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Materiality Assessment

At Zain, we conduct an annual materiality assessment to identify and prioritize sustainability-related topics that are critical for both the company as well as its operating communities. Through the materiality assessment, the company engages with internal and external stakeholders to understand their concerns and address their needs. We consider our long-term business success the result of successfully addressing our various stakeholders’ needs and concerns.

Determining Materiality to Zain:

Zain considers materiality as the principle that determines which topics are relevant and necessary to act upon and report. The company bases its annual Sustainability Report on the results of the materiality assessment exercise to further understand the consequential issues for the company and its stakeholders.
Zain established several methodologies to assess the significance of its impacts. The determination process of material issues was undertaken by identifying general sustainability topics in accordance with Zain’s social, economic, and environmental impacts; its operating context; and industry trends. This process also took into consideration internal and external factors such as Zain’s mission, vision, ‘4sight’ strategy, concerns expressed directly by stakeholders, social expectations, supply chain, and climate change risks and opportunities. The results, which prioritize sustainability topics on an internal and external basis, are based on the survey results shared across stakeholder groups.

A shortlist of 18 topics based on previous reports and upcoming trends was created, which included:

The macro-business environment
Benchmarking against other prominent players in the industry and the region
Inputs gathered from operational review meetings, business plan meetings, and from leadership and executive management
Sustainability interests raised by stakeholders
Socio-economic and political factors, including the implications of COVID-19

Stakeholder Inclusiveness:

Zain defines stakeholders using the definition provided by GRI:

“Stakeholders are entities or individuals that can reasonably be expected to be significantly affected by the organization’s activities, products and services, and whose actions can reasonably be expected to affect the ability of the organization to successfully implement its strategies and achieve its objectives.”
The stakeholders considered in this process range from those that directly invest in the organization such as employees, shareholders, investors, and suppliers, to those who are impacted by the company’s operations, including local communities and civil society.

Based on this definition, Zain identifies its main stakeholders for the purposes of this report as:

Internal

Employees
Executive Management

External

Regulators
Shareholders
Suppliers
Business Partners
Financial Institutions
General Public
Customers

As a standard business practice, Zain frequently carries out stakeholder engagement activities throughout the year that enable the organization to address the needs and expectations of its stakeholders. Related engagement activities include the following:

Corporate Sustainability (CS) Social Media Outreach: CS social media outreach campaigns engage Zain’s internal and external stakeholders to adopt a sustainability mindset. Zain encourages its audiences to provide feedback on the highlighted issues through social media engagement tools such as polls, surveys and questions highlighted in the posts’ caption. Through such an approach, the company assesses its stakeholders’ behavioral evolution by conducting pre- and post- surveys to further develop its messaging and understand its stakeholders’ priorities and concerns.
Internal Forums: These activities are designed to engage both the Group and the operating companies to measure priorities, share best practices and discuss issues related to their specific business area. Due to health and safety precautions, all forums were conducted virtually this year.
Stakeholder engagement process through various corporate functions: Several Zain functions devote significant resources to maintaining frequent dialogue and transparency with stakeholders through investor and shareholder meetings, frequent communication with regulatory bodies, meetings with partners, customer polling and other engagement activities related to each relevant function.

After conducting the Materiality Assessment exercise across our markets, Zain witnessed drastic changes in results as compared to the prior year. Employee Health & Safety remains of highest importance for Zain’s stakeholders. In addition, Data Privacy & Security, and Customer Service have risen in priority, which could be due to the rise in digitization experienced across Zain markets. Through this assessment, we noticed a drop in priority of Modern Slavery and Waste Management, which could be explained by the stabilization of societies post-COVID-19.

Materiality Assesstment - Survey Results

Material Topics	Ranking Order 2021	Ranking in 2020
Employee Health and Safety	1	1
Data Privacy and Security	2	5
Customer Service	3	15
Business Ethics and Governance	4	4
Economic Performance	5	12
Digital Transformation	6	(Grouped under Access to Healthcare (7th rank) and Access to Education and Skills Development (11th rank))
Digital Inclusion	7	10
Diversity and Inclusion	8	(Changed from People with Disabilities (6th rank))
Freedom of Expression	9	8
Child Online Protection	10	13
Entrepreneurs and SME Development	11	20
Tax Transparency	12	18
Socio-economic Compliance	13	14
Responsible Supply Chain	14	16
E-Waste and Waste Management	15	2
Climate Change	16	19
5G and Public Perceptions on Health	17	17
Modern Slavery	18	(Grouped under Modern Slavery (3rd rank) and Human Rights and Human Trafficking (9th rank))

The company responded to the identified priorities in the following ways:

1. Data Privacy & Security

Establishing technical and procedural controls to implement the principles outlined in Zain’s Data Privacy Policy. The company is currently working on updating its Privacy Policy in alignment with new data privacy-related regulations and recognizes the EU General Data Protection Regulation (GDPR) legislation and other region-specific laws.
Continuing to develop awareness content to all Group employees as part of the PAUSE.THINK.ACT cybersecurity awareness program. The company included new topics based on current cybersecurity trends. Additionally, Zain provided tips to employees to remain vigilant and protect themselves and the company from compromise.
As cyberattacks continue to evolve, Zain maintained its subscription to notifications and alerts from the GSMA’s Telecommunications Information Sharing Analysis Center’s (T-ISAC) Malware Information Sharing Platform. This allows the company to receive threat intelligence via the platform and take the necessary remedial steps to protect Zain from compromise.

2. Employee Health and Safety

In response to COVID-19, Zain formed a Crisis Response Committee in 2020 led by executive management to ensure that all country operations implemented appropriate measures to rapidly respond to the evolving situation. As the company began to operate at full capacity, Zain continued to follow the guidelines set by the Crisis Response Committee, in addition to following the respective country’s COVID-19 rules and regulations.
Zain implemented several measures to provide guidance with respect to travel, working remotely, and health & safety awareness through various communication channels that include SMS, social media, and internal announcements.
All Zain’s premises are periodically sterilized and maintenance crews are provided with specific sterilization and cleaning material to ensure proper sterilization and safety.
Hosted vaccination drives for employees in Kuwait, Iraq, Jordan, Saudi Arabia and Sudan.

3. Customer Service

Customer satisfaction surveys are conducted routinely to assess various aspects of customer experience with the goal of improving the customer journey experience.
Tracking customer satisfaction through Net Promoter Score (NPS) remains one of Zain’s primary methods of identifying pain points and setting actionable and impactful plans to resolve them.
Zain monitors its network performance and online transactions continually to detect any issues, which if identified, are escalated to relevant teams.

Stakeholder Engagement on Material Sustainability-related topics

The table below defines each sustainability-related priority for Zain and identifies the methods of engagement for each material issue in response to concerns of stakeholders. The company manages its sustainability-related topics based on the stakeholder engagement process and adapts to the issues and concerns raised. The topics are in line with Zain’s corporate sustainability strategy, the socio-economic and political context, upcoming environmental, social and governance (ESG) trends and the United Nations’ Sustainable Development Goals.

Sustainability-related Topics	Main Stakeholders Impacted	Zain’s Response
Employee Health and Safety	Shareholders and Investors Employees Business Partners	Maintaining an Employee Health and Safety Policy for all employees and temporary workers. The company ensures that it continuously engages, communicates and informs its employees on all health and safety precautions. All channels are utilized to communicate updates or concerns to all stakeholder groups.
Data Privacy and Security	Customers Shareholders and Investors Employees Government and Regulators	Currently updating our Data Privacy Policy to provide guidance to operations on the collection, processing, and usage of personally identifiable information in compliance with the applicable laws and regulations. Continuous training and informational announcements are provided to all employees under Zain’s PAUSE.THINK.ACT cybersecurity awareness program. Continuous enhancements on Zain’s cybersecurity capabilities are undertaken by updating policies and procedures, security tools, training and awareness, and periodic security assessment.
Customer Service	Customers	Maintaining a variety of activities on a proactive basis to ensure that our interactions with customers are positive and productive. Multiple engagement tools are used to track customer interaction and identify potential areas of improvement.
Business Ethics and Governance	Shareholders and Investors Employees Business Partners Government and Regulators	Publishing a Whistle-Blowing Policy to report and mitigate any unethical actions internally in adherence to best practices. To protect all stakeholders’ rights by maintaining transparency, the company’s Code of Conduct is publicly available.
Economic Performance	Customer Shareholders and Investors Employees Business Partners	Providing a transparent understanding of the strategy and business through frequent engagement by hosting forums and meetings, issuing periodic financial reports, disclosing the company’s financial performance, and engaging in earnings conference calls.
Digital Transformation	Customers Shareholders and Investors General Public and Community Institutions Business Partners	Enhancing customer experience and service through digitalization by continuously developing the company’s digital channels such as the Zain app, Zbot, and website.
Digital Inclusion	Customers General Public and Community Institutions Government and Regulators	Ensuring our sales channels are disability inclusive. Aligning to the Principles for Digital Inclusion for Persons with Disabilities and offering workshops that raise awareness on disability inclusion and customizing packages for specific marginalized segments.
Diversity and Inclusion	Customers Employees General Public and Community Institutions Government and Regulators	Conducting workshops and webinars that tackle gender diversity issues. Equipping employees with opportunities to submit startup ideas to Zain’s internal innovation platform, enhance the skills of employees under the youth segment through different programs. Partnering with organizations for people with disabilities to establish an inclusive culture at Zain. Providing Zain employees with tools and resources for mindfulness and mental health. To learn more about how the company is addressing diversity and inclusion in the workplace, visit ‘Our People’ section.
Freedom of Expression	Shareholders and Investors Employees Government and Regulators	Ensuring that processing of personal data is in place with the objective to respect the fundamental rights and freedoms of individuals including the right to the protection of personal data communicated through Zain’s Human Rights Policy Statement.
Child Online Protection	Customers Employees General Public and Community Institutions Government and Regulators	Position child online protection as a strategic focus area under Zain’s Corporate Sustainability strategy. To learn more about how the company is playing a key role in addressing online risks for children, visit ‘Our Sustainability Agenda’.
Entrepreneurs and SME Development	Customers Shareholders and Investors General Public and Community Institutions	Continuous engagement with the startup community through Zain Ventures, B2B, and community institutions to address their requirements, while fostering the entrepreneurship ecosystem.
Tax Transparency	Shareholders and Investors Government and Regulators	Submitting corporate income tax returns, Zakat and National Labor Support Tax (NLST), while engaging with tax authorities to ensure they are up-to-date with the most recent tax laws.
Socio-economic Compliance	Shareholders and Investors Employees Business Partners Government and Regulators	Publishing a Whistle-Blowing Policy to report and mitigate any unethical actions internally in adherence to best practices. Assessing regulatory trends on ESG indicators to ensure alignment and disclosure. Attend industry-wide forums and webinars on ESG to further align to international best practices.
Responsible Supply Chain	Shareholders and Investors Business Partners: Suppliers, contractors and distributors	Maintaining open channels of communication and clearly articulating contract terms and agreements. Communicating Zain’s Supplier Code of Conduct and the Human Rights Policy Statements. Providing Supplier Assessment Questionnaires when onboarding new suppliers and recommunicating to existing ones.
E-Waste and Waste Management	General Public and Community Institutions Business Partners Government and Regulators	Setting targets to minimize waste across Zain’s operation, including warehouses in alignment with best practices. Spreading awareness on the implications of waste on the environment and providing tips to mitigate this issue. Launched trade-in program for E-Waste and gradually substituting plastic bags with reusable ones for customers.
Climate Change	Customers Shareholders and Investors Employees General Public and Community Institutions Business Partners Government and Regulators	Committed to addressing its environmental footprint by setting stringent targets to reduce emissions, minimize waste, spread awareness, and identify the risks and opportunities of climate change. To learn more about Zain’s commitment to tackling climate change, visit ‘Our Climate Action’ section.
5G and Public Perceptions on Health	Customers General Public and Community Institutions Government and Regulators	Precaution and safety guidelines are included in Zain’s Environmental and Social Management Plan (ESMP) that was shared with all employees, and with Zain suppliers.
Modern Slavery	Shareholders and Investors Employees General Public and Community Institutions Government and Regulators	Committed to the principles of the Universal Declaration for Human Rights, the Core Conventions for the International Labor Organization, and the United Nations’ Guiding Principles on Business and Human Rights Reporting. Committed to investigating any concerns and if we discover any adverse human rights impacts, we will act appropriately without delay.

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