What are the material issues the company has identified? 

In its 2021 Sustainability Report Telstra identified a range of material issues, such as ethics, values and governance, customer experience, privacy and data security, climate change, diversity and inclusion. Among these, promoting sustainability among its suppliers 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
Communities	·      Team of Community Engagement Specialists ·      Ongoing engagement through Corporate Affairs, Telstra stores and Telstra Rural and Regional ·      Online channels ·      Feedback surveys ·      Sustainability programmes and partnerships ·      Community consultation ·      Individual meetings and proactive community engagement in response to electromagnetic energy (EME) concerns ·      Mobile base station consultation projects
Employees/potential employees	For employees: ·      Leadership engagement ·      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 For potential employees: ·      Early Career programmes like the intern and graduate programmes ·      Engagement and partnerships with universities ·      Partnership with the Pathways in Technology (P-TECH) programme offered in select high schools ·      Partnership with Career Trackers to offer internships to Indigenous students
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 Special 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
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 ·      Investigations ·      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 over 70 of its key community stakeholders, as well as over 100 domestic and foreign institutional investors, to get their view of its most material sustainability topics.

What actions were taken by Telstra to promote sustainability among its suppliers?

In its 2021 Sustainability Report Telstra reports that it took the following actions for promoting sustainability among its suppliers:

• Assessing suppliers
• To help make more informed purchasing decisions, Telstra continues to refine its Supplier Governance Framework, which assesses suppliers against twelve categories of risk. Telstra considers labour practices, environmental practices, health and safety, and bribery and corruption risks to be sustainability risks and assesses these risks as part of its selection and contract renewal process using a combination of due diligence reports, questionnaires, documentary review and, where warranted, onsite audits. A supplier’s ability to meet or exceed Telstra’s minimum standards set out in Telstra’s Supplier Code of Conduct (SCOC) is a key consideration for Telstra when it makes purchasing decisions. Since 2020, to help it gain a more in-depth understanding of its suppliers, Telstra has engaged a third party to perform an Enhanced Due Diligence (EDD) screening over 1,100 suppliers that it engages regularly, representing approximately 83 per cent of Telstra’s total spend. As part of Telstra’s EDD screening, suppliers are screened against public records, such as company registry records, media reports and civil litigation, regulatory, criminality and bankruptcy checks. In FY21 Telstra completed EDD screening of 1,317 suppliers, including 100 per cent of the 1,100 suppliers it committed to screen at the start of the EDD programme, as well as a further 217 suppliers as part of its selection and on-boarding process.

• Implementing a Supplier Code of Conduct
• Telstra’s Supplier Code of Conduct (SCOC) sets out the minimum standards Telstra expects from its suppliers and forms part of its standard purchasing terms. Through its policies, Supplier Governance Framework, training and audit programme, Telstra works with its suppliers to assess whether they are meeting its standards. Telstra’s SCOC is aligned with 10 universally accepted principles of the UN Global Compact, Responsible Business Alliance (RBA) Code of Conduct, and Joint Audit Cooperative (JAC) Supply Chain Sustainability Guidelines, as well as legislative obligations such as the Modern Slavery Act (UK) 2015 and the Modern Slavery Act 2018 (Cth). The SCOC was updated in June 2021 to include enhanced requirements in relation to resource efficiency, employee wages and identifying, mitigating and addressing forced and compulsory labour. A copy of the updated SCOC was communicated in June to all 4,900 suppliers engaged in FY21. All suppliers engaged subsequently receive the updated SCOC as part of Telstra’s standard purchasing terms. In 2021, Telstra hosted a forum with a number of its top 100 suppliers to discuss its expectation from its suppliers in the SCOC on climate change. Suppliers’ ability to meet or exceed standards detailed in the SCOC is considered by Telstra when making procurement decisions. This happens regardless of whether the SCOC has been formally incorporated into a particular contract with the supplier. In addition to the SCOC, Telstra may also include more specific social, environment, and/or ethical requirements in its contract terms based on the inherent risk of the agreement.

• Promoting compliance
• Telstra works with its suppliers to assess whether they are meeting the SCOC in a number of ways. This includes conducting governance meetings, reviewing reports and public records, monitoring adverse media alerts, and undertaking questionnaires and audits. The approach Telstra takes is based on the nature of the risks, and the category of the goods or services being provided. At Telstra, sustainability risks are more likely in ICT (information and communications technology) products and services, and construction and physical network infrastructure maintenance categories, which are also Telstra’s two largest categories of spend. Within the remaining categories of spend, Telstra has identified branded apparel and merchandise manufacturing, agriculture, and cleaning and waste management as categories warranting specific attention. Telstra focuses on these areas in the remaining categories due to the use of low-skilled and low-wage labour, together with the potential for environmental damage within these industries’ supply chains. Telstra monitors sustainability risks through a combination of internal and external questionnaires and site audits. In 2021, 64 of Telstra’s higher risk suppliers were selected to complete detailed questionnaires and provide evidence to support their responses. These questionnaires were designed using internal and external supplier sustainability experts and are aligned with industry standards. In some cases, a site audit is required in addition, or instead of, a questionnaire.

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

The GRI Standards addressed in this case are:

1) Disclosure 308-2 Negative environmental impacts in the supply chain and actions taken

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

 

Disclosure 308-2 Negative environmental impacts in the supply chain and actions taken 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: Gender Equality
• Targets: 5.2
• Sustainable Development Goal (SDG) 8: Decent Work and Economic Growth
• Targets: 8.8
• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.1

 

78% 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.

7 GRI sustainability disclosures get you started

Any size business can start taking sustainability action

GRI, ISEP, CPD Certified Sustainability courses (2-5 days): Live Online or Classroom  (venue: London School of Economics)

• Exclusive FBRH template to begin reporting from day one
• Identify your most important impacts on the Environment, Economy and People
• Formulate in group exercises your plan for action. Begin taking solid, focused, all-round sustainability action ASAP. 
• Benchmarking methodology to set you on a path of continuous improvement

See upcoming training dates.
References:

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 following link:

https://1u0b5867gsn1ez16a1p2vcj1-wpengine.netdna-ssl.com/wp-content/uploads/2021/09/Telstras-Bigger-Picture-2021-Sustainability-Report-1.pdf

Note to Telstra: With each case study we send out an email requesting a comment on this case study. If you have not received such an email please contact us.

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
Communities	·      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

 

78% 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.

7 GRI sustainability disclosures get you started

Any size business can start taking sustainability action

GRI, ISEP, CPD Certified Sustainability courses (2-5 days): Live Online or Classroom  (venue: London School of Economics)

• Exclusive FBRH template to begin reporting from day one
• Identify your most important impacts on the Environment, Economy and People
• Formulate in group exercises your plan for action. Begin taking solid, focused, all-round sustainability action ASAP. 
• Benchmarking methodology to set you on a path of continuous improvement

See upcoming training dates.
References:

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:

http://database.globalreporting.org/

2) https://www.globalreporting.org/standards/gri-standards-download-center/

Note to Telstra: With each case study we send out an email requesting a comment on this case study. If you have not received such an email please contact us.