2022 Communication on Progress

MTN Group Limited

Published date

July 29, 2022

No. of questions

67

Supplemental files

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    Optional comment
    MTN through its annual integrated reporting suite issues statements about both the relevance of sustainable development to the company, and the impacts of its activities, both positive and negative on its stakeholders and the environment. This includes our annual Integrated Report, Sustainability Report, CDP Disclosure, and GRI Report. All of these reports are published on the company website. These reports are developed and supervised at the management level of the organization (Group Sustainability and Group Technology), and at Board level through the Group Social, Ethics, and Sustainability Committee, and ultimately by the Group Board. Our disclosures are guided by international best practices, including the United Nations Global Compact (UNGC), the Global Reporting Initiative (GRI) Standards, the Carbon Disclosure Project (CDP), the TCFD Recommendations, UN Guiding Principles on Business and Human Rights, the FTSE/JSE Responsible Investment Index Series, and the King Code of Governance Principles (King IVTM). The outcomes of discussions regarding sustainable development matters and performance against targets, are regularly reviewed and serve as inputs to discussion on current and future company strategy, business model, procedures and processes, as well as execution. The Board of Directors works closely with the management team to develop an informed view of MTN’s key short- and long-term business risks, including environmental, social and governance risks and opportunities. MTN has an established group-level risk management framework that it relies upon to identify, prioritize, and manage risks to the business. Identified risks are incorporated into a risk register, including any mitigation measures and the action owner within the organization. The risk register is compiled by a team of managers and reported to the Board. The materiality determination process is in line with recommendations of the Value Reporting Foundation’s Integrated Reporting Framework as well as of the Sustainability Accounting Standards Board. It considers materiality in terms of financial and ESG aspects.

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The following documents outline our stated commitments on human rights, labour rights, environment, and anti-corruption. Also, MTN has made a public commitment to reduce its greenhouse gas emissions 47% by 2030 and reach Net Zero emissions by 2040. MTN will be submitting an updated climate commitment to the Science Based Targets Initiative (SBTi) for validation. Our core belief is centred on creating value for all people in our footprint. This sets the tone for our commitment to respect and promote the rights of all people. We consider the rights of each stakeholder group and protection of these is articulated in relevant policies relating to our customers, employees, partners, suppliers and the communities in which we operate. Our customers’ human rights are addressed in a suite of policies including digital human rights, data privacy and protection, and information security. Our commitment to digital human rights is an integral part of our business strategy and sustainability framework and is embedded in the highest levels of our governance structures. Human Rights: https://group.mtn.com/wp-content/uploads/2020/09/MTN-position-on-Digital-Human-Rights-1.pdf Further efforts on how we protect the rights of our stakeholders can be found in our Transparency report. Transparency Report: https://group.mtn.com/wp-content/uploads/2022/04/MTN-Transparency-Report-2021.pdf MTN has policy commitments on labour practices, diversity and inclusion, and health and safety. MTN is committed to responsible labour practices across its footprint. We believe that diversity and inclusion as core to our identity and purpose, as a responsible business. And MTN has a Health and Safety Policy based on South African Legislation, ISO 45001 and ILO Standards. Labour Rights/ Decent Work: https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Labour-practices-1.pdf https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Diversity-and-Inclusion-1.pdf https://group.mtn.com/wp-content/uploads/2021/08/MTN-position-on-Health-and-Safety-1.pdf MTN manages environmental impact through an environmental management system and policy, which was reviewed in 2021 to align with the ISO 14001 Environmental Management Standard. Aligning with the ISO 14001 standard ensures all policies, processes and procedures in our environmental management system are effective. Using the standard also assures internal management, employees as well as external stakeholders that environmental risks and impacts are being measured adequately and improved. Our environmental management policy covers all significant risks and legal requirements across a broad range of environmental management categories, including our GHG emissions, waste, water, hazardous material management as well as targets and objectives. Environment: https://group.mtn.com/wp-content/uploads/2020/03/Eco-responsibility-Energy-and-Climate-change.pdf https://group.mtn.com/wp-content/uploads/2021/10/MTN-Eco-responsibility-Environmental-resources.pdf https://group.mtn.com/wp-content/uploads/2020/03/Eco-responsibility-Mobiles-and-Health.pdf https://group.mtn.com/wp-content/uploads/2020/03/Eco-responsibility-Networks-and-the-Environment.pdf https://group.mtn.com/wp-content/uploads/2021/02/MTN-Position-on-Water-Management.pdf Our governance philosophy, framework and ecosystem are grounded on the core elements of good governance, including transparency, integrity, sound policy, stakeholder participation, accountability and anti-corruption. Anti-Corruption: https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Anti-bribery-Corruption-and-Gifts-1.pdf https://group.mtn.com/wp-content/uploads/2020/03/MTN-position-on-Gifts-Hospitality-and-Entertainment-redesigned.pdf https://group.mtn.com/wp-content/uploads/2020/09/MTN-position-on-Whistleblowing-1.pdf https://group.mtn.com/wp-content/uploads/2020/03/MTNs-Group-position-on-Conflict-of-Interest-redesigned.pdf https://group.mtn.com/wp-content/uploads/2021/02/MTNs-Group-position-on-Fraud.pdf

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Yes, MTN has a code of conduct regarding all of the sustainability topics listed above. MTN’s codes of conduct cover employees, suppliers, and other business relationships. These codes are reviewed and approved by the Board and management on a regular basis. They are communicated to the relevant stakeholders upon engagement with MTN and are also available through our communication platforms. In addition, training is provided on a regular basis to employees, and increasingly to suppliers to ensure awareness and compliance, as well as to support behavioural change, where needed.

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    At the Board level, matters pertaining to human rights, labour rights, the environment, and anti-corruption are managed through the Group Social, Ethics, and Sustainability Board Committee, chaired by Nkululeko Sowazi. This committee performs an oversight and monitoring role to ensure that MTN’s business is conducted in an ethical and socially responsible manner. It also assists the Board with in driving the creation of shared value in a sustainable manner through responsible environmental, social and governance business practices across MTN’s operating markets. Members of the executive management team such as the Group President and CEO, Group Chief Sustainability and Corporate Affairs Officer, Group Chief Human Resources Officer, Group Chief Risk Officer, Group Chief Legal & Regulatory Officer, are invited to attend meetings to provide the committee with additional input. The management of the highlighted sustainability topics is also supported by the work of other management sub-committees such as the Road to Zero Committee, which is focused on identifying climate-related risks, tracking progress toward MTN’s net-zero commitment, and steering the company’s strategy and climate-related investment decisions. At the executive management level, MTN has a Group Chief Sustainability and Corporate Affairs Officer, who is responsible for reinforcing the implementation of MTN’s strategic priority to create shared value and the integration of ESG at the core of the business. Her main areas of focus are on decarbonising; rural connectivity; greater diversity and inclusion; enhanced stakeholder management; and protecting digital human rights. Our governance of climate change-related issues is driven from the highest level within the Group through our appointment of Nkululeko Sowazi as a designated climate change Board member responsible for climate change-related issues.

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    See answer to G4.

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    MTN has well-developed processes to assess risks. MTN’s directors and executives provide oversight using a combined assurance model which considers the role of management, control functions, internal and external audit, and the Board committees of subsidiaries. The Group Audit Committee is responsible for oversight of the implementation of combined assurance. The combined assurance model means there are numerous lines of defence to identify, prevent and mitigate risks and provide independent assurance to both the Group Exco and the Board either through the Group Audit Committee or the Group Risk Management and Compliance Committee. MTN takes an enterprise-wide approach to risk management which defines the processes and practices in place across MTN for management to proactively identify and manage risks and opportunities that impact strategic and operational objectives. We view risk management as a core competency by embedding a risk culture supported by top-down and bottom-up processes, ensuring completeness, proportionality to our business and the robustness of mitigating actions. MTN’s Board and its sub-committees oversee an integrated risk management process through regular engagement with management across a wide scope of activities to ensure the effectiveness of risk management. Opco-level risks are discussed at Opco exco and Opco audit and risk committees. These risk management processes include, amongst others: Human Rights, Labour Rights, Environmental Risks and Anti-Corruption.

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    The MTN Group Supplier Code of Conduct is a prerequisite for doing business with MTN. The Code commits the suppliers to respect and promote human rights and fair workplace practices, including equal opportunities, environmentally sustainable business activities, and a zero-tolerance policy to bribery and corruption. The supplier code of conduct can be found at the following link: https://group.mtn.com/wp-content/uploads/2020/07/Final-Supplier-Code-of-Conduct-March-2020_v2.pdf

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    We manage material sustainability matters by (1) identifying, (2) prioritising, (3) responding and (4) reporting on them: 1. Identify • We determine our material matters by considering matters of significant importance to our stakeholders and factors that receive the most management and Board attention during the year. These themes take into account: the priority interests of our key stakeholders and the impact of these on our strategy; the Group’s top risks and opportunities; and the context in which we operate. 2. Prioritise • These central themes then form the basis of discussion at workshops at which representatives of key departments participate. They prioritise the Group’s material matters by considering the scale and nature of their impact on business operations, financial performance and interest of our stakeholders. These are then scrutinised and ultimately endorsed by the CFO, CEO, the Executive Committee and then the Board. 3. Respond • We respond to our material matters by putting in place appropriate management actions to capitalise on those factors that offer opportunity for greater value creation as well as interventions to mitigate those which have the potential to disrupt it. We reference our material matters throughout the annual Integrated and Sustainability Reports. 4. Report • We report on the material matters identified to all our stakeholders, both internal and external through our annual sustainability reporting suite as well as a dedicated sustainability portal on our website.

    7.1. During the due diligence process, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    The MTN Group Supplier Code of Conduct is a prerequisite for doing business with MTN. The Code commits the suppliers to respect and promote human rights and fair workplace practices, including equal opportunities, environmentally sustainable business activities, and a zero-tolerance policy to bribery and corruption, which are the core sustainability principles for Joint Audit Corporation (JAC), where MTN is a member of along with other telecommunications operators. To ensure application and alignment to the Code, site audits are conducted under JAC, which represents more than 50% of the industry revenue. Among all the audits, 71% are conducted in tier 2, tier 3, and even tier 4 factories. From 2010 to 2021, 812 on-site audits have been conducted by JAC, impacting lives and ensuring working conditions of 107 151 workers in 40 countries. MTN has also joined the Global Enabling Sustainability Initiative (GeSI) - which works to facilitate real-world solutions to real-word issues by contributing towards a sustainable future, communicating the ICT industry’s corporate responsibility efforts and driving the sustainability agenda. MTN Group promotes ESG awareness and capacity building to educate our suppliers on our ESG policies and mechanisms in support of responsible business practices.

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    MTN has a whistleblowing policy which was updated in 2021, placing greater emphasis on creating a conducive environment for confidential and anonymous reporting to ensure no retaliation of any kind against anyone who makes a good faith report about possible misconduct or legal violations. Employees are required to raise their concerns and report wrongdoing within the workplace. The whistleblowing facility is operated independently by an outsourced service provider and is governed by the MTN Group Whistleblowing Policy. The Group’s whistle-blower hotline (tip-offs anonymous) is available to employees, suppliers and any external party wishing to report concerns safely and anonymously. All ethics-related concerns are reported quarterly by operating companies to Group Risk and Compliance. All fraud-related concerns are reported by operating companies to Group Internal Audit & Forensics.

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    Optional comment
    For example, the localised channels of the whistleblowing service are configured to provide callers with the ability to interact in their preferred local language as an example in Nigeria various local Nigerian languages are available (e.g. Yoruba, Igbo, or Hausa), including Nigerian pidgin.

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    MTN Group has linked the remuneration of senior executives with the Group’s environmental, social and governance (ESG) targets. This supports the delivery of our Ambition 2025 strategy, and in particular the strategic priority to ‘create shared value’, with ‘ESG at the core’. The variable elements of executive compensation – both short-term incentives (STIs) and long-term incentives (LTIs) – now depend on progress on three ESG goals: reaching Net Zero; enhancing diversity and inclusion; and extending rural broadband.

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    14

    Male (%)

    64

    Female (%)

    35

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    1

    Above 50 years old (%)

    13

    From minority or vulnerable groups (%)

    64

    Executive (%)

    86

    Independent (%)

    14
    Optional comment
    In the context of South Africa, Black South Africans are a group that has been historically disadvantaged. As such, they are considered a vulnerable group.

    13. Do you produce sustainability reporting according to:

    In addition to the above-mentioned frameworks, MTN also produces sustainability reporting that aligns to the recommendations of the United Nations Global Compact, the Ranking Digital Rights Index, and the Global Network Initiative.

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Non-financial information on certain aspects has been assured by PricewaterhouseCoopers. Non-financial information assured includes: • Employee sustainable engagement score • Calls to whistle-blower line • Net Promoter Score (NPS) percentages: South Africa • Net Promoter Score (NPS) percentages: Nigeria • Net Promoter Score (NPS) percentages: Other key markets • Total tax contribution The assurance statement and MTN’s definition of the KPIs assured are online at the following web address: https://www.mtn.com/wp-content/uploads/2022/04/MTN-Group-FY-21-Independent-Assurance-Report.pdf

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Commitment

    2. Does the company have a policy commitment in relation to the following human rights issues?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Rights of women and/or girls

    2021

    Freedom of expression

    2021

    Rights of refugees and migrants

    Digital security / privacy

    2021

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    While the full policies are not publicly available, relevant extracts from the policies have been summarized into the MTN positions statements which are available here: https://group.mtn.com/sustainability/our-positions/

    2.1. For each human rights policy, is it:

    Aligned with international human rights standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving human rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of expression

    Digital security / privacy

    Rights of women and/or girls

    Access to culture

    Rights of indigenous peoples

    Free, prior and informed consent

    Rights of refugees and migrants

    Access to water and sanitation

    Prevention

    3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing /mitigating the risks/impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    5. Who receives training for the following human rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    MTN’s due diligence framework has been drawn from the UN Guiding Principles for Business and Human Rights framework (Protect, Respect and Remedy). The framework outlines the steps that all MTN operations would follow before, during and after the occurrence of a digital human rights incident. Incidents would come in the form of a request or instance where an authority or non-governmental entity approaches MTN on a matter related to freedom of expression, data privacy and information security. This framework includes assessing potential incidents and potential impacts of the incidents that may affect customers’ rights and enabling our teams to respond to incidents through a clearly defined process that includes identifying remedies for affected customers. The same process is followed irrespective of whether it is a non-judicial government demand or court order from local or foreign government jurisdictions. Part of our digital human rights framework is disclosure and performance management, which includes transparency reporting and ranking digital rights. While we are making progress on multiple fronts, we recognise the role we must play in addressing critical issues such as gender equality, as illustrated by our pursuit of Ambition 2025 with ESG at the core.

    Response

    7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    In June and October 2021, MTN eSwatini was issued with two separate directives by the eSwatini Communications Commission (ESCCOM) to suspend its internet and social media services of its customers. After review and in adherence with its license conditions, MTN eSwatini complied with the directives. The suspension of service order was a first of its kind in the country. In order to validate the legality of the order for suspension of services, MTN eSwatini reviewed the legislation relied upon by the Regulator to impose the order and reviewed the license conditions and Constitution of Eswatini. Engagement with key stakeholders in the ICT sector and beyond took place regarding the directive and its implications on customers, business, and society at large. Following extensive engagements and measures, network connectivity was restored on the 10th day of the disruptions and customer remedies were implemented.

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    MTN has engaged in a range of actions to uphold human rights principles, including stakeholder engagement, awareness campaigns and even digital human rights impact assessments. Please refer to the MTN 2021 Transparency report for more details in this regard. MTN’s three-year programme, the Marshall Plan, is aimed at accelerating the execution of the information security strategy, was largely concluded at the end of the financial year as planned. The programme has strengthened our governance and controls across key aspects of the information security risk landscape. Multiple teams at Group and operating company level contributed to the progress made as well as the procurement and deployment of necessary management capabilities. Continuous improvement and performance management is, however, vital as the information and cybersecurity threat landscape continues to evolve. Our approach is to embed security by design in everything we deploy, which is a long-term architectural goal. While extensions to the Marshall Plan activities will continue into 2022, we are in the process of refreshing the security strategy in support of Ambition 2025 as well as the wider threat landscape. The security strategy will ensure we continue to enhance MTN’s overall security position. In 2021, we set up a Privacy Office and implemented a Group data privacy and protection programme to support the policy. Our objective is to embed a corporate standard of best practice for privacy. The Privacy Office provides oversight on data privacy across all our markets and is driven at Group level by a steering committee that includes operating company representatives. The data privacy and protection programme is coupled with an extensive change management programme engaging employees and customers. More information on our data privacy statement can be found at: https://group.mtn.com/wp-content/uploads/2020/09/MTN-position-on-Data-Protection-and-Privacy.pdf

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    2021

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    Optional comment
    MTN has policy commitments on labour practices, diversity and inclusion, and health and safety. MTN is committed to responsible labour practices across its footprint. We believe that diversity and inclusion as core to our identity and purpose, as a responsible business. And MTN has a Health and Safety Policy based on South African Legislation, ISO 45001 and ILO Standards. MTN’s health and safety policies and procedures have been continuously adapted to address the changing landscape of pandemic and its progression over the last 24 months. Compliance requirements for both the Group, operating companies and our employees were carefully outlined and communicated to ensure alignment in execution. In 2021, we continued to enhance our health and safety policies, procedures, and processes ensuring that they are continuously implemented, understood, periodically reviewed and communicated throughout the organisation. The aim is to comply with all applicable statutory requirements, or in the absence thereof, apply both local and international guidelines, including ISO 45001 and ILO standards, to ensure consistent compliance within MTN Group for the achievement of certification as a declaration of compliance. More information is available at: https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Labour-practices-1.pdf https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Diversity-and-Inclusion-1.pdf https://group.mtn.com/wp-content/uploads/2021/08/MTN-position-on-Health-and-Safety-1.pdf

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Further information is available on MTN”s labour position statement: https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Labour-practices-1.pdf as well as the Supplier ode of Conduct: https://group.mtn.com/wp-content/uploads/2020/07/Final-Supplier-Code-of-Conduct-March-2020_v2.pdf

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    MTN has policy commitments on labour practices, diversity and inclusion, and health and safety. MTN is committed to responsible labour practices across its footprint. We believe that diversity and inclusion as core to our identity and purpose, as a responsible business. And MTN has a Health and Safety Policy based on South African Legislation, ISO 45001 and ILO Standards. MTN’s health and safety policies and procedures have been continuously adapted to address the changing landscape of pandemic and its progression over the last 24 months. Compliance requirements for both the Group, operating companies and our employees were carefully outlined and communicated to ensure alignment in execution. In 2021, we continued to enhance our health and safety policies, procedures, and processes ensuring that they are continuously implemented, understood, periodically reviewed and communicated throughout the organisation. The aim is to comply with all applicable statutory requirements, or in the absence thereof, apply both local and international guidelines, including ISO 45001 and ILO standards, to ensure consistent compliance within MTN Group for the achievement of certification as a declaration of compliance. More information is available at: https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Labour-practices-1.pdf https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Diversity-and-Inclusion-1.pdf https://group.mtn.com/wp-content/uploads/2021/08/MTN-position-on-Health-and-Safety-1.pdf

    Forced labour

    MTN has policy commitments on labour practices, diversity and inclusion, and health and safety. MTN is committed to responsible labour practices across its footprint. We believe that diversity and inclusion as core to our identity and purpose, as a responsible business. And MTN has a Health and Safety Policy based on South African Legislation, ISO 45001 and ILO Standards. MTN’s health and safety policies and procedures have been continuously adapted to address the changing landscape of pandemic and its progression over the last 24 months. Compliance requirements for both the Group, operating companies and our employees were carefully outlined and communicated to ensure alignment in execution. In 2021, we continued to enhance our health and safety policies, procedures, and processes ensuring that they are continuously implemented, understood, periodically reviewed and communicated throughout the organisation. The aim is to comply with all applicable statutory requirements, or in the absence thereof, apply both local and international guidelines, including ISO 45001 and ILO standards, to ensure consistent compliance within MTN Group for the achievement of certification as a declaration of compliance. More information is available at: https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Labour-practices-1.pdf https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Diversity-and-Inclusion-1.pdf https://group.mtn.com/wp-content/uploads/2021/08/MTN-position-on-Health-and-Safety-1.pdf

    Child labour

    MTN has policy commitments on labour practices, diversity and inclusion, and health and safety. MTN is committed to responsible labour practices across its footprint. We believe that diversity and inclusion as core to our identity and purpose, as a responsible business. And MTN has a Health and Safety Policy based on South African Legislation, ISO 45001 and ILO Standards. MTN’s health and safety policies and procedures have been continuously adapted to address the changing landscape of pandemic and its progression over the last 24 months. Compliance requirements for both the Group, operating companies and our employees were carefully outlined and communicated to ensure alignment in execution. In 2021, we continued to enhance our health and safety policies, procedures, and processes ensuring that they are continuously implemented, understood, periodically reviewed and communicated throughout the organisation. The aim is to comply with all applicable statutory requirements, or in the absence thereof, apply both local and international guidelines, including ISO 45001 and ILO standards, to ensure consistent compliance within MTN Group for the achievement of certification as a declaration of compliance. More information is available at: https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Labour-practices-1.pdf https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Diversity-and-Inclusion-1.pdf https://group.mtn.com/wp-content/uploads/2021/08/MTN-position-on-Health-and-Safety-1.pdf

    Non-discrimination in respect of employment and occupation

    MTN has policy commitments on labour practices, diversity and inclusion, and health and safety. MTN is committed to responsible labour practices across its footprint. We believe that diversity and inclusion as core to our identity and purpose, as a responsible business. And MTN has a Health and Safety Policy based on South African Legislation, ISO 45001 and ILO Standards. MTN’s health and safety policies and procedures have been continuously adapted to address the changing landscape of pandemic and its progression over the last 24 months. Compliance requirements for both the Group, operating companies and our employees were carefully outlined and communicated to ensure alignment in execution. In 2021, we continued to enhance our health and safety policies, procedures, and processes ensuring that they are continuously implemented, understood, periodically reviewed and communicated throughout the organisation. The aim is to comply with all applicable statutory requirements, or in the absence thereof, apply both local and international guidelines, including ISO 45001 and ILO standards, to ensure consistent compliance within MTN Group for the achievement of certification as a declaration of compliance. More information is available at: https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Labour-practices-1.pdf https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Diversity-and-Inclusion-1.pdf https://group.mtn.com/wp-content/uploads/2021/08/MTN-position-on-Health-and-Safety-1.pdf

    Occupational safety and health

    MTN has policy commitments on labour practices, diversity and inclusion, and health and safety. MTN is committed to responsible labour practices across its footprint. We believe that diversity and inclusion as core to our identity and purpose, as a responsible business. And MTN has a Health and Safety Policy based on South African Legislation, ISO 45001 and ILO Standards. MTN’s health and safety policies and procedures have been continuously adapted to address the changing landscape of pandemic and its progression over the last 24 months. Compliance requirements for both the Group, operating companies and our employees were carefully outlined and communicated to ensure alignment in execution. In 2021, we continued to enhance our health and safety policies, procedures, and processes ensuring that they are continuously implemented, understood, periodically reviewed and communicated throughout the organisation. The aim is to comply with all applicable statutory requirements, or in the absence thereof, apply both local and international guidelines, including ISO 45001 and ILO standards, to ensure consistent compliance within MTN Group for the achievement of certification as a declaration of compliance. More information is available at: https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Labour-practices-1.pdf https://group.mtn.com/wp-content/uploads/2021/02/MTN-position-on-Diversity-and-Inclusion-1.pdf https://group.mtn.com/wp-content/uploads/2021/08/MTN-position-on-Health-and-Safety-1.pdf

    Working conditions (wages, working hours)

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Holistic wellness and care of our employees is pivotal to our cultural operating system. We focused on several wellbeing initiatives in 2021, in continuation from the previous year, keeping in mind the evolution of the pandemic and its impact on the physical, mental, and social challenges experienced by people across our markets. Initiatives included our Global Health Monitor to track infections and recoveries, staff care support for employees affected by COVID-19 in some markets and special dispensation leave for self-care. We also invested in initiatives to manage the emotional wellbeing of MTNers. The challenges of remote work have impacted lives of our global workforce. Challenges have ranged from managing multiple priorities in work, life and healthcare, dealing with stress and digital fatigue. During the year, we conducted several surveys to identify key areas that employees are struggling with. The wellness team has been instrumental in addressing novel issues arising from the COVID-19 pandemic, working from home, and building a health and wellness culture. As part of the enhanced experience, we have identified five wellbeing pillars, our Wellbeing High 5, that will allow employees to focus on building mindful, healthy and balanced lives at home and at work. These pillars are: • Emotional and mental wellbeing • Physical wellbeing • Financial wellbeing • Career wellbeing • Social wellbeing. Each month we focus on one pillar, sharing ideas, initiatives and information to improve that specific wellbeing pillar and help our employees to adapt the new normal. We have a zero-tolerance approach to harassment and discrimination. This is supported by proactively creating awareness of what harassment and discrimination look like and MTN’s policy. Following the launch of the antiharassment policy in the previous year, senior leadership at MTN promoted awareness, highlighting the central tenants of the policy. An easily accessible SharePoint repository of all company policies is available to all employees. Our e-learning platform is another important tool in educating MTNers, providing animated, consumable, creative training on policies including those that cover the employer-employee relationship. Through the platform, we provide mandatory training touching on several human resource-related policies, including our anti-harassment policy, alongside other relevant topics such as our leave policy, grievance policy and our disciplinary code and policy. This training focuses on socialisation and creating awareness and outlines MTN’s stance on incidents related to harassment and discrimination, with a clear illustration of the negative effects of harassment in the workplace. We receive feedback from employees who access our policies through SharePoint and engage through our e-learning platform to develop additional initiatives based on their feedback. Nine incidents of workplace harassment or discrimination were reported in the year under review. Appropriate course correction and management action has followed.

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    The MTN Supplier Code of Conduct defines minimum standards that our suppliers and their employees and subcontractors must respect and adhere to when conducting business with MTN. The objective of this Code is to provide summarised information detailing the required minimum standards expected of every supplier in their interaction with MTN and its employees. Refer to our Supplier Code of Conduct: https://group.mtn.com/wp-content/uploads/2020/07/Final-Supplier-Code-of-Conduct-March-2020_v2.pdf

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Please see additional comment below

    Child labour

    Please see additional comment below

    Non-discrimination in respect of employment and occupation

    Please see additional comment below

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    MTN leverages strategic memberships such as Joint Audit Cooperation (JAC) and Global e-Sustainability Initiative (GeSI) to embed ESG considerations within our supply chain. Physical site audits on tier 1 suppliers and their respective supply chains will support MTN in safeguarding a responsible and sustainable supply chain. These audits include assessing elements relating to the relevant labour risks described above.

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    10

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    10

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    29

    Non-executive board

    29

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    25

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0.24

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0.0019

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    MTN is not aware of its involvement in incidents where it has caused or contributed to adverse impacts associated with labour rights issues.

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Holistic wellness and care of our employees is pivotal to our cultural operating system. We focused on several wellbeing initiatives in 2021, in continuation from the previous year, keeping in mind the evolution of the pandemic and its impact on the physical, mental, and social challenges experienced by people across our markets. Initiatives included our Global Health Monitor to track infections and recoveries, staff care support for employees affected by COVID-19 in some markets and special dispensation leave for self-care. We also invested in initiatives to manage the emotional wellbeing of MTNers. The challenges of remote work have impacted lives of our global workforce. Challenges have ranged from managing multiple priorities in work, life and healthcare, dealing with stress and digital fatigue. During the year, we conducted several surveys to identify key areas that employees are struggling with. The wellness team has been instrumental in addressing novel issues arising from the COVID-19 pandemic, working from home, and building a health and wellness culture. As part of the enhanced experience, we have identified five wellbeing pillars, our Wellbeing High 5, that will allow employees to focus on building mindful, healthy and balanced lives at home and at work. These pillars are: • Emotional and mental wellbeing • Physical wellbeing • Financial wellbeing • Career wellbeing • Social wellbeing. Each month we focus on one pillar, sharing ideas, initiatives and information to improve that specific wellbeing pillar and help our employees to adapt the new normal. We have a zero-tolerance approach to harassment and discrimination. This is supported by proactively creating awareness of what harassment and discrimination look like and MTN’s policy. Following the launch of the antiharassment policy in the previous year, senior leadership at MTN promoted awareness, highlighting the central tenants of the policy. An easily accessible SharePoint repository of all company policies is available to all employees. Our e-learning platform is another important tool in educating MTNers, providing animated, consumable, creative training on policies including those that cover the employer-employee relationship. Through the platform, we provide mandatory training touching on several human resource-related policies, including our anti-harassment policy, alongside other relevant topics such as our leave policy, grievance policy and our disciplinary code and policy. This training focuses on socialisation and creating awareness and outlines MTN’s stance on incidents related to harassment and discrimination, with a clear illustration of the negative effects of harassment in the workplace. We receive feedback from employees who access our policies through SharePoint and engage through our e-learning platform to develop additional initiatives based on their feedback. Nine incidents of workplace harassment or discrimination were reported in the year under review. Appropriate course correction and management action has followed.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2021

    Water

    2021

    Oceans

    2021

    Forests / Biodiversity / Land Use

    2021

    Air Pollution

    2021

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    2021

    Energy & Resource Use

    2021
    Optional comment
    MTN manages environmental impact through an environmental management system and policy, which was reviewed in 2021 to align with the ISO 14001 Environmental Management Standard. Aligning with the ISO 14001 standard ensures all policies, processes and procedures in our environmental management system are effective. Using the standard also assures internal management, employees as well as external stakeholders that environmental risks and impacts are being measured adequately and improved. Our environmental management policy covers all significant risks and legal requirements across a broad range of environmental management categories, including our GHG emissions, waste, water, hazardous material management as well as targets and objectives. The policy is supported by a supplementary management practice document that outlines the minimum standards that operating companies are required to comply with as well as a one-page policy summary to be put up in offices across our footprint. The supplementary document and one-page policy summary will be shared with operating companies and all employees in 2022. This Group-wide policy will gradually align all our operations with international environmental best practices, which will ultimately enable all operating companies to obtain ISO 14001 certification. We will prioritise companies with higher impacts for certification.

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    47% reduction of Scope 1 and Scope 2 emissions by 2030 and Net Zero by 2040.

    Energy & Resource Use

    >15% sites powered by renewable energy by 2030

    Water

    Develop water baseline

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Develop waste baseline

    Oceans

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    3083099

    Scope 2 Emissions

    Emissions (tCO2e)

    825170

    Scope 3 Emissions

    Emissions (tCO2e)

    4103038

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    8. Has the organization acted to support climate change adaptation and resilience?

    Optional comment
    In 2021, we took decisive steps towards our commitment to achieve Net Zero by 2040. This included improving our GHG emission measurement methodologies, developing Net Zero strategies for key operating companies, and engaging with various partners to reduce our emissions throughout the supply chain. In 2021, we called on our suppliers to: • Set targets in line with science-based target guidelines for their organisations and publicly communicate their commitment. • Report progress on reducing GHG emissions using the CDP system and share emissions data, at product and service level. • Embed GHG emission reduction at both product development and service delivery level. • Ensure their suppliers are aware of this call to action so that it can then be cascaded through their supply chain, actively building the capacity of local suppliers in the process. • Support the Eco Rating of each device and actively support our activities to provide life cycle product services to customers including trade-ins and recycling options. • 208 Group-wide suppliers have pledged to join MTN’s road to Net Zero to reduce Scope 3 emissions, exceeding our initial target of 150 Group-wide suppliers. • 87 of our suppliers’ subcontractors are also heeding the call to action on climate change from their suppliers. • 135 suppliers have set targets, including those that account for 38% of the Group’s supplier spend. • 48% of supplier spend covered by suppliers with SBTi targets. • 90 suppliers report in line with the Carbon Disclosure Project. The full letter is available at https://mtn-investor.com/mtn-road-to-zero/pdf/letter-to-partners-mtn-road-to-zero-signed.pdf

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Optional comment
    In 2021, we took decisive steps towards our commitment to achieve Net Zero by 2040. As part of this commitment, we worked on various technology requests for proposals (RFP) to introduce new suppliers into our supplier network who offer our operating companies more sustainable technology alternatives.

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Sector-specific: Forest, biodiversity, and land use

    14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

    Number

    Unknown

    Not applicable (Please provide additional information)

    Sites

    Hectares

    15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

    Conversion of natural resources (hectares)

    16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

    No

    No, but we plan to in the next 2 years

    Yes

    Forest ecosystem restoration

    Planting of tress in Cote d’Ivoire and Rwanda

    Other ecosystem restoration

    Reforestation

    220 Hectare reforestation project in Uganda

    Natural regeneration

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    Other (please specify in text box)

    Recycling, reuse, reduce waste initiatives

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    MTN has undertaken the following practical actions to manage our environmental impact: Green office programme: The programme helps our operations and office environments to identify how to conserve resources, reduce consumption and ensure responsible waste, recycling and upcycling management practices. E-waste: Our primary source of waste generation includes electronic and electrical waste included in our upstream and downstream supply chain (e.g. radio transmission equipment, batteries, lighting, computers, consumer devices, cellular handsets, SIM cards). Water consumption: MTN is not regarded as an intensive water user, as is the case throughout the telecommunications industry. We do not regard our operations as having a significant impact on water resources, although reducing water use forms part of MTN’s Sustainability Strategic Framework to reduce the Company’s environmental impact.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2021

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Prevention

    3. Who receives training on anti-corruption and integrity?

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    4. Does the company monitor its anti-corruption compliance programme?

    MTN’s Whistleblowing policy was updated in 2021 placing greater emphasis on creating a conducive environment for confidential and anonymous reporting to ensure no retaliation of any kind against anyone who makes a good faith report about possible misconduct or legal violations. The Group’s whistle-blower hotline (tip-offs anonymous) is available to employees, suppliers and any external party wishing to report concerns safely and anonymously. All ethics-related concerns are reported quarterly by operating companies to Group Risk and Compliance. All fraud-related concerns are reported by operating companies to Group Internal Audit & Forensics. Two thirds of the operating companies’ ethics officers are formally certified through the University of Stellenbosch, so far. In 2018, the ethics function was moved to risk and compliance, ensuring strong risk management skills of the full-time ethics officers.

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    Confirmed during the current year, and related to this year

    Optional comment
    We report the number of fraud cases and ethics related concerns and queries: MTN 2021 Sustainability report, page 76 https://www.mtn.com/wp-content/uploads/2022/04/MTN-Group-FY-21-Sustainability-Report.pdf

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    During the year, 147 supplier participants associated with seven operating companies participated in the Ethically Aware Supplier Induction training programme. In addition, Group Risk and Compliance (Ethics office) together with Group Forensic Services collaborated with our global sourcing and supply chain division to conduct ethics and fraud awareness training for a large contingent of MTN Group as well as GlobalConnect suppliers and vendors. The training also covered the MTN Group Supplier Code of Conduct. Our vendor awareness sessions were attended by 60 participants in South Africa and 670 in Dubai. MTN ranked at the 71st percentile by The Ethics Institute compared to 52 other organisations on Southern Africa.

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    MTN’s Whistleblowing policy was updated in 2021 placing greater emphasis on creating a conducive environment for confidential and anonymous reporting to ensure no retaliation of any kind against anyone who makes a good faith report about possible misconduct or legal violations. The Group’s whistle-blower hotline (tip-offs anonymous) is available to employees, suppliers and any external party wishing to report concerns safely and anonymously. All ethics-related concerns are reported quarterly by operating companies to Group Risk and Compliance. All fraud-related concerns are reported by operating companies to Group Internal Audit & Forensics. Two thirds of the operating companies’ ethics officers are formally certified through the University of Stellenbosch, so far. In 2018, the ethics function was moved to risk and compliance, ensuring strong risk management skills of the full-time ethics officers.