Letter from the CEO

21 July 2022

To our stakeholders:

I am pleased to confirm that Airtel Africa reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.
Airtel Africa is a business that is driven by the purpose to ‘transform lives’ – it lies at the heart of our decision making and is a genuine passion of my own. As an African business, we recognise the opportunities this continent has to offer: the talent of the people it nurtures and the potential for responsible development. But we are also aware of the challenges that communities across the continent face. Challenges such as climate change, a lack of access to basic education and healthcare services, and poor infrastructure in rural areas impacting digital communication and financial inclusion.

Our sustainability strategy has four focused pillars – each with specific and measurable goals or commitments. It is designed to reduce as well as mitigate our impact on the environment and to support communities through digital access. We believe that this will help to develop a sustainable future for individuals, families, communities and businesses across Africa. A sustainable future that is built on increasing equality through digital and financial inclusion, through ensuring children have access to vital education and through the provision of rewarding employment for people across the continent.

We have worked closely with our stakeholders to ensure that this strategy is ambitious, robust and credible. We have been guided by their feedback and will continue to engage regularly and listen carefully to their views. This collaborative approach underpins all the work we will deliver through our strategy. We will look to collaborate across the industry, recognising that by working together, we will be able to drive greater impact for the people who need it most. We plan to publish our first Sustainability Report later in 2022 where we shall provide more detail about the work we undertake to further integrate and embed sustainability into our operations and the progress we have made in the past year.

Sincerely yours,

Olusegun Ogunsanya
Chief Operating Officer
Airtel Africa plc

At Airtel Africa, we have clear business standards with stakeholder interests at their core. Our broadly drafted Code of Conduct covers respect for human rights to data privacy, and to acting lawfully. This sets out our high expectations for how all of us at Airtel Africa should act in ways that create value for, and build trust among, our many stakeholders. Furthermore, our sustainability strategy is aligned with six the UN SDGs and supported by goals and active policies to respect human rights, drive positive social impacts, protect the natural environment and conserve resources.

In our Code of Conduct 2021 we state that we will conduct our business in a way which respects human rights. We are committed to combatting any form of slavery, trafficking, child labour, forced labour, inhuman treatment or working conditions that are a threat to life or hinder the physical, emotional and/or mental wellbeing of a person.

At Airtel Africa, we ensure that all of us embrace the strength of our differences. We provide equal access to opportunity and treat each other with respect and care. We foster sensitivity and open communication and measure performance of employees only on the basis of their achievements and contribution towards organisational objectives. We are focused on building a workplace that promotes diversity and appreciates individual differences. We require that our business partners also abide by these commitments and monitor our business partners’ commitment to respect for human rights on an ongoing basis.

We are committed to providing an inclusive culture and work environment where each employee has an equal opportunity to reach his/her maximum capacity. We encourage cultural inclusion and diversity in our workforce which are reflected in our sustainability strategy under the pillar ‘Our people’.

The work we deliver through our sustainability strategy is aligned to the UN SDGs and address three of our priority material topics:

1. Labour management: we are committed to providing every one of our people with a fulfilling and rewarding work environment that provides a path for career development and personal growth.

2. Employee health and safety: we recognise our responsibility to ensure the highest levels of health and safety for all our employees and to create and maintain an appropriate health and safety management system.

3. Diversity and inclusion: a genuine commitment to diversity and inclusion lies at the heart of our culture. We will build on this to create even more opportunities regardless of gender, ethnicity, religion, or disability.

Under our sustainability strategy, we have four ongoing commitments around ‘Our people’ which we implement through our strategy:

1. Diversity and inclusion: we achieve this through recruitment and programmes to provide training and advancement for everyone regardless
of gender, nationality or disability.

2. Training and development: we do this through upskilling and reskilling initiatives to ensure our people can succeed in their future careers. We are also
committed to supporting female entrepreneurs through training and increasing women’s participation in the technology and engineering sectors.

3. Healthy and safe work environment: we achieve this through the introduction of a best practice social and health and safety management system, improved policies and full compliance with all legislation and regulation.

4. Employee engagement: we will continue to listen to our people through the introduction of the additional channels that provide every one of our people with a voice.

We monitor our progress and will report in more detail in the Sustainability Report 2022. Meanwhile, our Code of Conduct and Sustainability Strategy can be found on our corporate website www.airtel.africa/

The Health and Safety across our operations is key to a sustainable business. We are committed to have in place procedures and policies that will ensure the health and safety of our employees and all other individuals within our premises while complying with governing legislation.

At Airtel Africa, we recognise that sustainable business leadership can only be achieved through a productive workforce, operating in a safe and healthy environment. We therefore devote necessary effort and investment in ensuring the health and safety of all our employees and business associates operating within any of our office locations and facilities. Health and Safety is an essential part of our risk management. It is the responsibility of everyone to maintain a clean and organised workspace that does not present any hazard to oneself, colleagues, customers or other partners/visitors, as well as neighbours.

Furthermore, we are committed to eliminating hazardous and non-hazardous waste from our operations under our long-term goal ‘Environmental stewardship’ by 2040 which means that we shall be eliminating the end-of-life lead-based batteries to protect the environment and wellbeing of our people and communities where we operate. While we carry out the reduction of the lead-based batteries, we take the utmost care of our employees and contractors ensuring they work in a safe workplace.

In addition to guaranteeing all employees a decent wage, benefits, inclusive work environment and safe working conditions, we also updated our reward policy. This is based on our robust performance management system and incentivise our employees through a variable pay component.

All of the above mentioned measures and programmes contribute to maintaining the high standards of human rights within the organisation.

We adhere to International Labour Organisation's (ILO) best practices, UN Human Rights practices, UN Global Compact’s 10 principles and legislative requirements within each of our operating units.

Our Modern slavery statement can be found on our corporate website www.airtel.africa/

We are an equal opportunity employer and are committed to creating a safe and conducive work environment that enables employees to work without fear of prejudice, gender bias and/or sexual harassment. We strictly prohibit sexual harassment or any other form of harassment. We do not tolerate any threats of harm – either direct or indirect – or any conduct that harasses, disrupts or interferes with another employee’s work or performance, or creates an intimidating, hostile work environment.

We also encourage freedom of association and labour representation across our workforce. We recognise that trade unions help employees feel protected and defend their interests. Therefore, we regularly engage with and cooperate with recognised trade unions in all our markets. We strive to ensure appropriate representation through recognised unions and collective bargaining agreements across our entire business.

The Code of Conduct requires all of us to act ethically and to always comply with legal requirements, putting our principles into practice in everything we do. Everyone who works for Airtel Africa is required to report suspected breaches of the Code of Conduct, including via the Airtel Africa anonymous and confidential whistleblowing hotline reporting service – online and phone reporting hotline in a local language, which is prominently communicated to our workforce and contractors on a regular basis. Every report submitted is assessed and investigated.

Our whistleblowing programme is a confidential channel through which employees can report unethical practices or wrongdoing. We have an independent whistleblowing process managed by an external professional services firm from their Centre of Excellence in South Africa. Throughout the reporting period, the Audit and Risk Committee received updates on the volume of reports, key themes emerging from these reports and the results of related investigations. We assess the reports for the category and level of concern and consider these in line with a protocol for review, investigation, action, closure and feedback. This is done independent of management where necessary but involving senior business unit or HR management as appropriate. We continue to monitor the volume, geographic distribution and range of reports made to the hotline to understand key themes, the results of investigations undertaken, significant regional compliance concerns, and whether access to this facility is less understood or publicised in some countries.

During the 12 months ended 31 March 2022, we investigated 74 incidents received through various customer touch points and our formal whistleblowing channels. These were of varying magnitude, with two above the Executive Committee threshold. One was investigated by an external partner. The very small number of reports that contained allegations of a breach of our Code of Conduct were thoroughly investigated and disciplinary action was taken where appropriate. The majority of reports received during the period were human resources issues which indicated no compliance concerns or serious breaches of our Code of Conduct.

The Audit and Risk Committee’s chair reports to the Board at each of its meetings on the operation of our Code of Conduct, anti-bribery and corruption and whistleblowing procedures. This report contains enough detail to enable the Board to oversee these areas and make sure arrangements are in place for a proportionate and independent investigation of related matters and for follow-up action.

Every year we run campaigns and conduct mandatory online training to ensure that our employees are aware of the whistleblowing mechanism – for ease of reference, there are posters with the hotline number available in each OpCo and data centre where it is displayed in conspicuous areas. It was also set as a screen saver on company computers and regular reminders are sent to the workforce electronically.

More information is available in our Annual Report and Accounts 2021/22 which can be found on our corporate website www.airtel.africa/

Our ambition under the environmental sustainability pillar is to address and minimise the impact of our operations on the environment.
Our ultimate goal is to achieve net zero greenhouse gas (GHG) emissions ahead of 2050. To achieve this we must fully identify, measure and reduce our GHG emissions which can only be achieved in partnership with our peers and the wider industry.

Recognising the impact of the climate crisis on Africa, we acknowledge the responsibility to limit our environmental impact. We are focused on reducing our direct carbon emissions and are investigating ways to optimise our operational energy efficiency. We fully support the 2015 Paris Agreement to limit global temperature rises below 1.5°C, and the GSMA Task Force defining the emission reduction pathway for the telecoms industry.

Our updated security, environment, social and H&S policy reflects our commitment.

As part of our sustainability strategy, under the pillar 'Our environment; we set ourselves two long-term goals: 'Reduction of GHG emissions' and 'Environmental stewardship' both focussing on climate change and circular economy. These goals include programmes to improve the energy efficiency of products, services and processes, replace damaging materials, expand recycling schemes and build employees’ awareness around protection of natural resources. To ensure the delivery of our commitments, we have defined our environmental management framework that will be underpinned by: developing and publishing our standalone environmental policy, creating and incorporating our environmental management system, obtaining certification ISO-14001 for our environmental management system in the coming years, and establishing our environmental risk management system. Work is underway to achieve these commitments.

Since the launch of our sustainability strategy in October 2021, we have been carrying out internal assessments, collecting data and working with the Carbon Trust, the leading global environmental consultancy, to evaluate our current Scope 1, 2 and 3 emissions and establish a carbon accounting policy, which will guide our approach to carbon accounting and provide an overview of Scope 1, 2 and 3 emissions. It will allow us to accurately set our baseline emissions ahead of target-setting. We have also carried out high-level analysis to identify carbon hotspots in our operations and functions, which will be focus points for our decarbonisation programme. This is essential foundation work for our ‘Pathway to net zero’ strategy, which we will launch ahead of our first Sustainability Report, due to be published later in 2022.

Furthermore, we undertook a thorough gap analysis and assessment of our current disclosure readiness and maturity against the TCFD’s four thematic areas – governance, strategy, risk management, and metrics and targets – as well as against the 11 underlying recommendations. The results of this assessment are published on pages 54-58 of our Annual Report and Accounts 2021/22.

We also worked on raising awareness of our environmental focus among our workforce in 2021/22 so that our commitments are further embedded in our culture. We encourage our employees and business partners to help reduce environmental impact through mutual understanding of policies and implementation guidelines, building awareness for our partners and customers on environmentally friendly practices. One of our long-term sustainability goals ‘Supply Chain’ focusses on aligning our ESG policies and criteria with those of our partners and suppliers: we are undergoing detailed reviews and will require annual certification for our vendors to confirm their adherence with our ESG policies and procedures.

We have also appointed Environmental and Social Lead who reports to the Chief Strategy, Partnerships and Sustainability Officer.

We consciously improve resource consumption, efficiency and minimise waste generation through prevention, reduction, recycling and reuse within our operations.

Our progress and implementation of the environmental goals is monitored and reviewed by the Sustainability Committee which meets monthly and will be reported in more detail in our first Sustainability Report 2022. We shall publish our decarbonisation plan ‘Pathway to net zero’ later in 2022 and ahead of our Sustainability Report 2022.

Our Code of Conduct clearly states that Airtel Africa has zero-tolerance to bribery and corruption. Consequently, Airtel Africa employees shall at all times act with integrity ensure that all decisions are based on legitimate considerations. In building and maintaining relationships with various stakeholders, our employees focus on creating trust and mutual respect based on the principles laid down in the Code of Conduct.

We make it clear to all third parties that Airtel Africa has zero-tolerance to bribery and corruption. We accurately reflect the true nature of transactions and expenditure to ensure improper payments are not made, offered, solicited or received. Any breach or suspected breach should be reported to the Airtel Africa Ombudsperson.

Furthermore, minimising the risk of fraud is one of the key priorities for our Internal Assurance team, and we take a range of actions to do this. These include assessing the quality of balance sheet reconciliations, key judgement matters, tenders and quotations, and controls over payments and associated applications. We continue to focus on limiting our potential exposure to bribery and corruption risks, for example by providing mandatory training, reviewing financial records and developing our policies and procedures.

We also have policies covering operational, compliance, corporate responsibility and stakeholder matters, including ones related to the Bribery Act 2010 and anti-corruption – these are updated as necessary in line with developments in corporate governance and legislation. In line with the Bribery Act 2010, we have written policies on avoiding and not tolerating bribery or corruption. These apply across all our businesses and can be found on our website www.airtel.africa. All employees are trained in anti-bribery and anti-corruption to help mitigate the risk of reputational damage, financial penalties and possible exclusion from certain approved partnerships.

Our contract management system includes mandatory certification to our Code of Conduct and anti-bribery and corruption policy. Each year, every employee must take part in computer-based training on anti-bribery and corruption and our Code of Conduct. Our Internal Audit team reviews our anti-bribery compliance programme to assess its continued effectiveness. We will continue to assess bribery risks in our markets to refine and improve our anti-bribery compliance programme. The Audit and Risk Committee also monitors and oversees procedures around allegations of improper behaviour and employee complaints.

We operate in diverse legal and regulatory environments. Establishing and maintaining adequate procedures, systems and controls enables us to comply with our obligations for the services we provide to our customers in all the jurisdictions where we operate. We are required to comply with Know Your Customer, anti-money
laundering, anti-bribery and corruption, sanctions, data privacy, quality of service and other laws and regulations. We know that failure to comply could lead to unanticipated regulatory penalties and sanctions or tax levies, as well as damage to our reputation. To prevent breaches, we focus on instituting various policies across the Group to comply with legal requirements in jurisdictions where we operate, continuing engagement with regulators and industry bodies on key policy matters, implementing a regular compliance tracking process, identifying root causes for cases of non-compliance and taking corrective actions, implementing an escalation process for reporting significant matters to the Group office, and communicating with and training employees on relevant company policies.

Our external auditor is Deloitte LLP (UK). We work very closely with our external auditor to monitor controls and compliance with policies and procedures.

We continue to operate with openness and transparency, and a spirit of robust challenge when necessary, to make sure our shareholders and other stakeholders are protected. We also ensure all employees have mandatory training in compliance areas such as our Code of Conduct, anti-bribery and corruption, and information security. We also have policies focused on anti-bribery and corruption, whistleblowing and data protection (GDPR) setting out the ethical framework that all companies and employees are expected to follow. Each year, our employees receive up-to-date training on legislative and regulatory matters.

For more detailed information, refer to our Annual Report and Accounts 2021/22.