-time incident rate 
per 1,000 employees
0.81
0.62
0.62
* Data includes LTIs from India up until 1 September 2018.
45
Supply chain integrity
Safety
Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix
Human rights
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

Human rights
Respect for human rights, together with 
established processes to reduce the 
risk of human rights abuses, is critical 
to our long-term success. Vodafone’s 
Code of Conduct is very clear about 
our expectations and responsibilities 
regarding human rights. 
We recognise our responsibility to respect the 
rights and freedoms of every individual who 
works for us, either as an employee or through 
our supply chain, and of the communities 
close to our operations. We adhere to our 
responsibility to respect human rights as set 
out in the International Bill of Human Rights 
and the eight International Labour Organization 
fundamental conventions on which the United 
Nations Guiding Principles on Business and 
Human Rights are based.
Our approach to managing 
human rights issues
We have identified the most salient human 
rights risks that matter the most for Vodafone’s 
operations and supply chains. We have 
established policies, governance and due 
diligence processes to avoid, reduce and 
mitigate these risks. These processes and 
policies, along with details on our governance 
model on human rights issues, are summarised 
on our website.
  Further details on our human rights 
due diligence process and overall 
approach can be found online at 
www.vodafone.com/humanrights
Our most salient human rights risks
Privacy and freedom of expression 
Our most salient human rights risks relate to 
the individual’s right to privacy and freedom of 
expression. Our Digital Rights and Freedoms 
Reporting Centre contains information related 
to the protection of our customers’ private 
communications and our views, policies and 
approach regarding:
–	 Law Enforcement Disclosure;
–	 Customer Privacy;
–	 Respecting the Digital Rights of the Child;
–	 Freedom of Expression and Network 
Censorship; and
–	 our Legal Annexe, which gives an overview 
of the relevant legal powers in place in our 
markets of operation.
GNI assessment
As part of our membership of the GNI, we 
must commit to implement the GNI Principles, 
putting concrete measures in place to 
protect and advance freedom of expression 
and the right to privacy. All GNI companies 
undergo an independent assessment of their 
implementation of the Principles every two 
years, to demonstrate their efforts in practice.
We started preparations for our first 
independent assessment in August 2018 by 
setting up a team of senior level experts from 
across the business and across our operating 
markets to participate in the required 
interviews, evidence collection and report 
writing. We continued this work until the 
March 2019 Board review meeting, working 
together with our independent assessor, 
who reviewed our processes, policies and the 
governance model that we use to safeguard 
our user’s rights to freedom of expression and 
right to privacy, to ensure all relevant areas 
were covered.
Vodafone completed its first formal GNI 
assessment in March 2019, during which the 
Board reviewed a detailed report on Vodafone 
and determined that we are making good faith 
efforts to implement the GNI Principles with 
improvement over time.
We will issue a public report on any related 
recommendations in early 2020, following  
the release of the formal GNI report on the 
2019 assessments.
In 2017, we joined the Global Network Initiative 
(GNI) as a Board member. The GNI is a multi-
stakeholder forum created to address the 
complex challenge of protecting digital 
rights globally. Joining the GNI strengthened 
and broadened our commitment to digital 
rights and followed our founding role in the 
Telecommunications Industry Dialogue on 
Freedom of Expression and Privacy.
The GNI brings together information and 
communications technology companies, 
civil society groups (including human rights 
and media freedom groups), academics 
and investors with a shared commitment to 
promote and advance freedom of expression 
and privacy worldwide.
The Ranking Digital Rights Corporate 
Accountability Index ranks Vodafone annually 
on its public disclosure on its policies and its 
  For more information on the 
GNI company assessments visit 
www.globalnetworkinitiative.org/
company-assessments.
practice on freedom of expression and privacy. 
In 2018, Vodafone Group received the top score 
in the telecommunications sector.
We are also actively engaged in the dialogue 
on emerging technologies and their potential 
impact on human rights. As artificial 
intelligence (AI) grows in usage and impact 
across geographies and industries, Vodafone 
has a responsibility to consider how our use 
of this technology affects our customers, our 
employees and wider society. We will shortly 
publish our Vodafone AI Framework, which 
outlines our approach to protecting consumers 
from discrimination and taking an ethical 
approach to artificial intelligence. We will 
indicate when customers are interacting directly 
with artificial intelligence. Our framework also 
includes how we extend our standards to third 
parties developing AI systems in collaboration 
and on behalf of Vodafone. 
46
Vodafone Group Plc Sustainable Business Report 2019
Safety
Human rights
Introduction
Transformation
Operating responsibly
Our people
Appendix
Supply chain integrity
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

Human rights risks in our supply chain 
Vodafone has developed and implemented 
policies and processes to extend our human 
rights commitments into our supply chain, 
as specified in our Code of Ethical Purchasing. 
The Code sets out the standards we expect our 
suppliers to meet on health and safety, labour 
(including child or forced labour) rights, ethics 
and environmental protection.
  Read more on our approach to supply 
chain integrity on page 37.
Working with others to tackle 
modern slavery
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 remain 
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. 
The following provides some examples of how 
we have engaged on this issue during the year.
i.	 Business Against Slavery Forum: 
UK Home Office
	
During the year, Vodafone’s Human Rights 
team engaged with other companies on 
the issue of modern slavery through its 
participation in the Home Office’s Business 
Against Slavery Forum working group. This 
group was established as a partnership 
between government and business to 
accelerate progress in the fight against 
modern slavery and to create and facilitate 
the sharing of best practice. Vodafone 
continues to be actively involved in this 
working group in 2019. 
	
In October 2018, Vodafone provided input 
into the independent review of the Modern 
Slavery Act 2015, chaired by Baroness Young. 
The roundtable discussion gathered the 
views and expertise of the private sector 
on the operation and effectiveness of, and 
potential improvements to, provisions in 
the Modern Slavery Act. Vodafone is also 
a member of the Transparency in Supply 
Chains Advisory Group, which supports 
the Government’s modern slavery agenda 
and is one of six groups that feed into the 
Home Office’s Modern Slavery Strategy and 
Implementation Group. Vodafone UK’s CEO, 
Nick Jeffery, is also a member of the UK 
Home Office’s Business Against Slavery 
CEO Forum, which facilitates senior-
level private sector engagement on the 
implementation of the Modern Slavery 
Act in large FTSE companies.
ii.	 Tech Against Trafficking (TAT)
	
This year, Vodafone became a member of the 
Tech Against Trafficking (TAT) initiative. Hosted 
by Business for Social Responsibility (BSR), 
TAT is a coalition of technology companies 
collaborating with global experts to help 
eradicate human trafficking using technology. 
	
TAT’s goal is to work with civil society, law 
enforcement, academia and survivors to 
identify and create technology solutions 
that disrupt and reduce human trafficking, 
prevent and identify crimes, and provide 
remedy mechanisms for victims and support 
survivors through innovation, collaboration, 
guidance and shared resources.
iii.	 Joint Money Laundering Intelligence 
Taskforce (JMLIT) 
	
The JMLIT has been developed in partnership 
with the UK government, law enforcement 
agencies and more than 40 major UK and 
international banks under the leadership 
of the Financial Sector Forum. Vodafone 
shared its approach to modern slavery and 
the company’s e-learning training module at 
the JMLIT Expert Working Group on Human 
Trafficking and Organised Crime. 
  Further details on our approach and 
policies relating to modern slavery 
can be found in our Slavery and Human 
Trafficking Statement.
Employee reporting 
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 or processes 
and therefore a breach of our Code of Conduct. 
Employees are encouraged to use our Speak 
Up process to report a wide range of unlawful 
and unethical activities, including bribery, 
fraud, price-fixing, suspected abuses of human 
rights, privacy breaches, safety risks, bullying, 
harassment, conflicts of interest and the 
potential for serious harm to the environment.
Employees can report suspected breaches 
in three ways:
–	 via their line manager;
–	 via the local human resources team; or
–	 via a confidential external hotline in their 
own language, by phone or online.
Our Group Risk and Compliance Committee 
reviews reports about the effectiveness of the 
Speak Up process and benchmarks it against 
those used by other multinationals. You can 
read more about Speak Up on page 50.
Highlights in our supply chain 
activities to mitigate human rights 
risks during the year:
–	 we launched a common industry 
supplier academy to build 
capability; 
–	 we joined new multi-stakeholder 
coalition Tech Against Trafficking 
(TAT), which is focused on modern 
slavery issues; and 
–	 we conducted an investigation into 
a modern slavery grievance. 
47
Vodafone Group Plc Sustainable Business Report 2019
Safety
Human rights
Introduction
Transformation
Operating responsibly
Our people
Appendix
Supply chain integrity
Mobiles, masts and health
Privacy and cyber security 
Anti-bribery and corruption and political engagement

Anti-bribery and corruption
Our anti-bribery policy
Vodafone does not tolerate bribery or corruption 
in any form. Our policy is summarised in our 
Code of Conduct. It states that employees or 
others working on our behalf must never offer or 
accept any kind of bribe. Our anti-bribery policy 
is consistent with the UK Bribery Act and the US 
Foreign Corrupt Practices Act and any breaches 
can lead to dismissal or termination of contract.
The policy provides guidance about what 
constitutes a bribe and prohibits the giving
 or receiving of any excessive or improper gifts 
and hospitality. It also makes clear that where 
our policy differs in degree from an equivalent 
local law, we must follow the more stringent of 
the two.
Governance and risk assessment 
Our Group Chief Executive and Group Executive 
Committee (ExCo) oversee Vodafone’s work 
to prevent bribery and corruption. They are 
supported by local market Chief Executives, who 
are responsible for ensuring that our anti-bribery 
programme is implemented effectively in their 
local market. Local specialists and a dedicated 
Group team that is solely focused on anti-bribery 
policy and compliance support them in turn.
As part of our anti-bribery programme, every 
Vodafone business must adhere to minimum 
global standards, which include:
–	 ensuring there is a due diligence process for 
suppliers and business partners at the start 
of the business relationship;
–	 completion of the global e-learning training 
for all employees, as well as tailored 
classroom training for higher-risk teams; and
–	 using Vodafone’s global online gift and 
hospitality registration platform, as well as 
ensuring there is a process for approving local 
sponsorships and charitable contributions.
In addition, facilitation payments are strictly 
prohibited by our policy. Employees are provided 
with practical guidance on how to respond to 
demands for facilitation payments. The only 
exception is when an employee’s personal safety 
is at risk. In such circumstances, when a payment 
is made under duress, the incident must be 
reported to the local compliance team as soon as 
possible afterwards.
Local markets regularly monitor implementation 
of the anti-bribery policy as part of the annual 
Group Policy Compliance Review assurance 
process, which reviews key anti-bribery controls. 
In addition, rotating reviews in local markets 
enable us to assess the implementation of 
the anti-bribery programme on the ground in 
more detail. This year, reviews were conducted 
in Turkey and Hungary. The Group Policy 
Compliance Review also included a desktop 
review in all local markets. The overall findings 
demonstrated good implementation of key 
controls and processes. Areas for improvement 
related to supplier management and monitoring, 
and these are being addressed. 
Vodafone’s Risk and Compliance Committee 
assists the Group ExCo to fulfil its accountabilities 
with regard to risk management and policy 
compliance. The anti-bribery programme was 
one of the compliance programmes reviewed 
by the Risk and Compliance Committee during 
the year. The output of the Risk and Compliance 
Committee meeting is reported to the Group 
ExCo. The key actions are documented for the 
programme for the coming year in the bribery risk 
‘line of sight’ report, which is updated regularly by 
our General Counsel.
The table overleaf summarises the principal risk 
categories and the mitigation measures 
we take for each.
Vodafone does not 
tolerate bribery or 
corruption in any form.
48
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Anti-bribery and corruption and political engagement
Introduction
Transformation
Operating responsibly
Our people
Appendix
Safety
Supply chain integrity
Mobiles, masts and health
Privacy and cyber security

Risk
Response
High-risk markets 
We operate in a number of countries where there is a heightened risk of bribery and corruption.
We undertake biennial risk assessments in each of our local operating companies and at Group level 
so we can understand and limit our exposure to risk. The principal risk categories are included below.
Business acquisition and integration 
When we acquire or merge with another entity, we risk inheriting its potential bribery and corruption 
risks. These may persist if we do not identify and promptly address them.
Our due diligence process before any decisions to acquire, or merge with, another entity takes into 
account its current and past anti-bribery and corruption processes and performance. Red flags 
identified during the due diligence are reviewed and assessed. Following any acquisition, we implement 
our anti-bribery programme.
Spectrum licensing  
Communications operators require access to sufficient radio spectrum to deliver mobile and some 
fixed-line services. Spectrum is a limited sovereign resource and therefore valuable. Whenever 
governments allocate spectrum to operators there is a risk of bribery.
We encourage governments and regulators to release spectrum to the market through competitive, 
transparent and well-managed auctions. A specialist policy team oversees our participation in all 
negotiations and auctions to reduce the risk of attempted bribery. We provide appropriate training 
and guidance for employees who interact with government officials on spectrum matters. We have 
also published our ‘Spectrum policy in emerging markets’ report, which provides further support for 
employees in these markets.
Building and upgrading networks 
Communications networks are infrastructure intensive. They require access to, and leasehold 
arrangements on, both public and private land. We currently have more than 164,000 mobile base-
station sites across multiple countries, and ensuring we can maintain and upgrade them requires 
constant engagement with landowners, community leaders and municipal authorities. 
This engagement must be undertaken in compliance with our anti-bribery policy.
Our anti-bribery policy makes it clear that we never offer any form of inducement to secure a permit, 
lease or access to a site. We regularly remind all employees and contractors in network roles of this 
prohibition, through tailored training sessions and communications.
Working with third parties 
Our supply chain is complex, involving more than 10,800 vendors, contractors and sub-contractors. 
As a result, there is a risk of improper conduct when third-party services are procured and delivered, 
particularly in countries where corruption is endemic.
Everyone who works for or on behalf of Vodafone, including suppliers and other relevant third 
parties, must comply with the business principles set out in our Code of Conduct and Code of Ethical 
Purchasing. Select high-risk third parties are trained to ensure awareness of our zero-tolerance policy.
We screen our potential suppliers for anti-bribery compliance and ensure they understand our anti-
bribery policy. We regularly remind current suppliers of our policy requirements and complete detailed 
compliance assessments across a sample of higher-value and higher-risk suppliers.
Winning and retaining business 
Vodafone Business accounts for around 30% of our global revenues. We serve some of the world’s 
largest companies and public sector organisations. Competitive tenders are how Vodafone Business 
contracts are appointed and there is a risk that improper inducements may be sought or offered 
by either party. Vodafone also partners with local operators across the world, with alliances with 28 
partners in over 41 countries.
In addition to the mandatory anti-bribery and corruption training completed by all Vodafone 
employees, we provide mandatory targeted training for our Vodafone Business and Partner Markets 
sales teams and other employees in higher-risk roles. In addition, we also maintain and monitor a global 
register of gifts and hospitality to ensure that inappropriate offers are neither accepted nor extended by 
our employees.
49
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Anti-bribery and corruption and political engagement
Introduction
Transformation
Operating responsibly
Our people
Appendix
Safety
Supply chain integrity
Mobiles, masts and health
Privacy and cyber security

Supporting a compliance culture in Lesotho
In October 2018, Vodacom Lesotho held 
its first Annual Compliance Forum, with 
the objective to create a platform for 
sharing experiences on compliance issues 
such as anti-bribery, anti-corruption, 
anti-money laundering and ethical 
leadership. Attendees at the Forum included 
representatives from the government 
(including the Minister of Communications), 
other businesses, the Central Bank of 
Lesotho, non-governmental organisations 
and local media.
To demonstrate the importance of the topic 
for Vodacom Lesotho, members of our 
local executive committee participated in a 
number of different panel discussions during 
the day including sharing our approach to 
mitigate risks associated with bribery, privacy 
and money laundering. 
Engaging employees to raise 
awareness of bribery risk
Every Vodafone employee has an obligation 
to help us address the risk of bribery and 
corruption. To ensure our employees understand 
how they can each play a part, we run a high-
profile communications programme, Doing 
What’s Right. This uses a range of materials to 
highlight some of the most common compliance 
challenges facing employees, including handling 
personal data, accepting gifts and conflicts of 
interests. The global campaign makes use of 
multiple communication channels to engage 
with employees and raise awareness and 
understanding of the policy, including digital 
news articles, games and quizzes.
The Doing What’s Right programme also features 
e-learning training, which includes a specific 
anti-bribery module and uses gamification to 
enhance the learning experience. To date, over 
90% of active employees around the world have 
completed the e-learning training1. In addition, 
for higher-risk employees, such as those working 
in procurement, network operations, Vodafone 
Business sales and government relations, 
tailored face-to-face training programmes are 
used to cover relevant scenarios.
Training in our Code of Conduct is incorporated 
into our standard induction processes for new 
recruits and all employees compete refresher 
training every two to three years.
Speak Up
All Vodafone employees are encouraged to 
report any suspected breaches of our Code of 
Conduct as soon as possible. We call our process 
for this Speak Up, and we make it as easy to use 
as we can for any kind of employee concern.
In most instances, employees feel comfortable 
about raising concerns with a line manager or 
human resources colleague. However, they 
can also use a confidential third-party hotline, 
accessible in their local language online or by 
telephone. Speak Up operates under a non-
retaliatory policy, meaning that everyone 
who raises a concern in good faith is treated 
fairly, with no negative consequences for their 
employment with Vodafone, regardless of the 
outcome of any subsequent investigation.
Senior executives review every Speak Up report 
and the Group Risk and Compliance Committee 
reviews the whole programme. This year, 738 
separate concerns were reported using Speak 
Up on a wide range of issues (though only a 
very small fraction were related to bribery and 
corruption). In our latest Global People Survey, 
84% of respondents said they would use Speak 
Up to report unethical behaviour of any kind.
Engaging suppliers and third parties 
Through their contracts with us, our suppliers, 
partners and other third parties make a 
commitment to implement and maintain 
proportionate and effective anti-bribery 
compliance measures. Every year, we review the 
anti-bribery controls put in place by a sample of 
suppliers. We do this in collaboration with them 
to ensure they understand what we expect, and 
to enable us to share best practice with them. 
This also gives us the opportunity to learn from 
our suppliers’ experiences in this area.
If our review highlights inadequacies, and 
assuming there is no immediate risk of improper 
conduct, we support the supplier involved to 
improve their practices and to ensure that these 
inadequacies are corrected appropriately.
Engaging civil society 
We want to play our part in tackling bribery and 
corruption along with other stakeholders who 
share our concerns and standards. We play an 
active role in the Transparency International 
Business Integrity Forum and the Institute of 
Business Ethics.
50
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Anti-bribery and corruption and political engagement
Introduction
Transformation
Operating responsibly
Our people
Appendix
Safety
Supply chain integrity
Mobiles, masts and health
Privacy and cyber security

Our approach to political engagement
At Vodafone, everyone who works for and 
with us must follow rules designed to reduce 
the risk of improper behaviour and the 
perception of such behaviour (even when this 
has not actually occurred) in dealings with 
politicians, civil servants, regulators, advisors 
and others involved regarding policy or 
government operations.
Vodafone’s Code of Conduct has specific rules 
regarding gifts, hospitality and sponsorship 
involving politicians and government officials 
and states that no political donations can be 
made. It also clearly states that Vodafone may 
not intervene in party political matters. We 
review relationships with government officials 
in our supplier on-boarding due diligence 
processes. We also provide specific anti-bribery 
and corruption training to employees whose 
roles involve interacting with policymakers 
and advisors.
Everyone must also abide by the rules 
governing political activity conducted in a 
personal capacity, as articulated in our Code of 
Conduct. Employees cannot use any Vodafone 
resources – from communications services 
and meeting rooms to their own working time 
– to provide support for any political campaign, 
political party, political candidate or any 
affiliated organisation. 
Why and how we engage politically
Interactions with ministers, opposition 
politicians, elected representatives, civil 
servants and independent statutory bodies, 
such as regulators and political or sector 
specialist advisors, are an essential part of 
managing our businesses around the world. 
Our discussions may include:
–	 the operating challenges that arise 
from obligations specified under the 
telecommunications licences awarded 
by governments, which we must operate 
lawfully;
–	 proposed legislation or new or amended 
regulations that would affect how we operate 
or would have an effect on our customers’ 
experience;
–	 spectrum matters;
–	 provision of communications services by 
Vodafone as a major supplier to government 
bodies and other public sector customers;
–	 security matters, particularly those focused 
on Vodafone’s role as an operator of critical 
national infrastructure;
–	 privacy and data protection matters 
(discussed in detail in our Digital Rights and 
Freedoms Reporting Centre);
–	 online child protection and the digital rights 
of the child (referred to in detail in our Digital 
Rights and Freedoms Reporting Centre);
–	 financial inclusion and mobile money 
services such as the M-Pesa service; and
–	 industrial policy and the growth of the IoT, 
including the development of intelligent 
networking across a wide variety of 
devices, services and processes in the 
home and workplace.
While we do use external political consultancies 
for internal advisory support and back-office 
activity such as monitoring of parliamentary 
debates, wherever possible, our strong 
preference is to ensure that Vodafone is 
represented in public policy and political 
meetings by senior individuals from within 
our businesses. 
When our interests are represented by a third 
party in a public policy or political meeting with 
no Vodafone executive present, the third party 
must comply with internal political engagement 
processes and approval mechanisms. We also 
maintain an internal register of any external 
parties who engage in policy discussions on 
our behalf.
Offers of hospitality for government 
representatives
When appropriate, we may invite government 
representatives to business meals or a hospitality 
event. We apply internal governance rules to 
invitations of this kind and those rules in our 
global Code of Conduct are strictly enforced.
Where a regulatory decision relating specifically 
to our business is under consideration or 
imminent, we expressly prohibit gifts and 
hospitality of any kind to any parties involved 
in making that decision. We also stipulate that 
every gift or offer of hospitality for a government 
representative, or sponsorship with government 
over the value of €100, must be approved (prior 
to acceptance) by our Group External Affairs 
Director, who is a member of the Vodafone 
Group ExCo.
Engaging with the EU institutional 
stakeholders
We actively engage with all EU institutions on 
the future of the digital economy in Europe, 
including the Digital Single Market. 
As a company with significant businesses in 
12 EU Member States, we believe we have the 
expertise and experience to comment on policy 
initiatives intended to drive economic growth 
and create better-quality services for customers 
across Europe.
This year Vodafone engaged with EU institutions 
on the main issues relating to the Digital 
Single Market, in particular when it comes to 
infrastructure regulation, platform regulation, 
cyber security and privacy. Examples include 
the following legislative proposals: 
–	 the European Electronic Communications 
Code, finalised in summer 2018, which 
provides the regulatory framework for all 
electronic communications networks and 
services across the EU; 
–	 the ePrivacy Regulation, which is still under 
negotiation and covers confidentiality of 
communications; 
–	 the Platform-to-Business Regulation, 
concluded in early 2019, which strengthens 
the fairness and transparency obligations of 
platforms; and
–	 the Cybersecurity Act, which creates a 
new EU-wide cyber security certification 
framework.
The Brexit negotiations were also a topic 
of engagement for Vodafone in Brussels.
 We disclose these political activities and
 related expenditure, as mandated, through 
the EU Transparency Register.
51
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Anti-bribery and corruption and political engagement
Introduction
Transformation
Operating responsibly
Our people
Appendix
Safety
Supply chain integrity
Mobiles, masts and health
Privacy and cyber security

1 This rate excludes employees in Germany due to local works councils restrictions.
Political engagement in Africa, 
Middle East and Asia-Pacific (AMAP)
During the year, in Vodafone’s AMAP region, 
Vodafone engaged with governments and 
regulators on a number of topics, including 
national ICT strategies, communications 
legislation consultations, spectrum policy, 
data, security, net neutrality, payments, SIM 
registration and consumer issues. This was 
mainly done through policy, legislative and 
regulatory consultation and decision-making 
processes conducted by such authorities in 
accordance with the applicable law. Examples 
of engagement during the year included: 
–	 supporting regulatory approvals for the 
merger between Vodafone India and Idea 
Cellular in August 2018, and Vodafone Idea 
rights issue in April 2019;
–	 the new National Digital Communications 
Policy issued by the Indian government in 
September 2018;
–	 the Electronic Communications Amendment 
Act Bill and ministerial policy directions on 
the wholesale open access network and 
high-demand spectrum assignment in 
South Africa; 
–	 a priority markets review and data pricing 
inquiry by South Africa’s communications 
and competition regulators respectively;
–	 radio spectrum auctions in Tanzania (July 
2018) and Mozambique (October 2018);
–	 Mozambique 2G and 3G service licence 
renewals in July 2018;
–	 the Communications Bill and 4G licence 
application in the Democratic Republic 
of Congo; 
–	 a parliamentary inquiry on telecoms and 
draft national broadband strategy in Kenya;
–	 the Vision 2030 ICT strategy in Egypt; 
–	 a regulatory application for the merger of 
Vodafone Hutchinson and TPG, and a 5G 
auction in Australia; and
–	 new communications legislation in 
New Zealand. 
Hiring former public servants
Vodafone recognises that potential (or perceived 
potential) conflicts of interest can arise 
when Vodafone or its subsidiaries hire people 
whose most recent prior employment was in 
a government or other public sector role. The 
potential for a perceived or actual conflict of 
interest is particularly acute if the individual is 
employed subsequently by Vodafone to work 
on projects that are directly relevant to their 
previous role.
We believe that every individual should be free 
to apply their skills – and choose who they work 
for – as they see fit. However, we also believe 
it is important to have rules in place to ensure 
that former government or other public sector 
employees do not have undue influence over, 
or inappropriate levels of access to, their former 
colleagues on relevant issues.
Our Revolving Doors Statement provides a 
mandatory global approach that prohibits former 
government or other public sector employees 
from working on projects for Vodafone that are 
relevant to their former role, from engaging 
directly with any former colleagues, or from 
interacting directly with departments or other 
bodies with which they worked in their previous 
role. This formal ‘cooling-off’ period lasts a 
minimum of six months or for the duration of 
any local market government or public sector 
‘purdah’ rules, whichever is the longer, and 
applies to all employees at all levels.
52
Human rights
Vodafone Group Plc Sustainable Business Report 2019
Anti-bribery and corruption and political engagement
Introduction
Transformation
Operating responsibly
Our people
Appendix
Safety
Supply chain integrity
Mobiles, masts and health
Privacy and cyber security

Privacy and cyber security
Vodafone has strict governance 
processes and controls in place to 
protect our customers’ personal data, 
respect their privacy and proactively 
manage the cyber security risks that 
face businesses today.   
Our commitment to privacy and security is a 
vital part of our responsibility to our customers 
and is central to our Code of Conduct that 
everyone who works for us and on our behalf 
must follow. 
This chapter contains information on our privacy 
and cyber security programmes and the policies 
that govern how we collect, use, manage and 
protect our customers’ personal data.
Privacy 
We believe that everyone has a right to privacy, 
wherever they live in the world. That is why 
Vodafone applies a global approach to 
managing privacy. 
We know that respecting our customers’ privacy 
is essential to maintaining their trust in our 
business. Managing privacy risks effectively 
– and putting customers in control of their 
data – is core to our approach. Our privacy 
programme governs how we collect, use and 
manage our customers’ personal data to make 
sure we respect the confidentiality of their 
communications and any choices that they have 
made regarding the use of their data. 
Privacy policies
Two privacy policies underpin Vodafone’s 
programme and approach and help to 
make sure we address specific areas of high 
privacy risk. The Group ExCo oversees the 
implementation of these policies.
1.	 Privacy Management Policy
	
This policy sets out the resources and 
privacy risk control processes that must 
be in place in each of our local markets to 
ensure compliance with applicable local 
data protection and privacy laws and with 
Vodafone’s privacy programme. 
2.	 Law Enforcement Assistance Policy 
	
This policy addresses the balance between 
our customers’ right to privacy and freedom 
of expression and the statutory requirements 
Our privacy programme is underpinned by 10 privacy ‘commandments’ that go beyond legal 
compliance and drive how we develop and operate our products and services in a way that 
respects our customers’ privacy and the trust they place in us:
Design for privacy
Incorporate privacy and security into 
the design of products and services, 
and manage risks.
Collect relevant data
Only collect and process data that 
is necessary and relevant for the 
purposes for which it was collected.
Protect confidentiality
Protect confidentiality of 
communications and sensitive 
personal information.
Provide a privacy notice
Provide a clear, transparent and 
understandable privacy notice.
Provide choices
Obtain and manage necessary 
permissions when using the content of 
communications, traffic data, location 
data and marketing and analytics.
Manage data carefully
Maintain data quality, delete 
unnecessary or outdated data and 
do not take unnecessary copies.
Respect individual rights
Design products to allow individuals to 
exercise their right to access, request 
deletion and portability.
No unauthorised disclosures
Do not disclose personal data to 
unauthorised bodies and make sure 
suppliers comply with Vodafone’s 
privacy and security requirements.
Secure data
Apply technical and organisational 
controls against unauthorised access, 
use, disclosure or loss.
Protect children’s privacy
Protect children’s data and, where 
necessary, acquire parental consents.
to provide law enforcement assistance 
to government agencies and authorities, 
through either lawful interception or 
retention of communications data.
Our Digital Rights and Freedoms Reporting
Centre contains additional information 
related to the protection of our customers’ 
privacy, in our privacy disclosure, and the 
actions of government agencies and 
authorities to ensure public safety, in our 
law enforcement disclosures.
A globally consistent 
approach to privacy 
Vodafone’s privacy programme applies a 
global, high standard to managing privacy 
challenges irrespective of whether there 
are local data protection or privacy laws.  
Managed across Vodafone markets 
both inside and outside the European 
Economic Area, Vodafone’s privacy 
management policy is based on the 
European Union General Data Protection 
Regulation. 
Vodafone’s privacy management policy 
sets a framework within which local data 
protection and privacy laws are respected, 
and sets a baseline for those markets 
where there are no such specific legal 
requirements.
53
Vodafone Group Plc Sustainable Business Report 2019
Privacy and cyber security 
Anti-bribery and corruption and political engagement
Introduction
Transformation
Operating responsibly
Our people
Appendix
Human rights
Safety
Supply chain integrity
Mobiles, masts and health

Cyber security
Using a combination of fixed, mobile and cloud and 
hosting services, we provide high-quality, reliable 
and secure networks that are relied on by our 
customers around the world. Our approach to cyber 
and information security makes sure our processes, 
procedures, programmes and people safeguard the 
security and privacy of our customers’ information 
across Vodafone. Our security controls are layered 
and integrated by design.
Risk management is central to our approach and 
is fundamental to maintaining the security of our 
services across every aspect of our business. To 
help us identify and manage emerging risks, we 
assess our business strategy, new technologies, 
government policies and regulation and cyber 
threats. We conduct regular reviews of the most 
significant security risks affecting our business 
and develop strategies to detect, prevent and 
respond to them.
Building on best practise from a range of 
expert organisations and initiatives from 
around the world, our cyber security policies 
and programmes are applied across our entire 
telecoms network and IT systems. Against these 
policies and programmes the principles of the 
ISO 27001 standard are applied, to which our 
core data centres and networks are certified. 
Our security systems and processes are 
continually updated and monitored to prevent, 
detect, deter and respond to cyber threats. We 
invest in our technologies and embed security 
into all of our products and services from the 
outset. We test our mobile network security 
controls with an independent third party to make 
sure they are effective.
We also run global awareness campaigns. In 
2019, we launched the Vodafone Cyber Code 
(see page 55), which has been designed to 
simplify and explain the basic security controls 
to all employees. Embedded in our Code of 
Conduct, the Cyber Code is the cornerstone of 
how we expect all employees to behave when it 
comes to best practice in cyber security. 
Our vision is a secure digital future for our 
customers, which is why we employ people with 
specialised cyber security expertise around the 
world. This vision drives a focus on protecting our 
services, products, systems and data via a single 
and integrated cyber security programme, in 
order to maintain the security of our customers’ 
privacy and personal information.
Cyber security policies
Vodafone’s approach to cyber security is 
underpinned by a portfolio of policy principles 
that include the following.
–	 Doing what is right when using Vodafone 
information and equipment in order to 
protect ourselves, our company and, most 
importantly, our customers. 
–	 Making sure that we, and anyone we manage, 
only have access to the information and 
assets we require in order to perform our 
roles.
–	 Securing our information and systems at 
least as strongly in the cloud as we do on-
premise.
–	 Reporting any suspected malicious or 
unauthorised activity through local or 
Group security teams so this can be managed 
and remediated.
Outlining our approach to privacy:  
Our privacy approach is governed by an 
unwavering respect for an individual’s right 
to privacy. From ownership and oversight by 
senior management to robust assurance, 
elements include:
Accountability
A member of the Group ExCo oversees 
Vodafone’s privacy programme. A global 
privacy officer, ultimately reporting to 
ExCo, manages the programme at Group 
level. At a local level, accountability for the 
implementation of the privacy programme 
sits with the local operating company. Each 
market has a local ExCo-level owner and a 
privacy officer tasked with implementing the 
programme locally, with a dotted line to the 
global privacy officer. 
Group and local operating companies each 
have a privacy steering committee that 
brings together privacy and security teams, 
and a senior person from each of the relevant 
business departments (e.g. commercial, 
technology, HR and finance). Detailed 
key performance indicators are reported 
regularly to senior management. 
Assurance
Each Vodafone entity has numerous systems 
for processing personal data and all high-risk 
processes are subject to regular testing. New 
products, services and operations undergo 
privacy by design and assurance processes 
to make sure that possible privacy risks are 
identified and mitigated. Detailed personal 
data processing registers and data-retention 
practices are maintained and updated 
continuously. Our supplier compliance 
processes mean we only appoint suppliers 
that meet our privacy standards. 
Transparency
Our privacy notices provide straightforward, 
easy to understand and relevant information 
to our employees and customers. Our 
permission management platforms enable our 
customers to control how Vodafone uses their 
data. We also publish extensive information 
about our approach to managing governments 
requests for access to customer data.
Human-centred decision making
Big data analytics use cases are subject to 
privacy and ethics reviews to identify and 
mitigate possible privacy or data ethics 
challenges. Data scientists sign up to our Code 
of Ethics for Analysts before they are given 
access to our analytics platform. When we 
are required to balance the right to privacy 
against other obligations in support of a free 
and secure society, we work to minimise 
privacy impacts. 
Engagement
We actively engage with stakeholders, 
including civil society, academic institutions, 
industry and government, in order to share 
our expertise and best practices with others, 
to contribute to the discussions that shape 
public policy and to learn from others. 
54
Vodafone Group Plc Sustainable Business Report 2019
Privacy and cyber security 
Anti-bribery and corruption and political engagement
Introduction
Transformation
Operating responsibly
Our people
Appendix
Human rights
Safety
Supply chain integrity
Mobiles, masts and health

Elements of our cyber security 
approach: 
Our cyber security approach focuses on 
minimising the risk of cyber incidents that 
affect our networks and services.  We take a 
multi-layered approach to security to keep 
our employee and customer information safe. 
We implement controls that prevent attackers 
from gaining access through our perimeter, 
and also protect our internal network, 
applications and data with specific measures 
including encryption and restricting access. 
Our approach includes:
Defence
No organisation will ever be immune to 
cyber attacks.  A key part of a strong cyber 
security programme is the ability to prevent 
the majority of attacks and quickly detect 
and respond to attacker activity. Vodafone 
faces threats similar to any large company 
that holds customer data. However, there 
are also specific threats that relate to the 
telecommunications industry and different 
geographic locations. We build our networks 
to defend against attack so our customers 
can trust that our networks are secure, fast 
and high quality. We also make sure we build 
diversity into our networks and services to 
avoid reliance on any one supplier. 
Workforce user controls
We apply user controls to our whole workforce. 
This includes data loss prevention, anti-
malware, endpoint protection and detection, 
building security and phishing protection. 
Our Cyber Code helps to drive the appropriate 
employee culture and highlights the 
behaviours they need to display in order to 
support our cyber security programme.  
Network
Our focus has been to secure our existing 
2G, 3G and 4G network and systems, and 
we independently test the security of our 
networks every year. With the launch of 5G 
taking place in Europe this year, we are working 
to deploy 5G securely by building on our 4G 
experience. With greater security by design 
features, 5G will offer a similar or better level 
of protection than equivalent features in 4G 
when it comes to protecting customers from 
interception, impersonation and location 
tracking. 
Security by design
We apply our security policy, including 
technical and procedural standards, wherever 
we build and deploy new solutions (security 
by design). For secure IoT solutions, Vodafone 
has helped establish the GSMA IoT Security 
Guidelines, and the accompanying self-
assessment scheme. Where we work with 
partners or third parties to build and deploy 
IoT solutions, we advocate the approach 
taken and co-developed between Vodafone 
and Consumers International, as seen in their 
publication of the Consumer IoT Trust by 
Design Guidelines.
Engagement
We actively engage with stakeholders, 
including civil society, academic institutions, 
industry and government, in order to protect 
Vodafone, respond to cyber threats and work 
together to share best practice. Given our 
expertise and extensive experience, we also 
engage with a wide range of organisations 
to help improve the understanding of cyber 
security thinking and practice, and contribute 
to public policy, defence operations, technical 
standards, information sharing and analysis, 
risk assessment and governance. 
Vodafone Cyber Code 
Always use multi-factor 
authentication for remote 
systems that hold sensitive 
information.
Never allow unsupported 
end-of-life systems in 
Vodafone infrastructure, 
or release insecure products 
or services.
Always apply the latest 
security patches, close critical 
and high vulnerabilities and 
configure systems securely.
Never click on links 
or download without knowing 
who it is from. Report 
suspicious behaviour.
Always remove access when 
staff change roles or leave 
Vodafone. Secure privileged 
access and only use it for 
privileged tasks.
Never share or reuse 
your passwords. 
Longer is stronger.
Always classify, label 
and protect information 
you work with.
–	 Considering the content of all information 
we handle, labelling the information with the 
correct classification and applying protection 
according to the classification level.
–	 Making sure that anyone physically 
accessing our property is authorised 
to do so.
–	 Considering and integrating security into 
all new/updated projects, processes or 
technology with which we are involved.
–	 Being aware of any risks to the information 
and systems we use, and working in a way 
that minimises this risk.
–	 Holding our suppliers to the same policies 
for protecting Vodafone information as the 
ones to which we hold ourselves. Making sure 
we work with technology and security teams 
to identify the requirements that apply to 
each supplier.
–	 Implementing strong general security 
practices to:
	
- capture and monitor activity logs 
to identify malicious or unauthorised 
behaviour;
	
- apply patches to remediate vulnerabilities 
and keep software up to date;
	
- configure systems in a way that reduces 
security risks, e.g. by carrying out hardening 
or installing anti-malware tools; and
	
- secure the connections between systems, 
both internally and externally, to protect 
communications from unauthorised access 
or modification.
55
Vodafone Group Plc Sustainable Business Report 2019
Privacy and cyber security 
Anti-bribery and corruption and political engagement
Introduction
Transformation
Operating responsibly
Our people
Appendix
Human rights
Safety
Supply chain integrity
Mobiles, masts and health

Mobiles, masts and health
The health and safety of our 
customers, the wider public, our 
employees and our contractors is 
an absolute priority for Vodafone.
Mobile devices use radio waves to send and 
receive calls and data from a network of 
base stations. These radio waves are a type 
of electromagnetic field (EMF). They occur 
naturally or are produced from man-made 
sources and are around us all the time. They 
are produced by any electrical appliance 
connecting to the mains power supply and 
switched on. Most experts agree that there 
is no evidence that mobile phones or base 
stations adversely affect human health when 
operated within international science-based 
guideline compliance limits1.
Our vision
Vodafone’s vision is to lead within the industry 
in responding to public concerns about mobile 
phones, masts and health, by demonstrating 
leading-edge practices and encouraging 
others to follow. Through our Group-wide risk 
management and compliance assessment and 
our local community engagement, together 
with coordinated regular best practice sharing 
through the year, we ensure that we deliver on 
our commitments.
International science-based guidelines
Our base stations and the mobile devices we 
supply to our customers operate according 
to the guidelines set by the International 
Commission on Non-Ionizing Radiation 
Protection (ICNIRP), an independent advisory 
body that works in collaboration with the World 
Health Organization (WHO). These guidelines 
are science based and include substantial safety 
margins. They are regularly reviewed and reflect 
decades of research.
In 2018, ICNIRP concluded a review of the 
EMF-related science published since its last 
exposure guidelines were produced (in 1998). 
In its draft, published for public consultation 
in July 2018, it makes recommendations to 
account for new types of exposure scenarios and 
improved scientific assessment accuracy. Based 
on the conclusions of many independent expert 
reviews, it remains the case that no health risk 
has been established for mobile devices or base 
stations that comply with ICNIRP guidelines. The 
review covers all the frequencies allocated to the 
delivery of new 5G services. The publication of 
the final ICNIRP guidelines following the public 
consultation is expected in 2019. 
Vodafone complies with national regulations in 
all markets and will continue to do so across the 
range of new devices for 5G, new radio masts 
and small cells. Despite the current scientific 
consensus, we recognise that some people are 
concerned about mobiles, masts and health. 
We always endeavour to address their concerns 
openly and transparently through regular local 
community engagement and sharing the latest 
research on our website.
5G and EMF 
With the development of 5G technology and its 
commercial launch during 2019, we have been 
working across the industry to ensure that new 
technology continues to be compliant with 
national regulations and international (ICNIRP) 
guidelines for EMF. 
It is important to note that the frequencies 
proposed for 5G are covered by existing 
international and national RF-EMF exposure 
guidelines. These international guidelines 
are based on extensive reviews of published 
scientific research. They apply to 5G just as they 
do to existing 2G, 3G and 4G technologies and 
other radio frequencies such as radio and 
TV transmissions. 
A number of national government health 
advisory bodies (in Germany, Finland, Norway 
and the UK) have reviewed the science relating 
to 5G and published statements. These state: 
–	 ICNIRP guidelines apply up to 300 GHz, well 
beyond the maximum frequencies under 
discussion for 5G;
–	 electromagnetic fields from base stations will 
not rise significantly with the introduction of 
5G. Overall exposure is expected to remain 
low in relation to the guidelines and so there 
are no consequences for public health; and
–	 as long as the levels set by ICNIRP are 
adhered to, the overall research shows 
that electromagnetic fields from mobile 
technology are not hazardous to 
human health.
One health authority, the German Federal Office 
for Radiation Protection, has recommended 
that more research is needed into millimetre 
wave range.
56
Vodafone Group Plc Sustainable Business Report 2019
Mobiles, masts and health
Privacy and cyber security 
Introduction
Transformation
Operating responsibly
Our people
Appendix
Anti-bribery and corruption and political engagement
Human rights
Safety
Supply chain integrity

Monitoring scientific research
We have a science-monitoring process and 
regularly review research conducted into 
mobiles, base stations and health. On our 
website and in our reports, we focus on research 
that is designed, carried out and reported 
independently by experts on behalf of a national 
or international health agency where all 
published results and conclusions are subjected 
to peer review. We publish links to many of those 
scientific research publications on the mobiles, 
masts and health section of our Group website.
National, regional and international research 
programmes respond to the priorities set by the 
WHO, which does not undertake research itself. 
Ensuring that objective, well-funded research 
programmes are completed is essential to fully 
understand the potential risks. Consequently, 
we contribute funds indirectly, through national 
government research programmes, to some of 
these independent studies. This is to make sure 
that the methodology, outcomes, analysis and 
publications are objective.
Studies continue in this area including those 
prioritised by the WHO that monitor the health 
effects on children of their mobile use and any 
health effects from long-term use of mobiles.
Governance and compliance
Our Group EMF Leadership Team, chaired by the 
Group Director for Health, Safety and Wellbeing, 
determines our strategy on mobiles, masts and 
health and oversees compliance in our local 
markets. The team meets regularly and 
reported twice this year to the Vodafone Group 
Plc Board about developments in science, policy 
and compliance.
1  International guidelines set by ICNIRP were incorporated into the Council Recommendation of 12 July 1999 on the limitation of exposure of the 
general public to electromagnetic fields (0 Hz to 300 GHz). 
Every year, our Group EMF Manager conducts 
in-depth on-site compliance assessments in 
two local markets. This year, the visits were 
to Germany and Hungary. In Germany, the 
assessments showed that all our controls were 
implemented correctly. The visit demonstrated 
a well-established programme delivered across 
the relevant functions of Vodafone Germany and 
well supported at a senior level. In Hungary, the 
assessment showed that managers are generally 
risk conscious, routinely monitor key business 
areas and implement mitigation plans on a 
timely basis with effective oversight. There was 
one remedial action, which was to improve the 
procedures ensuring that only people who have 
been EMF trained are permitted to work on site. 
This year, we developed and rolled out an 
e-learning course about mobiles, masts and 
health. It included a simple introduction to how 
mobiles work and provided information and tips 
for our people to use when talking with friends 
and family about mobiles, masts and health. 
This e-learning module is available via the 
Vodafone University platform to all employees 
and has been translated for use in Vodacom 
DRC, Vodacom Mozambique, Vodafone Portugal, 
Vodafone Greece and Vodafone Spain. Since 
launch, the training has been completed by 
over 500 employees and is also available to 
partner markets, joint ventures and tower 
company partners. 
Our website provides in-depth 
information about mobiles, masts and 
health, including links to independent 
scientific research.
57
Vodafone Group Plc Sustainable Business Report 2019
Mobiles, masts and health
Privacy and cyber security 
Introduction
Transformation
Operating responsibly
Our people
Appendix
Anti-bribery and corruption and political engagement
Human rights
Safety
Supply chain integrity

Our people
We employ around 92,000 people and work with over 
10,000 contractors globally. Our business performance 
and our customers’ experience depend on our ability to 
attract, develop and retain talented individuals at all levels.
Our people are fundamental to every aspect of our 
Vodafone strategy and are committed to delivering 
a superior network performance and providing 
exceptional customer experience.
This chapter outlines our approach to supporting 
our employees through developing skills and 
capability, building a diverse and inclusive business, 
supporting wellbeing and managing change. 
Developing skills and capability
60
Building a diverse and inclusive business
61
Wellbeing
63
Managing change and reorganisations
64
58
Introduction
Transformation
Operating responsibly
Vodafone Group Plc Sustainable Business Report 2019
Our people
Appendix
Managing change and reorganisations
Wellbeing
Building a diverse and inclusive business
Developing skills and capability
Appendix
Our people
Operating responsibly

Our people 
We strive to create an open, diverse 
and inclusive environment in which 
all employees feel equally valued and 
understand that ethical conduct is 
critical to our business success.
We are very clear about the behaviours we 
expect from everyone who works for Vodafone. 
These are defined by our global policies and 
set out in our Business Principles and Code of 
Conduct. They are also reinforced in The Digital 
Vodafone Way, the guidance we provide to all our 
employees on how they should behave in order 
to ensure Vodafone is admired and respected 
by our customers and by society as a whole. 
Speed, simplicity and trust remain our three 
core principles.
Employee engagement 
Every year, we run our online Global People 
Survey across our entire workforce to help 
us to assess our employees’ concerns and 
aspirations. It is anonymous, confidential and 
conducted by a third-party provider. Our senior 
leadership team uses it to identify shortcomings 
highlighted by employees and to plan remedial 
action. Managers and their teams also discuss 
and implement changes based on the findings.
This year, 87% of our employees responded: a 
two percentage point decrease on the previous 
year. The 2019 survey demonstrated that 85% of 
employees who responded are proud to work for 
Vodafone. The overall Engagement Index score 
– demonstrating employees’ desire to continue 
working with Vodafone and their inclination to 
recommend us as an employer – increased by 
one percentage point this year, to 80%.
Respondents were also asked for their views 
of their individual line managers. The resulting 
Manager Index score also remained high, at 82%, 
and 88% of employees said they felt they are 
treated with respect as an individual.
Vodafone’s Global People Survey results (%)
2018
2019*
Overall response rate
85 
87  
Employee Engagement Index
79
80  
Manager Index
80
82 
Engagement and values
I am proud to work for Vodafone
83
85  
Vodafone is socially responsible
83
85  
Training
I have opportunities to learn the skills 
and knowledge I need to do my job well
77
80  
Diversity and inclusion
People in my team are treated 
fairly regardless of their age, gender, 
disability, sexual orientation, cultural 
background or beliefs
85
90 
People have an equal opportunity to 
succeed at Vodafone, regardless of their 
age, gender, disability, sexual orientation, 
cultural background or beliefs
78
82  
I am treated with respect as an individual
85
88  
I feel able to be myself at work
83
87  
I am comfortable expressing my views and 
opinions at work
80
83  
Health, safety and wellbeing
The Absolute Rules for Health and safety 
are taken seriously at Vodafone
88
89  
My manager takes genuine interest in the 
wellbeing of his/her employees
83
84  
* The survey was conducted in October 2018.
Employee statistics*
2017
2018
2019
Average number 
of employees
92,200
91,980
92,005
Part-time employees
8,310
7,979
7,560
Total number of 
voluntary leavers
12,378
11,644
12,339
Total number of 
involuntary leavers
4,225
3,912
3,680
Newly hired 
employees
16,380
14,837
17,276
Average turnover 
rate (%)
18%
17%
17%
* 2017 and 2018 data has been restated to exclude employees from our 
joint ventures in the Netherlands and India, and Vodafone Qatar which 
was sold in March 2018.
59
Introduction
Transformation
Operating responsibly
Vodafone Group Plc Sustainable Business Report 2019
Our people
Appendix
Managing change and reorganisations
Wellbeing
Building a diverse and inclusive business
Developing skills and capability

Our industry is evolving at great speed. 
New platforms and technologies are 
driving demand in artificial intelligence 
machine learning, cloud computing 
and data analytics. This means we 
need to look continuously at what 
critical skills our people need to have 
to ensure we have the organisational 
capability to succeed now, and that we 
are investing in developing the skills 
we will need in the future.
Last year, we launched a strategy to increase 
our information technology capabilities and 
rolled out programmes to ensure people adopt 
agile ways of working so we can respond much 
more quickly to the needs of our customers. 
Over the last year, 8,500 of our employees have 
completed training on the agile mindset and 
scrum methodology. There has also been an 
increased focus on building capabilities in data 
analytics (the ability to analyse and interpret 
large volumes of data), application program 
interfaces, coding, robotics and automation. 
With our network being a core part of our 
strategy, we are also reviewing our capabilities 
in this area. For example, to support the rollout 
of 5G, we are reskilling our engineers in data, 
automation and coding to help Vodafone create 
the best platform to deliver 5G services. 
Equipping our people with the right skills
Building our employees’ skills through 
continuous development programmes is 
an essential component of driving business 
performance, and this year we invested more 
than €60 million in learning and development. 
Our programmes take many forms, from 
structured learning and formal training, to 
personal coaching and mentoring. During the 
year, we provided an average of 20 training hours 
for every employee, with 97,300 of our people 
over the year completing at least one course on 
Vodafone University, our global learning platform 
that allows our employees to access local and 
global learning content from any device.
Our employees welcome these programmes; 
in the 2019 Global People Survey, 80% of 
employees surveyed said that they benefited 
from opportunities to learn the skills they 
needed to do their jobs well.
Throughout this year, a core focus was 
developing digital skills across the organisation 
and leadership and management skills 
needed for agile and digital working. We also 
evolved our Vodafone University to enable 
recommendations for relevant courses based on 
identified skills and launched a programme with 
LinkedIn Learning, a content platform with over 
10,000 pieces of new content.
Developing digital leaders
Clear, effective and flexible leadership is critical 
to our business success. All of our leaders, from 
the supervisor early in their career to the most 
senior global executive, are expected to serve as 
positive role models for their teams.
This year we identified the key shifts that
leaders need to make in order to lead effectively 
in a digital environment. With this information, 
we refreshed our global leadership 
development programmes. 
Our new Digital Leadership Essentials 
programme was completed by 83% of all 
new managers within their first 120 days. 
This programme enables new leaders to build 
their self-awareness and practise key techniques 
to build high-performing individuals and 
teams. Also this year, we launched an online 
programme in partnership with LinkedIn 
Learning to provide all our colleagues with 
access to leadership development. The 
programme emphasises the importance of 
influencing others, leading and working in 
teams, simplifying internal processes and 
ensuring that decisions and actions are taken 
with the customer in mind.
We invest in leaders of the future, and this year 
over 60 participants engaged in our refreshed 
Inspire programme. Participants from across the 
world came together in locations throughout the 
Vodafone footprint, listening to industry experts 
and Vodafone leaders and working together to 
fine-tune their capabilities to become the senior 
leaders that Vodafone needs for the future.
Engaging our employees on our policies
Everyone who works with us makes a formal 
commitment to follow our Code of Conduct at 
all times. Our Doing What’s Right training and 
communication programme is key to embedding 
in our daily work a shared understanding 
of the Code of Conduct across Vodafone. 
Throughout the year, Doing What’s Right 
communications promoted different areas of our 
Code, from Speak Up, anti-bribery and privacy 
to competition law, security, and health and 
safety. Doing What’s Right training is included 
in our standard induction processes for new 
employees, and current employees complete 
refresher training every two to three years.
  Read more on our approach  to increase 
the number of digital opportunities 
provided by Vodafone to young people 
on page 25.
Developing skills and capability
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Transformation
Operating responsibly
Our people
Appendix

It is fundamental that our employees 
feel they belong. In our 2019 
annual Global People Survey, 87% 
of our employees felt they were 
able to be themselves at work. Our 
employees should never be subject 
to discrimination and 90% of our 
employees said they felt treated fairly, 
regardless of age, gender, disability, 
sexual orientation, gender identity, 
cultural background or beliefs.
We expect those who work with us to conduct 
themselves with dignity and respect in their 
dealings with customers, co-workers, partners, 
suppliers, local communities and any other 
stakeholders affected by, or with an interest 
in, Vodafone’s activities. This expectation, 
mandated in our Code of Conduct, applies 
across all of our businesses, to our employees’ 
interactions with all individuals regardless of 
gender, sexual orientation, gender identity, 
disability, race, age or any other factor.
In our aspiration to become the world’s best 
employer for women by 2025, increasing the 
proportion of women in management and 
senior leadership roles is a core focus of our 
global diversity and inclusion programmes. 
  Read more about our goals and 
programmes to achieve our aspiration 
in the Women’s empowerment section 
of this report.
Focusing on LGBT+ inclusion
We focus on creating an inclusive working 
environment for employees who identify 
as lesbian, gay, bisexual, transgender or 
other sexual orientation and gender identity 
categories (LGBT+). Our global executive sponsor 
for LGBT+, who is a member of our senior 
leadership team, provides leadership on LGBT+ 
inclusion and raises the profile of LGBT+ topics. 
A further 20 executive sponsors from the senior 
leadership team in local markets and at Group 
level support their area of business.
For the second year, Stonewall recognised 
Vodafone as a Top Global Employer. We also 
received additional recognition in the form of 
a Global Senior Champion Award in 2018. In 
the UK, Vodafone jumped 10 places from our 
previous year’s ranking to reach position 32 in 
the Stonewall Top 100 Employers list this year, 
with the LGBT+ Friends Network also being 
highly commended.
Understanding our LGBT+ population
This year, for the first time, colleagues across 
Europe, New Zealand and South Africa had the 
option to provide their sexual orientation and 
gender identity as part of the annual Global People 
Survey. 1.3% of the population identified as lesbian 
or gay, 1.1% as bisexual and over 4% indicated that 
they would ‘prefer not to say’. In addition, less than 
1% of the population identified as transgender. 
We believe there is an opportunity for more work 
to be done so that our LGBT+ employees feel 
comfortable to identify themselves.
LGBT+ youth
This year we increased our focus on supporting 
the LGBT+ youth community. Vodafone 
commissioned research to survey more than 
3,000 LGBT+ young people across 15 countries 
and multiple industries. The research found that 
more than half (58%) of young LGBT+ people 
are not open about their sexual orientation or 
gender identity at work because they worry 
they will face discrimination from managers and 
colleagues. It also found that one in three (31%) 
LGBT+ people admitted that they went ‘back into 
the closet’ when they started their first job. This 
figure rises to 41% among 18 to 25-year-olds.
To help create a culture where employees can 
be open about their sexual orientation and 
gender identity, Vodafone has launched a 
number of initiatives. 
Vodafone has also shared the research 
it conducted with a number of FTSE 100 
companies and our suppliers, and hosted 
roundtable discussions to encourage other 
employers to also take up these initiatives.
Our established global LGBT+ employee 
network, LGBT+ Friends, supports managers 
and employees and connects them with active 
networks in 14 countries.
During the year, we supported Pride events in 
15 of our local markets. Our Group Chief Executive 
also hosted a global webinar and was joined by 
chief executives from 11 different markets. In 
addition, we participated in Spirit Day (which 
highlights challenges such as bullying for young 
LGBT+ people), holding events in nine countries.
Vodafone is committed to supporting LGBT+ people at work with:
*Lesbian, gay, bisexual, transgender and other identities
LGBT+* inclusive messaging on job adverts and career channels
A refreshed Code of Conduct which will support LGBT+ inclusivity
Toolkit for managers to create an LGBT+ inclusive workplace
A global ‘buddying’ programme for LGBT+ graduates
Graduate, induction and leadership training programmes 
to support, retain and help attract LGBT+ employees
An interactive learning programme for all accreditation
Building a diverse and inclusive business
Also see our Gender Pay Gap Report 
online, produced for our UK businesses.
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Wellbeing
Managing change and reorganisations

Increasing cultural understanding 
and awareness across countries
Vodafone is a multicultural company. We employ 
people from 131 different nationalities across 
21 local markets, with members of our global 
senior leader team drawn from more than 28 
different nationalities.
We encourage our managers to broaden their 
understanding of other cultures and believe they 
benefit professionally from assignments outside 
their home nation. 45% of our senior leaders 
have completed an international assignment at 
some point during their career with Vodafone.
Understanding our ethnically diverse 
population in the UK
This year we worked to understand more 
about the experiences of our colleagues from 
ethnic minorities, particularly in the UK. With 
the support of EMPower, Black and Asian 
colleagues participated in focus groups to build 
an understanding of their experiences and what 
further support is needed.
In addition, this year the annual Vodafone 
Global People Survey included ethnicity as a 
demographic, asking people to declare this on 
a voluntary basis. The survey found that of the 
13,470 respondents from the UK (representing 
over 80% of the UK employee population), 11% 
were from Black or Asian ethnic groups, and a 
further 4% indicated they were from mixed or 
other ethnic demographics.
Multicultural network launch
In response to feedback from our ethnic 
minority community, this year we launched our 
Multicultural Inclusion Network at Vodafone UK 
and Group functions based in the UK to create 
an internal support group for managers and 
employees. Baroness McGregor Smith attended 
the launch event on 3 October 2018, and the 
network currently has over 450 members. An 
executive sponsor and a network chair have 
been appointed, along with leads for different 
locations across the UK. 
Creating awareness about 
our disabled population
In order to improve the inclusivity of our 
approach, this year we created a digital 
‘disABILITY’ site for all our employees, which 
provides guidelines, videos and toolkits to 
create awareness around this topic, increase 
the knowledge of our colleagues and give 
guidance on what they can do to create a more 
inclusive culture. We also conducted a review 
of our websites to increase the accessibility for 
our colleagues. Every year Vodafone features 
internal and external best practices on what 
markets are doing for colleagues, customers, 
communities or co-partners during a global 
webinar. Over 2,800 colleagues viewed last 
year’s webinar, which featured personal stories 
from colleagues and showcased products that 
Vodafone has developed to support customers 
with disabilities.
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Wellbeing
Managing change and reorganisations

Helping our employees to stay safe, 
fit and healthy is a priority for us. It 
contributes to productivity, reduces 
absenteeism and creates an attractive 
working environment for all employees.
In 2016, we launched our wellbeing framework. 
The framework focuses on six key aspects 
of wellbeing and is designed to support the 
development and implementation of employee 
wellbeing activities in all of our markets.
The framework is a guideline to help us to 
achieve optimal wellbeing for all of our people, 
respecting cultures, available resources and 
Employee wellbeing
requirements. Market wellbeing teams develop 
initiatives tailored to local needs and share 
information and best practice through our 
Health, Safety and Wellbeing Network. Our 
global Health, Safety and Wellbeing objectives 
measure employee wellbeing. Year on year, 
our annual Global People Survey question ‘My 
manager takes genuine interest in the wellbeing 
of his/her employees’ achieves consistently high 
scores (84% in the most recent survey).
Our wellbeing framework
Digital 
Balance
Emotional &
Mental
Financial
Physical
Connections & 
Community
Purpose &
Growth
Supporting employees to thriVe
In October 2018, we launched a new 
digital web and mobile wellbeing 
platform, thriVe, for employees who work 
for Vodafone UK and UK-based Group 
employees. The UK launch was the first 
stage in the forthcoming rollout of the 
platform to all Vodafone markets. The 
mobile platform provides access to a 
number of health and wellness tools, 
along with information and resources for 
people working in more remote locations. 
thriVe is also available to our employees’ 
family and friends, encouraging 
employees to engage more broadly 
to help motivate and support others 
to maintain a healthy lifestyle. thriVe 
offers a wellbeing self-assessment to 
help people identify strengths and 
opportunities for improvement. People 
can then set goals and participate in 
challenges to help drive their progress. 
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Developing skills and capability
Managing change and reorganisations

Managing change and reorganisations 
The pace of change in technology 
means that our industry is always 
evolving. Vodafone must continue 
to respond to the changing world to 
remain sustainable and take advantage 
of new opportunities and challenges. 
Over the last year, there have been a number 
of organisational changes in both the global 
offices and local markets. Demand for services 
continues to grow exponentially, but this is not 
the case with prices, which means that Vodafone 
has had to respond to continue to compete in 
all segments within our markets. In addition, our 
customers demand an agile, simple and instant 
relationship with us, which means that we need 
a simpler organisational model that strengthens 
coordination and synergies between teams. 
We will continue to invest in strengthening our 
business model to protect our capacity to invest 
and design a more competitive organisation. 
When we need to reorganise part of our business, 
we engage with employees directly to discuss 
the implications of the planned reorganisation 
and the options available to those individuals 
potentially affected by it. Proposed changes 
are communicated clearly in team briefings and 
(when appropriate) one-to-one meetings led by 
line managers and human resources teams. Our 
managers and human resources partners work 
closely with teams to support them through the 
change and answer any questions employees 
might have.
Where proposed changes result in redundancies, 
we aim to help affected employees find new 
jobs, either by identifying other opportunities 
within Vodafone that suit their skill set, where 
appropriate, or through outplacement services 
and recruitment events. We also offer training 
to improve interview techniques and CV-
writing skills. Any reorganisation is conducted 
in compliance with local legislation and in 
consultation with employee representatives, 
works councils and local unions.
Employee consultation
We recognise the rights of employees to join 
trade unions. In Europe, we also consult with 
our employees through the Vodafone European 
Employee Consultative Council, which meets 
twice a year and gives employee representatives 
an opportunity to raise any concerns with our 
executive management team.
Supporting employees through change in Spain
Vodafone Spain is one of our markets where we have made a number of organisational 
changes during the year to support our new strategy and operating model. As part of 
the restructuring process, we reached an agreement with all eligible works council 
representatives and, in addition to enhanced severance packages, the collective 
agreement included a nine-month outplacement programme and the provision of 
specific training for employees seeking to become entrepreneurs in the future. Both of 
these provisions aimed at helping employees remain in the workforce once they have 
left Vodafone.
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Managing change and reorganisations
Introduction
Transformation
Operating responsibly
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Appendix
Building a diverse and inclusive business
Developing skills and capability

Appendix
Find out more about our governance 
process, the scope of our reporting, 
environmental management, 
materiality and read Grant 
Thornton’s Assurance Statement. 
Managing and reporting 
on sustainable business
66
Materiality
68
Environmental management
69
Scope of reporting
70
How we report our 
key performance indicators
71
Independent Limited 
Assurance Report
79
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Appendix
Operating responsibly

Managing and reporting on sustainable business
Vodafone’s sustainable business management 
and reporting systems focus on activities 
and risks that are both potentially material 
to our business and are of greatest interest 
to our many and diverse stakeholders. In this 
appendix to the Report, we provide an overview 
of the governance processes that underpin our 
approach and summarise the methodology 
used to identify the most important business 
and socio-economic themes that are now at 
the centre of our sustainable business strategy.
We report on progress against our sustainable 
business strategy annually, in parallel with 
the Vodafone Group Plc Annual Report, which 
contains key highlights and progress on our 
sustainable business strategy. During the year, 
we also publish separate transparency reports 
on two areas of significant public debate: 
Tax and our total economic contribution to 
public finances and on law enforcement and 
freedom of expression matters within our 
Digital Rights and Freedoms Reporting Centre. 
Additionally, we provide detailed information 
regarding electromagnetic frequency 
emissions from mobile devices and base 
stations in a dedicated area of our website.
GRI Standards Index
Our 2019 Sustainable Business Report has been prepared in reference to the 
GRI’s Sustainability Standards 2016. The GRI Standards allow companies to report 
their material impacts for a range of economic, environmental and social issues.
  Read our 2019 GRI Standards Index
We publish an annual statutory Conflict 
Minerals Report (in line with US regulatory 
requirements) and an annual Slavery and Human 
Trafficking statutory statement (in line with the 
requirements of the UK Modern Slavery Act 
2015). This year, we also published Vodafone’s 
second UK Gender Pay Gap Report as required 
under the Equality Act 2010 (Gender Pay Gap 
Information) Regulations 2017. These statutory 
documents are available on the Sustainable 
Business section of our website.
In this appendix, we provide an overview 
of our governance and our environmental 
management approach, a summary of the 
scope of our sustainable business reporting, 
a list of our key performance indicators and 
an Assurance Statement from Grant Thornton.
In addition, our Index of Conformance with 
the Global Reporting Initiative (GRI) Standards 
can be found on our website here.
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Governance
Our sustainable business strategy has been 
designed to ensure close alignment between our 
business goals and the maximum possible socio-
economic benefit achievable as a consequence 
of these goals. Realising that ambition requires 
strong corporate governance at multiple levels 
of our businesses. Leadership vision is critically 
important – so too is ensuring a commitment to 
effective operational implementation.
The Group Sustainable Business team defines 
and leads Vodafone’s activity in this area. The 
strategy summarised in the Report was created 
with input and advice from a wide range of 
stakeholders – as we explain below – and was 
formally approved by the Group Executive 
Committee in November 2015.
The Vodafone Group Sustainable Business 
team works with Vodafone’s local market and 
professional function teams to advance the 
various programmes, projects and initiatives 
discussed in this Report. Implementation of 
the sustainable business strategy relies on 
leadership within the relevant business areas 
together with a strong partnership with the 
Vodafone Group Sustainable Business team. The 
team provides expert advice and guidance to 
core business owners within the Group’s global 
senior leadership team while supporting the 
operational delivery of Vodafone’s sustainable 
business agenda in conjunction with sustainable 
business specialists in each of our local markets.
The Group Executive Committee (ExCo) – 
chaired by the Group Chief Executive – has 
overall accountability to the Vodafone Group 
Plc Board for Vodafone’s sustainable business 
performance. The Group Director of Corporate 
Affairs defines and leads Vodafone’s sustainable 
business strategy worldwide and is responsible 
for the activities of the Group Sustainable 
Business team. The Group Director of Corporate 
Affairs reports to the Group External Affairs 
Director who is a member of the ExCo.
The ExCo regularly reviews the progress of 
the sustainable business strategy. All external 
publications – including this Report – are 
reviewed by the Vodafone Group Disclosure 
Committee. The Committee is responsible for 
ensuring the accuracy and timeliness of Group 
disclosures and approves, on behalf of the Group 
Chief Executive, the controls and procedures 
related to the release of financial and non-
financial information. The Vodafone Group Plc 
Board receives an update on the progress of the 
Group sustainable business strategy once a year.
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Sustainable business governance structure 
–	 Ultimate accountability for Vodafone’s 
sustainable business strategy.
Core accountabilities 
and responsibilities
–	 Sets overarching sustainable 
business direction.
–	 Responsible for sustainable business 
strategy and performance.
–	 Implements strategy.
–	 Engages with and supports the business 
through Group and local market teams.
–	 Engages with key external stakeholders.
Sustainable Business is led by Group 
Corporate Affairs Director, reporting to 
Group External Affairs Director (ExCo) 
CEO and Executive Committee (ExCo)
Vodafone Group Plc Board
Local 
markets
Group functions
Group Sustainable Business team

During 2016, we conducted a materiality 
assessment of our ten priorities, using the GRI 
Principle of Materiality, to identify the most 
important social, economic, environmental 
and ethical factors of greatest relevance to 
our businesses and to society as a whole. That 
assessment was informed by the views of a wide 
range of stakeholders and, in turn, led to the 
creation of our sustainable business strategy.
Understanding stakeholder views
Many people and organisations have an 
interest in what we do and how we work. 
Our stakeholders include:
–	 consumer and enterprise customers;
–	 shareholders and investors;
–	 employees;
–	 suppliers and partners;
–	 governments and regulators;
–	 local communities;
–	 non-governmental organisations (NGOs) 
and civil society activists; and
–	 industry peers.
In designing our sustainable business strategy, 
we took into account factors including:
–	 insights from our engagement with 
peers, NGOs and civil society activists and 
sustainable business specialists;
–	 a review of existing and emerging issues that 
are the focus of ongoing public debate in 
multiple countries;
–	 global socio-economic trends, such as 
climate change and youth unemployment;
–	 a review of the issues covered in the GRI 
Standards;
–	 the priorities identified in the United Nations 
Sustainable Development Goals (SDGs); and
–	 an evaluation of how the Principles of the 
Blueprint Framework for Better Business 
would apply to Vodafone.
We used the Global e-Sustainability Initiative’s 
materiality tool (specifically designed for use 
within the communications industry) to analyse 
these factors and then rank them in a materiality 
matrix. That analysis resulted in the identification 
of 24 issues that we considered to be the most 
material, both for Vodafone and for society as a 
whole. We then mapped those 24 issues against 
the five Principles of the Blueprint Framework 
for Better Business to identify ten overarching 
priorities of equal impact and importance.
Materiality
Our ten priorities
Digital rights including privacy, data protection and security
Management of supply chain risks
Health and safety
Business conduct and ethics
Corporate taxation and total economic contribution
£
Public concerns regarding electromagnetic frequency emissions
Employee equality and diversity
Energy consumption and greenhouse gas emissions
CO2
Customer relationships
Socio-economic benefits arising from our products and services
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All of our local markets operate environmental 
management systems that encompass factors 
such as energy consumption, waste management 
and water usage. These systems are certified to 
international standard ISO 14001 in the Czech 
Republic, Greece, Portugal, Romania, South Africa, 
Spain and the UK.
We have a number of initiatives in place to reduce 
the energy used in our office buildings and 
administrative systems, and to help our employees 
reduce their own carbon impact. Several of 
our offices are LEED (Leadership in Energy and 
Environmental Design) certified and rated on the 
basis of their design, construction, operation and 
maintenance. The following Vodafone buildings 
have been awarded certification under the 
Commercial Interiors category:
–	 Vodafone Spain headquarters, Germany 
headquarters, office and call centre in Turkey 
headquarters – platinum standard;
–	 Vodafone Czech Republic headquarters – 
gold standard; and
–	 Vodafone Italy – gold standard for its 
offices in Padua and silver standard for its 
headquarters in Milan.
Compliance with environmental 
regulations 
Our environmental management systems are 
designed to ensure compliance with relevant 
legislation in each local market as well as with 
European regulations, including:
–	 the EU’s Restriction of the Use of Certain 
Hazardous Substances in Electrical and 
Electronic Equipment Directive;
Environmental management  
–	 the Waste Electrical and Electronic 
Equipment Directive in EU countries;
–	 the EU’s Registration, Evaluation, 
Authorisation and Restriction of Chemicals 
Directive; and
–	 the EU’s Energy Efficiency Directive.
Managing waste 
We implement resource efficiency and waste 
management programmes in all our local markets 
in order to minimise emissions from the end-of-
life treatment of network waste, IT equipment 
and other office waste. Our Group policy on waste 
management prioritises the reuse or recycling of 
unwanted equipment, safely and responsibly, to 
help keep resources in use for as long as possible, 
extracting the maximum value from equipment 
while in use and then recovering and re-using 
materials before recycling them responsibly. 
Our electronic-waste (e-waste) impact 
includes network waste such as base station 
equipment, air conditioning units, cables, 
waste from handsets, routers, transmission 
equipment and device waste such as mobile 
phones, accessories and tablets. In developed 
markets, we use specialist e-waste contractors 
that comply with international regulations, but in 
emerging markets managing waste can be more 
challenging. Access to appropriate waste facilities 
is often limited and there may be few legal 
safeguards in place to ensure that potentially 
hazardous substances are handled responsibly. 
All our local markets are required to keep records 
of their e-waste equipment and to use recycling 
suppliers that are regulated, licensed or have 
been assessed and approved through our supplier 
qualification processes. 
This year, we have established a new goal to aim 
for 100% reuse and recycling of our network 
waste. We have also investigated ways to improve 
the reuse and repair of devices across our local 
markets by assessing existing schemes across our 
local markets which include: trade-in and device 
buy-back schemes, drop-off boxes in retail stores, 
freepost return envelopes and repair services to 
encourage customers to repair or return their old 
devices and routers. 
In our own operations, we generated an estimated 
8.5 million kg of waste and we recovered and 
recycled 93.9%. Globally, 99.5% of our network 
waste was sent for reuse and recycling. 
Managing water
Compared with businesses in other industries, 
we do not use water intensively. This year, we used 
0.94 million m3, a decrease of 4.5% on last year. 
In South Africa, where water scarcity is a 
significant issue, Vodacom has invested in a 
number of water efficiency initiatives to reduce 
water consumption. These have included 
planting water-wise, indigenous plants and 
installing rainwater harvesting at Vodacom’s 
head office in Johannesburg.
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Scope of reporting
Performance data included in the scope of 
this Report:
–	 our operating companies in 21 countries 
where we have operational control: Albania, 
Czech Republic, Egypt, Germany, Ghana, 
Greece, Hungary, Ireland, Italy, Malta, 
New Zealand, Portugal, Romania, Spain, 
Turkey, the UK, Vodacom in South Africa 
and Vodacom Group’s subsidiaries in the 
Democratic Republic of Congo (DRC), 
Lesotho, Mozambique and Tanzania; and
–	 operations under Vodafone Global Enterprise 
and Vodafone Group Services.
Performance data excluded from the scope of 
this Report:
–	 joint ventures where Vodafone does not have 
operational control: VodafoneZiggo in the 
Netherlands, Vodafone Hutchinson Australia, 
Vodafone Idea and Indus Towers in India and 
our associate Safaricom in Kenya;
–	 Partner Market networks in which Vodafone 
neither has any equity interests nor holds an 
operating licence, including those Partner 
Markets that operate under the Vodafone 
brand;
–	 countries in which we are required to hold 
an operating licence in order to provide local 
customer support to multinational enterprise 
customers but where we neither own nor 
operate any licensed telecommunications 
network infrastructure; and
–	 retail stores that are Vodafone-branded 
by way of franchise and exclusive dealer 
arrangements but are not owned or operated 
by Vodafone.
Exceptions:
–	 our M-Pesa customer numbers and our 
50 million women emerging market target, 
which both include our associate Safaricom in 
Kenya and Vodafone customers in India (data 
from Vodafone India is taken from August 
2018, prior to the merger of this business with 
Idea to create Vodafone Idea. We are working 
on appropriate methodology to account for 
the change in the business going forward);
–	 our safety performance numbers include 
data from India up until 1 September 2018.
Any additional exclusions are noted in the text.
On 31 August 2018, Vodafone announced the 
completion of the merger between Vodafone 
India and Idea to create Vodafone Idea. Vodafone 
Idea is a joint venture controlled by Vodafone 
and the Aditya Birla Group. Vodafone no longer 
has operational control of this business, and 
therefore, Vodafone Idea is no longer included 
into the Group performance data, apart from the 
exceptions highlighted above.
Vodafone Foundation
Within this Report, we highlight some of the 
activities of Vodafone Foundation as these 
complement much of the Group’s sustainable 
business strategy. However, Vodafone 
Foundation’s activities overall are not within 
the scope of this Report. Vodafone Foundation 
supports projects around the world that are run 
in partnership with charitable organisations 
and NGOs. Vodafone Foundation is a UK 
registered charity (1089625) and receives 
annual contributions from Vodafone Group Plc. 
Through its Connecting for Good programme, 
Vodafone Foundation leverages the technology 
and expertise within Vodafone to maximise 
its charitable impact. Vodafone Foundation’s 
independence is key to its ability to work 
globally with a wide range of partners to meet its 
charitable objectives. Vodafone Foundation also 
sits at the centre of a network of 27 local social 
investment programmes, referred to as the 
local foundations. Vodafone Foundation has a 
funding partnership with these local foundations 
to provide public benefit by investing in 
programmes that support communities in 
Vodafone’s operating countries.
Setting revised baselines after 
acquisitions, disposals and changes 
in operational control
The inclusion or exclusion of data from business 
units that have been acquired or sold, or where 
there is change in operational control (for 
example, through a merger), is determined by the 
date that the transaction in question is formally 
concluded with all approvals received.
Our policy on environmental data reporting is to 
include performance data from newly acquired 
businesses at the end of their first full year of 
new ownership. In terms of setting a revised 
baseline to reflect acquisitions, disposals or a 
change of control, our policy is that:
–	 acquisitions are built into the baseline using 
either actual or estimated data at the end of 
their first full year as a controlled subsidiary;
–	 disposals are removed from the baseline in 
the year of disposal; and
–	 any identified errors >1% of the Group total 
are re-baselined wherever possible.
Trade mark notice
Vodafone, the Vodafone Speech Mark, 
The future is exciting. Ready?, Vodacom and 
M-PESA are trade marks of Vodafone. Other 
product and company names mentioned in 
this document may be the trade marks of their 
respective owners.
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Appendix

How we report our key performance indicators
This section of the Report outlines the basis of 
preparation of the key performance indicators 
(KPIs) reported in the Women’s empowerment, 
Energy innovation, Youth skills and jobs, and 
Supply chain integrity and safety sections of the 
Sustainable Business Report.
We publish our reporting definitions and 
methodology so that readers can understand 
the basis upon which the disclosures have 
been prepared and be in a position to make 
comparisons across different reports. 
1. Women’s empowerment
Diversity performance: % of female 
employees
We report the percentage of female employees 
across our four global employment bands:
•	 senior leadership (our top approximately 200 
employees) including ExCo members;
•	 senior management (1,100–1,600 
employees);
•	 middle management (6,000–7,500 
employees); and
•	 the non-management employees who make 
up the rest of the population.
Each of these categories is defined through a 
consistent global role-banding process overseen 
by the Vodafone HR function.
Calculation of progress against our target of 
30% women in management and leadership 
roles includes the diversity figures for all 
management bands.
We also report on the percentage of female 
management and leadership employees in our 
Technology function. This is calculated using 
data sources from two KPIs:
•	 the percentage of management and leadership 
females in the Technology function (comprised 
of employees from local operating companies 
and Vodafone Group); and
•	 the percentage of management and 
leadership females supporting the 
Technology function within Vodafone 
Shared Services.
The diversity figures are based on the number of 
employees (full-time/part-time) as at 31 March. 
These numbers are not pro-rated. An employee 
is defined as a person with an employee 
(as opposed to consultant or contractor) 
relationship with Vodafone (or its operating 
companies), who is paid by Vodafone (or its 
operating companies) through the payroll. 
This includes graduates and people on 
international assignments as well as people on 
work experience who are on the payroll or have 
been at Vodafone (or an operating company) for 
longer than six months. The numbers exclude 
pensioners and non-employees.
Progress against the goal of bringing 
the benefits of mobile to an additional 
50 million women in emerging markets 
by 2025
For the purposes of this goal, the definition of 
a connected woman is a SIM connection that is 
estimated to belong to a female primary user.
This goal is calculated as the number of 
additional connected women at the end of 
the ten-year target period against the initial 
31 March 2016 baseline. Progress towards the 
ten-year target is reported at the end of each 
financial year.
The 50 million women target applies across nine 
emerging markets where we have an operating 
presence and where we believe we have the 
greatest scope to make a difference. These 
are Egypt, Ghana, India (Vodafone customers 
only) and Turkey plus through our sub-Saharan 
subsidiary Vodacom Group, DRC, Mozambique, 
South Africa, Tanzania and Kenya through our 
associate Safaricom.
The process used to estimate the number of 
women connected is as follows:
•	 the total number of connections (for both 
male and female customers) is calculated 
based on the closing number of active 
customers at the end of each financial 
year; and
•	 the percentage of female mobile customers 
is calculated using information from two 
surveys over a selection of customers in 
each market:
- the Net Promoter Score conducted across 
the Vodafone customer base in each local 
market; and
- the Vodafone brand tracking survey conducted 
in each local market.
The number of women connected is then 
estimated by calculating the percentage of 
female customers as a proportion of the total 
number of Vodafone connections in each local 
market, aggregated across the nine countries 
listed above.
Given the nature of the target demographic – 
typically, women on very low incomes in poor 
communities – it is assumed that the very large 
majority will not have a mobile phone in their 
own right and, therefore, will not be customers 
of competitor mobile networks. However, it is not 
possible to distinguish between women who are 
new to mobile and women who already have a 
mobile and are switching networks.
The calculation via customer survey of the 
proportion of women reached is subject to 
the risks inherent to this kind of sampling and 
does not distinguish between existing and new 
customers. Assumptions are therefore made 
based on the entire customer population in 
a market.
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2. Youth skills and jobs
Number of young people supported 
to access digital skills, learning and 
employment opportunities
Our goal is to support 10 million young people 
to access digital skills, learning and employment 
opportunities by 2022. This goal incorporates 
our internal target, which is to provide 100,000 
opportunities for young people to receive a 
digital learning experience at Vodafone. It also 
incorporates additional initiatives, such as the 
number of people who have completed our 
Future Jobs Finder tool (read more about the 
tool on page 21).
The number of completions of the Future 
Jobs Finder tool is defined as the number of 
unique users who complete the first quiz in 
the tool, which focuses on the user’s interests 
and affinities and matches the results to a set 
of five digital job types that best suit. This data 
is collated via the use of Google analytics. 
The Future Jobs Finder tool is a global online 
platform and as such could be completed by 
anyone, and we do not actively track the age of 
the users who are completing the tool. As the 
tool is heavily targeted towards young people 
(e.g. through targeted social media campaigns), 
we report the total number of unique users 
who complete this step of the tool, rather than 
segmenting the age of users.
Number of opportunities for young 
people to receive a digital learning 
experience at Vodafone
We report on the number of opportunities 
we offer to young people to receive a digital 
learning experience at Vodafone. This number is 
broken down into five categories, each of which 
is defined through consistent global guidelines 
(see table on the right).
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Opportunity
Sub-category
Definition
Direct hires
N/A
Any individual hired into full or part-time 
employment who is aged 26 or below at the 
point of joining Vodafone.
Workplace 
experience and 
training
Work experience
Offered to individuals between 14 and 19 
years of age. This is an opportunity to join 
Vodafone for up to one month unpaid to gain 
experience of the working world.
Digital learning workshops
Opportunities to gain a direct digital 
learning experience, facilitated by Vodafone. 
An example includes Vodafone Turkey 
Foundation’s Coding Tomorrow programme 
(see page 23).
#Codelikeagirl
Inviting girls aged 14–18 to learn how to 
code through a four-day workshop
Apprenticeship
N/A
Open to individuals aged 16+ who will 
join Vodafone to study for a professional 
qualification and work at the same time.
Internship
N/A
Open to individuals aged 18+, offering short-
term assignments from between one and 12 
months.
Graduate 
recruitment
N/A
Our Discover programme offers graduates a 
two-year placement with Vodafone, where 
they will rotate across business divisions.

3. Energy innovation
Overview
We report energy and greenhouse gas (GHG) 
emissions data for the following indicators:
–	 energy consumption by fuel source (in GWh);
–	 energy consumption by type (in GWh);
–	 renewable electricity consumption (as a 
percentage of total grid electricity);
–	 Scope 1 GHG emissions (in carbon dioxide 
equivalent (CO2e));
–	 Scope 2 GHG emissions (in CO2e) using both 
the location and market-based methods of 
calculation;
–	 Scope 3 GHG emissions (in CO2e);
–	 total GHG emissions Scope 1 and 2 (in CO2e); 
and
–	 total GHG emissions per unit of mobile data 
(in tonnes CO2e/petabyte data).
Standards and guidance
Our methodology for the reporting of GHG 
emissions has been developed using the 
following guidance and standards:
–	 GHG Protocol standards and guidance, 
including the Corporate Standard, Scope 2 
Guidance and Scope 3 Calculation Guidance; 
–	 CDP guidance including the 2018 Climate 
Change Responders Pack and the Technical 
Note on Accounting of Scope 2 Emissions; and
–	 the Climate Disclosure Standards Board 
Climate Change Reporting Framework.
Data gathering process and methods
We use an electronic data collection process to 
gather our data. In the majority of the countries 
where we operate, energy usage data is based 
on invoices from our energy suppliers. In some 
countries, those bills are based on the supplier’s 
estimated readings. 
Where data does not match our reporting period 
exactly – for example, where we only have 11 
months of data – we forecast this information by 
extrapolation. For sites where energy invoices 
are unavailable, we estimate this information 
based on typical site consumption.
Increasingly, we measure our energy 
consumption through smart metering, a 
technology that uses mobile communications to 
collect real-time consumption data from energy 
meters. 
Renewable electricity definition
Our figures for renewable electricity include all 
renewable electricity from third-party renewable 
suppliers which is traceable to Vodafone through 
a signed contract or provision of surrendered 
renewable energy certificates (RECs). The figures 
exclude any renewables for which RECs have 
been passed on and retired by a third party.
Scope 1
These are emissions within our direct control and 
include those from:
–	 diesel, petrol and other fuel used by cars and 
commercial vehicles owned by Vodafone or 
leased for six months or more;
–	 natural gas and other heating fuels used for 
space heating and hot water in our premises;  
–	 diesel and petrol used for generators in 
off-grid areas, or where back-up capacity is 
required; and
–	 fugitive releases of refrigerants or fire 
suppressants used for air-conditioning or fire 
control systems in network buildings and 
offices.
Conversion factors from the UK government’s 
Department for Business, Energy and Industrial 
Strategy have been used to calculate GHG 
emissions from other fuel sources such as diesel, 
petrol, natural gas and fuel oil as well as those 
from vehicles. A conversion efficiency of 30% has 
been used for diesel generators.
Scope 2
These are emissions from electricity (and heat/
steam) purchased to power our networks, 
technology centres, offices and retail stores. 
We report two different Scope 2 emission values: 
one using a ‘location-based’ method and one 
using a ‘market-based’ method. The location-
based method involves using an average 
emissions factor that relates to the grid on 
which energy consumption occurs. This usually 
relates to a country-level electricity emissions 
factor. The market-based method applies if 
the company has operations in any markets 
where energy certificates or supplier-specific 
information are available. The method involves 
using an emissions factor that is specific to 
the electricity purchased. We have reported 
Scope 2 figures using both the location-based 
and market-based methodologies.
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The following external factors have been used to calculate our market-based emissions.
Location-based emissions
Emissions are calculated using a kWh to CO2e 
conversion factor provided by the IEA for the 
calendar year 2017, which was the latest dataset 
available at the time of publication. 
Market-based emissions
Emissions are calculated using a kWh to CO2e 
conversion factor based on one of the following 
sources (in order of priority):
–	 supplier conversion factors specific to our 
contract; these include some markets where 
supplies are 100% renewable, and where 
this is this case, we have sought evidence of 
singularity of supply;
–	 residual mix figures for 2017 – where the 
conversion factor reflects the removal of 
certificates, contracts and supplier-specific 
factors claimed by other organisations; and
–	 location-based conversion factors as 
described above.
Scope 3
With the Carbon Trust, we have conducted an in-
depth analysis of our Scope 3 emissions. These 
are indirect emissions that we do not directly 
control but that we may be able to influence. 
They include emissions from our suppliers in 
providing us with goods and services; emissions 
from our joint ventures where do we not have 
full operational control; and emissions 
associated with the use of our products 
and services by our customers.
The GHG Protocol Scope 3 Standard defines 
15 categories of emissions as detailed in the 
table below. We have undertaken a qualitative 
assessment of the extent to which we can 
influence and reduce emissions in the most 
material categories. Further details of the 
methodology and results for each relevant 
category are also shown.
The estimation of Scope 3 emissions is a very 
approximate process. The values given in the 
table are not precise and are not intended to be 
read as absolute figures. Rather, they provide 
an indication of where the most significant 
emissions in our value chain arise and help 
us to target our action.
Local market
Source
Conversion factor 
(kg CO2e/kWh)
Albania
International Energy Agency (IEA)
Czech Republic
Supplier factor and residual mix
Zero and 0.614
DRC
IEA
Egypt
IEA
Germany
Supplier factors
Various
Ghana
IEA
Greece
IEA and residual mix
0.625
Hungary
IEA and residual mix
0.413
Ireland
Supplier factors
Zero and 0.641
Italy
Supplier factor and residual mix
Zero and 0.308
Lesotho
IEA
Zero and 0.465
Malta
Supplier factor and residual mix
0.443 and 0.661
Mozambique
IEA
New Zealand
Supplier factor
0.013
Portugal
Supplier factor and residual mix
0.411 and 0.383
Romania
Supplier factors
Various
South Africa
IEA
Spain
Supplier factor and residual mix
0.270 and 0.446
Tanzania
IEA
1.010 and IEA
Turkey
IEA
0.1500 and 0.3995
UK
Supplier factors and residual mix
0.210, 0.281 and 0.367

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GHG Protocol category
What does this mean for Vodafone?
Emissions 
(million tCO2e)
Methodology for assessment
Ability to influence
Purchased goods and services;
capital goods and services
Emissions from the extraction, production and 
transportation of goods and services purchased by 
Vodafone (includes capitalised goods and services).
4.0
Calculated using an environmentally extended economic input-output approach 
– this uses macro-economic modelling to determine the GDP value of different 
sectors of the economy, and to associate that with the GHG emissions incurred 
by those sectors. At its simplest, the total GHG emissions of the sector are divided 
by the total GDP value generated by the sector to produce an emission factor of 
x kgCO2e/€ value. By multiplying these emission factors by the amount we 
spend on goods and services in each sector, we can obtain a rough estimate of 
our emissions for purchased goods and services.  
High for some suppliers, more 
limited for others
Fuel and energy-related activities
Emissions from the extraction, production and 
transportation of fuels and energy purchased by Vodafone 
and not already included in Scopes 1 and 2. It includes 
emissions from electricity transmission and distribution.
0.7
Upstream fuel and energy emissions are calculated by applying emission factors 
produced by the UK Department for Environment, Food and Rural Affairs (DEFRA) 
to Vodafone fuel and energy consumption data.
Moderate
Upstream transportation and distribution
Not calculated as this category is not material.
Waste generated in operations
Disposal and treatment of waste generated by our activities.
0.0008
Calculated by applying emission factors from DEFRA to data for waste generated 
by Vodafone ready for treatment and disposal.
High
Business travel
Transportation of employees for business-related activities.
0.06
Calculated by applying emissions factors from DEFRA to distances travelled for 
business by different modes (air, rail and personal car).
High
Employee commuting
Not calculated as this category is not material.
Upstream leased assets
Operation of assets leased by Vodafone, including third-
party network sites. This includes the relevant sites leased 
from tower companies in Greece (Victus), Tanzania, Ghana 
and the UK (CITL). 
0.05
Emissions have been estimated either by dividing the cost of electricity and 
diesel for these sites by unit price/kWh, or by extrapolating based on the number 
of leased sites and an average emission value per site obtained from Vodafone-
owned sites.
Moderate
Downstream 
transportation and distribution
Not calculated as this category is not material.
Processing of sold products
Not relevant to Vodafone as we do not produce products for further processing.
Use of sold products
Emissions from the use of goods and services sold by 
Vodafone, principally from the energy used by network 
equipment, such as routers, and the energy required to 
charge mobile devices.
2.1
Calculated by multiplying the number of products sold by the energy usage for 
that product and electricity emission factors on a country basis. The total is the 
sum of all values.
Low
End-of-life treatment of sold products
Not calculated as this category is not material.
Downstream leased assets
Not relevant to Vodafone as we do not have equipment or assets that we own and lease to third parties.
Downstream leased assets
Not relevant to Vodafone as we do not have equipment or 
assets that we own and lease to third parties.
Franchises
Not calculated as this category is not material.
Investments
Operation of investments not included in Scope 1 or 2 – our 
joint ventures in Australia, Kenya, India and the Netherlands. 
6.0
For joint ventures in Australia, Kenya, India and the Netherlands, Scope 1 and 2 
emissions are based on actuals and Scope 3 emissions are extrapolated from 
Vodafone’s emissions. A percentage of emissions are reported based on our 
equity share. 
High

GHG savings for customers enabled by 
our products and services
Our Internet of Things (IoT) products and 
services help our customers to reduce 
electricity, gas and the consumption of other 
fuels through applications such as smart meters, 
road navigation systems, fleet management and 
mobile health. In each of these applications, our 
IoT services are providing connectivity, enabling 
our customers to reduce their GHG emissions. 
More examples are provided in the Energy 
innovation section of the Report.
To quantify the GHG savings for our customers 
enabled by our products and services, we have 
calculated – in conjunction with the Carbon 
Trust – the total quantity of emissions that 
we have helped our customers to avoid. The 
concept of the enabling effect of information 
and communications technology was introduced 
in the SMART 2020 report, and the methodology 
has since been developed by the Global 
e-Sustainability Initiative (GeSI) and others. The 
GeSI Mobile Carbon Impact Report has been 
used as guidance for many of our calculations, 
according to the Carbon Trust methodology. 
The starting point for the calculation is a 
list of our products and services that help 
customers avoid using energy or fuel. The full 
list is provided in the following table. For each 
product or service, a GHG-saving mechanism 
has been identified and quantified based on 
an external study, an internal Vodafone study 
or documented expert assumptions. For 
example, we know that smart electricity meters 
can typically reduce a domestic customer’s 
electricity usage by 3% per year – so the GHG 
abatement from one of our IoT smart meter 
connections is 3% of annual GHG emissions from 
a domestic home.
For each product and service, a unit of sale has 
been identified – for example, the number of 
smart electricity meter connections that we 
have sold. This unit of measurement is then 
multiplied by the GHG abatement savings for 
each type of application to provide the total 
saving for that application. The value for each 
product and service category is then added 
together to give the total GHG emissions abated 
by our technology.
It should be noted that a number of suppliers 
will contribute to providing an IoT application 
that enables a customer to avoid or reduce GHG 
emissions. We have not attempted to apportion 
emissions savings between ourselves and other 
suppliers in the value chain. We are careful in 
our reporting not to claim the avoided emissions 
as our own. Instead, we are clear that we are 
one of a number of parties who have helped our 
customers reduce their GHG emissions. Further 
details of products and services, the mechanism 
for abating emissions and the abatement factors 
used are provided in the table overleaf.
Reporting the ratio of the GHG emissions 
we help our customers reduce for every 
tonne of GHG we generate from our own 
operations
We report the quantity of GHG emissions that 
we are enabling our customers to avoid – as 
calculated by the methodology laid out above – 
as a ratio against that of our total Scope 1 and 2 
GHG emissions.
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IoT application
Description
GHG abatement mechanism
GHG abatement factor
Smart metering (domestic)
IoT-enabled meters, which regularly record utility 
consumption (gas, electricity or water) and communicate the 
information back to the energy or utility company to allow 
remote reporting.  
Smart meters are seen as an important tool to reduce domestic utility 
consumption and manage utility networks more efficiently. Many studies 
have demonstrated that the installation of smart meters and associated 
initiatives have resulted in energy consumption reductions.
Average electricity and gas usage reduction assumed is 3% 
per annum1.
Smart metering 
(commercial)
As per above but for commercial properties, which often 
have multiple smart meters to isolate different areas of 
consumption.
Smart meters in commercial property provide visibility to building 
managers as to where and when an organisation is consuming energy 
or water. Smart meters have been shown to lead to energy savings, as 
consumption can be optimised remotely. 
Average electricity and gas usage reduction assumed is 
16.8% per annum2.
Smart logistics and fleet management 
(bus)
Connected telematics system that consist of an in-vehicle 
unit (IVU) connected to a central server. This feeds back real-
time information on the GPS location of the vehicle, and may 
include other performance metrics such as fuel consumption 
and driver performance.
Connected buses can communicate with traffic light systems to prioritise 
bus routes, improving fuel efficiency. GPS location services can also be 
used to inform passengers of bus arrival times. Both features can help to 
increase bus patronage and improve emissions per passenger.
Fuel saving assumed is 6%. This is applied to average annual 
emissions for a bus.
Smart logistics and fleet management 
(cars)
Connected telematics system that consist of an IVU 
connected to a central server. Within a car fleet this is 
primarily used for satellite navigation and feedback on driver 
behaviour. Information may also be used for usage-based 
insurance. 
Fleet management systems may be used for optimised routing and 
avoiding congested areas, which directly reduces fuel consumption. 
Telematics systems can offer real-time feedback to drivers on their driving 
performance and behaviour. This technology is an enabler; the efficiency 
gains can only be realised if the driver acts in response to the feedback.
Fuel saving assumed is 6%. This is applied to average annual 
emissions for a car3,4.
Smart kogistics and fleet management 
(light and heavy goods vehicles (LGVs/
HGVs))
As per above but for LGVs and HGVs. Commercial vehicle 
applications include optimised delivery and dispatch routing, 
tracking of fuel consumption and monitoring of driver 
performance.
Optimised delivery and dispatch routing for goods vehicles ensures that 
unnecessary journeys are minimised, resulting in improved fuel efficiency. 
Telematics systems can offer real-time feedback to drivers on their driving 
performance and behaviour. This technology is an enabler; the efficiency 
gains can only be realised if the driver acts in response to the feedback.
Fuel saving assumed is between 2% and 10%, dependant 
on classification and application. This is applied to average 
annual emissions for an LGV or HGV.
Smart logistics and fleet management 
(Taxis)
Connected telematics system that consists of an IVU 
connected to a central server. This is usually connected to 
passenger mobile applications to locate and summon nearby 
taxis. Multiple users may be connected to pool journeys.
Carbon savings are achieved by taxis having fewer miles travelled without a 
customer, based on optimised central control and dispatch of the taxis.
Fuel saving assumed is 5%. This is applied to average annual 
emissions for a taxi.
Smart logistics and fleet management 
(smart bin)
IoT-enabled units within smart bins communicate with waste 
collection services to notify when they are full and prevent 
unnecessary journeys being made by waste collection 
vehicles.
The primary enablement mechanism is reduced journeys by waste 
collection vehicles, resulting in fuel savings.
Abatement factor of 5kgCO2e per smart bin was used5.
Street lighting
IoT-enabled street lighting allows variable levels of lighting, 
depending upon the time of day and extent to which people 
are nearby.
The carbon saving is achieved by avoiding the use of street lighting when 
it is not necessary. Lower levels of lighting may also be used in less busy 
areas.
Reduction in energy consumption of street lights assumed 
is 20%6.
Electric vehicle (EV) charging
IoT-enabled EV charging points interact with electric vehicles 
or driver mobile apps to direct drivers to the most appropriate 
EV charging point, giving drivers the confidence to carry out 
more journeys in EVs.
The use of an EV over a traditional fuel vehicle has significant carbon 
savings. It is assumed each EV journey provided by the charging point 
replaces a traditional fuel journey.
Annual distance driven was calculated from the charge 
provided by a charging point . The saving is the difference 
in emissions for that distance between an average petrol 
vehicle and an EV7.
Healthcare
Connected devices allow chronic or high-risk patients to 
be monitored within their own home. This prevents excess 
journeys to and from the hospital by both patients and 
healthcare professionals, and frees up hospital beds.
The emissions associated with one hospital stay are avoided by allowing 
the patient to remain at home. There are also the avoided emissions from 
not having to make the car journey to and from the hospital.
Assumed 42% reduction in hospital admissions8.

4. Supply chain integrity performance
Selection process for assessment
Any supplier that provides a product or service to 
Vodafone is screened for potential social, ethical 
and environmental risks, as defined by the Code 
of Ethical Purchasing. Existing or new suppliers 
are then selected for assessment depending on a 
number of different risks, including the supplier’s 
scale, the countries in which the activity takes 
place and the nature of the activity.
Suppliers to Vodafone who also supply two 
or more other members of the Joint Audit 
Cooperation (JAC) initiative (an association of 
telecom operators aiming to verify, assess and 
develop supply chain practices in the industry) 
are audited through JAC assessments. Vodafone 
audits are typically focused on suppliers of 
network infrastructure products and services, 
Vodafone-branded consumer equipment 
(such as mobile phones or set-top boxes) and 
Vodafone Automotive IoT products. We also use 
anonymous mobile phone-based surveys of 
workers to complement an on-site audit or as a 
standalone assessment.
Joint Audit Cooperation (JAC) 
assessments
JAC audits are reported on a calendar-year basis 
while Vodafone audits are reported on a financial 
year basis. The majority of JAC audits focus on 
suppliers in Vodafone’s supply chain.
The JAC audits are conducted by independent 
auditors paid for by the JAC member companies. 
Reports are issued in a standard format focused 
on verifying social, environmental and ethical 
factors. Audits that are funded and conducted by 
Vodafone on behalf of the JAC initiative are not 
reported under the total number of Vodafone 
audits to avoid double-counting.
The JAC companies hold quarterly steering 
committee meetings to review progress in 
remediating shortcomings identified in JAC audits.
Vodafone audits
Vodafone audits are conducted by either 
Vodafone’s internal auditors or by independent 
auditors on site at the supplier’s operation 
or factory using the JAC methodology and 
checklists. Follow-up audits are counted as 
individual audits.
Anonymous mobile phone-based surveys
Anonymous and confidential mobile phone-
based surveys of supplier employees and 
contractors are carried out by an independent 
survey service provider, Elevate, using 
pre‑recorded questions and an interactive 
voice response (IVR) system. The independent 
provider is present on site distributing calling 
cards directly to groups of workers in factories 
and other work sites. The mobile phone-based 
survey figures represent the number of unique 
mobile phone callers registering a survey 
response. The IVR questions are provided in 
audio form in the workers’ local language, and 
their responses are captured using touch-tone 
keypads. The service works on all mobile phones, 
including very low-cost basic devices.
Tier
In the context of the Sustainable Business 
Report, a ‘Tier’ is defined as the level of 
contractual separation between Vodafone and 
its suppliers downstream in the supply chain. 
Tier 1 is defined as a direct supplier to Vodafone 
with whom a contract or purchasing terms 
are established. Tier 2 is defined as an entity 
with whom a Tier 1 supplier has a contract or 
relationship. Tier 3 is defined as an entity that has 
a contract or relationship with a Tier 2 supplier, 
and so on for Tiers downstream in the supply 
chain. ‘Tier’ in this context does not signify 
strategic importance or segmentation.
5. Safety performance data
Safety data is collected by the local markets 
and then shared with the Group Health, Safety 
and Wellbeing team. The local market must 
report, record and investigate all incidents. An 
incident management system is used for the 
reporting, recording, investigation and action 
tracking of incidents.
Recordable fatalities
We report all fatal incidents related to our 
operations when – after investigation and 
review – we conclude that our controls were 
not operating as effectively as required. We also 
consider circumstances where it is reasonable 
to assume that if our controls could have 
been enhanced, the outcome may have been 
different, including potentially preventing the 
incident from occurring at all. We therefore 
report accidents both on our owned sites and 
also in areas that are outside our full control – 
for example, on public roads. We report every 
life lost within the control definition stated 
above, irrespective of the individual’s status – 
whether an employee, contractor, suppliers’ 
employee or contractor (of any Tier) or a 
member of the public.
Where a fatal incident is under investigation 
by national authorities, we are typically unable 
to gain access to the authorities’ findings, and 
therefore, unable to conclude our internal 
investigation or include in our reporting until any 
investigations are complete. We note any fatal 
incidents in our reporting that are still under 
investigation.
Lost-time incidents
Lost-time incident (LTI) is the term used when 
a Vodafone employee is injured while carrying 
out a work-related task and is unable to perform 
his or her regular duties for a complete shift or 
period of time after the incident.
The lost-time injury rate is calculated as the 
percentage of LTIs compared to the average 
number of employees over the reporting year.
1	 Energy Demand Report, 
Ofgem 
2	 Average figure used from 
a selection of case studies 
varying from 7.5% to 25% 
see BBP Better Metering 
Toolkit and ASB Bank and 
Vodafone M2M smart 
metering
3	 Various published and 
unpublished studies 
indicate savings from 
5–15%, dependant on level 
of intervention. Examples 
of some published sources: 
A guide to Telematics, 
Energy Saving Trust; 
Telematics Explained
FIAG; and Mix Telematics 
Furl Savings
4	 Abatement factor derived 
from Smart Bin case study 
5	 Abatement factor derived 
from Smart Bin case study
6	 Telensa city data and 
smart lighting
7	 Transport for London 
electric charging vehicle 
factsheet, 2014
8	 Telehealth interventions 
reduce hospitalisation 
by 55% and reduce A&E 
admissions by 29%. An 
average figure of 42% was 
used.
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Introduction
Transformation
Operating responsibly
Our people
Appendix

Independent Limited Assurance Report to Vodafone Group Plc
Grant Thornton UK LLP (‘Grant Thornton’ or 
‘we’) were engaged by Vodafone Group Services 
Limited to provide limited assurance to Vodafone 
Group Plc (‘Vodafone’) over the Subject Matter 
Information described below for the year ended 
31 March 2019. 
Limited assurance conclusion
Based on the procedures we have performed 
and the evidence we have obtained, nothing has 
come to our attention that causes us to believe 
that the Subject Matter Information has not been 
collated, in all material respects, in accordance 
with the Reporting Criteria.
This conclusion is to be read in the context of 
what we say in the remainder of this report.
Subject Matter Information
The scope of our work was limited to assurance 
over the information included within Vodafone’s 
Sustainable Business Report (‘the Report’) for 
the year ended 31 March 2019 as set out in 
Appendix 1 to our report (‘the Subject Matter 
Information’).
Our assurance does not extend to any other 
information that may be included in the Report 
or displayed on Vodafone’s website for the 
current year or for previous periods unless 
otherwise indicated.
Reporting Criteria
The Reporting Criteria used for the measurement 
or evaluation of the Subject Matter Information 
and to form our judgements are Vodafone’s 
Basis of Preparation as set out in the ‘Scope 
of reporting’ and ‘How we report our key 
performance indicators’ sections (together 
‘the Reporting Criteria’) of the Appendix of the 
Report.  The Subject Matter Information needs 
to be read and understood together with the 
Reporting Criteria.
Inherent limitations
Our procedures were designed to consider the 
collation of the Subject Matter Information and 
were not designed to test the underlying market 
level data. Our procedures were conducted at 
the Vodafone Group Head Office and remotely 
at Grant Thornton offices. Physical visits to other 
Vodafone locations did not take place.
The absence of a significant body of 
established practice on which to draw 
to measure or evaluate the Subject Matter 
Information allows for different, but acceptable, 
measurement or evaluation techniques 
and can affect comparability between 
entities and over time. In particular we 
draw attention to the methodological and 
assumption-based limitations Vodafone 
have disclosed in the Reporting Criteria.
Directors’ responsibilities
The Directors of Vodafone are responsible for:
–	 the design, implementation and 
maintenance of internal control relevant to 
the preparation and presentation of Subject 
Matter Information that is free from material 
misstatement, whether due to fraud or error;
–	 selecting and/or establishing suitable 
Reporting Criteria; 
–	 measuring or evaluating and presenting the 
Subject Matter Information in accordance 
with the Reporting Criteria; and
–	 the preparation of the Report and the 
Reporting Criteria and their contents.
Our responsibilities
We are responsible for: 
–	 planning and performing the engagement to 
obtain limited assurance about whether the 
Subject Matter Information has been collated 
in accordance with the Reporting Criteria; 
–	 forming an independent limited assurance 
conclusion, based on the work we have 
performed and the evidence we have 
obtained; and 
–	 reporting our limited assurance conclusion 
to Vodafone. 
Our independence, professional 
standards and quality control
We have complied with the independence 
and other ethical requirements of the Code of 
Ethics for Professional Accountants issued by 
the International Ethics Standards Board for 
Accountants which includes independence and 
other requirements founded on fundamental 
principles of integrity, objectivity, professional 
competence and due care, confidentiality and 
professional behaviour.
We apply International Standard on Quality 
Control (UK) 1, ‘Quality Control for Firms 
that Perform Audits and Reviews of Financial 
Statements, and Other Assurance and Related 
Services Engagements’ and accordingly we 
maintain a comprehensive system of quality 
control including documented policies and 
procedures regarding compliance with ethical 
requirements, professional standards and 
applicable legal and regulatory requirements.
Assurance standards and level 
of assurance
We performed a limited assurance engagement 
in accordance with International Standard 
on Assurance Engagements 3000 (Revised) 
‘Assurance Engagements other than Audits 
and Reviews of Historical Financial Information’ 
(ISAE 3000) and, in respect of the greenhouse 
gas emissions information included within 
the Subject Matter Information, in accordance 
with International Standard on Assurance 
Engagements 3410 - ‘Assurance Engagements 
on Greenhouse Gas Statements’ (ISAE 3410), 
issued by the International Auditing and 
Assurance Standards Board. These standards 
require that we plan and perform this 
engagement to obtain limited assurance about 
whether the Subject Matter Information is free 
from material misstatement.
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Introduction
Transformation
Operating responsibly
Our people
Appendix

A limited assurance engagement is 
substantially less in scope than a reasonable 
assurance engagement in relation to both 
the risk assessment procedures, including 
an understanding of internal control, and 
the procedures performed in response to the 
assessed risk which vary in nature from, and are 
less in extent than for, a reasonable assurance 
engagement.  Consequently, the level of 
assurance obtained in a limited assurance 
engagement is substantially lower than the 
assurance that would have been obtained had 
a reasonable assurance engagement been 
performed.  Accordingly, we do not report a 
reasonable assurance conclusion.
Work performed 
Considering the circumstances of the 
engagement our work included, but was not 
restricted to:
–	 assessing the suitability of the Reporting 
Criteria as the basis of preparation for the 
Subject Matter Information;
–	 assessing the risk of material misstatement 
of the Subject Matter Information, whether 
due to fraud or error, and responding 
to the assessed risk as necessary in the 
circumstances;
–	 conducting interviews with relevant 
Vodafone management and examining 
selected documents to obtain an 
understanding of the processes, systems and 
controls in use for collating and reporting the 
Subject Matter Information;
–	 performing selected limited substantive 
testing including agreeing a selection of 
the collated Subject Matter Information to a 
selection of the Vodafone market level data 
submissions submitted by Vodafone markets 
to the Vodafone Group Head Office;
–	 considering the appropriateness of a 
selection of selected carbon conversion 
factor calculations, and other calculations 
used by Vodafone to collate the Subject 
Matter Information including by reference 
to widely recognised and established 
conversion factors;
–	 re-performing a selection of selected 
calculations used by Vodafone to collate the 
Subject Matter Information;
–	 agreeing a selection of the relevant prior 
period and baseline data to previously 
reported data where these were used in the 
calculation of the Subject Matter Information, 
including re-performing a selection of the 
calculations; 
–	 performing analytical review procedures 
over the collated Subject Matter Information, 
including a comparison to the prior period’s 
amounts having due regard to changes in the 
business;
–	 evaluating the overall presentation of the 
Subject Matter Information; and
–	 reading the Report and narrative 
accompanying the Subject Matter 
Information in the Report with regard to the 
Reporting Criteria, and for consistency with 
our findings.
Intended use of this report
This limited assurance report, including our 
conclusion, is made solely to Vodafone in 
accordance with the terms of our engagement 
letter dated 18 March 2019. That agreement 
permits disclosure to other parties, solely for 
the purpose of Vodafone showing that it has 
obtained an independent limited assurance 
report in connection with the Subject Matter 
Information.  Our work has been undertaken 
so that we might state to Vodafone those 
matters we are required to state to them in an 
independent limited assurance report and for no 
other purpose. 
We have not considered the interest of any 
other party in the Subject Matter Information.
To the fullest extent permitted by law, we do not 
accept or assume responsibility and deny any 
liability to any party other than Vodafone for our 
work or this limited assurance report, including 
our conclusion.
 
Grant Thornton UK LLP
Chartered Accountants 
Reading 
31 May 2019 
The maintenance and integrity of Vodafone’s 
website is the responsibility of the Directors 
of Vodafone; the work carried out by us does 
not involve consideration of these matters 
and, accordingly, we accept no responsibility 
for any changes that may have occurred to 
the reported Subject Matter Information, the 
Report or the Reporting Criteria presented
on Vodafone’s website since the date of our 
limited assurance report.
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Introduction
Transformation
Operating responsibly
Our people
Appendix

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Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix
Subject Matter Information (Appendix 1)
The Underlying Subject Matter and Subject 
Matter Information are listed here.  The 
information in this Appendix needs to be read 
together with the attached limited assurance 
report and the Reporting Criteria.
Underlying Subject Matter 
Subject Matter Information 
Women’s empowerment
 
Progress towards our 50 million women goal: number of estimated additional female customers (million) (cumulative progress to date)
19.4
Women in senior leadership team (including ExCo members) (%)
28
Women in senior management (%)
28
Women in middle management (%)
31
Women (all non-management employees) (%)
40
Women in management and leadership roles (%)
31
Women in technology management and leadership roles (%)
21
Energy innovation
 
Vodafone energy use: Total (GWh)
5,582
Vodafone GHG emissions: Scope 1 (million tonnes CO2e)
0.26
Vodafone GHG emissions: Scope 2 (market-based method) (million tonnes CO2e)
1.74
Vodafone GHG emissions: Total Scope 1 and 2 (market-based method) (million tonnes CO2e)
2.00
Vodafone GHG emissions: Scope 3 (air travel only) (million tonnes CO2e)
0.06
Vodafone GHG emissions: Scope 2 (location-based method) (million tonnes CO2e)
1.91
Vodafone GHG emissions: Total Scope 1 and 2 (location-based method) (million tonnes CO2e)
2.17
Energy and GHG emissions: Electricity purchased from renewable sources (%)
15.4
GHG emissions per petabyte of mobile traffic on Vodafone’s mobile networks (tonnes CO2e/petabyte)
371
Number of total emissions avoided as a consequence of IoT technologies and services (million tonnes CO2e)
5.9
Ratio of GHG emission savings for customers to own GHG footprint (ratio)
2.9
Youth skills and jobs
 
Number of young people gaining experience of Vodafone’s digital workplace through apprenticeships
518
Number of young people gaining experience of Vodafone’s digital workplace through internships
974
Number of young people gaining experience of Vodafone’s digital workplace through the graduate programme
677
Number of young people gaining experience of Vodafone’s digital workplace through the work experience programme
46,833
Number of young people (under 26) directly hired by Vodafone
5,710
Progress towards our goal of providing 100,000 opportunities for young people to receive a digital learning experience at Vodafone 
(cumulative progress to date)
54,712
Number of Future Jobs Finder completions (cumulative completions to date)
478,986
Progress towards our goal of supporting 10 million young people to access digital skills, learning and employment opportunities 
(cumulative progress to date)
533,698

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Vodafone Group Plc Sustainable Business Report 2019
Introduction
Transformation
Operating responsibly
Our people
Appendix
Underlying Subject Matter 
Subject Matter Information 
Supply chain integrity and safety
 
Number of supplier site assessments conducted by the JAC
79
Number of supplier site assessments conducted by Vodafone
6
Number of sites assessed using a mobile survey of workers
12
Number of factory workers surveyed using mobile survey
1,693
Total recordable fatalities
2
Recordable fatalities – members of the public
0
Recordable fatalities – number of suppliers’ contractors/employees
2
Recordable fatalities – number of employees
0

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