Telia Company: Human Rights Impact Assessments

BSR helped the telecommunications firm Telia Company integrate human rights into business decision-making in two ways: Human Rights Impact Assessments (HRIAs) in six Eurasian markets where the company is exiting and HRIAs in two European markets where the company continues to invest.

The Challenge

In September 2015, Telia Company announced its intention to divest from Region Eurasia, including through the sale of its subsidiaries in Azerbaijan, Georgia, Kazakhstan, Moldova, Tajikistan, and Uzbekistan. For this reason, Telia Company sought to create a “responsible divestment plan” that would take into consideration the human rights impacts, risks, and opportunities arising from the divestment, including:

• How to minimize human rights risks from the announced sale.
• What to look for in the due diligence of potential buyers, such as their human rights record and commitments.
• What activities to undertake during the sales period, such as using the final HRIA reports to build the capacity of the buyer to manage its new assets with respect for human rights.

At the same time, Telia Company announced its intention to invest in a new generation of products and services in its European markets, such as the internet of things, entertainment, and security. Telia Company sought to understand the actual and potential human rights impacts in these markets, and how to address them in its policies, strategies, and plans.

Our Strategy

For each of the eight markets (the six Region Eurasia markets, plus Sweden and Lithuania of Telia Company’s European markets) BSR undertook HRIAs using methodologies based on the UN Guiding Principles on Business and Human Rights. For each HRIA, BSR completed four phases:

• Immersion, where we built knowledge of the company and the local context through document review, company interviews, and meetings with subject matter experts.
• Mapping, where we visited the country to identify actual and potential human rights impacts with local stakeholders and rightsholders.
• Prioritization, where we reached conclusions on where Telia Company and its subsidiaries should focus their human rights efforts.
• Final report, where we made recommendations for a company human rights action plan over the short, medium, and long term, and reached conclusions about the use of company leverage.

For the six Region Eurasia markets BSR made recommendations to Telia Company for how to integrate human rights into the sales process through a responsible divestment plan, and to each subsidiary and its future owners for how to manage and mitigate human rights impacts during the ongoing management of the companies.

For the two European markets BSR made recommendations to Telia Company for how to integrate human rights into its companywide strategy, governance, and management, and for the local subsidiary we made recommendations for how to manage human rights impacts in that market.

Our Impact

The impact of this work will arise through the implementation of BSR’s recommendations, which covered a diverse range of human rights issues, such as privacy, freedom of expression, non-discrimination, security, land rights, child rights, and labor rights.

In Region Eurasia, Telia Company has implemented BSR’s recommendations by undertaking human rights due diligence of potential buyers and sharing the HRIAs with them. Both Telia Company and the local subsidiaries have maintained human rights action plans and tracked progress over time.

Similarly, in Sweden and Lithuania, Telia Company is creating and maintaining action plans to implement recommendations and track progress. The implementation of these human rights action plans is overseen by Telia Company’s Governance, Risk, Ethics, and Compliance Committee.

In addition, Telia Company has published the Sweden and Lithuania HRIAs, and summary versions of the Region Eurasia HRIAs.

Lessons Learned

BSR and Telia Company gained many new insights into how to apply the UN Guiding Principles on Business and Human Rights in practice.

• Stakeholder and rightsholder engagement is essential. Across the eight HRIAs BSR and Telia Company met with around 100 stakeholders and rightsholders from a wide range of backgrounds. We met with human rights defenders, advocates, policymakers, diplomats, and regulators. Valuable insights were gained, and new relationships were forged that will be essential for the successful implementation of HRIA recommendations.
• Transparency by companies on human rights issues has impact. Over recent years a number of internet and telecoms companies, including Telia Company, have become much more transparent in their approach to freedom of expression and privacy. While these reports can be long and detailed, it has been striking to learn how many insights local human rights defenders and advocates gain from the reports, and how they are put to use.
• An industry lens is required. The UN Guiding Principles on Business and Human Rights are written for all companies in all industries, so applying them in a telecoms industry context raises all sorts of challenging questions—for example, how disruptive technologies such as the internet of things alter human rights risks, or how companies navigate situations where compliance with local laws, regulations, and licenses can result in human rights violations.
• The link between ethics and human rights is strong. While freedom from corruption is not a human right, it was clear throughout the HRIAs that there are strong links between ethics, corruption, and human rights. An ethics violation—such as the selection of an unqualified supplier with poor health and safety practices—can result in significant human rights consequences, while the victims of both ethics and human rights violations are often the most vulnerable populations.

Most of all, these HRIAs illustrated the importance of a proactive approach to integrating human rights into business decision making. Without the intelligence gathering required by the HRIAs, Telia Company’s senior decision-makers would have fewer decision-useful insights available on important issues of material significance to the company.