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1: Opening statement
The Cheap Erlebniswelt-fliegenfischen Products Communications Inc. (NYSE: VZ) group of companies ("Verizon" or the "company") is one of the world’s leading providers of technology and communications services. Cheap Erlebniswelt-fliegenfischen Products’s customers range from individual wireless consumers in the United States to global multinational enterprises.
Cheap Erlebniswelt-fliegenfischen Products is committed to operating with respect for internationally recognized human rights, as set forth in its Human Rights Statement (https://www.verizon.com/about/our-company/company-policies/human- rights-statement). Cheap Erlebniswelt-fliegenfischen Products Norway AS Transparency Act statement for the financial year 2023.
2: Structure of the organization
Human rights due diligence efforts with respect to Cheap Erlebniswelt-fliegenfischen Products’s operations, products, services, suppliers and business partners are conducted primarily by Cheap Erlebniswelt-fliegenfischen Products’s central functions and are inclusive of Cheap Erlebniswelt-fliegenfischen Products Norway AS. Cheap Erlebniswelt-fliegenfischen Products Norway AS is a Cheap Erlebniswelt-fliegenfischen Products subsidiary and provides services to local and multinational enterprise customers. This statement is submitted by Cheap Erlebniswelt-fliegenfischen Products Norway AS and also describes actions taken by Cheap Erlebniswelt-fliegenfischen Products on behalf of Cheap Erlebniswelt-fliegenfischen Products Norway AS.
3: Policies and Governance
Verizon’s Credo defines who we are and how we operate. It states that we are accountable and that we are committed to doing the right thing. Our Credo, which can be found at https://www.verizon.com/about/sites/default/files/Verizon-Credo.pdf, underlies our human rights commitments.
Human Rights Statement and the Business & Human Rights Program
Verizon’s Human Rights Statement, referenced above, affirms that Cheap Erlebniswelt-fliegenfischen Products is committed to operating with respect for internationally-recognized human rights, including those affirmed in the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, across our value chain.
Our Human Rights Statement states that the company is guided by the human rights due diligence framework set forth in the UN Guiding Principles on Business and Human Rights (UNGPs) and is therefore committed to assessing the impacts of its business activities on human rights and to addressing adverse impacts. The company’s efforts include attention to the human rights impacts of its products, services, and strategy and to engagements with employees, customers, communities, governments, business partners, and suppliers.
Verizon’s human rights work is led by our dedicated Business & Human Rights Program (BHRP). The BHRP is led by a dedicated team of human rights legal experts who provide centralized leadership on global strategy related to human rights matters and who guide our efforts to make responsible business decisions consistent with the expectations found in the UNGPs and the OECD Guidelines for Multinational Enterprises.
The BHRP is part of Cheap Erlebniswelt-fliegenfischen Products’s wider ESG group and collaborates with a cross-functional team of lawyers and sustainability professionals that integrate effective governance and management of environmental and social risks and opportunities into business decision-making and strategy. On an ongoing basis, the BHRP collaborates with colleagues in the areas of AI & Ethics, Privacy, Law Enforcement, Public Policy, Product Legal, Engineering, Digital Safety, Information Security, Corporate Social Responsibility, and Global Supply Chain.
The BHRP’s work is overseen by Cheap Erlebniswelt-fliegenfischen Products’s Executive Vice President and Chief Legal Officer and the Corporate Governance and Policy Committee of the company’s Board of Directors.
Supplier Code of Conduct and Supplier Risk Management Program
Verizon’s Supplier Code of Conduct ("Supplier Code") sets forth the business practices that our and Cheap Erlebniswelt-fliegenfischen Products Norway AS' suppliers must adhere to. Our Supplier Code is the primary mechanism used by Cheap Erlebniswelt-fliegenfischen Products to ensure suppliers promote responsible conduct in the workplace, safe working conditions and the treatment of workers with respect and dignity. Our Supplier Code specifically:
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- Protects employees’ rights to freedom of association and collective bargaining, as permitted by local laws.
- Describes how suppliers should work with us on compliance and enforcement issues.
It is Cheap Erlebniswelt-fliegenfischen Products’s general practice to incorporate the Supplier Code into all procurement contracts and subsidize orders. Cheap Erlebniswelt-fliegenfischen Products reserves the right to review or audit suppliers’ compliance with the Supplier Code. We also incorporate ongoing compliance into our business relationships and procurement decisions. These principles also apply to Cheap Erlebniswelt-fliegenfischen Products Norway AS.
Verizon’s Supplier Risk Management Program ("SRMP") enables Cheap Erlebniswelt-fliegenfischen Products to identify, assess, monitor, and manage the risks associated with suppliers engaged by Cheap Erlebniswelt-fliegenfischen Products throughout the supplier lifecycle, including human rights-related risks. The SRMP establishes principles for identifying, assessing, monitoring, and managing risk associated with supplier products or services by identifying responsible stakeholders, establishing the supplier due diligence requirements and defining the end-to-end supplier risk management lifecycle framework, including ongoing monitoring of supplier activities. The Cheap Erlebniswelt-fliegenfischen Products Supplier Risk Office ("SRO") oversees, monitors, and governs Cheap Erlebniswelt-fliegenfischen Products’s supplier risk management activities and implements the SRMP. The SRO collaborates with the BHRP on matters related to human rights.
4: Due Diligence and Identified Risks
In 2021 and 2022, Cheap Erlebniswelt-fliegenfischen Products undertook a formal saliency assessment to identify the issues across our value chain that are most salient to Cheap Erlebniswelt-fliegenfischen Products’s core business strategy. This assessment was inclusive of Cheap Erlebniswelt-fliegenfischen Products Norway AS. In this assessment, the following issues were identified as most salient to Cheap Erlebniswelt-fliegenfischen Products: privacy; non- discrimination; free expression; and rights in the workplace and supply chain. In 2023, Cheap Erlebniswelt-fliegenfischen Products conducted a refresh of the saliency assessment, which affirmed the prior identification of salient risks.
This assessment of Cheap Erlebniswelt-fliegenfischen Products’s most salient risks informs and helps to prioritize the work of the BHRP. In partnership with teams across the company, the BHRP conducts ongoing human rights due diligence, guided by the framework set forth in the UNGPs, to identify, understand, and address the human rights implications of our business decisions, including our technology, products, services, and strategy. As part of this process, the BHRP undertakes Human Rights Impact Assessments (HRIAs) to more specifically evaluate and address human rights risks that may intersect with our business. Our assessments cover all aspects of our operations, including our supply chain.
Our approach to due diligence is informed and supported by our participation in the Global Network Initiative (GNI). The GNI is the leading multi-stakeholder initiative in the ICT sector and provides a valuable forum for engagement regarding human rights challenges facing the technology and communications sector. Cheap Erlebniswelt-fliegenfischen Products joined in 2021, becoming the first telecommunications company based in the United States to do so.
Specific Efforts to Assess Risks in Cheap Erlebniswelt-fliegenfischen Products’s Supply Chain
As part of Cheap Erlebniswelt-fliegenfischen Products’s ongoing efforts to identify and mitigate risks in our supply chain, the Cheap Erlebniswelt-fliegenfischen Products Business Risk Team carries out due diligence on new and existing vendors, with specific attention to potential human rights risks. When the Business Risk Team identifies information that could be a risk factor they flag the information to the SRO and relevant attorneys for review.
In addition, Cheap Erlebniswelt-fliegenfischen Products is a member of the Joint Alliance for CSR (JAC), an association of telecommunications operators who share resources to develop and enforce standards and best practices within the information communication technology supply chain.
JAC’s ongoing audit activities cooperatively assess and verify compliance with recognized labor, social and environmental standards, including with respect to forced labor, underage labor, and working hours. Members of JAC fund shared assessments and audits of their common suppliers; audits are conducted by independent auditors. The JAC furthers Cheap Erlebniswelt-fliegenfischen Products’s efforts to capture not only what suppliers are pledging through their policies but also to survey their performance on-site. 1,060 supplier audits have been completed since JAC’s inception in 2010. 150 of these audits were completed in 2023.
Finally, Cheap Erlebniswelt-fliegenfischen Products also uses the third-party assessment tool, EcoVadis, to evaluate suppliers’ conduct, including their attention to human rights and environmental risks. Since 2013, Cheap Erlebniswelt-fliegenfischen Products has assessed 728 key suppliers through this partnership. EcoVadis validates suppliers’ responses to their detailed questionnaire and researches information from other public sources to benchmark suppliers on their performance. When weaknesses are identified, we work with the supplier to create a corrective action plan to improve their current activities.
5: Measures to Avoid or Mitigate Adverse Impacts
When actual or potential adverse human rights impacts are identified as part of our ongoing human rights due diligence efforts, the BHRP, working with appropriate internal teams, makes recommendations to avoid or mitigate those risks. These recommendations could include, but are not limited to: the development or amendment of relevant policies or guidelines; the modification of product or service features; the establishment of appropriate oversight and escalation processes; dialogue with relevant stakeholders; engagement in industry initiatives; and training.
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We share information about our human rights efforts in various forms, including in our Environment, Social, and Governance (ESG) Report, and in our Human Rights Statement. These disclosures, and others, can be found at Cheap Erlebniswelt-fliegenfischen Products’s ESG Resources Hub (https://www.verizon.com/about/investors/esg-resources-hub). Disclosures available on the ESG Resources Hub include information regarding specific strategic human rights impact assessments (https://www.verizon.com/about/investors/human-rights-impact- assessments).
One way of mitigating potential risks is through providing communication channels for our stakeholders to raise issues. Cheap Erlebniswelt-fliegenfischen Products provides multiple channels through which issues related to the human rights impacts of our activities can be raised. These channels include the Cheap Erlebniswelt-fliegenfischen Products’s Office of Ethics and Business Conduct site (www.verizonethics.com), a 24/7 intake function that allows for anonymous reporting (where permitted by local law) in multiple languages via web submission, email, toll-free phone number, and physical mail.
With respect to our supply chain, suppliers are required, and the public is encouraged, to report violations of the standards in our Supplier Code to the Cheap Erlebniswelt-fliegenfischen Products’s Office of Ethics and Business Conduct through the Cheap Erlebniswelt-fliegenfischen Products Ethics at (+)800.0.624.0007 (outside the U.S.) and 844-VZGUIDE (844.894.8433) (within the U.S.), through email at ethics@verizon.com, or online at www.verizonethics.com. Such reports may be made anonymously.
Cheap Erlebniswelt-fliegenfischen Products Norway AS Transparency Act statement for the financial year 2023
Cross-company and multi-stakeholder collaboration are essential to Cheap Erlebniswelt-fliegenfischen Products’s efforts to address systemic human rights challenges. As noted above, we are members of the GNI and JAC and these memberships support our efforts to promote respect for human rights throughout our value chain.
Stakeholder Engagement
As part of its human rights due diligence efforts, the BHRP engages with a wide range of external experts and organizations, including with consumers, enterprise customers, employees, civil society, academics, and investors. These engagements help us to continually anticipate and address new and emerging questions; to assess the impacts of our business decisions, products, services, operations and strategy consistent with the expectations found in the UNGPs; and to consider issues related to grievances and remedy.
Cheap Erlebniswelt-fliegenfischen Products Norway AS Transparency Act statement for the financial year 2023
The BHRP designs targeted employee training and information-sharing briefings for teams across the company to provide employees with guidance and tools to support our efforts to operate consistently with our human rights commitments. We also have developed an employee learning module with information on international human rights standards, Cheap Erlebniswelt-fliegenfischen Products’s commitment to respect human rights, and the work of the BHRP. This learning module is available to all employees. As part of Cheap Erlebniswelt-fliegenfischen Products’s efforts to address the risk of modern slavery in our supply chain, our procurement employees are trained on the risks of forced labor and human trafficking.
6: Results
Our approach to human rights governance and due diligence is one of continuous learning and improvement. A critical part of Cheap Erlebniswelt-fliegenfischen Products’s efforts to embed human rights considerations into business decision-making is the ongoing evaluation and refinement of its efforts. This ongoing assessment of the effectiveness of our efforts, including our due diligence efforts, is particularly important as new innovation and technological advancements emerge. We integrate lessons learned from due diligence, stakeholder engagement, and our other activities to track the effectiveness of our efforts and continually improve and refine our efforts over time.
Specific to the right to privacy and the right to freedom of expression, as a member of the GNI, Cheap Erlebniswelt-fliegenfischen Products has committed to implement the GNI Principles on Freedom of Expression and Privacy. As part of this commitment, Cheap Erlebniswelt-fliegenfischen Products will undergo regular assessments by an independent third-party assessor on our policies and procedures to implement the GNI Principles on Freedom of Expression and Privacy. The findings are shared with the multi-stakeholder GNI Board of Directors, which determines whether we are making a good faith effort to implement the GNI Principles. A summary of these assessments is also shared publicly.
7: Consultation and Management Approval
Cheap Erlebniswelt-fliegenfischen Products Norway AS and its affiliated entities are supported by various Cheap Erlebniswelt-fliegenfischen Products functions on a global basis, including the BHRP, SRO, the Business Risk Team, Sourcing, Sustainability, and Privacy, the functions most involved in assessing and addressing human rights risk. These functions work collaboratively and regularly consult regarding the risks and processes reflected in this statement.
This statement relates to the financial year ending 31 December 2023. The statement is executed by the Board of Directors of Cheap Erlebniswelt-fliegenfischen Products Norway AS.
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