Policy overview
The Swisscom Group has adopted several policies that target material impacts, risks and opportunities. The corresponding minimum disclosure requirements (MDR-P) are set out below. Following the acquisition of Vodafone Italia by Swisscom through its subsidiary Fastweb, the two companies are working on aligning and harmonising their respective corporate policies.
| Name | Key contents and consideration given to stakeholders | Scope of policy | Accountability | Third-party standards respected | Availability |
|---|---|---|---|---|---|
| Environmental policy | The Group’s environmental policy embeds sustainability considerations and ambitions across the Group’s decisions, operations and the entire value chain. It explicitly states the commitment to climate protection, covering biodiversity, soil, air and water, while promoting goods and services that conserve the environment. It highlights commitments towards energy efficiency and renewable energy, responsible supply chain management, international climate action and targeted training, as well as the assessments of environmental risks and opportunities. | Swisscom Ltd (Group) | Group CEO; Group Communication and Responsibility | ISO14001, Sustainable Development Goals, SBTi | Website, internally |
| Supplier code of conduct (ESG contract addendum) | The supplier code of conduct defines the economic, environmental and social principles to be adhered to by direct suppliers and subcontractors. Swisscom aims to expose any corporate risks in order to take action where necessary. | Swisscom (Switzerland) Ltd | Group Finance | Ten principles of the UN Global Compact, GHG Protocoll, Paris Agreement, ILO Conventions, OECD Guidance for Responsible Business | Website, internally |
| Human rights policy | The Group’s human rights policy sets out the human rights due diligence (HRDD) system and the commitment to respect and promote internationally recognised human rights towards all stakeholders, including employees, customers, workers in the value chain and members of local communities, including children. It explicitly addresses human trafficking, forced or compulsory and child labour. | Swisscom Ltd (Group) | Group CEO; Group Communication and Responsibility | Universal Declaration of Human Rights, Fundamental Conventions of the International Labour Organization (ILO), United Nations Guiding Principles on Business and Human Rights (UNGPs), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and more (see Annex 1 of policy) | Website, internally |
| Code of conduct | This code of conduct contains the minimum expectations of the Board of Directors and the CEO in regard to managers and employees of Swisscom Group. It contains an explicit commitment to integrity and compliance with the law, external and internal rules and regulations. The Group expects its employees to behave responsibly, show consideration for people, society and the environment, and report any violations of the code of conduct. | Swisscom Ltd (Group) | Board of Directors | n/a | Website, internally |
| Personal integrity | The directive aims to protect Swisscom employees from any form of violation to personal integrity, for example, discrimination, sexual harassment, bullying and violence in the workplace. It describes problematic and unacceptable behaviour, the responsibility of employers, line managers and employees, action to be taken if problems occur, the procedure in the event of violations and sets out any legal basis. | Swisscom (Switzerland) Ltd, Swisscom Broadcast Ltd, Swisscom Services Ltd, Swisscom Trust Services Ltd, Worklink Ltd, cablex Ltd, Swisscom RE Ltd | Group Human Resources | n/a | Website, internally |
| Compliance policy | The compliance policy sets out the Group-wide Compliance Management System (CMS) regarding strategic, operational, monitoring and supporting elements and procedures. It is designed with regard to all internal and external stakeholders, including customers, partners and society. Requirements for specific groups of addressees are detailed in specialised guidelines. | Swisscom Ltd (Group) | Group Security & Corporate Affairs | ISO 37301 standard | Internally |
| Anti-corruption directive | This directive sets out permissible or forbidden conduct in the course of professional activities. It is intended to protect employees, third parties involved and the entire Swisscom Group from criminal prosecution. | Swisscom Ltd (Group) | Group Security & Corporate Affairs | Swiss law, UK Bribery Act, U.S. Foreign Corrupt Practices Act applicable to business activities | Website, internally |
| Security policy | The security policy outlines the framework for maintaining security across the organisation on a tactical level, focusing on information security, workplace safety and physical security. It includes objectives, roles, procedures, standards and guidelines, ensuring compliance and continous improvement through regular updates and audits. For subsidiaries domiciled abroad, the policy refers to the mandatory legal system and practice applicable. | Swisscom Ltd (Group) | Group Security & Corporate Affairs | ISO/IEC 27001 | Internally |
| Security directive | The security directive sets out a comprehensive framework for managing security and detailing objectives, roles, and responsibilities at a strategic level. Its goal is to ensure the protection, detection, response and recovery of assets, aiming for effective security management and continuous improvement across all subsidiaries. | Swisscom Ltd (Group) | Group Security & Corporate Affairs | ISO/IEC 27001, NIST Cybersecurity Framework | Internally |
| Policy action plan whistleblowing | This policy provides guidelines for the submission, intake, audit and evaluation of notifications of misconduct submitted through the whistleblowing channel. It ensures that all concerns are addressed fairly, promptly and anonymously in compliance with relevant whistleblowing and data protection legislation. | Swisscom Ltd (Group) | Board of Directors | EU Directive 2019/1937 | Internally |
| Privacy and personal data protection policy | This policy defines the governance framework for safeguarding data in compliance with the GDPR and European regulations. It defines roles, responsibilities and procedures to ensure the security of confidential information, prevent unauthorised access and protect customer privacy. | Fastweb + Vodafone | Legal & Regulatory Fastweb + Vodafone | EU General Data Protection Regulation (GDPR 2016/679), | Internally |
| Code of ethics | The code of ethics requires suppliers to commit to the protection of human rights, comply with labour regulations, and observe legal provisions on health and safety and environmental protection. It defines clear principles of integrity and transparency in data management and customer privacy. It establishes rules for handling information and provides control mechanisms and sanctions in case of violations. | Fastweb + Vodafone | Board of Directors Fastweb + Vodafone | Universal Declaration of Human Rights, Fundamental Conventions of the International Labour Organization (ILO), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct | Website, internally |
| Code of conduct for ethical and sustainable procurement | This code of conduct defines stringent standards of sustainability, social responsibility and transparency for Fastweb + Vodafone suppliers, ensuring alignment with national and international regulations. | Fastweb + Vodafone | Finance Fastweb + Vodafone | Principles of SA8000 standard | Website, internally |
| Social responsibility policy | This policy prohibits child and forced labour, safeguards health and safety, promotes freedom of association, pay equity and non-discrimination, and is monitored by a dedicated Social Performance Team composed of both employee and management representatives. It defines a strong commitment to sustainable development and ethical management of the social impacts. | Fastweb, Vodafone Italia | Human Resources Fastweb + Vodafone | SA8000:2014 standard, Universal Declaration of Human Rights, Conventions of the International Labour Organization (ILO) | Internally |
| Cultural and inclusion policy | This policy is designed to foster an inclusive and safe working environment, valuing diversity in all its forms, such as gender, disability, age, sexual orientation and cultural background. It is committed to equal opportunities, pay equity, work-life balance and the prevention of discrimination. | Vodafone Italia | Human Resources Fastweb + Vodafone | n/a | Internally |
| Diversity and inclusion policy | This policy focuses on various dimensions of diversity, including gender, disability, generational differences, sexual orientation and gender identity, multiculturalism and intersectionality. Fastweb is committed to a safe and inclusive workplace without discrimination or harassment. | Fastweb | Human Resources Fastweb + Vodafone | n/a | Internally |
| Domestic violence and abuse policy | This policy provides support tools for all employees, regardless of gender, nationality, culture or social background. It establishes a principle of zero tolerance towards any form of violence or harassment, with disciplinary or legal measures applied to those responsible. | Vodafone Italia | Human Resources Fastweb + Vodafone | n/a | Internally |
| Health and safety management policy | This policy defines the commitment to health and safety in the workplace as a fundamental element of its technical and economic development. | Fastweb, Vodafone Italia | Human Resources Fastweb + Vodafone | ISO 45001 | Internally |
| Linee guida anticorruzione/ Anti-corruption Guidelines | This document defines common principles and rules of conduct adopted by Fastweb and Vodafone Italia for the prevention of corruption. | Fastweb + Vodafone | Board of Directors Fastweb + Vodafone | n/a | Internally |
| Modello 231 | The Modello 231 establishes behavioral rules for employees to prevent crimes under Legislative Decree 231, implementing a system of procedures and controls to minimise risks. Through activity mapping, ’sensitive processes’ exposed to crime risks have been identified. | Fastweb, Vodafone Italia | Legal and Regulatory Fastweb + Vodafone | n/a | Website, internally |
| Direttiva anticorruzione / Anti-corruption directive | This directive establishes guidelines for managing gifts and event invitations, preventing corruption risks in compliance with internal regulations and the Group policy. It is part of the Anti-corruption Guidelines. | Fastweb + Vodafone | Board of Directors Fastweb + Vodafone | n/a | Internally |