S172(1) statement

The following section 172(1) statement and statement on employee involvement and commitment, which is referred to in the section 172(1) statement, are extracted from the Vodafone Limited (the "Company") Strategic Report and Director's Report (respectively) in its Financial Statements for the year ended 31 March 2025. These reports were approved by the board of directors on 17 December 2025.

172(1) Statement

The Company's long-term success is central to the directors' discussions and decision making. In accordance with section 172 of the Companies Act 2006 each of the directors acts in the way that he or she considers, in good faith, would most likely promote the success of the Company for the benefit of its members as a whole. In doing so, section 172 requires the directors to have regard, amongst other matters, to the:

• likely consequences of any decisions in the long-term;

• interests of the Company's employees;

• need to foster the Company's business relationships with suppliers, customers and other key stakeholders;

• impact of the Company's operations on the community and the environment;

• need to protect the Company's reputation for high standards of business conduct; and

• need to act fairly as between members of the Company.

Stakeholder engagement

The Company takes stakeholder engagement seriously because it appreciates the fundamental need to build a holistic view of its business to promote a strategy which takes account of the broader operating environment. Directors benefit from improved insight into the needs of our stakeholders, provoking discussion of the potential risks and opportunities for our business in satisfying those needs and understanding the potential impact of decisions on affected stakeholders. Better insight and diversity of perspectives leads to more productive and balanced board of directors' discussions on complex issues and, as a result, decisions are well- considered.

The Company's board of directors is committed to engaging with stakeholders directly wherever possible. Provided below is an overview of the Company's board engagement with our key stakeholder groups during the year.

Further details on our engagement with stakeholders including the way we engaged and responded as a Group can be found in the financial statements of Vodafone Group Plc for the year ended 31 March 2025 on its website vodafone.com

People:

A number of engagement and feedback mechanisms for our employees are well established at the Company which are discussed further within the Directors' Report under Employee Involvement and Commitment.

We continue to use regular employee Spirit Beat surveys as part of our employee engagement process and these provide us with very useful feedback on important employee matters relating to the Company.

We want to make sure that we have a positive impact on people and society, which includes respecting human rights in all our operations. The Group has been a long-standing member of the UN Global Compact and followed the United Nations Guiding Principles on Business and Human Rights to guide our approach.

Suppliers:

During the year, the Company operated within the Group under a global supply chain management function. The UK is helped by more than 800 suppliers who partner with it. These range from start-ups and small businesses to large multinational companies. Our suppliers provide us with the products, services and the devices we need to deliver our strategy and connect our customers.

As part of the wider Group, the Company engaged its supply chain through regular collaborative performance reviews, safety forums, events, conferences, and site visits. Purpose criteria relating to planet, diversity and safety are included in tenders and the Group conducts supplier audits and assessments. Key topics from this engagement included driving health and safety standards, net-zero emissions supply chains and supplier/product innovation.

The UK hosted its annual supplier safety forum, where the Group worked together with industry peers and suppliers through the Joint Alliance for Corporate Social Responsibility (JAC). This collaboration included taking corrective actions for human rights within supply chain. Additionally, the Group continued with its environmentally linked supply chain finance programme, which offers benefits to suppliers in the UK.

Community and Environment:

At Vodafone, our aim is to create a digital society that includes everyone and helps protect the planet. We believe superfast connectivity and technology is the key to unlocking the UK's potential. We are connecting people, businesses, and communities, so everyone can tap into the benefits of a digital society. In addition to delivering best in class services to our Vodafone Business customers, we also deliver social value and environmental benefits to their local communities.

Everyone.connected

Our purpose north star in the UK is our everyone.connected campaign which has put tackling the digital divide at the heart of our business. Our directors believe connectivity is essential, and everyone should have access to the opportunities it provides. The digital divide between those who have access to digital technology, and the 5% of UK households who are offline, is at risk of widening further.

The Company is committed to helping 4 million people and businesses cross the digital divide by the end of 2025. To date, 3.7 million people and businesses have benefitted from our programme, delivering £249 million in social value nationwide.

We deliver our goal through three workstreams:

1. Donating connectivity and tech

We donate six months' free mobile connectivity to over 3,000 grassroots charities nationwide and through our partners the Trussell Trust and Good Things Foundation. Our free SIM card offering also includes 40BG data, along with unlimited calls and texts. We also call on the public and businesses to donate old devices which we restore and donate to young people through Barnardo's and Good Things Foundation.

Through our sponsorship with Glastonbury Festival we supported their fully funded volunteer scheme by providing volunteers with six months free connectivity. The scheme was aimed at providing opportunities to volunteer at the Festival for people who would not typically have access to it otherwise due to social, cultural, financial and accessibility barriers.

2. Offering affordable tariffs and services

We offer social mobile and broadband tariffs for those receiving Government benefits through VOXI for Now and Essentials Broadband respectively and we provide support to users who finish their six-month free SIM to access 7GB data, unlimited calls and texts at a half-price tariff of £5 per month.

3. Working with partners to upskill businesses and communities

We work with the National Society for the Prevention of Cruelty to Children ('NSPCC') to help families and children stay safe online, including our TRUST toolkit and 'Your Child's First Phone' platform. We also offer business.connected with the goal of reaching 1,000,000 small businesses by the end of the year, and support Good Things with growing their network of over 5,000 Digital Inclusion hubs that provide digital skills training across the UK.

Our commitment to the end of 2025 highlights our ambition to drive holistic change. We have built lasting partnerships with key charities: NSPCC, the Trussell Trust and Good Things Foundation. They have the expertise, network, and capability to reach the most vulnerable members of society and have co-created these programmes to ensure they are successful.

Our most recent partnership with NSPCC further embeds online safety into our programmes. The partnership resonates strongly with our employees and helps us work cross-functionally to launch new initiatives like 'Digitales' a compilation book of fables for a digital age written by young people through a partnership with First News. This helped the voices of young people be shared, promoted online safety and increased our customers' awareness of our partnership with NSPCC.

The directors are committed to achieving our four million goal and will continue to work with existing and new partners to reach digitally excluded people who need it most, however we know providing connectivity is just one part of the solution. The Board are also committed to work to raise awareness of the issue of digital exclusion, seek out reliable data to drive impact and change, upskill those needing help, provide accessible tariffs for the financially vulnerable, and continue to donate connectivity where needed.

Net zero

In 2020, Vodafone set a series of ambitious objectives and established greenhouse gas emissions reduction targets which were approved by the Science Based Targets initiative ('SBTi') in line with reductions required to keep warming to 1.5°C. In the UK, we expedited our target to achieve net zero emissions across our operations to 2027. Vodafone is committed to achieving net zero status across its complete value chain by 2040.

The Company has been powered by 100% renewable electricity since July 2021, and we have already cut carbon emissions from our operations by 93% (scope 1 and 2 market-based emissions vs 2019/20 baseline). This is being delivered through a major rationalisation and efficiency programme, moving to electric vehicles, and powering our business and network with renewables.

In the year ended 31 March 2025, the Company:

• Continued to deploy and optimise energy saving software solutions across our technical estate to reduce energy consumption during periods of low or no network traffic. Through a combination of lighting upgrades, enhanced sub-metering and building management system enhancements energy usage has dropped by 171 million kilowatt-hours (kWh) in the last six years.

• Extended our programme to move to fire suppression solutions with lower global warming potential within our data centres.

• Continued our transition to an electric fleet and our commitment to sustainable employee commuting by only offering electric vehicles via our company car scheme.

Climate Adaptation and Resilience

Beyond reducing our emissions, our connectivity, data and technology is continuing to support the UK become a more climate resilient economy and society. For example, our role within the River Severn Partnership sees us contribute rainfall nowcasting to forecast the impact of potential flood events.

Circular economy

We have grown our offer of refurbished devices to customers and launched our new Xchange solution which enables customers to return their phones in a good condition before their plan ends which increases the volume of high-quality refurbished devices.

Furthermore, we continue to support customers extend the lifecycles of their devices with our Lifetime Service Promise and we became the first major UK network to introduce Screen Damage insurance, from as little as £2 per month.

Governments and regulators

Our relationship with governments and regulators is important and we hope to work together on policies impacting our industry and customers, while also enabling them to better understand the positive impact we can have on the environment and communities we operate in.

Employee involvement and commitment

Employee involvement and commitment is encouraged throughout the Company and is the responsibility of the board of directors.

To ensure consistent and meaningful engagement, the directors engage regularly and directly with employees via Connect Live, a regular virtual interactive session run by our CEO and General Management Team, via an internal social media platform. We provide regular updates on the UK strategic priorities and financial results, and it provides a forum for employees to ask questions directly of our directors. Our directors are also kept informed of employee feedback via regular employee surveys and receive feedback on important employee matters relating to the Company.

The Company also recognises the importance of providing information to, and consulting with, its employees about workplace issues, such as company policies, health & safety and matters affecting terms and conditions of employment. The Employee Consultation Council ("the ECC") was established in 2014 as the primary mechanism for informing and consulting upon such matters. In recognition of the significant number of UK based employees of other companies within the Group, the ECC also operates as an information and consultation forum for those employees.

People with disabilities

Applications for employment by people with disabilities are always fully considered, bearing in mind the respective aptitudes and abilities of the applicant concerned. In the event of members of staff having a new disability, every effort is made to ensure that their employment continues with the Company and that appropriate training is arranged. It is the policy of the Company that the training, career development and promotion of a colleague with disabilities should, as far as possible, be identical to that of a person who does not have a disability and we consider all reasonable adjustments to achieve that aim.

We have an active and engaged employee network, called VodABILITY, which supports colleagues who have, and raises awareness of, disabilities. Our commitment to supporting colleagues who have a disability is supported by the fact that we have an Executive Sponsor of the VodABILITY network.