Committed to observing human rights
O2 Telefónica has made a commitment to respect and protect human rights all along the value chain.
“With the Declaration of Principles and the Human Rights Policy, we have made a clear commitment to upholding human rights and to assuming responsibility in our value chain. We are committed to identifying all the negative effects of our business activities on human rights and to remedying them.”
Claudia von Bothmer
Human Rights Officer Telefónica Deutschland
Human Rights Officer Telefónica Deutschland
As such, O2 Telefónica is not only observing the statutory requirements, but also its own understanding of values. The company makes a commitment to protecting human rights in a declaration of principles and its Human Rights Policy specifies the company’s obligations in this regard. The actions of O2 Telefónica are directed by the United Nations Guiding Principles on Business and Human Rights. The Management Board of O2 Telefónica bears responsibility for monitoring compliance with and implementation of the human rights due diligence. A cross-departmental human rights and environment committee promotes the topic within the company.
O2 Telefónica has been extending responsibility for upholding human rights to its suppliers and sub-suppliers too for many years now. The requirements for suppliers and sub-suppliers regarding the compliance of human rights are set out in the Supply Chain Sustainability Policy. Making supplier relations sustainable enables O2 Telefónica to first and foremost reduce the risk of any regulations being violated. A prerequisite for this is maximum transparency, which is to be achieved by analysing supply chain structures and identifying country-specific as well as product-specific risks.
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Reporting channel for complaints and whistleblowing
Even with the measures O2 Telefónica implements to protect human rights, violations cannot be entirely ruled out and it is possible that they are not adequately brought to the company's attention. O2 Telefónica puts a reporting channel for complaints and whistle-blowing on human rights and environmental violations at the disposal of all of its stakeholders. Information is treated in confidence and the human rights and environment committee follows up all reports. At the same time, the O2 Telefónica ombudsperson can be contacted anonymously via a confidential helpline at any time. Here, too, compliance with our privacy policies is a top priority.
Identifying human rights risks and areas of action
The German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG) requires companies to establish a risk management system for compliance with human rights and environmental due diligence. This also includes regular risk analyses and impact assessments, which the company carries out annually and, where necessary, also on an ad hoc basis. They are helping O2 Telefónica to understand how its business activities and relationships, as well as its products and services, affect people and the environment. The company examines its own business operations (every six months) and its direct supply chain (every year) and prioritises the risks from the perspective of the affected parties (inside-out perspective) and O2 Telefónica (corporate relevance). Based on the identified risks, O2 Telefónica implements targeted preventive measures and remedial actions. An efficient management system as well as guidelines and measures contribute to counteracting risks. The key sustainability risks in the supply chain of the international Telefónica Group relate to labour conditions, environmental impacts, and data protection and information security. O2 Telefónica is dedicated to environmental, social and, above all, human rights standards throughout the supply chain. To strengthen human rights in the supply chain, O2 Telefónica conducted on-site audits at selected suppliers’ premises in 2022, for example in the areas of employee health and safety and also data protection. Risk analyses are not new for O2 Telefónica. In 2018 and 2020, the company has already conducted targeted analyses for product and service categories, which have provided valuable insights into specific risks.
For mobile phones and accessories
O2 Telefónica analysed the product group of mobile phones and mobile phone accessories regarding human rights risks in 2018. The complex value chains of mobile phones are potentially affected by human rights violations. Reports on inadequate production conditions in the mining and processing of so-called conflict raw materials such as tin, coltan and gold are increasing and voicing criticism. All along its value chain – from the mining of raw materials to production and disposal – the company identified the key countries and determined the human rights risks that could potentially occur there. They were transferred into a heat map that shows the prioritised human rights risks. The main conclusions included the decision that O2 Telefónica would step up its involvement in the working groups of multi-stakeholder initiatives that in particular deal with human rights risks related to raw materials. The framework for this is provided by the Telefónica, S.A. Group’s membership of the Responsible Business Alliance, the Public-Private Alliance for Responsible Minerals Trade and the Joint Audit Cooperation. As a consequence of the risk analysis, O2 Telefónica coordinated the collaboration with the Telefónica, S.A. Group on the topic of human rights even more closely. A key topic of the intensified collaboration is communication regarding the supply chain audits, in particular the Joint Audit Cooperation checks. The measures since implemented include greater transparency requirements made of its business partners and greater involvement of the suppliers in the EcoVadis sustainability assessments. O2 Telefónica sees a particular need for action with regard to the responsible use of raw materials and products. For example, the company has since designed the O2 My Handy hardware offering to be more sustainable and complemented its commitment with its mobile phone recycling programme and the Eco Rating offer.
For services and works
In 2020 O2 Telefónica performed a human rights risk analysis for the product group of services and works, focusing on the service processes. The company selected this product group as it represents a large share of its total purchasing volume. Among other things O2 Telefónica examined the sectors of logistics, cleaning and building services, energy supply, customer service and call centres, temporary employment, and the installation and servicing of the telecommunications infrastructure and identified especially at-risk service sectors with the assistance of experts. The factors that foster risks include opaque subcontractor structures, false self-employment and illicit work. In some sectors, these lead to problematic labour conditions such as low pay, violations of working time regulations and health risks. O2 Telefónica derived risk-minimising recommendations for action from this.
Particular protection of children’s rights
O2 Telefónica devotes special attention to the protection of children and young people. The company's own human rights policy excludes child labour in its business activities and obliges all suppliers to exclude child labour along the supply chain. The actions of O2 Telefónica are guided in particular by UNICEF Children’s Rights and Business Principles. These ten principles define measures that companies can take to uphold and promote children’s rights. For information on the individual contributions O2 Telefónica makes here, see its commitments to children’s rights.