The online Vodafone Group Sustainability Report 2013/14 (the Report) has been prepared by the management of Vodafone, who are responsible for the collection and presentation of the information within it. Our responsibility, in accordance with Vodafone management’s instructions, is to carry out a limited assurance engagement on the following subject matter:

Collection, consolidation and presentation of:

Sustainability data relating to:

  • Energy
  • Carbon (CO2) emissions
  • Greenhouse gas (GHG) emissions
  • Network waste
  • Fatalities
  • Lost time incidents (LTIs)
  • Gender diversity

Tax disclosures relating1 to:

  • Direct revenue contribution: taxation
  • Direct revenue contribution: other non-tax
  • Indirect revenue contribution
  • Capital investment
  • Direct employment

The balance and accuracy of claims made in the following sections of the Report, marked with an Ernst & Young footnote:

  • Environmental footprint
  • Health and safety
  • Our people – diversity & inclusion
  • Human rights
  • Tax and our total contribution to public finances1
  • Privacy and security – Vodafone’s alignment with the industry dialogue guiding principles on freedom of expression and privacy

Our responsibility in performing our assurance activities is to the management of Vodafone Group only in accordance with the terms of reference agreed with them. We do not accept or assume any responsibility for any other purpose or to any other person or organisation. Any reliance any such third party may place on the Report is entirely at its own risk.

What we did to form our conclusions

Our assurance engagement has been planned and performed in accordance with the International Federation of Accountants’ International Standard for Assurance Engagements Other Than Audits or Reviews of Historical Financial Information (ISAE3000). The subject matter has been evaluated against the following criteria:

  • Coverage of the material issues determined through a review of documentation and an assessment of coverage against Vodafone’s own materiality process.
  • Consistency of performance claims and selected data with underlying company level documentation and explanation provided by relevant managers.
  • Completeness of the data in terms of coverage of material reporting entities.
  • Accuracy of data collation and presentation (including limitations) of data within the report.

In order to form our conclusions we undertook the steps outlined below:

  1. Interviewed Vodafone executives and senior managers to understand the current status of social, ethical, environmental and health & safety issues, and understand the progress made during the reporting period.
  2. Reviewed Vodafone’s representation of material issues included in the ‘in scope’ sections of the Report. We re-assessed prior year conclusions on the coverage of material issues and conducted media analysis across the reporting period to enable us to test the coverage of topics within this year’s Report.
  3. Reviewed information or explanations supporting Vodafone’s reporting of progress in the ‘in scope’ sections of the Report. Supporting documentation was sought and reviewed for a sample of 75 sustainability performance claims.
  4. Reviewed the collection, consolidation and presentation of data relating to energy; CO2 emissions; GHG emissions; network waste; fatalities; LTIs and gender diversity. This included:
    1. Interviewing staff responsible for managing, collating, and reviewing data at group level for internal and public reporting purposes.
    2. Testing evidence provided by Group to support the reported figures, for example, reviewing energy and GHG emissions calculation spreadsheets, incident reports for a sample of safety incidents and HR dashboards for diversity data.
    3. Remotely reviewing energy and network waste data reported by six operating companies (OpCos) on a sample basis, to assess whether the data had been collected, consolidated and reported accurately. The six OpCos selected for review were Egypt, Germany, India, South Africa, Turkey and Italy.
    4. Testing whether energy; carbon; GHG emissions; network waste; fatalities; LTIs and gender diversity data has been collected, consolidated and reported appropriately at Group level.
    5. Reviewing a selection of management documentation and reporting tools including guidance documents.
    6. Reviewing the Report for the appropriate presentation of the data including the discussion of limitations and assumptions relating to the data presented.
  5. Reviewed the narrative and supporting data in the tax section of the Report in order to confirm consistency with the online publication from December 2013. The worksteps that we undertook in order to form our conclusions can be found in the tax report from December 2013 (pdf, 143 KB).

Level of assurance

Our evidence gathering procedures have been designed to obtain a sufficient level of evidence to provide a limited level of assurance2 in accordance with ISAE3000.

The limitations of our review

  • Our work included headquarters based activities and limited remote testing of six OpCos for Environmental data and six OpCos for tax disclosures.
  • Our review was limited to the following sections of the Report which is found in the sustainability section of the Vodafone Group website on Environmental footprint; Health and safety; Our people – diversity and inclusion; Human rights; Tax and our total contribution to public finances; and Privacy and security – Vodafone’s alignment with the industry dialogue guiding principles on freedom of expression and privacy. Our review covered a limited number of claims selected on a risk basis and only the pages marked with an Ernst & Young verification footnote formed part of our assurance.
  • As part of our scope in 2013/14 we reviewed Vodafone’s alignment with the Telecommunications Industry Dialogue Guiding Principles on freedom of expression and privacy. Our review was limited to assessing whether relevant policies and procedures are in place and did not extend to assessing Vodafone’s implementation or effectiveness of these within the business.

Our conclusions

Based on our review:

Balance and accuracy of sustainability performance claims

  • Nothing has come to our attention to suggest that the claims on performance in the sections of the Report included within our scope of review are not fairly stated.
  • We are not aware of any material aspects of Vodafone’s sustainability performance which have been excluded from the Report.


  • With the exception of the points below, we are not aware of any OpCos that have been excluded from the environmental, safety, diversity and tax data presented in the Report.
    • 2013/14 network waste figures exclude data from the following OpCos: Ghana, India, Qatar and Tanzania.


  • Nothing has come to our attention that causes us to believe that the data included within the scope of our review has not been collated and presented properly in the Report.
  • With the exception of the points below we are not aware of any matters that would materially affect the data presented in the Report.
    • 2013/14 energy, CO2 and GHG emissions data for Ghana has been estimated using 2012/13 figures.

Observations from our work

Our detailed observations and areas for improvement will be raised in a report to Vodafone management. The following observations do not affect our conclusions on the Report as set out above.

Safety performance

  • Vodafone has continued to make improvements to its safety performance during the reporting year. However, the number of fatalities and LTIs remain high, particularly relating to traffic incidents. Vodafone needs to continue its focus on workforce safety in order to achieve further progress.

Environmental Data

  • We noted an improvement in the review activities conducted by the OpCos to support the accuracy and completeness of the data submitted to Group. This included clear accountability and sign off for material KPIs.
  • Reporting network waste remains a challenge in a number of markets. This is set in the wider context of immature waste infrastructure in many emerging markets. Vodafone should consider providing more information in the future into how it is supporting local governments and SMEs to support this important area.

Progress against targets

  • With limited targets in place Vodafone needs to consider how to communicate its sustainability ambition and measure progress. It will need to consider how this can be done across both mature and emerging markets so as to engage the business and create ownership to help deliver the long term ambition.


  • Vodafone has demonstrated a positive intention to engage its stakeholders and the public in relation to the tax and economic contribution that the business makes.
  • This is the second time that Vodafone has sought to report such a detailed level of tax data. We have noted several process improvements in how the data required for the Report has been gathered, reviewed and consolidated. This included:
    • A formal and documented methodology in place that sets out the process for data collection.
    • Local teams were provided with sufficient time and improved guidance to enable effective collation of country data.
    • The local reporting template is more intuitive to use due to improved instruction and providing greater detail within captions.
  • Consideration could be given to further improvements to the level of automation used to extract and consolidate the data.

Our independence

This is the fourth year that Ernst & Young LLP has provided independent assurance services in relation to the Vodafone Group Sustainability Report. We have provided no other services relating to the sections of Vodafone Group’s Sustainability Report which are included within our scope of work.

Our assurance team

Our assurance team has been drawn from our global Climate Change and Sustainability Services and Tax network, which undertakes engagements similar to this with a number of significant UK and international businesses.

Ernst & Young LLP


June 2014


  1. Tax disclosures within the Report were previously reported in December 2013 and were subject to a separate independent assurance statement (pdf, 143 KB) by Ernst & Young LLP.
  2. The extent of evidence gathering procedures for a ‘limited level’ of assurance is less than that of a ‘reasonable’ assurance engagement (such as a financial audit) and therefore a lower level of assurance is provided.
  3. These observations are also found in the tax assurance statement in December 2013 (pdf, 143 KB).