Global Supply Chain Sustainability Policy

In an era where corporate responsibility and sustainability are at the forefront of business operations, Telefónica underlines the Group’s unwavering commitment to creating sustainable production environments in which respect for and promotion of Human Rights is fostered throughout its supply chain in the fourth edition of its `Global Supply Chain Sustainability Policy’. To this end, it has the Supplier Code of Conduct, through which it seeks to ensure that all links in the chain operate with the utmost respect for legal, ethical, social, environmental and privacy principles. The ‘Global Supply Chain Sustainability Policy’ is applicable across all companies within the Telefónica Group. 

In 2025, this policy was updated to align with the new European regulatory frameworks on sustainability, such as the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). This update also responds to the Group’s commitment to the continuous improvement of its internal regulatory framework and to the expectations of investors, analysts and stakeholders. 

Commitments to the supply chain

The new version of Telefónica’ s Supply Chain Sustainability Policy replaces the previous ones. While maintaining continuity with previous editions, the wording and structure have been adapted to reflect the results of the double materiality analysis – which includes the Impact, Risk and Opportunity Assessment (IRO) – and ensure stronger management, aligned with the standards of the Corporate Sustainability Reporting Directive (CSRD).

Telefónica is deeply committed to upholding the highest standards of rigour, objectivity and transparency in its interactions with suppliers. These key principles include:

• Avoid any lack of integrity, conflict of interest, or undue advantage. 
• Promote equal opportunities in purchasing processes. 
• Fulfill the commitments acquired with suppliers. 
• Identify adverse impacts on the supply chain. 
• Implement a supplier evaluation system based on sustainability risks. 
• Integrate ESG (environmental, social and governance) criteria into supplier procurement processes. 
• Facilitate access to clear information on sustainability requirements and monitoring mechanisms. 
• Collaborate with suppliers in the implementation of effective redress mechanisms. 
• Provide training and technical support to suppliers, especially small and medium-sized enterprises, to facilitate the implementation of ethical and sustainable practices and compliance with the requirements set out in this Policy. 
• Cooperate at the sectoral level to drive the best available management practices. 
• Encourage the active participation of relevant stakeholders in the identification, assessment and monitoring of impacts and risks in the supply chain. 

Telefónica’s dedication to these principles underscores its commitment to supply chain sustainability, ensuring that every step in the supply chain aligns with the company’s values and standards.

Supplier Code of Conduct, Minimum Sustainability Requirements 

As a new feature, the minimum requirements have been consolidated and simplified in a new annex document: the Supplier Code of Conduct. This code, which forms part of the Policy, is integrated into the GEP purchasing system and must be accepted by suppliers upon registration, ensuring their knowledge and compliance from the outset of the business relationship. 

These minimum requirements are as follows: 

• Legal Compliance and Human Rights: Suppliers must always comply with the applicable regulations, whether international, national or local. It must guarantee respect for Human Rights in its own operations, subsidiaries and supply chains.
• Ethical criteria and integrity:  Telefónica expects its suppliers to combat corruption in all its forms, including bribery and money laundering. Suppliers must avoid situations of conflict of interest and engaging in anti-competitive behaviour. 
• Social Criteria: Suppliers must comply with aspects relating to the employment relationship, working hours, wages and freedom of association and the right to collective bargaining. Suppliers shall also ensure that there is no child labour or forced labour in their activity and in their own supply chain. Telefónica’s Supplier Code of Conduct also stresses the importance of equal treatment and opportunities for all.  Similarly, suppliers shall provide their employees with a safe and healthy working environment, commensurate with the specific hazards/risks of each activity. 
• Environmental Criteria: Suppliers must adhere to all environmental laws, especially those concerning waste, energy, emissions, and resource consumption. They should consider the entire life cycle of their products and services, from raw material extraction to waste management. Moreover, suppliers should have an environmental policy in place and operate an environmental management system. Preferably aligned with ISO 14001 or similar standards. Furthermore, actions to mitigate climate change, promote energy efficiency, and support renewable energy initiatives are also emphasised. 
• Criteria for Privacy, Confidentiality, and Freedom of Speech: Suppliers must process personal data in accordance with applicable personal data protection legislation and may not, under any circumstances, use it for their own purposes. They must implement appropriate cybersecurity measures and ensure that technologies such as artificial intelligence are used in an ethical and responsible manner. In addition, they must sign a personal data protection agreement containing the commitments they assume as data processors for the data for which Telefónica is responsible, in accordance with all applicable data protection regulations. 

The full document can be consulted at the link below: