GRI disclosures index

GRI statement of use

This report has been prepared in accordance with the GRI Standards (2021). It covers the reporting period from 1 April 2024 to 31 March 2025 and covers Airtel Africa’s operations across its 14 markets. Where data is disclosed on a Group-wide basis, this is clearly indicated in the GRI disclosures index, which also provides detailed references to the specific disclosures made in line with the GRI standards.

Some information requirements could not be provided due to limited data availability. However, we continue to work towards improving data availability and enhancing our reporting process.

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 2: General disclosures 2021	2-1 Organisational details	Airtel Africa at a glance Annual Report and Accounts 2025 – see 'Corporate governance’
	2-2 Entities included in the organisation’s sustainability reporting	The report covers all 14 OpCos. Airtel Africa at a glance
	2-3 Reporting period, frequency and contact point	Sustainability reporting is aligned with the financial reporting: 1 April to 31 March.
	2-4 Restatements of information	See ‘Our journey towards a net zero future’ for adjustment of our 2023/24 energy consumption data.
	2-5 External assurance	No external assurance conducted during this reporting period.	All requirements	Information incomplete	Airtel Africa will consider obtaining external assurance at the future date
	2-6 Activities, value chain and other business relationships	Airtel Africa at a glance Supply chain management Annual Report and Accounts 2025 – see 'How we engage with our stakeholders' in the Governance Report
	2-7 Employees	Our people ESG data
	2-8 Workers who are not employees	ESG data
	2-9 Governance structure and composition	Sustainability governance Annual Report and Accounts 2025 – see Governance Report
	2-10 Nomination and selection of the highest governance body	Annual Report and Accounts 2025 – see Governance Report
	2-11 Chair of the highest governance body	Annual Report and Accounts 2025 – see Governance Report
	2-12 Role of the highest governance body in overseeing the management of impacts	Sustainability governance Annual Report and Accounts 2025 – see Governance Report
	2-13 Delegation of responsibility for managing impacts	Sustainability governance Annual Report and Accounts 2025 – see Governance Report
	2-14 Role of the highest governance body in sustainability reporting	Sustainability governance Annual Report and Accounts 2025 – see Governance Report
	2-15 Conflicts of interest	Annual Report and Accounts 2025 – see Governance Report
	2-16 Communication of critical concerns	Annual Report and Accounts 2025 – see Governance Report
	2-17 Collective knowledge of the highest governance body	Annual Report and Accounts 2025 – see Governance Report
	2-18 Evaluation of the performance of the highest governance body	Annual Report and Accounts 2025 – see Governance Report
	2-19 Remuneration policies	Annual Report and Accounts 2025 – see the Directors’ remuneration report (p149)
	2-20 Process to determine the remuneration	Annual Report and Accounts 2025 – see the Directors’ remuneration report (p149)
	2-21 Annual total compensation ratio		All requirements	Not applicable	Quoted companies with more than 250 UK employees are required to report each year on the difference in pay between their CEO and their UK employees. Airtel Africa is outside the scope of this requirement, given its small number of UK employees, therefore, we will not be disclosing our pay ratio for the reporting period
	2-22 Statement on sustainable development strategy	Our sustainability strategy
	2-23 Policy commitments	ESG policies
	2-24 Embedding policy commitments	Sustainability governance structure
	2-25 Processes to remediate negative impacts	Our people
	2-26 Mechanisms for seeking advice and raising concerns	ESG policies Also, see ‘Community grievance mechanism’ on www.airtel.africa
	2-27 Compliance with laws and regulations	ESG risk management Annual Report and Accounts 2025 – see ‘Our compliance with the UK Corporate Governance Code’
	2-28 Membership associations	Annual Report and Accounts 2025 – see 'How we engage with our stakeholders' section in the Governance Report
	2-29 Approach to stakeholder engagement	ESG policies Annual Report and Accounts 2025 – see 'How we engage with our stakeholders'
	2-30 Collective bargaining agreements	ESG data

High-priority material topics

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-1 Process to determine material topics	Identifying and managing our material topics
	3-2 List of material topics	Identifying and managing our material topics
	3-3 Management of material topics	Identifying and managing our material topics

Data security

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Data security
GRI 418: Customer privacy 2016	418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data	There were no significant breaches reported during the reporting period.

Ethical business practices and human rights

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	ESG policies Human rights
GRI 406: Non-discrimination 2016	406-1 Incidents of discrimination and corrective actions taken	There were no confirmed incidents of discrimination during the reporting period. Our commitments towards non-discrimination by any basis are outlined in the ‘Human rights’ section
GRI 407: Freedom of association and collective bargaining 2016	407-1 Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk	There are no confirmed significant risks or incidents in which the right to freedom of association and collective bargaining may be at risk during the reporting period. Our commitments to promote and protect the right to freedom of association and collective bargaining can be found in the ‘Human rights’ section
GRI 408: Child labour 2016	408-1 Operations and suppliers at significant risk for incidents of child labour	There are no confirmed significant risks or incidents of child labour during the reporting period. Our commitments to promote and protect human rights can be found in the ‘Human rights’ section
GRI 409: Forced or compulsory labour 2016	409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labour	There are no confirmed significant risks or incidents of forced or compulsory labour during the reporting period. Our commitments to promote and protect human rights can be found in the ‘Human rights’ section
GRI 412: Human rights assessment	GRI 412-1 Operations that have been subject to human rights reviews or impact assessments	We conduct environmental and social impact assessments for our greenfield centres and other network instrastructure	All requirements	Information unavailable / incomplete	We do not currently collect data on number or percentage of operations subject to human rights reviews or assessments
	GRI 412-2 Employee training on human rights policies or procedures		All requirements	Information unavailable / incomplete	We do not currently collect data on human rights training
	GRI 412-3 Significant investment agreements and contracts that include human rights clauses or that underwent human rights screening	All Airtel Africa suppliers are contractually committed to comply with Airtel Africa’s Code of Business Ethics for partners and suppliers which includes labour and human rights clauses.

Anti-bribery and corruption

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	ESG policies
GRI 205: Anti-corruption 2016	205-1 Operations assessed for risks related to corruption	Annual Report and Accounts 2025 – see ‘Managing our risk’
	205-2 Communication and training about anti-corruption policies and procedures	Annual Report and Accounts 2025 – see ‘Managing our risk’
	205-3 Confirmed incidents of corruption and actions taken	There were not any confirmed incidents of corruption during the reporting period

Digital inclusion

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Digital inclusion

Financial inclusion

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Financial inclusion

Education and digital literacy

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Access to education

Economic value creation

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Annual Report and Accounts 2025 – see ‘Financial review’
GRI 201: Economic performance 2016	201-1 Direct economic value generated and distributed	Economic value generated through job employment and tax contribution in Driving impact Annual Report and Accounts 2025 – see ‘Financial review’
		Annual Report and Accounts 2025 – see ‘TCFD disclosures’
	201-3 Defined benefit plan obligations and other retirement plans		All requirements	Information unavailable/ incomplete	At Airtel Africa, in each country of operation, we manage the pension scheme of our employees under the regulations of relevant jurisdictions. We aim to develop more detailed disclosures concerning our pension obligations and plans in future reporting periods
	201-4 Financial assistance received from the government	Total incentive received during the reporting period : $2.086m. Both GSM/Airtel Tanzania (ATPLC) and Airtel Money Tanzania Limited (AMTL) are owned by the Government of United Republic of Tanzania (GoT). ATPLC is directly owned by GoT (49%) while AMTL is directly owned by GoT (48.9%) and indirectly through ATPLC (0.098%).

Ethical labour management

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Our people
GRI 401: Employment 2016	401-1 New employee hires and employee turnover	ESG data
	401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employee	Among the benefits provided to full-time employees (on-roll) are pension contributions, life insurance, medical insurance and handset benefit. However, for off-roll employees, life and medical insurance is provided by their direct employer (a third-party entity)
	401-3 Parental leave	ESG data	Requirements omitted: 401-3 (c, d, e)
GRI 402: Labour/management relations 2016	402-1 Minimum notice periods regarding operational changes	There is a two-month notice period for on-roll employees, and one month for off-roll employees. At the request of an employee, the notice period may be extended
GRI 404: Training and education 2016	404-1 Average hour of training per year per employee	Training and development
	404-2 Programmes for upgrading employee skills and transition assistance programmes	Training and development
	404-3 Percentage of employees receiving regular performance and career development reviews	All of our on-roll employees receive regular performance reviews

Employee health and safety

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Healthy and safe work environment
GRI 403: Occupational health and safety 2018	403-1 Occupational health and safety management system	Healthy and safe work environment
	403-2 Hazard identification, risk assessment, and incident investigation	Healthy and safe work environment
	403-3 Occupational health services	Healthy and safe work environment
	403-4 Worker participation, consultation, and communication on occupational health and safety	Healthy and safe work environment
	403-5 Worker training on occupational health and safety	Healthy and safe work environment
	403-6 Promotion of worker health	Healthy and safe work environment
	403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships	Healthy and safe work environment
	403-8 Workers covered by an occupational health and safety management system	All employees are covered by the occupational health and safety management system
	403-9 Work-related injuries	During the reporting period, there were 4 injuries reported for on-roll employees	Requirements omitted: 401-3 (b)	Information unavailable/ incomplete	We’re in the process of developing an internal data collection system to cover this disclosure in the future

Service quality

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Service quality

Transparency and reporting

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Sustainability strategy overview

Supply chain

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Supply chain management
GRI 204: Procurement practices 2016	Disclosure 204-1 Proportion of spending on local suppliers	ESG data
GRI 308: Supplier environmental assessment 2016	308-1 New suppliers that were screened using environmental criteria		All requirements	Information unavailable/ incomplete	We’re in the process of developing an internal data collection system to cover this disclosure in the future
GRI 308: Supplier environmental assessment 2016	308-2 Negative environmental impacts in the supply chain and actions taken	There were no negative impacts in supply chain related to the environment in 2024/25. This is based on the formally reported cases only
GRI 408: Child Labor	GRI 408-1 Operations and suppliers at significant risk for incidents of child labour	No suppliers have been identified with significant risk for child labour
GRI 409: Forced or Compulsory Labor 2018	GRI 408-1 Operations and suppliers at significant risk for incidents of forced or compulsory labour	No suppliers have been identified with significant risk for forced or compulsory labour
GRI 414: Supplier social assessment 2016	414-1 New suppliers that were screened using social criteria	New suppliers are screened against social criteria, including ethical labour practices, as part of the supplier onboarding process. Social criteria are included into the standard procurement contract, which suppliers sign to comply with the company's requirements and standards. All suppliers and vendors are also required to adhere to Airtel Africa's code of business ethics for partners and suppliers (for more information visit Link to the code of business ethics for partners and supplier).
GRI 414: Supplier social assessment 2016	414-2 Negative social impacts in the supply chain and actions taken		All requirements	Information unavailable/incomplete	We are in the process of developing an internal date collection system to cover this disclosure in the future reporting period

Indirect socio-economic benefits

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Our community section
GRI 203: Indirect economic impacts 2016	203-1 Infrastructure investments and services supported	Digital inclusion Financial inclusion Access to education
GRI 203: Indirect economic impacts 2016	203-2 Significant indirect economic impacts	Digital inclusion Financial inclusion Access to education

Anti-competitive behaviour

GRI standard	Disclosure	Location in the report/comment	Omission
GRI 206: Anti-competitive behaviour 2016	Disclosure 206-1 Legal actions for anti-competitive behaviour, anti-trust, and monopoly practices	In February 2024, the Common Market for Eastern and Southern Africa (COMESA) Competition Commission launched an investigation under case number CCC/ACBP/A21/07/01/2023 to determine whether agreements between American Tower Corporation and Airtel Africa plc amount to prohibited business practices contrary to COMESA Regulations. In January 2025, a notice of withdrawal of complaint was submitted by Atlas Tower Group (Complainant) to the Commission. The investigation by the Commission is still ongoing as issuance of the notice of withdrawal is not sufficient to cease the investigation and we are awaiting the outcome of the investigations. In July 2023, the High Court – Lilongwe (Malawi) issued its decision in favour of Airtel Malawi plc in the in the case number 798 of 2021 – Airtel Malawi plc versus Competition and Fair-Trading Commission with respect to alleged unfair trading practices by Airtel Malawi. The parties appeal the decision before the Supreme Court of Appeal of Malawi. The Director of Public Prosecutions (DPP) issued a notice of intention to commence criminal investigations against Airtel Malawi based on the 2023 High Court judgment where the High Court had referred the matter to the DPP for criminal investigations. Airtel was able to subsequently obtain an order of stay against the judgment. Airtel Malawi has formally written to the DPP informing them of the existing stay. In 2023, following issuance of notification for an intended commission review, four retail distribution partners filed complaints with the Competition Authority of Kenya (CAK) alleging abuse of buyer power on the part of Airtel Kenya. Airtel Kenya filed High Court Judicial Review Case No. E195/2023 challenging the jurisdiction of the CAK, considering there exists a dispute resolution process provided for under contract and the dispute is purely commercial. On 3 October 2024 a ruling was delivered where the High Court held that Airtel should have challenged the CAK investigation at the Competition Appeals Tribunal rather than refer the same to the High Court for judicial review. Airtel Kenya has filed an appeal against the ruling. In 2021, a betting company filed a complaint with the Zambia Competition Consumer Protection Commission (CCPC) against Airtel Mobile Commerce Zambia Limited (AMCZ) on account of alleged discriminatory pricing. The CCPC investigated the matter and in December 2022, found that AMCZ had abused its dominant position by unfairly increasing the charges and applying dissimilar prices to equivalent transactions within the betting portfolio. The Commission fined AMCZ 3% of its 2019 revenue for the alleged breach. AMCZ appealed, and the matter is currently before the CCPC Tribunal and is yet to be determined.

GRI standard

Disclosure

Location in the report/comment

Omission

Requirement(s) omitted

Reason

Explanation

GRI 206: Anti-competitive behaviour 2016

Disclosure 206-1 Legal actions for anti-competitive behaviour, anti-trust, and monopoly practices

In February 2024, the Common Market for Eastern and Southern Africa (COMESA) Competition Commission launched an investigation under case number CCC/ACBP/A21/07/01/2023 to determine whether agreements between American Tower Corporation and Airtel Africa plc amount to prohibited business practices contrary to COMESA Regulations. In January 2025, a notice of withdrawal of complaint was submitted by Atlas Tower Group (Complainant) to the Commission. The investigation by the Commission is still ongoing as issuance of the notice of withdrawal is not sufficient to cease the investigation and we are awaiting the outcome of the investigations.
In July 2023, the High Court – Lilongwe (Malawi) issued its decision in favour of Airtel Malawi plc in the in the case number 798 of 2021 – Airtel Malawi plc versus Competition and Fair-Trading Commission with respect to alleged unfair trading practices by Airtel Malawi. The parties appeal the decision before the Supreme Court of Appeal of Malawi. The Director of Public Prosecutions (DPP) issued a notice of intention to commence criminal investigations against Airtel Malawi based on the 2023 High Court judgment where the High Court had referred the matter to the DPP for criminal investigations. Airtel was able to subsequently obtain an order of stay against the judgment. Airtel Malawi has formally written to the DPP informing them of the existing stay.
In 2023, following issuance of notification for an intended commission review, four retail distribution partners filed complaints with the Competition Authority of Kenya (CAK) alleging abuse of buyer power on the part of Airtel Kenya. Airtel Kenya filed High Court Judicial Review Case No. E195/2023 challenging the jurisdiction of the CAK, considering there exists a dispute resolution process provided for under contract and the dispute is purely commercial. On 3 October 2024 a ruling was delivered where the High Court held that Airtel should have challenged the CAK investigation at the Competition Appeals Tribunal rather than refer the same to the High Court for judicial review. Airtel Kenya has filed an appeal against the ruling.
In 2021, a betting company filed a complaint with the Zambia Competition Consumer Protection Commission (CCPC) against Airtel Mobile Commerce Zambia Limited (AMCZ) on account of alleged discriminatory pricing. The CCPC investigated the matter and in December 2022, found that AMCZ had abused its dominant position by unfairly increasing the charges and applying dissimilar prices to equivalent transactions within the betting portfolio. The Commission fined AMCZ 3% of its 2019 revenue for the alleged breach. AMCZ appealed, and the matter is currently before the CCPC Tribunal and is yet to be determined.

Diversity and inclusion

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Diversity and inclusion
GRI 405: Diversity and equal opportunity 2016	405-1 Diversity of governance bodies and employees	ESG data Annual Report and Accounts 2025 – see Governance Report
GRI 405: Diversity and equal opportunity 2016	405-2 Ratio of basic salary and remuneration of women to men	Not disclosed	All requirements	Information incomplete/unavailable	We are in the process of establishing internal data collection process to be able to cover this disclosure at a future date

Engagement with local communities

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Our community
GRI 411: Rights of indigenous peoples 2016	411-1 Incidents of violations involving rights of indigenous peoples	There were no reported cases of violations involving rights of indigenous peoples during the reporting period
GRI 413: Local communities 2016	413-1 Operations with local community engagement, impact assessments and development programmes	ESG policies Also, see www.airtel.africa
GRI 413: Local communities 2016	413-2 Operations with significant actual and potential negative impacts on local communities	ESG policies Also, see www.airtel.africa

Climate change

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Reduction of GHG emissions
GRI 302: Energy 2016	302-1 Energy consumption within the organisation	Reduction of GHG emissions
	302-2 Energy consumption outside of the organisation	Reduction of GHG emissions	All requirements		Our scope 3 emissions for the financial year 2024/25 will be available with a one-year lag when data is available from our partners and suppliers and verified before publication
	302-3 Energy intensity				The information is not available for 2024/2025
	302-4 Reduction of energy consumption	Reduction of GHG emissions
	302-5 Reductions in energy requirements of products and services		All requirements	Not applicable	The disclosure is not applicable due to the nature of the telecom business
GRI 305: Emissions 2016	305-1 Direct (scope 1) GHG emissions	Reduction of GHG emissions
	305-2 Energy indirect (scope 2) GHG emissions	Reduction of GHG emissions
	305-3 Other indirect (scope 3) GHG emissions	Reduction of GHG emissions	All requirements		Our scope 3 emissions for the financial year 2024/25 will be available with a one-year lag when data is available from our partners and suppliers and verified before publication
	305-4 GHG emissions intensity	Reduction of GHG emissions goal
	305-5 Reduction of GHG emissions	Reduction of GHG emissions
	305-6 Emissions of ozone-depleting substances (ODS)		All requirements	Not applicable	As a telecom company, we do not produce, import or export any ODS as it’s not a raw material or input in our business operations
	305-7 Nitrogen oxides (NOx), sulphur oxides (SOx), and other significant air emissions		All requirements	Not applicable	As a telecom company, we do not generate any nitrogen oxides (NOx), sulfur oxides (SOx) in significant volumes. Our GHG emissions from fuel consumption are shown in CO₂ equivalent

Circular economy

GRI standard	Disclosure	Location in the report/comment	Omission
GRI standard	Disclosure	Location in the report/comment	Requirement(s) omitted	Reason	Explanation
GRI 3: Material topics 2021	3-3 Management of material topics	Environmental stewardship
	301-1 Materials used by weight or volume		All requirements	Not applicable	We do not use any raw materials/natural resources for our main business operations due to the nature of the telecom business.
	301-2 Recycled input materials used		All requirements	Not applicable	We do not use any raw materials/natural resources for our main business operations due to the nature of the telecom business.
	301-3 Reclaimed products and their packaging materials		All requirements	Not applicable	We do not use any raw materials/natural resources for our main business operations due to the nature of the telecom business.
303: Water and effluents 2018	303-1 Interactions with water as a shared resource	Environmental stewardship
	303-2 Management of water discharge-related impacts	Environmental stewardship
	303-3 Water withdrawal	ESG data
	303-4 Water discharge	ESG data
	303-5 Water consumption	Environmental stewardship ESG data
GRI 306: Waste 2020	306-1 Waste generation and significant waste-related impacts	Environmental stewardship
	306-2 Management of significant waste-related impacts	Environmental stewardship
	306-3 Waste generated	Environmental stewardship ESG data
	306-4 Waste diverted from disposal	Environmental stewardship ESG data
	306-5 Waste directed to disposal	Environmental stewardship ESG data

Airtel Africa plc

Sustainability Report 2025