Vodafone Group PLC

Sign up to access all our data and the evidence and analysis underlying our overall scores. Once you've created an account, we'll get in touch with further details:

Sign Up

Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Vodafone provides an unusually detailed picture of its climate-related advocacy. It identifies multiple concrete policy files it has engaged on – including the consultation of the Radio Spectrum Policy Group on the role of spectrum in cutting CO₂, the EU Energy Efficiency Directive, the EU Ecodesign & Energy Labelling regulation, BEREC’s work on environmental indicators, and elements of the European Green Deal such as Extended Producer Responsibility and the Circular Economy Action Plan – giving enough information to locate each initiative in time and jurisdiction. The company also spells out how it attempts to influence those files: it “responded to consultations on EU Ecodesign & Energy Labelling policy,” filed submissions to BEREC and the Radio Spectrum Policy Group, took part in European Commission-DG ENER workshops and technical roundtables, and held “bi-lateral discussions with relevant members of the European Commission,” thereby naming both the methods and the specific targets of its lobbying. Finally, Vodafone is explicit about the outcomes it is pursuing. It calls for spectrum rules that encourage investment in newer, more energy-efficient radio technologies and allow the phase-out of legacy networks; proposes that the Energy Efficiency Directive focus on the most energy-intensive data centres and establish a harmonised EU framework; and urges Ecodesign rules that require longer device lifetimes, higher repairability and greater use of recycled materials. This level of specificity across the policies addressed, the channels used and the changes sought demonstrates comprehensive transparency in the company’s climate-policy lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	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.	2