The case for CSR/ Sustainability Reporting Done Responsibly


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Case study: How Telstra respects and promotes human rights

Telstra is Australia’s leading telecommunications and technology company, whose world-leading networks cover 99.5 per cent of the Australian population. Telstra’s commitment to respect and support human rights is aligned to the UN Guiding Principles on Business and Human Rights, and is outlined in its Code of Conduct and Human Rights Policy.

This case study is based on the 2019 Sustainability Report by Telstra published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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Across its value chain, Telstra seeks to make sure that, along with its business partners, it operates with respect for human rights.  Tweet This! In order to respect and promote human rights Telstra took action to:

  • implement a human rights compliance plan
  • promote human rights among suppliers
  • report on modern slavery

What are the material issues the company has identified?

In its 2019 Sustainability Report Telstra identified a range of material issues, such as ethics, values and governance, privacy and data security, product and service responsibility, network resilience, climate change. Among these, respecting and promoting human rights stands out as a key material issue for Telstra.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups Telstra engages with:

Stakeholder Group                Method of engagement
Customers ·      Customer service channels including face-to-face, online and calls

·      External market research

·      Social media

·      Newsletters and white papers

·      Telecommunications Industry Ombudsman (TIO)

·      Regular messages issued through the mobile safety information SMS campaign

·      Face-to-face consumer forums.




·      Team of Community Engagement Specialists

·      Ongoing engagement through Corporate Affairs, Telstra stores and Telstra Regional Australia

·      Online channels

·      Feedback surveys

·      Sustainability programmes and partnerships

·      Community consultation

·      Individual meetings and proactive community engagement in response to EME concerns

·      Mobile base station consultation projects

Employees/potential employees



·      Annual and monthly employee engagement surveys

·      Employee networking and engagement through internal social media channels

·      Intranet corporate news

·      Grievance mechanisms

·      Performance reviews

·      Regular team/ departmental/ company-wide meetings

Government ·      Ongoing personal engagement

·      Newsletters

·      Online channels

·      Public policy participation

·      Government inquiries

·      Feedback surveys

·      Complaints/inquiries

·      Information requests

·      Partnerships

Industry ·      Participation in industry associations

·      Memberships such as Groupe Speciale Mobile Association (GSMA), Joint Audit Committee (JAC) and Global e-Sustainability Initiative (GeSI)

Shareholders and investment community


·      Half year and full year briefings

·      Investor days

·      Investor roadshows

·      Investor meetings

·      ASX announcements

·      Direct phone and email correspondence

·      Telstra annual general meeting

·      Telstra website

·      Online Telstra Exchange

Media ·      Ongoing direct engagement with Telstra’s communications, investor relations and media teams

·      Media releases

·      Interviews

 Unions ·      Formal consultation meetings and correspondence

·      Ongoing engagement through Work Health Safety representatives

Suppliers ·      Ongoing engagement by Telstra’s procurement team

·      Supplier surveys

·      Ongoing assessments and onsite audits

·      Participation in JAC-appointed audits and GeSI initiatives

·      Commenced roll out of the Supplier Governance Framework

·      Quarterly contractor HSE Forum with major suppliers of Telstra’s construction workforce

·      Ongoing collaboration with the Indigenous Workforce Programme and activities under Telstra’s Indigenous Labour Programme

·      Direct engagement of suppliers with higher potential human rights risks

Regulators ·      Participation in reviews conducted by regulators

·      Information provision under various reporting requirements

·      Ongoing regulatory inspections

·      Ongoing regular engagement

·      Newsletters

·      Participation in industry bodies

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics Telstra reached out to 80 of its key community stakeholders and to over 40 environmental, social and governance (ESG) and institutional investment analysts, to get their view of its most material sustainability topics.

What actions were taken by Telstra to respect and promote human rights?

In its 2019 Sustainability Report Telstra reports that it took the following actions for respecting and promoting human rights:

  • Implementing a human rights compliance plan
  • Telstra continues to embed its human rights compliance plan to manage and mitigate its seven salient human rights risks: labour rights, freedom of association, health and safety, privacy and data protection, anti-discrimination, anti-bribery and corruption, access to grievance mechanisms. During FY19, Telstra updated its compliance plan to align with its organisational structure changes. This included reviewing the applicability of each of Telstra’s human rights requirements against the new functional areas, as well as re-assessing each of the assigned risk levels. As Telstra further defines its control environment (e.g. through the introduction of new training), it updates the compliance plan, to reflect these additional controls.
  • Promoting human rights among suppliers
  • As Telstra’s supply chain is one of its areas of greatest potential human rights risk, Telstra continues to devote significant effort to deepening its understanding of the specific types of human rights risks associated with different types of products, source countries and sectors. Telstra prioritises its assessments of its suppliers’ human rights performance based on risk and has integrated this process into its broader supplier risk governance processes. This includes Telstra’s supplier risk assessments and ongoing supplier management and due diligence, as well as procurement training for Telstra’s employees.
  • Reporting on modern slavery
  • The Modern Slavery Act 2015 (UK) requires companies operating in the UK with annual global turnover exceeding £36 million to publish an annual ‘slavery and human trafficking statement’. To respond to the legislation, every year Telstra produces its Modern Slavery Act Statement, which is available on Telstra’s In December 2018, Australia implemented similar legislation to the UK and on 1 January 2019, the Modern Slavery Act 2018 (Cth) came into force. The Modern Slavery Act 2018 (Cth) requires Australian entities with annual consolidated revenue exceeding AUD $100 million to produce an annual statement. The statement must disclose the risks of modern slavery in the entity’s operations and supply chains and what they are doing to address those risks. Telstra is subject to the legislation, its first reporting year will be FY20 and will be required to produce a statement by 31 December 2020. Telstra also aims to produce one Modern Slavery Statement which will fulfil its obligations under both the UK and Australian legislation.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standards addressed in this case are:

1) Disclosure 412-2 Employee training on human rights policies or procedures

2) Disclosure 414-2 Negative social impacts in the supply chain and actions taken


Disclosure 412-2 Employee training on human rights policies or procedures does not correspond to any SDG.

Disclosure 414-2 Negative social impacts in the supply chain and actions taken corresponds to:

  • Sustainable Development Goal (SDG) 5: Achieve gender equality and empower all women and girls
  • Business theme: Workplace violence and harassment
  • Sustainable Development Goal (SDG) 8: Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all
  • Business theme: Labor practices in the supply chain
  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Workplace violence and harassment


80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

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Most importantly, you will gain the knowledge to use the GRI Standards, project manage your own first-class sustainability report and:

  • Identify your most important impacts on the Environment, Economy and Society
  • Begin taking solid, focused, all-round sustainability action ASAP



1) This case study is based on published information by Telstra, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:


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