ZAIN 2022 All Rights Reserved
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Addressing Key Challenges to Human Rights
Zain Group continues its commitment to ensuring it inclusively addresses human rights, respects the rule of law, and the wellbeing of society. The company takes a systematic approach to making sure that its human rights policies and procedures can be adopted and are applicable across all of its operating markets. By integrating such practices into the business and across the value chain, Zain is able to leverage its reach and create maximum impact.
The company’s strategic approach towards human rights is framed by the following:
- Governance and Policy
- Position towards human rights
- Identification of Salient Human Rights through engagement
- Reporting and Impact
Zain continues its alignment with the UNGP on Business and Human Rights Reporting
The company aligns its human rights reporting methods to the United Nations Guiding Principles on Business and Human Rights Reporting Framework. Zain’s commitment to the principles showcases its strong stance in upholding the highest standards across its operations.
Governance and Policy
Centered on respecting the dignity of all, Zain’s commitment to human rights is guided by its Human Rights Policy Statement that aims to define the governance and requirements set out for all stakeholders that engage with the company.
Zain defines human rights as per the definition of the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the ILO Declaration on Fundamental Principles and the Rights.
The policy is guided by the United Nations Guiding Principles for Business and Human Rights; the UN Convention on the Rights of Persons with Disabilities; the UN Convention on the Rights of the Child; the Guidelines of the Organization for Cooperation and Economic Development for Multinational Companies; and it is in aligned with the principles of the United Nations Global Compact and the Global Network Initiative’s principles on Freedom of Expression and Privacy – GNI Principles.
Zain’s policy can be found on the Group’s website, here:
Position Towards Human Rights
Upholding the rights and dignity of all our stakeholders is of utmost importance to Zain. As a digital service provider, we believe it is our role to provide people with access to tools, mechanisms and information to promote, protect, and enable our stakeholders to fulfil their rights. In our sector, potential human right risks are present across our value chain, and it is our responsibility to ensure such risks are mitigated against.
Zain’s scope for human rights extends to all its areas of operations, which include Bahrain, Iraq, Jordan, Kuwait, Saudi Arabia, Sudan, and South Sudan. Based on the company’s continuous engagement with its stakeholders, assessment of its operating context and communities, industry landscape and the Sustainable Development Goals (SDGs), the following human rights have been identified:
Salient Human Rights
Labor Rights, Treatment and Safety
Public Safety
Customers’ Right to Privacy
Child Online Safety
Value Chain and Impact
Supply Chain
Supply Chain and Community
Community and General Public
Community and Vulnerable Segments
Identification of Salient Human Rights Through Engagement
Zain identified the most relevant human rights issues primarily through high-level interactions within the company, namely between the Vice-Chairman and Group CEO, Chief Sustainability Officer, and other senior executives including the Board of Directors, Chief Risk Officer, Head of Legal/Legal Counsel, and Chief Communications Officer. In addition, the company continued to conduct its annual stakeholder engagement exercise where it aims to gather the input of all stakeholders through a Group-wide survey. Based on the results of the survey, Zain processes its stakeholders’ concerns, prioritizes, and address them.
In addition, Zain continued to discuss specific relevant human rights topics, utilizing its social media channels. Some of the topics of discussion included children as victims of violence; promoting the importance of child hotlines; protecting data privacy; and raising awareness on the importance of humanitarian workers and preservation of human dignity and rights.
Zain also continued to engage with shareholders and key investors; communicate with local communities regarding site selection; and human rights impact assessment studies prepared as part of the due diligence process when applicable for corporate investments, joint ventures, and mergers and acquisitions.
To ensure that Zain’s policies to uphold human rights continue to be effective, the company frequently engages with employees, suppliers, the public, and other stakeholders who may be potentially impacted by such policies. Employees, for example, maintain several internal channels through which to communicate labor grievances. In cases where people are harmed by the company’s actions, effective remedies are stipulated within Zain’s HR Policy Statement, its Supplier Code of Conduct, and its ESMP Guidelines. Each document clarifies channels for impacted people to communicate their grievances to the company.
Impact and Reporting
The policies related to addressing human rights issues are shared and readily available to all relevant stakeholders and accessible to all employees through the Zain Group website. Such specific policies are articulated within the Human Rights Policy Statement, Human Resources Policy, the Supplier Code of Conduct, the Corporate Sustainability (CS) Policy and the Environmental and Social Management Plan Guidelines. With regards to customers, Zain’s policy of protecting its customers’ data privacy is articulated in the GSMA Mobile Privacy Principles, which Zain took part in developing and to which it maintains its adherence. Zain’s position on the non-disclosure of customer information and the protection of the confidentiality and privacy of all personal information is publicly available on the website: (http://www.zain.com/en/policy).
In addition, Zain ensures that its local and international suppliers also share its commitment to responsible business practices, which include human rights. Such human rights standards are upheld by Zain’s suppliers and partners through compliance mechanisms with Zain’s Supplier Code of Conduct and through a screening process that takes place prior to the registration of new suppliers.
Established in 2017, Zain initiated its supplier self-assessment exercise, which touched upon human rights amongst other relevant topics, by conducting site visit evaluations for material suppliers. This exercise continued in 2018, 2019, and 2020. This year, Zain continued to expand and reach a larger number of international and local suppliers. Through this engagement, suppliers must also commit to the human rights policy statement before registering onto Zain’s supplier portal.
Furthermore, in matters regarding geographical expansion or entry into new revenue streams through acquisitions of licenses or existing businesses, Zain pays attention to human rights impact assessments including gender equality, inclusiveness, as well as fair and equal opportunity labor practices such as child labor, compulsory labor, etc. This report covers all of Zain’s most pertinent human rights issues that took place during the course of the year. During this period, there were no human rights abuses committed under Zain’s scope.
Labor Rights
The Challenge:
This year, the region’s labor markets continued to experience the impact of the COVID-19 pandemic. The difficulty to find meaningful employment; gender disparity in the workplace; and lenient regulations and laws in protecting labor rights are some examples of the challenges faced in the region. Economic and political insecurity further compounds the difficulty to find stable and safe working environments.
Stakeholder Engagement:
Zain’s Code of Conduct is publicly available on the company’s website, and its Human Rights and Human Resources Policies are communicated to and shared with all employees. Zain also has in place open communication channels across the Group, which enables all employees to voice their concerns, feedback and views on the company’s policies and procedures. As such, the Human Rights and Human Resources Policies remain fluid documents that are responsive to employee priorities and are revised accordingly. In 2020, the establishment of the Human Rights Policy and amendments to the Supplier Code of Conduct were developed in line with industry best practice as far as labor practices, including forced and child labor. Zain further developed the mechanism by which suppliers adhere to the Supplier Code of Conduct and Human Rights Policy Statement by embedding it in the onboarding process through Zain’s website.
Impact on Policies:
Zain maintains multiple channels for employees to report any violations of their labor rights or mistreatment. In addition, Zain’s geographical expansion or entry into new revenue streams is preceded by human rights impact assessments that influence the company’s decision-making processes and resulting action.
Public Safety
The Challenge:
Stakeholder engagement is required to continue safeguarding the public safety when it comes to installing sites and ensuring we are aligned to regulations and license renewals. With the roll out of 5G networks, we have noticed a rise in mischievous theories and myths of the impact of 5G on public health. The company continues to work closely with authorities and regulators in each of our markets in addition to industry experts to ensure we address health and safety topics related to our operations.
Stakeholder Engagement:
Zain ensures that its activities, such as the establishment of base stations, are in accordance with the Environmental and Social Management Plan (ESMP) guidelines and are carried out in compliance with relevant regulatory bodies.
Impact on Policies:
Zain maintains the policies specified in the ESMP Guidelines that safeguard against exposure to electromagnetic fields (EMF), radiation, and other potentially harmful exposures.
Customers’ Rights to Privacy
The Challenge:
Overall, the MENA region’s approach to data privacy is addressed through general rules and laws as opposed to laws specifically dedicated to safeguarding personal data. Furthermore, there is a lack of data protection authorities to enforce data privacy laws. However, momentum is gathering in some countries where entities have been established and are designated to protect the privacy of individuals’ data. A cohesive and unified framework is required in the region to bridge data protection rules across the board.
Stakeholder Engagement:
Zain ensures that its activities, such as the establishment Zain’s protection of its customers’ personal data is communicated through its annual Sustainability Report in the ‘Our Products and Customers’ section and through the website. This year, we continue to align to the Sustainability Accounting Standards Boards (SASB). Further information can be found in the Enterprise Risk Management section.
Impact on Policies:
Zain continues to adhere to the GSMA Mobile Privacy Principles and is committed to protecting the personal information of its customers. The company applies stringent measures to avoid data leaks, theft and/or loss. Zain also aims to respond to such issues with the utmost precaution and diligence. Zain complies with laws and regulations related to the protection of customer privacy and data, and takes steps to align with ISO certifications related to the subject.
Child Online Safety
The Challenge:
With more children online now more than ever, certain risks have become more prominent. In the context in which Zain operates, there is a lack of child protection infrastructure with respect to specific tools and mechanisms that keep children safe online. In addition, there is a lack of awareness on the potential harm the online space poses on children’s wellbeing. In addition,, there is a sense of taboo in the region culturally with regards to discussing child sexual abuse material found online. The lack of dialog is extremely problematic as 44% of respondents of a recent survey conducted by The Economist experienced online sexual harm during childhood in the MENA region.
Stakeholder Engagement:
Zain’s firm commitment to protect children is demonstrated in the company’s proactive engagement in initiatives that focus on protecting children and collaboration with key stakeholders such as UNICEF and related stakeholders such as academic institutions. Due to the ongoing impact of COVID-19, there has been a dramatic rise in online activity, placing children at greater risk of online harm. In response, Zain ensured that its Human Rights Policy Statement covers and protects children’s rights and online safety. The company also assessed the risks of online gaming as well as installing blocking mechanisms on its networks to restrict access to child sexual abuse material (CSAM).
Impact on Policies:
Zain maintains its adherence to the GSMA’s Mobile Alliance Against Child Sexual Abuse Content.
This year, the company continued to evolve its global MoU with UNICEF by having each of our operating companies establish a local MoU to establish initiatives on protecting children. The MoU covers aspects on online gaming, raising awareness about child online safety, and convening stakeholders on online protection.
Zain also conducted UNICEF’s Mobile Operations Child’s Rights Impact Assessment Tool (MO-CRIA), which resulted in the company identifying specific challenges, gaps and opportunities. Through this assessment Zain is diligently working on devising a plan that requires continuous engagement with various stakeholders. Zain also contributed to updating the MO-CRIA Toolkit, providing its insights in updating the tool this year.
Zain was able to further develop the child online safety space and integrate safety mechanisms to ensure all children are safe when surfing the web by partnering with the Canadian Child Protection Center (C3P). The C3P’s software, called Project Arachnid, aims to reduce the availability of child sexual abuse material (CSAM by crawling URLs previously reported to Cybertip.ca, as well as URLs reported directly into the Arachnid API. This year, Zain was able to integrate the Arachnid API onto Zain Kuwait’s network is planning for implementation across the rest of Zain’s operation.
