Human Rights Management

At Airtel we believe that economic value cannot be sustained unless it is created on a foundation of
ethics and responsibility. Respecting the human rights of stakeholders across our value chain is one of
our core priorities, which begins through responsible action at our own operations. Creating a safe and
empowered workplace with a culture that drives equal opportunity, non-discrimination, meritocracy
and freedom of expression is paramount to us. Similarly, we ensure that our business activities do not
adversely impact any of our external stakeholders such as our suppliers, partners, customers and the
wider community.

Our commitment to human rights is reinforced through our Code of Business Conduct (COBC), as well as
guided by U.N. Universal Declaration of Human Rights and International Labor Organization’s
declaration on Fundamental Principles & Rights at Work. While these provide the guidelines for
responsible business conduct at a global level, our policies are shaped and customized by local
regulations. Our Human Rights policy is applicable to all employees across the organization, while the
code of conduct for business associates and vendor compliance policy details the requirements for
partners and suppliers to uphold and respect human rights.

Human Rights Risk Management

Training: All employees undergo a training on the COC and other Airtel policies at the time of induction
as well as an annual refresher training, to ensure that employee behavior is in line with the principles
upheld by the company. This serves as the first step towards our commitment to prevent risks related to
human rights.

Due Diligence: In order to identify potential risks, we have a human rights due diligence process which is
conducted annually through Airtel’s group wide compliance monitoring. This entails undertaking a
detailed monitoring at 100% of our sites including all business functions, to track performance on
various human rights related subjects such as working conditions, minimum compensation, equal
opportunity, privacy and information security, freedom of association etc. including labour laws of the
country.

Airtel also regularly tracks human rights issues prevalent across the business sector to update the
potential risks which are monitored internally. In addition to this an independent audit is conducted
periodically to assess the statutory risks pertaining to human rights and any observations are promptly
reported and remediated.

These assessments also enable us to identify ‘risk hot spots’ or areas where potential human rights
issues can occur in our operations, as well as target group of stakeholders i.e. groups most vulnerable to
the identified risks.

Ombuds process: We have a robust ombuds process which allows employee, contractors and vendors,
to raise a grievance or complaint without any fear of reprisal. Every complaint is addressed through
prompt action. Moreover, the ombuds team does a trend analysis basis the complaints received to
identify the root causes and accordingly highlight any existing risks of human rights violations to the
management.
Sexual Harassment: In order to prevent sexual harassment in workplace, the company has set up
Internal Complaints Committees across geographies comprising of a Presiding officer who is a senior
level woman employee, one member with legal knowledge or experience in social work, one member
from the Ombuds office and one independent member from outside the organization with expertise and
experience in dealing with such cases. The committee constitution is communicated to all employees
and is also prominently displayed in the public areas of all offices.

Risk Identification in Value Chain

It is our endeavor to not only prohibit undesirable practices but to not associate with any partner who is
in dissonance with our principles of ethical practices. Every vendor/supplier before on-boarding,
undergoes a comprehensive screening where compliance to labour laws and human rights such as child
labour, working conditions, remuneration, freedom of association, health and safety practices etc. is
assessed. The suppliers post on-boarding are assessed at regular intervals to ensure timely identification
of any existing risks and they are free to raise any concerns/issues through our Ombuds process.

Since stakeholder engagement is decentralized at Airtel, employees are accountable for managing
relationships, meeting expectations and thus upholding the human rights of all stakeholders within their
areas of responsibility. There are a number of opportunities that allow stakeholders to report grievances
/issues which are appropriately addressed. These complaints are also assessed to identify any prevalent
risks related to human rights in our value chain or occurring due to our operations, products and
services.

Risk Addressal

The risks identified in own operations or in the value chain are addressed through implementation of
appropriate corrective actions which can range from risk prevention through awareness sessions and
precautionary measures, risk reduction through building capacity and safeguards or risk elimination
through modifications in the business process or termination of contract.

Cases of human rights violations are dealt as per our consequence management policy and can include
warnings, counselling, penalties and even termination of employment depending upon the severity of
violation. In the reporting year, 100% of sites were assessed for risks of human rights violations and no
material violations have been reported.

No incidences of child labour, forced labour or discrimination were reported in FY 2018-19. 23 cases of
sexual harassment were reported out of which allegations were substantiated in 19 cases. These were
addressed through counselling, written warning or termination.