Vodafone Group PLC

Vodafone has put in place a defined governance process to align its climate-related lobbying, with responsibility placed on its Group External Affairs team and senior executives but without a clear mechanism for indirect lobbying or an independent audit. Specifically, "Vodafone's policy engagements are governed and coordinated by Group External Affairs," and the company requires that "any policy engagement regarding energy and climate change must follow our environmental policy requirements which set out our position on energy and climate change," indicating a formal policy to shape direct lobbying. External affairs professionals receive training on these requirements, and "annually, as part of our environmental data collection process, we ask all markets to describe the engagements they have taken place in," providing a recurring monitoring step. Oversight sits with the Executive Committee and ultimately the Board, which "established an Environment, Social, and Governance ('ESG') Committee in 2021," and the "Chief External and Corporate Affairs Officer, a member of the Executive Committee, is the sponsor for the Planet agenda ... and has overall accountability for climate change action within the Group." However, we found no evidence of a similar process for indirect lobbying through trade associations or a publicly available audit or third-party review of its climate‐lobbying alignment compliance.