ESG Metrics For Telecom Sector

ESG Metrics
for Mobile
Realising value for society through
common industry KPIs
June 2022
Executive The value of The industry Environment Digital inclusion Digital integrity Supply chain Detailed
Introduction Next steps
summary the KPIs ESG framework KPIs KPIs KPIs KPIs guidance
The GSMA is a global organisation unifying the mobile EY | Building a better working world
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thrive. Representing mobile operators and organisations
across the mobile ecosystem and adjacent industries, the Sustainability is one of the defining issues of our time
GSMA delivers for its members across three broad pillars: and taking a lead on climate change is a vital element of
Connectivity for Good, Industry Services and Solutions, building a better working world.
and Outreach. This activity includes advancing policy,
tackling today’s biggest societal challenges, underpinning Enabled by data and technology, diverse EY teams in over
the technology and interoperability that make mobile 150 countries provide trust through assurance and help
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convene the mobile ecosystem at the MWC and M360
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transactions, EY teams ask better questions to find new
We invite you to find out more at gsma.com.
answers for the complex issues facing our world today.
Follow the GSMA on Twitter: @GSMA
ey.com/en_uk/tmt
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Advisor:
Yale Center for Business

and the Environment
EY authors:
Praveen Shankar, Barend van Bergen, Greg Sumner,
Adrian Baschnonga, Matt Wilson, Vibs Bhatia, Rachel Fisch
ESG Metrics for Mobile 2

Acknowledgements
We would like to thank the following organisations for the contributions they have made
to the development of the industry KPIs and this publication:
Mobile operators: External experts:
Airtel ESG Book

América Móvil FCLTGlobal
Deutsche Telekom International Telecommunication Union (ITU)
Globe Refinitiv
Millicom Threefold Sustainability
MTN United Nations Development Programme (UNDP)
MTS Value Balancing Alliance
Orange World Benchmarking Alliance
Safaricom World Economic Forum
Singtel
STC
Telefónica
Telenor
Tele2
Telia
Telstra
TIM
VEON
Vodafone
Zain

Contents
Foreword 5
Executive summary 6
Introduction 8
The value of the industry KPIs 12
The industry ESG framework 16
ESG KPIs for the mobile industry 18
Category 1: Environment 19
Category 2: Digital inclusion 24
Category 3: Digital integrity 27
Category 4: Supply chain 30
Next steps 32
Appendix: Detailed guidance on the industry KPIs 35

Foreword
As the mobile industry strives to ‘Connect Everyone and These efforts have resulted in an initial proposal of 10 core
Everything to a Better Future’, mobile operators across industry-specific and actionable KPIs. We believe they offer
the world are deploying the networks and connected an important starting point for driving consistency and
solutions that help address the needs of society and the comparability across the industry, providing stakeholders
planet. Integrating purpose into core business requires with the opportunity to better understand how the industry
the industry to consider its impact on stakeholders and generates value for society. They will enable operators
society, and to understand which are the most pressing to take a more proactive position in providing relevant
sustainability issues that should be prioritised. material disclosures, and provide the tools and setting
for both data preparers and data users to have a more
The GSMA plays a critical role in driving forward these enhanced and constructive dialogue on ESG performance.
efforts by providing member CEOs and their teams with By using them, mobile operators will generate insights
tools and guidance to raise responsible business practice that can support internal decision-making, fact-based
and leadership in their organisations. This work took a stakeholder dialogue, communicate progress towards
critical step forward in early 2021, when the GSMA convened ESG goals and help build trust with customers. We hope
mobile operators and other industry stakeholders to map these KPIs will have a positive impact for the industry and
the environment, social and governance (ESG) reporting move the dial.
ecosystem and identify the related topics that are most
material for the industry. This initiative had one ambitious We would like to thank the mobile operator representatives
aim: to build early consensus on how mobile operators who contributed to the development of the industry KPIs,
can best measure and demonstrate their value to society and for the commitment and spirit of collaboration they
and impact on the planet. and their talented teams have brought to this project. We
also appreciate the perspectives shared by investors and
To demonstrate progress on efforts made, measurement is subject matter experts, as well as global standard setters
key. The GSMA and EY worked collaboratively with GSMA who have provided input and advice. In the coming
members to develop, for the first time, a harmonised set months, we look forward to soliciting additional feedback
of ESG key performance indicators (KPIs) and metrics. from stakeholders, and are ready to support companies
A forum was created where operators from across the as they test the integration of the KPIs into their ESG
globe could share and discuss their perspectives on which reporting cycles.
ESG-related indicators were most impactful, decision-
useful, and feasible to implement. In-depth interviews and
consultations with mobile operators, intergovernmental
organisations, standard setters, subject matter experts
and investors were conducted to solicit advice.
John Giusti Praveen Shankar

Chief Regulatory Officer, GSMA EY Managing Partner & UKI Technology,
Media and Telco (TMT) Sector Leader

Executive summary
There is a critical need for more effective and consistent approaches to measuring
and communicating ESG performance
Sustainability is one of the defining issues of our generation. However, the existence of around 600 global
Consumers, employees and regulators are increasingly ESG reporting standards and what has long been
vocal regarding their expectations for companies to act described as an “alphabet soup” of standard-setters,
responsibly and to demonstrate how they create value to has contributed to fragmentation and an increasing
society. EY research has found that 90 per cent of investors reporting burden on companies.
attach greater importance to companies’ ESG performance
when it comes to their investment strategy and decision Many operators find it challenging to fully report the
making than they did before the global pandemic.1 Mobile information deemed to be material by the sector and
operators recognise that, by placing greater focus on their its stakeholders, and data collection and reporting
ESG performance, they can build stronger relationships processes can be cumbersome and labour-intensive. This
with stakeholders and create financial value. is hindering meaningful action and transformation, as well
as limiting the industry’s ability to fully demonstrate its
As ESG is increasingly becoming a decision component value to society.
of asset allocation there is a growing attention on
reporting which is currently complex, fragmented and not
necessarily aligned to the impact of the industry.
Mobile operators currently report on most of the industry’s key topics, but not always in a consistent way
A review of the ESG data in 25 leading mobile operators’ However, operators do not always report on these
sustainability or integrated reports found that nearly topics in a way that is consistent, limiting the industry’s
all provide information on material topics such as ability to fully demonstrate their value to society. The
greenhouse gas emissions, energy consumption, digital industry KPIs are designed to address this challenge.
inclusion and waste management.
% of mobile operators reporting on the following topics2:
96% 96% 92% 84%

Scope 1 and 2 energy digital inclusion waste
emissions consumption initiatives management
60% 52% 20% 52%

Scope 3 renewable energy affordability of e-waste
emissions consumption devices or data plans management
1. ‘Sixth global institutional investor survey’, EY, 2021

2. Included in this analysis are the 25 GSMA Board Members elected for the 2021-2022 term, who reflect the largest operator groups as well as smaller independent
operators with global representation.
Our proposed industry KPIs are The mobile industry can use the
designed to enhance consistency and proposed KPIs to measure and improve
impact ESG performance
Through consultations and workshops with mobile The progress made to date is an important step forward
operators, industry stakeholders and subject matter experts, in establishing common KPIs that allow mobile operators
a set of 10 core KPIs has been proposed for the mobile to measure and improve their ESG performance. The
industry. They are designed to complement and build on the proposed core set of KPIs will evolve as they are tested
disclosures that many operators are already making through by mobile operators, as ESG strategies mature and as
universal reporting frameworks, and they align to existing global reporting requirements evolve. Mobile operators
standards, guidance and methodologies where possible. and industry experts also agree that “aspirational” metrics
This includes those established by the Global Reporting with a sharper focus on impact can — and must — be
Initiative (GRI) and the Sustainability Accounting incorporated into the reporting framework in the coming
Standards Board (SASB). Aligning the KPIs to established years to help drive even more significant outcomes for
standards and guidance will streamline and improve business, the economy, society and the planet.
consistency in reporting, and ease internal adoption.
An open consultation period, ending September 2022, will
The industry KPIs are organised into four categories: provide an opportunity for operators, ESG and industry
1. Environment stakeholders, and subject matter experts to further
2. Digital inclusion assess and validate the KPIs and the reporting processes
3. Digital integrity underpinning them.
4. Supply chain
In parallel, there are three critical steps that mobile
They have been selected on the basis that they are operators and their stakeholders can take to raise
comparable, will be relatively easy to introduce now, awareness and ensure adoption of the industry ESG
are meaningful to external stakeholders, and are useful framework. First, align their leadership and organisation to
for internal decision-makers. The KPIs provide a lens the KPI framework. Second, engage in ongoing dialogues
through which companies can identify and manage with the investment community and other external
emerging opportunities and risk, while demonstrating to stakeholders. And third, adopt the KPIs in future reporting,
stakeholders how their corporate purpose is brought to life. measure your performance and deliver improvements.
Furthermore, the framework creates an opportunity for the
industry to amplify its environmental and social impact by
aligning operators around the same ‘north star’ KPIs.
To provide feedback in the open consultation, or for more information on this initiative, go to
gsma.com/betterfuture/esg

Introduction

Attitudes towards ESG are shifting
The global COVID-19 pandemic, climate crisis and ongoing 9 in 10 investors surveyed by EY in the wake of the
disruptions to supply chains have brought into focus pandemic said that they are now attaching greater
the critical role the private sector must play to mitigate importance to companies’ ESG performance in their
global temperature rise, drive socio-economic inclusion, investment strategies, and that strong ESG performance
and accelerate rates of productivity and innovation. now has a significant and direct impact on analyst
Consumers and employees are increasingly vocal about recommendations.3 Companies, meanwhile, increasingly
the need for companies to act responsibly, and are recognise that they can build resilience and drive long-
more interrogating of the measures they take to do term value creation by maintaining a focus on ESG and
so. The investor imperative is also clear: approximately addressing global challenges such as climate change.
Management attitudes to ESG and long-term value4
86% 83% 76%

Say a focus on ESG has been Say companies that maintain their Say addressing major global
critical to build trust with their focus on ESG and long-term value challenges, such as climate change,
stakeholders in uncertain times will be more resilient in the face of will be key to driving and protecting
increasing disruption and volatility their company’s long-term value

4. ‘Long-Term Value and Corporate Governance Survey’, EY, February 2022
Mobile operators are uniquely placed to accelerate progress on a range of ESG issues
As with other sectors, the mobile industry is expected to digital connectivity is transforming access to healthcare,
respond to more demanding stakeholder expectations. education and financial services. Meanwhile, mobile is
This year, for the first time, poor management of the enabling carbon reductions across society of at least 10
sustainability agenda appears in EY’s report, The top 10 times the industry’s emissions.6 By first addressing and
risks in telecommunications, ranking fifth, reflecting its disclosing their own organisation’s ESG impacts, risks and
growing prominence.5 High energy consumption acts as opportunities, mobile operators will be well positioned to
an impediment to many operators’ net-zero ambitions, enable ESG solutions for their customers.
and future business growth will be linked to operators’
ability to address challenges related to digital exclusion, With the advancement of 5G, enterprises are more
data privacy and circularity. receptive than ever to mobile-enabled use cases that can
help them meet their sustainability needs. Ultimately,
However, there is evidence that mobile operators are mobile operators’ unparalleled touchpoints with billions
a force for ESG improvements not only within their of consumers puts them in a unique position to help drive
own industry but also across the entire economic greater levels of social inclusion, economic participation
ecosystem. A shift towards energy-efficient networks and environmental sustainability.
and sustainable business practices is taking place, and
Almost 70% of executives cite growing interest in using 5G and IoT to meet sustainability goals
Source: Reimagining industry futures study, EY, 2022
Statement: “My organisation is more interested than before in 5G and IoT use cases that can help it meet its
sustainability goals.”
32% 36% 26% 6%
Strongly agree Agree Neither agree or disagree Disagree
The global COVID-19 pandemic has seen mobile operators services is partnered by greater levels of anxiety regarding
act as a lifeline during periods of national lockdown. Indeed, digital safety and well-being. EY research, for example,
mobile operators’ progress on social issues has been led by shows four in 10 consumers are more worried than before
concerted efforts to bridge the digital divide. Yet the nature about the privacy and security of their personal data, with
of the ESG challenge is changing. Greater reliance on online concern highest among younger users.7
Consumer attitudes to online well-being and safety since the global COVID-19 pandemic
Source: Sixth global institutional investor survey, EY, 2021
57% 59%
54%
51%
45% 44%
41% 40%
36%
33% 31% 32%
30%
24%
All respondents 18–24 years 25–34 years 35–44 years 45–54 years 55–65 years 66+ years
Considering more than before how the internet impacts well-being

More concerned than before about privacy and security of personal data
5. ‘TMT’s dual role in building a sustainable future’, EY, 2022

6. ‘The enablement effect’, GSMA, 2019
Measuring and communicating ESG performance is critical
These trends underline that digital inclusion, well-being and Of investors surveyed by EY, 89 per cent said they
privacy are often interrelated issues. Even for consumers would like to see reporting of ESG performance
within range of high-speed networks, issues of affordability, measures against a set of globally consistent
digital skills and online trust can present significant standards become a mandatory requirement.8
obstacles to service adoption. Furthermore, supply chains
require additional focus with electronic waste, human There is a clear opportunity for the industry to take a
rights, labour practices and greenhouse gas (GHG) leadership position in this space by aligning behind a core
emissions in mind, underlining the importance of ESG set of KPIs that will maximise ESG performance and bring
strategies that consider supplier and partner ecosystems. consistency and comparability to sustainability reporting.
With these complex forces in play, the industry’s ability to

effectively measure and communicate progress is more
important than ever before.

The value of
the industry
KPIs

The value of aligned, industry-specific

ESG KPIs
Investors and other stakeholders expect mobile operators that allows for greater comparability and consistency of
to report ESG data that can be used to make informed reporting across global standards.
decisions about material sustainability-related risks
and opportunities. Meaningful disclosures will require This, in turn, will create an opportunity for companies
operators to report against three “tiers” of ESG metrics: across all sectors and geographies to benchmark
universal, industry-specific (which is the focus of this their progress, improve decision making and
paper) and company-specific. accountability, and increase trust.
The three tiers of ESG reporting The ISSB will consolidate and build on existing
frameworks, standards and guidance rather than create
something new. In addition to the ISSB, the European
Commission and the U.S. Securities and Exchange
Commission (SEC) have taken steps to develop regional
COMPANY reporting solutions in recent months.
To start on the path towards meaningful disclosures,

INDUSTRY-SPECIFIC mobile operators can consider the universal metrics
which were prioritised by the World Economic Forum.
The Stakeholder Capitalism Metrics were developed in
consultation with more than 200 companies, investors
and other key players. They are organised under four
UNIVERSAL
pillars — Principles of Governance, Planet, People and
Prosperity — and have been drawn wherever possible
from existing standards and disclosures, with the
In the last two years, momentum towards the aim of amplifying the rigorous work already done by
harmonisation of universal standards has accelerated. standard setters. The metrics have been selected for
The International Sustainability Standards Board (ISSB), their universality across industries and business models,
launched in November 2021 at COP26, aims to provide a but the intention is not to replace relevant sector- and
comprehensive, global sustainability reporting baseline company-specific indicators.

Building upon universal ESG reporting
The Stakeholder Capitalism Metrics are well Industry-specific KPIs form the second tier of ESG
positioned to form mobile operators’ foundational reporting. The proposed set of 10 core KPIs is
tier of ESG reporting, as they encompass many not intended to replace universal metrics; rather,
of the topics operators have agreed are material it is designed to complement and build on them
to the industry. This includes, for instance, in ways that will allow stakeholders to better
critical issues such as diversity and inclusion, assess the extent to which the mobile industry is
business ethics, employee health and safety, creating value for society. The KPIs are organised
social investments and tax transparency. Mobile under four categories: environment, digital
operators can report material information through inclusion, digital integrity and supply chain. Where
as many of the metrics as they find relevant and possible the metrics align to, or are adapted
appropriate, based on a “disclose or explain” from, international reporting frameworks and
approach. existing standards. As with universal frameworks,
companies are encouraged to report against
as many of the core industry KPIs as they find
material and appropriate.

KPI criteria and overview
During the consultation process, five criteria were used to define the minimum requirements that a sector KPI should meet:
1 2 3 4 5
Meaningful for
stakeholders
Decision-useful Comparable Feasible Best indicator
The KPI will influence The KPI will influence The KPI will enable The KPI can be For the given topic,
the assessments internal decision meaningful peer-to- implemented by the the KPI represents
and decisions of making and convey peer comparisons company. It is simple the best indicator of
external stakeholders, information to the across geographies, and short, aligns to the company’s ability
including investors. mobile operator that and the definitions existing standards to create value in the
can substantively and calculation where possible, and short, medium and
enhance the methods are uses standardised long term.
company’s ability to transferable to most measurements. The
create value. companies. underlying methods
and approaches are
robust and follow
accepted approaches.
The proposed KPIs include those that are more established change over time. It is recognised that global comparisons
and focus on enterprise value, such as emissions and for some of the KPIs will be constrained by contextual factors
energy consumption. These types of metrics will be the such as electric grid reliability, GDP per capita, regulatory
focus of the global reporting baseline established by the environments and infrastructure costs. Operators could
ISSB. Alongside of these are broader stakeholder KPIs that, enable more meaningful disclosures by reporting at
in many cases, are less mature and tested, and which focus the country or regional level. Supporting narrative can
on stakeholder value. This includes, for instance, device also be used to provide data users with the contextual
and subscription affordability and digital skills training. As information they need to understand why some markets
operators begin to measure and improve their performance will seem to outperform others against individual KPIs.
against the industry KPIs, they will help generate
evidence that a company’s future prospects and financial In addition to the core KPIs that are feasible and impactful
performance will increasingly be determined by the value it to implement now, operators and industry experts
delivers to all of its stakeholders — including shareholders, suggest that additional “aspirational” metrics can — and
employees, customers and society as a whole. must — be incorporated into the reporting framework
in the coming years to help drive even more significant
Where possible, the KPIs use a denominator such as “per 1GB outcomes for business, the economy, society and the
of data” or ‘per million subscribers’ to make the data more planet. Suggestions for aspirational metrics are therefore
comparable between operators. The denominators were included for each KPI category, but are not yet included
chosen through consultation with mobile operators and may as part of the core KPIs.

The industry ESG framework
COMPANY
INDUSTRY-SPECIFIC
Two tiers of
ESG reporting
UNIVERSAL
The World Economic Forum’s Stakeholder Capital Metrics cover many of the issues that are material to the
mobile industry. The proposed set of 10 core KPIs are designed to complement these universal metrics and
form the important, industry-specific layer of ESG reporting.
Mobile industry KPIs
DIGITAL DIGITAL
ENVIRONMENT SUPPLY CHAIN
INCLUSION INTEGRITY
Emissions Network coverage Data protection Sustainable supply chain

INDUSTRY-SPECIFIC
Science-based targets Population covered by Customer data incidents Sustainable procurement

Scope 1, 2 and 3 emissions mobile network policy
Supplier assessments
Energy Affordability Digital rights

Energy consumption Device and subscription Digital rights policy
affordability
Waste reduction Digital skills Online safety

Materials repaired/reused Digital skills programmes Online safety measures
Waste generated
Materials recycled Yes/no questions
KPIs
Stakeholder Capitalism Metrics Themes
PRINCIPLES OF
PLANET PROSPERITY PEOPLE
GOVERNANCE
UNIVERSAL
• Climate change (GHG • Employment and wealth • Governing purpose • Dignity and equality
emissions and TCFD t generation • Quality of governing body • Health and well-being
implementation) • Innovation of better • Stakeholder engagement • Skills for the future
• Nature loss products and services • Ethical behaviour
• Fresh water availability • Community and social • Risk and opportunity
vitality oversight

Benefits to the industry and stakeholders
The KPIs demonstrate the value that can be created when

an industry comes together to collectively identify the Operators involved in the development of the
ESG issues that are most material to their sector and align framework also indicated that the metrics would
on a common set of indicators. They will allow investors to help them generate insights that can be applied to
gain access to a much deeper level of comparability and decision making, fact-based stakeholder dialogues
understanding of the industry’s nuances and contexts, and client development. The four most compelling
and will also create opportunities for the industry to use cases for the industry KPIs, according to
demonstrate its environmental and social impact in a operators are:
more consistent manner.
1. Inform decision making
Taken together, the universal and industry-specific KPIs Support strategic investment, inform capital
will help create less burdensome and more meaningful allocation, identify new business opportunities
data collection and reporting processes, and provide and target efforts in the right areas to move the dial.
greater consistency in the information disclosed about
operators’ ESG performance. This will enable operators 2. Support fact-based stakeholder dialogues
to take a proactive position in providing relevant material
Support dialogue with external stakeholders,
disclosures, and supply the tools and setting for data
investors, analysts and policymakers on the
preparers and data users to have a more enhanced and
industry’s impact and progress on ESG.
constructive dialogue on ESG performance.
3. Underpin the sustainability/ESG narrative
Drive the sustainability and ESG narrative presented
to investors and other key stakeholders (e.g., board
members and employees) by articulating how the
company’s purpose is integrated into core business.
4. Strengthened client and customer

relationships
Build recognition and trust with clients and
customers, improve brand loyalty and reduce churn.

ESG KPIs for

the mobile
industry
ESG Metrics for Mobile A

Category 1:
Environment
Mobile operators’ impact on the planet is primarily driven
by energy-intensive network infrastructure and a growing Environment KPI use cases
volume of electronic waste, particularly from consumer
devices. As the environmental impacts of mobile Feedback from mobile operators suggests that
operations and services become more visible to investors, reporting against the environment KPIs will help
regulators and consumers, the business risk associated inform internal decision making, including how to
with failing to demonstrate a good understanding of, and set decarbonisation strategies or how to allocate
response to, these challenges will be amplified.9 capital to improve energy efficiency. Disclosures
related to emissions and energy will also provide
The mobile industry is already taking steps to decarbonise, a foundation for strategic dialogues with external
including the accounting and granular reporting of GHG stakeholders such as investors, regulators and
emissions, implementing energy-efficiency programmes policymakers, which will ultimately create
and promoting circularity.10 The KPIs in this category wider industry and societal change. Operators
aim to complement the disclosures found in universal also concluded that the KPIs associated with
frameworks and improve comparability across the industry waste reduction would be particularly helpful
through the reporting of intensity metrics. For consistency, in underpinning their ESG narrative, reinforcing
all environment KPIs use “gigabyte (GB) of data” as a the organisation’s stated mission and purpose to
denominator. This follows guidance received from mobile investors, employees and customers.
operators as well as an analysis of 25 mobile operators’
sustainability reports, which founds that data is the most
common denominator when reporting emissions and energy
intensity. Guidance on the calculation of the intensity
metrics may evolve over time as the KPIs are tested.
9. ‘Measuring stakeholder capitalism: towards common metrics and consistent reporting of sustainable value creation’, World Economic Forum, 2020
10. ‘Climate action handbook’, GSMA, 2019
Environment topics
Emissions
In 2020, the ICT industry took an unprecedented step
forward in tackling climate change, with the release of the
first-ever science-based pathway to reduce GHG emissions
across the telecoms sector. The new science-based target
(SBT) includes emissions reductions trajectories designed
to help operators meet the ambitious Paris Agreement
goal of limiting global warming to 1.5°c by 2030.
Today, 48 operator groups representing 62 per cent

of the global mobile industry by revenue connections
are already committed to SBTs.
Energy
Many mobile operators prepare corporate-level GHG
Energy usage has a measurable impact on both the
emissions inventories and are seeking to improve their
environment and operators’ balance sheets:
ability to accurately measure and track GHG emissions
across their entire operations.11 The industry KPIs
Energy costs currently account for between 15 per
ask operators to disclose their total Scope 1, 2 and 3
cent and 40 per cent of operators’ annual operating
emissions in line with universal standards, in addition
expenditure (opex) and are subject to rising prices.13
to the change in emissions from the previous reporting
period. The complementary emissions intensity KPI has
Although network equipment and data centres are
been designed to build on this information by enhancing
becoming more energy-efficient, mobile operators’ overall
comparability across the sector.
energy consumption is set to increase as infrastructure
expands, networks are upgraded to 4G and 5G, and data
Although challenges remain in the accurate and
traffic increases.
consistent quantification of Scope 3 emissions, operators
should strive to report against as many categories as
Companies that improve the energy-efficiency of their
possible. This is particularly important given that a high
operations are likely to see cost savings and higher profit
proportion of operators’ emissions sit within this category.
margins. A focus on the amount of energy consumed
An analysis of 25 operators’ ESG reports found that more
across the network, and a breakdown of the network
than half are currently reporting against nine or more of
energy mix (renewable vs. non-renewable) by location
the 15 categories. The GSMA is working with operators
(grid vs. off-grid), will allow operators to target where
to develop guidance on measuring Scope 3 emissions,
efficiencies can be made. The intensity measure will
with an aim to create an agreed approach across the
also provide comparability between operators, although
mobile sector on how to measure each of the 15 Scope 3
geographical differences will have to be considered by
emissions categories.
data users.
In time, there will be an opportunity to establish
For instance, many countries in low- and middle-income
“enablement” KPIs that allow operators to measure
countries (LMICs) will not have enabling policies or
the industry’s positive impact on other sectors’
regulatory frameworks in place that incentivise corporate
decarbonisation efforts. Many of the mobile technologies
power purchase agreements (PPAs), which often improve
that can enable a transition to a low-carbon economy
the economics of renewable energy usage for operators.
already exist and can enable sectors to decarbonise in a
In these locations, emissions from diesel generators used
faster, yet methodical and sustainable, manner.12
to power mobile towers may continue to account for a
small but significant percentage of operators’ energy mix.
11. ‘Mobile Net Zero — State of the Industry on Climate Action’, GSMA, 2021
12. ‘The enablement effect’, GSMA, 2019
13. ‘Mobile Net Zero — State of the Industry on Climate Action’, GSMA, 2021
Environment topics
Waste reduction
As networks continue to be upgraded, and as connected of new goods and repurposing existing goods and
equipment and devices become more ubiquitous, the risks components so they can have new uses.
associated with mismanaged waste will grow.
Actions towards the bottom require more energy and
Electronic waste (or e-waste) is one of the fastest- resource use, so should be used only as a last resort when
growing waste streams in the world. options higher up have been explored.
In response, many jurisdictions have implemented Extending equipment lifetime could be preferable from
e-waste recycling laws mandating that both electronics a life cycle perspective for some products, as has been
retailers and manufacturers create a system for the explored in the GSMA Strategy Paper for Circular Economy:
recycling, reuse or proper disposal of waste. Network Equipment.14 In the future, aspirational KPIs could
be developed to measure the extent to which consumer
A deeper understanding of how equipment and devices devices are designed with repairability and recyclability
move into and out of the organisation can help provide in mind. The Ellen MacArthur Foundation has developed
a holistic overview of waste generation and its causes, circularity indicators which disclose the extent to which
which in turn can support the organisation in identifying products use recycled or reused materials, the durability
opportunities within its entire value chain for waste of products, how much material goes to landfill, and the
prevention and the adoption of circularity measures. efficiency of recycling practices.15 Eco Rating can also be
The illustration below, created by the GSMA through used to evaluate the environmental impact of the entire
consultation with its members, shows a hierarchy of waste process of production, transportation, use and disposal of
management actions. The industry KPIs prioritise those mobile phones.16 There are also opportunities to explore
that are towards the top of the hierarchy. These create enablement metrics that help to measure the industry’s
the lowest environmental impact by avoiding the creation impact on other sectors’ waste reduction efforts.
Waste hierarchy GUIDELINES

Source: Strategy Paper for Circular Economy —
Network Equipment, GSMA, 2022 Is a new product needed?
RETHINK If yes, design for longevity,
disassembly and repair.
Reuse in another location.

REUSE Minimal change, possibly
recertification.
Repair any defects

and then reuse.
REPAIR Remanufacture
same product.
Disassemble into components

RECYCLE and recycle in other products.
Recover raw materials through

RECOVERY physical and chemical extraction
to reuse as feedstocks.
Safely dispose of any residual

RESIDUAL or hazardous waste in secure
landfill or incineration.
No ground and water pollution,

REFUSE! e.g., littering. No destruction of
resources, e.g., burning.
14. ‘Strategy paper for circular economy: network equipment’, GSMA, 2022
15. See: ellenmacarthurfoundation.org
16. See: ecoratingdevices.com
Environment KPIs
Topic Core metrics KPI code Alignment
Emissions Science-based targets GSMA- Stakeholder

ENV-01 Capitalism
1.1 Disclose whether you have set, or have committed Metrics; TCFD
to set, GHG emissions targets that are in line with Recommendations;
the goals of the Paris Agreement — to limit global CDSB R01, R02,
warming to well below 2°C above pre-industrial R03, R04 and R06;
levels and pursue efforts to limit warming to 1.5°C — SASB 110; SBTs
and to achieve net-zero emissions before 2050. initiative
Scope 1, 2 and 3 emissions GSMA- GRI 305:1-3, TCFD,

ENV-02 GHG Protocol
1.2a Scope 1 and 2 GHG emissions (modified)
i. Absolute Scope 1 and 2 emissions (tonnes CO2e)
ii. Absolute Scope 1 and 2 emissions (tonnes CO2e) per
1GB data
iii. Percentage change in absolute Scope 1 and 2
emissions since last reporting period
1.2b Scope 3 GHG emissions

i. Absolute Scope 3 emissions (tonnes CO2e)
ii. Absolute Scope 3 emissions (tonnes CO2e) per 1GB
data
iii. Percentage change in absolute Scope 3 emissions
since last reporting period
Energy Energy consumption GSMA- GRI 302-1; SASB

ENV-03 TC-TL-130a.1
1.3a Total energy consumption (modified)
i. Total energy consumed (MWh)
ii. Total energy consumed (MWh) per 1GB of data
1.3b Network energy consumption

i. Total network energy consumed (MWh)
ii. Total network energy consumed (MWh) per 1GB of
data
1.3c Network energy mix

i. Percentage grid renewable
ii. Percentage grid non-renewable
iii. Percentage off-grid renewable
iv. Percentage off-grid non-renewable

Environment KPIs
Topic Core metrics KPI code Alignment
Waste Materials repaired or reused GSMA- SASB TC-TL-440a.1

reduction ENV-04 (modified)
1.4a Network equipment repaired or reused
i. Percentage of network equipment repaired or reused,
by units
ii. Percentage of network equipment repaired or reused,
by purchase price
1.4b Handsets and other customer premises

equipment (CPE) repaired or reused
i. Percentage of handsets and CPE repaired or reused,
by units
ii. Percentage of handsets and CPE repaired or reused,
by purchase price
Waste generated GSMA- GRI 306-3

ENV-05 (modified)
1.5a Total waste generated (tonnes) per 1GB of data
1.5b Network waste (tonnes) per 1GB of data
1.5c Handset and other CPE waste (tonnes) per 1GB

of data
1.5d All other waste (tonnes) per 1GB of data

GSMA-
Materials recycled SASB TC-TL-440a.1
ENV-06
(modified)
1.6a Network waste recycled
i. Percentage of network waste (from 1.5b) recycled
(units)
ii. Percentage of purchase price of recycled network
waste
1.6b Handset and CPE waste recycled

i. Percentage of handset and CPE waste (from 1.5c)
recycled (units)
ii. Percentage of purchase price of recycled handset
and CPE waste
1.6c All other waste recycled

i. Percentage of all other waste (from 1.6d) recycled
(units)
ii. Percentage of purchase price of all other recycled
waste

Category 2:
Digital inclusion
Digital inclusion is a key topic for the sector, and an area
where mobile operators have the ability to make tangible Digital inclusion KPI use cases
impact and support in bridging the “digital divide”. Digital
connectivity has never been more important — it is the Operators agreed that strategic dialogues
lifeline by which we communicate with friends, family with external stakeholders, such as investors,
and colleagues. Its critical role has become even more regulators and policymakers, could be further
apparent since the COVID-19 pandemic, enabling societal enhanced by providing a clear understanding of
well-being and the continued functioning of our economy what “digital inclusion” means and the absence
during a period characterised by physical isolation.17 of an industry-wide value generation story.
Reporting progress against the core KPIs will
Global network coverage continues to grow, with 94 help operators demonstrate the effort being
per cent of the world’s population covered by mobile made to reach underserved and vulnerable
broadband networks.18 However, a lack of literacy and segments of the population, while simultaneously
digital skills, as well as device and data affordability, building brand recognition and trust with clients
remains a key barrier to mobile internet adoption for and customers.
millions of underserved consumers. In line with the mobile
industry’s purpose of connecting everyone and everything
to a better future, targeted action must be taken to address
barriers to digital inclusion and to ensure consumers
are able to use the internet and gain access to life- and
livelihood-enhancing services. A common set of digital
inclusion KPIs will be critical to achieving this ambition.
17. ‘Reset or level up. How can Gigabit Britain deliver for all? Digital connectivity to stimulate the UK’s recovery in 2021’, EY, 2020
18. ‘The state of mobile internet connectivity report’, GSMA, 2021
Digital inclusion topics
Network coverage Operators wishing to go beyond this metric might

consider comparing their disclosure with the Broadband
Mobile connectivity requires continuous investment by
Commission’s affordability target, which aims to make
operators to meet the growing demand for mobile services
entry-level broadband services less than 2 per cent of
from businesses and consumers. Measuring population
monthly income per capita by 2025. In countries where
coverage provides a good approximation of the availability
the average income masks deep income inequality,
of mobile broadband (defined as 3G and above) in both
operators could also look at affordability in each country
urban and rural settings, and, over time, the breakdown of
for the poorest fifth of the population, using income
coverage between 3G, 4G and 5G will allow stakeholders
distribution data sourced from the World Bank.22
to track operators’ ability to roll out network upgrades.
Beyond this KPI, operators may consider reporting

Digital skills training
against more dynamic indicators, such as year-on-year
improvements in network coverage. As most urban and Digital skills underpin nearly every aspect of modern
peri-urban areas are now covered by mobile networks, work and life, particularly in the post-pandemic world.
this indicator would provide a good proxy for network
expansion in less densely populated areas where Operators that implement comprehensive digital
underserved customers are typically located. Operators skills training strategies ensure their customers and
can also help measure progress in closing the internet communities have the skills they need to be more
usage gap by disclosing the percentage of their total employable, productive, creative and successful while
customers who purchase data, and the amount of data enabling them to be safe and secure when online.
used monthly by the average customer.
The industry KPI asks operators to report against the
number of people (external to the company) who have
Affordability completed any form of basic, intermediate or advanced
digital skills training, as defined in the ITU’s Digital Skills
Affordable internet-enabled handsets and data
Toolkit.23 Dividing the total number of beneficiaries by
are critical to increase demand for mobile internet
the operator’s total customer base will allow for more
services, including in markets where pre-paid plans
meaningful comparisons across the sector.
remain dominant.
As this KPI is output-focused rather than impact-focused,
Once users become comfortable with consuming data
in the future, operators engaging in digital skills training
on smart phones and smart feature phones, their needs
could also consider how to measure the outcomes the
often shift towards more data-intensive services.19 While
training programmes have produced. This could include,
the cost of entry-level internet-enabled handsets has
for example, higher usage of mobile internet or other
decreased in more than half of LMICs and the cost of
digital services, demonstratable skills improvements or
data has continued to decline, affordability remains a
improved income generation.
significant barrier for the poorest individuals.20
Disclosing the cost of data and the most affordable

smartphone, as a percentage of monthly GDP per capita,
will help internal decision makers and other stakeholders
evaluate the extent to which affordability is limiting access
to mobile broadband services. To ensure that the KPI is as
transparent and comparable as possible, the KPIs use a
“basket” approach to look at the cheapest way a consumer
can access 1GB of data per month from the operator. This
is in line with the GSMA’s affordability methodology.21
19. ‘Accelerating affordable smartphone ownership in emerging markets — RFI’, GSMA, 2019
20. ‘The state of mobile internet connectivity report’, GSMA, 2021
21. ibid
22. ibid
23. ‘Digital skills toolkit’, ITU, 2018
Digital inclusion KPIs

Topic Core metrics: prosperity KPI code Alignment
Network Population covered by mobile network GSMA- ITU Indicator 2.6

coverage INC-01
2.1 Percentage of population covered by operator’s
mobile network
Breakdown by: 3G, 4G, 5G
Affordability Device and subscription affordability GSMA- GSMA

INC-02 Methodology
2.2a Cost of the most affordable smartphone, as
percentage of monthly GDP per capita
2.2b Average cost of 1GB of data, as percentage of

monthly GDP per capita
Digital skills Digital skills programmes GSMA- ITU Digital Skills

INC-03 Toolkit
2.3 Number of people (excluding employees) who
have completed a basic, intermediate or advanced
digital skills training programme (as per ITU
definition), divided by total subscribers

Category 3:
Digital integrity
As mobile services become increasingly ingrained in
our social, economic and professional lives, there is a Digital integrity KPI use cases
corresponding need to ensure that consumers can use
these services safely and securely. The mobile sector has Unsurprisingly, operator feedback suggests that
a key role to play in both support evolving digital needs the most compelling use case for KPIs related
and addressing anxiety around data protection and to data integrity will be building trust and brand
digital well-being. If consumers cannot trust the integrity recognition with clients and customers, and
of mobile services, or worry that their personal data or to support a data-driven sustainability/ESG
information may not be protected, they are much less narrative with investors and other key internal
likely to use them. stakeholders. In addition to this, measuring data
incidents — particularly the number of customers
impacted — is seen as an opportunity to inform
strategic decisions regarding how to enhance data
protection measures.

Digital integrity topics
Data protection
Like all ICT industries, the mobile sector is often the target
of data security threats.
Companies manage an increasing volume of their

customers’ personally identifiable information, as
well as demographic, behavioural and location data.
Inadequate prevention, detection and remediation of

data security threats can influence customer acquisition
and retention, and is likely to affect reputation and brand
value — this will have a long-term impact on market share
and revenue growth potential.24
The KPIs in this category are aligned to the industry

standards developed by SASB, with a focus on the
number of data breaches, the percentage of data Online safety
breaches involving personally identifiable information
Controls or programmes that help to address
(PII), the number of customers affected and the number of
consumers’ concerns around online safety will
regulatory actions taken. Dividing each KPI by the number
drive digital inclusion, especially among vulnerable
of subscribers (in millions) will improve comparability.
segments of the population.
Per the 2020 UN Roadmap for Digital Cooperation,

Digital rights
vulnerable groups can include women, older people,
A mobile operator’s digital rights policy should seek to young people, children, migrants, refugees, internally
demonstrate that it has considered how it should work to displaced people, people with disabilities, rural
address a wide range of salient topics such as data privacy, populations and Indigenous people. Helping consumers
transparency, freedom of expression, government mandates feel safer when using the mobile internet is also a
to shut down or restrict access, and government requests commercial opportunity for mobile operators. According
for data. Operators around the world are having to challenge to a GSMA study focusing on in LMICs, improving online
specific interventions from governments that they assess safety can support customer acquisition, improve average
as disproportionate, misaligned to international human revenue per user (ARPU), reduce churn, and improve
rights frameworks or even potentially counter-productive handset and data revenue.
to public safety goals.25 Policies should outline how they
respond to government and others’ demands, but also in Future aspirational metrics could include the public
how they determine, communicate and enforce policies disclosure of policies related to online safety or consumers’
and commercial practices that affect users’ fundamental rights in the digital environment. To promote child online
right to privacy, freedom of expression and information.26 safety in particular, operators might also report on the
availability of parental control tools offered free of charge
While the existence of a policy is a good starting point, for the company’s mobile and fixed internet services, or
more aspirational metrics could include a strong public measures that are in place to restrict access, sharing and
commitment to transparency and evidence of a due storing of child sexual abuse material (CSAM).28
diligence process to identify, prevent, mitigate and account
for how they address their impacts on digital rights. It Finally, operators might disclose if and how they work
might also include evidence of how the organisation has with relevant partners to promote and provide free access
provided for or cooperated in their remediation of adverse to hotlines to report online abuse or helplines to enable
impacts through legitimate processes.27 children and other vulnerable groups to seek support.
24. From SASB metric TC-TL-230a.1

25. ‘An introduction to human rights for the mobile sector’, GSMA, 2019
26. See: 2020 Ranking Digital Rights Corporate Accountability Index
27. ‘An introduction to human rights for the mobile sector’, GSMA, 2019
28. ‘A framework to understand women’s mobile-related safety concerns in low-and middle-income countries’, GSMA, 2018
Digital integrity KPIs

Data Customer data incidents GSMA- SASB TC-TL-230a.1

protection INT-01 (modified)
3.1a Number of data breaches, per million
subscribers
3.1b Percentage of data breaches involving PII
3.1c Number of customers affected, per million

subscribers
3.1d Number of regulatory actions for data

protection violations (e.g. marketing-related
complaints, data breaches), per million subscribers
Digital Digital rights policy GSMA- 2020 Ranking

rights INT-02 Digital Rights
3.2 Is there a policy specifically covering digital rights Corporate
protection and transparency, privacy, freedom of Accountability
expression, government mandates to shut down or Index
restrict access, and/or government requests for data?
(yes/no)
Online Online safety measures GSMA-

safety INT-03
3.3 Do you have controls or programmes in place to
improve online safety for children and other
vulnerable groups? (yes/no)

Category 4:
Supply chain
For the mobile industry, the supply chain is of significant
importance to business operations; many levers which Supply chain KPI use cases
impact ESG are activated through the supply chain,
such as suppliers’ contribution to Scope 3 emissions, Operator feedback shows that the supply
which form a significant portion of overall emissions, chain KPIs have two particularly compelling
or compliance with sustainability policies. This reliance use cases. First, they will help inform internal
on a diverse supplier base can span infrastructure decision making, including how to set sustainable
manufacturing, deployment and maintenance, handsets procurement strategies or policies, and how to
or technology software providers. Due to the wide allocate capital to improve procurement spend.
geography and complex nature of operators’ supply Secondly, the disclosures will also help underpin
chains, collaboration with socially and environmentally the ESG narrative, reinforcing the organisation’s
conscious suppliers will help mitigate a significant stated mission and purpose to investors,
proportion of operators’ sustainability risks, while also employees and customers — and possibly
providing a competitive advantage.29 enabling operators to take a leading role in
raising supply chain sustainability standards.
29. ‘The Singtel reset: sustainability report 2021’, Singtel, 2021

Supply chain topics
Sustainable procurement policy Supplier assessment

Sustainable procurement is “the process of making The disclosure on supplier assessments asks operators to
purchasing decisions that meet an organisation’s needs report the percentage of suppliers that have been selected
for goods and services in a way that benefits not only the or contracted following a due diligence process covering the
organisation but society as a whole while minimising its environmental and social impacts outlined in the sustainable
impact on the environment.”30 This can be achieved by procurement policy. In line with GRI guidance, operators
ensuring that suppliers exhibit good governance, respect are expected to initiate due diligence as early as possible
human rights (including the rights of their employees), in the development of a new relationship with a supplier
implement fair operating practices, and sell products and to prevent or mitigate negative impacts. Additionally, the
services that positively impact people and the planet. operator should report the percentage of suppliers that
The KPI asks operators to disclose whether a sustainable have been assessed through a coordinated on-site audit
procurement policy is in place and how many elements within the last two years — for instance, through initiatives
derived from ISO 20400 the policy covers. such as the Joint Audit Cooperation (JAC).31
Supply chain KPIs

Sustainable Sustainable procurement policy GSMA- ISO 20400:2017

supply chain SUP-01
4.1a Do you have a sustainable procurement policy in
place? (yes/no)
4.1b If yes, how many of the following elements does

it cover?
a. Organisational governance
b. Human rights
c. Labour practices
d. Environment
e. Fair operating practices
f. Consumer issues
g. Community involvement and development
Supplier assessments GSMA- GRI 308-1; GRI 414-

SUP-02 1 (partially)
4.2a Percentage of suppliers screened against the
sustainable procurement policy using company-
defined and documented assessment procedure,
within the previous two years
4.2b Percentage of suppliers assessed against the

sustainable procurement policy through site visits,
30. See: ISO 20400:2017. Sustainable procurement — Guidance

31. See: Joint Audit Cooperation
Next steps

Next steps for mobile operators

and other stakeholders
Open consultation on the industry KPIs
The endeavour to align the industry behind a core set of ESG During the open consultation period, the GSMA will
KPIs has made significant progress over the last 12 months. provide operators, other ESG and industry stakeholders,
Iterative sessions with mobile operators, multi-stakeholder and subject matter experts with the opportunity to
workshops, consultations with industry and subject matter assess and validate the KPIs and the reporting processes
experts and the incorporation of insights from other global underpinning them, or to offer recommendations
standard-setting initiatives has led to a proposed set of 10 for further refinement. This will ensure that the KPI
core KPIs that will help the industry better articulate how framework remains fit for purpose going forward.
it creates value for all of its stakeholders.
Following the consultation period, the GSMA will consider
The GSMA is now seeking feedback on the proposed all feedback with the intention of supporting a pilot
KPIs through an open consultation period which closes initiative with its member operators.
on 30 September 2022.
To provide feedback in the open consultation, go to gsma.com/betterfuture/esg

In parallel, there are three critical steps that mobile

operators and their stakeholders can take to ensure that For more information, please go to:
the industry ESG framework accelerates performance
across the mobile industry and beyond:
GSMA ESG website
1. Align company’s leadership behind
the ESG KPIs
Contact the team
ESG reporting should be owned by the Board, CEO and betterfuture@gsma.com
CFO — with relevant inputs from functional teams. There
should be clarity around what ESG-related transformation with subject header ‘ESG
means for corporate strategy, how investments in Consultation’
sustainability contribute to financial performance, and
how the KPIs can help organisations measure success.
#BetterFuture #ESG
2. Raise awareness of the framework

with the investment community and
other external stakeholders
Open and ongoing conversations between operators
and investors will also be a critical step to refining
and validating the KPIs. Operators can help investors
understand which ESG issues are most material to their
organization and be able to frame ESG discussions in the
context of financial performance. These dialogues should
also ensure that the KPIs provide the information that
investors need to make assessments of the company’s
long-term value. At the same time, socializing the KPIs
with policymakers, partners or customers in other
industry verticals can also pave the way for better
alignment on cross-sector enablement metrics in years to
come.
3. Adopt the metrics in future reporting,

measure your performance and deliver
improvements
Operators can begin to test their ability to report against
the KPIs and incorporating them into their ESG reporting
cycles. This will generate the evidence, insights and
experience needed to further refine the KPIs and draw
better, more compelling links between ESG scores,
stakeholder value and financial performance. At all stages,
operators should ensure they take action where needed
— whether that relates to improving KPIs themselves,
or reorienting systems and processes to deliver more
relevant and timely information that avoids duplication.
Measuring sustainability performance is the critical
step operators should take to move from ambition and
strategy towards successful execution.

Appendix:
Detailed
guidance on
the industry
KPIs

Environment
Topic KPI Alignment
Science-based 1.1 Disclose whether you have set, or have committed TCFD Recommendations;
targets to set, GHG emissions targets that are in line with CDSB R01, R02, R03, R04 and
the goals of the Paris Agreement — to limit global R06; SASB 110; SBTs initiative
warming to well below 2°C above pre-industrial
levels and pursue efforts to limit warming to 1.5°C —
and to achieve net-zero emissions before 2050.
Guidance (based on Stakeholder Capitalism Metrics):

Disclose if the company has set, or committed to set, GHG emissions targets that are in line with the goals of the
Paris Agreement and to achieve net-zero emissions before 2050. Guidance for mobile networks operators on how to
set SBTs can be found in the GSMA’s Guidance for ICT Companies Setting Science Based Targets report.
Scope 1, 2 and 3 1.2a Scope 1 and 2 GHG emissions GRI 305:1-3, TCFD, GHG
emissions i. Absolute Scope 1 and 2 emissions (tonnes CO2e) Protocol (modified)
ii. Absolute Scope 1 and 2 emissions (tonnes CO2e) per
1GB data
iii. Percentage change in absolute Scope 1 and 2
emissions since last reporting period
1.2b Scope 3 GHG emissions

i. Absolute Scope 3 emissions (tonnes CO2e)
ii. Absolute Scope 3 emissions (tonnes CO2e) per 1GB
data
iii. Percentage change in absolute Scope 3 emissions
since last reporting period
Guidance (based on Stakeholder Capitalism Metrics):

• 1.2a(i): Disclose all relevant Scope 1 and 2 GHG emissions (e.g. carbon dioxide, methane, nitrous oxide, F-gases,
etc.).
• 1.2a(ii): The Scope 1 and 2 emissions intensity KPI is calculated as: (total metric tonnes of carbon dioxide
equivalent (tCO2e) GHG Protocol Scope 1 and Scope 2 emissions/total GB of data sold to all subscribers) x 1,000.
• 1.2a(iii): Percentage change in absolute Scope 1 and 2 emissions should be calculated as: [(total emissions in
current reporting period — total emissions in previous reporting period)/total emissions in previous reporting
period] x 100. A negative value indicates a reduction in emissions.
• 1.2b(i): Disclose all material categories of Scope 3 emissions and provide explanation for why any categories are
not considered material.
• 1.2b(ii): The Scope 3 emissions intensity KPI is calculated as: (total estimated material upstream and downstream
(GHG Protocol Scope 3) emissions/total GB of data sold to all subscribers) x 1,000.
• 1.2b(iii): Percentage change in absolute Scope 3 emissions should be calculated as: [(total emissions in current
reporting period — total emissions in previous reporting period)/total emissions in previous reporting period] x
100. A negative value indicates a reduction in emissions.

Environment
Topic KPI Alignment
Energy 1.3a Total energy consumption GRI 302-1; SASB TC-TL-130a.1

consumption i. Total energy consumed (MWh) (modified)
ii. Total energy consumed (MWh) per 1GB of data
1.3b Network energy consumption

i. Total network energy consumed (MWh)
ii. Total network energy consumed (MWh) per 1GB of
data
1.3c Network energy mix

i. Percentage grid renewable
ii. Percentage grid non-renewable
iii. Percentage off-grid renewable
iv. Percentage off-grid non-renewable
Guidance (based on SASB TC-TL-130a.1):

• 1.3a(i): Disclose the total amount of energy consumed in megawatt hours in the reporting period (MWh):
• The scope of energy consumption includes energy from all sources, including energy purchased from sources
external to the company and energy produced by the company itself (self-generated). For example, direct fuel
usage, purchased electricity, and heating, cooling, and steam energy are all included within the scope of energy
consumption;
• The scope of energy consumption includes all operations (core, data centres, etc.).
• The scope of energy consumption includes only energy directly consumed by the company during the
reporting period.
• In calculating energy consumption from fuels and biofuels, the company should follow guidance from the CDP,
found here: CDP Technical Note: Conversion of fuel data to MWh
• 1.3a(ii): The energy intensity KPI is calculated as: (total energy consumed in megawatt hours (MWh) in the
reporting period/GB of data sold to all subscribers) x 1,000.
• 1.3b(i): Disclose the total amount of network energy consumed in megawatt hours (MWh) in the reporting period.
This value will be a subset of the total value reported in 1.3a(i).
• 1.3b(ii): The energy intensity KPI is calculated as: (total network energy consumed in megawatt hours (MWh) in
the reporting period/GB of data sold to all subscribers) x 1,000.
• 1.3c: Disclose the percentage of network energy consumed falling into the following categories: grid renewable;
grid non-renewable; off-grid renewable; off-grid non-renewable.
• Renewable energy is defined as energy from sources that are replenished at a rate greater than or equal to their
rate of depletion, such as geothermal, wind, solar, hydro and biomass.
• The scope of renewable energy includes renewable fuel the company consumed, renewable energy the
company directly produced, and renewable energy the company purchased, if purchased through a renewable
PPA that explicitly includes renewable energy certificates (RECs) or guarantees of origin (GOs), a Green-e®
certified utility or supplier programme, or other green power products that explicitly include RECs or GOs, or
for which Green-e® certified RECs are paired with grid electricity.

Environment
Topic KPI Alignment
Materials 1.4a Network equipment repaired or reused SASB TC-TL-440a.1 (modified)

repaired and i. Percentage of network equipment repaired or
reused reused, by units
ii. Percentage of network equipment repaired or
reused, by purchase price
1.4b Handsets and other CPE repaired or reused

i. Percentage of handsets and CPE repaired or reused,
by units
ii. Percentage of handsets and CPE repaired or reused,
by purchase price

• 1.4a(i): Disclose the percentage of total network equipment prevented from becoming waste through repair or
reuse, by units. This is calculated as: [(number of units of network equipment repaired or reused in the reporting
period)/(total units of equipment deployed)] x 100.
• 1.4a(ii): Disclose the percentage of total network equipment prevented from becoming waste through repair or
reuse, by purchase price. This is calculated as: [(purchase price of network equipment repaired or reused in the
reporting period)/(total price of network equipment purchased in the reporting period)] x 100.
• 1.4b(i): Disclose the percentage of handsets or CPE prevented from becoming waste through repair or reuse, by
units. This is calculated as: [(number of units of handsets or CPE repaired or reused in the reporting period)/(total
units of handsets or CPE sold or deployed in the reporting period)] x 100.
• 1.4b(ii): Disclose the percentage of handsets or CPE prevented from becoming waste through repair or reuse, by
purchase price. This is calculated as: (purchase price of handsets and CPE repaired or reused in the reporting
period)/(total price of handsets and CPE purchased in the reporting period) x 100].
Waste generated 1.5a Total waste generated (tonnes) per 1GB of data GRI 306-3 (modified)
1.5b Network waste (tonnes) per 1GB of data
1.5c Handset and other CPE waste (tonnes) per 1GB of

data
1.5d All other waste (tonnes) per 1GB of data
Guidance:
• 1.5a: Disclose the total amount of waste produced by the company during the reporting period (in tonnes),
divided by GB of data sold to all subscribers x 1,000. This value should be equal to the sum of the values reported
in 1.5(b), 1.5(c) and 1.5(d).
• 1.5b: Disclose the total amount of network waste produced by the company during the reporting period (in
tonnes), divided by GB of data sold to all subscribers x 1,000.
• 1.5c: Disclose the total amount of handset and CPE waste produced by the company during the reporting period
(in tonnes), divided by GB of data sold to all subscribers x 1,000.
• Handset and CPE waste includes consumer devices or equipment that are returned to the operator through
take-back schemes and not intended to be reused or repaired, as well as any unsold/unused inventory that has
reached the end of its useful life and become waste.
• 1.5d: Disclose the total amount of all other waste produced by the company during the reporting period (in
tonnes), divided by GB of data sold to all subscribers x 1,000.
• When reporting composition of all other waste, the organisation should describe the type of waste (such as
hazardous waste or non-hazardous waste) or the waste streams relevant to its activities.

Environment
Topic KPI Alignment
Materials 1.6a Network waste recycled SASB TC-TL-440a.1 (modified)

recycled i. Percentage of network waste recycled (units)
ii. Percentage of purchase price of recycled Network
waste
1.6b Handset and CPE waste recycled

i. Percentage of handset and CPE waste recycled
(units)
ii. Percentage of purchase price of recycled handset
and CPE waste
1.6c All other waste recycled

i. Percentage of all other waste recycled (units)
ii. Percentage of purchase price of all other recycled
waste

• 1.6a(i): Disclose the percentage of network equipment waste recycled, by units. This is calculated as: [(total units
of network equipment recycled)/(total units of network equipment identified as waste in KPI 1.5b)] x 100.
• 1.6a(ii): Disclose the percentage of network equipment waste recycled, by purchase price. This is calculated
as: [(purchase price of units of network equipment recycled in the reporting period)/(total price of network
equipment purchased in the reporting period)] x 100.
• 1.6b: The scope of this disclosure includes mobile devices and other consumer products, materials, and parts
that are at the end of their useful life and would have otherwise been disposed of as waste but have instead been
collected and recycled. The scope of disclosures includes both materials physically handled by the company or by
contracted third parties.
• 1.6b(i): Disclose the percentage of handsets and CPE waste recycled, by units. This is calculated as: [(total units of
handsets and CPE recycled)/(total units of handsets and CPE identified as waste in KPI 1.5c)] x 100.
• 1.6b(ii): Disclose the percentage of handset and CPE waste recycled, by purchase price. This is calculated as:
[(purchase price of units of handsets and CPE recycled in the reporting period)/(total price of handsets and CPE
purchased in the reporting period)] x 100.
• 1.6c: The scope of this disclosure includes any other materials that are at the end of their useful life and would
have otherwise been disposed of as waste but have instead been collected and recycled. The scope of disclosures
includes both materials physically handled by the company or by contracted third parties.
• 1.6c(i): Disclose the percentage of all other waste recycled, by units. This is calculated as: [(total units of other waste
recycled)/(total units identified as other waste in KPI 1.5d)] x 100.
• 1.6c(ii): Disclose the percentage of other waste recycled, by purchase price. This is calculated as: [(purchase price
of units of other waste recycled in the reporting period)/(total price of other materials purchased in the reporting
period)] x 100.

Digital inclusion
Topic KPI Alignment
Population 2.1 Percentage of population covered by operator’s ITU Indicator 2.6

covered by mobile network
mobile network Breakdown by: 3G, 4G, 5G
Guidance (based on ITU Indicator 2.6):

• Disclose the percentage of inhabitants within range of a mobile cellular signal provided by the company,
irrespective of whether or not they are subscribers or users. This is calculated as: [(total number of inhabitants
covered by the company’s mobile cellular signal)/(total population of country)] x 100.
• Coverage should only refer to 3G, 4G and 5G mobile cellular technologies. Each technology type should be
disclosed separately.
Device and 2.2a Cost of the most affordable smartphone, as GSMA Methodology
subscription percentage of monthly GDP per capita
affordability 2.2b Average cost of 1GB of data, as percentage of
monthly GDP per capita
Guidance (based on GSMA Methodology for calculating affordability):

• These disclosures should be reported at the country level.
• 2.2a: Device affordability is calculated as: [price of the cheapest smartphone device/(GDP per capita in reporting
country as reported by the IMF World Economic Outlook/12)] x 100.
• 2.2b: Data affordability is calculated as: [price of 1Gb of data in reporting country/(GDP per capita in reporting
country as reported by the IMF World Economic Outlook/12)] x 100.
Digital skills 2.3 Number of people (excluding employees) who ITU Digital Skills Toolkit
programmes have completed a basic, intermediate or advanced
digital skills training programme (as per ITU
definition), divided by total subscribers.
Guidance:
• Disclose the total number of people (not including employees) who have completed a digital skills training
programme run by the company, divided by the company’s total subscribers. Break down by basic, intermediate or
advanced skills training. If a course covers multiple levels for a participant, report the highest level of training.
• Digital skills training programs must focus on establishing or improving at least one of the basic, intermediate or
advanced digital skills identified in the ITU Digital Skills Toolkit (2020), which is designed to improve digital
literacy or competency.
• Individual beneficiaries may be counted multiple times if they have attended more than one training programme,
but not in instances where they have attended the same programme more than once.

Digital integrity
Topic KPI Alignment
Customer data 3.1a Number of data breaches, per million SASB TC-TL-230a.1 (modified)
incidents subscribers
3.1b Percentage of data breaches involving PII
3.1c Number of customers affected, per million

subscribers
3.1d Number of regulatory actions for data

protection violations (e.g. marketing related
complaints, data breaches), per million subscribers

• 3.1a: Disclose the total number of data breaches identified during the reporting period, divided by million subscribers.*
• 3.1b: Disclose the percentage of data breaches in which PII** was subject to the data breach. PII is defined as any
information about an individual that is maintained by a company, including:
• Any information that can be used to distinguish or trace an individual’s identity, such as name, identity number, date
and place of birth, mother’s maiden name or biometric records; and
• Any other information that is linked or linkable to an individual, such as medical, educational, financial, and
employment information.
• 3.1c: Disclose the total number of unique customers who were affected by data breaches (which includes all those
whose personal data was compromised in a data breach), divided by million subscribers.
• 3.1d: Disclose the number of instances in which a data protection violation resulted in regulatory action of any
kind, divided by million subscribers.
Digital rights 3.2 Is there a policy specifically covering digital rights 2020 Ranking Digital Rights
policy protection and transparency, privacy, freedom of Corporate Accountability Index
expression, government mandates to shut down or
restrict access, and/or government requests for data?
(yes/no)
Guidance (based on the 2020 Ranking Digital Rights Corporate Accountability Index):
• Disclose if the company has a policy in place that specifically covers the protection of consumers’ digital rights.
• Policies related to freedom of expression and information might cover: the terms of service enforcement; ad
content and ad targeting rules and enforcement; algorithmic system use and curation policies; government and
private demands; identity policies; and network management and shutdowns.
• Policies related to privacy might cover: the collection and handling of user information; internal measures they
take to keep their products and services secure; and their process for responding to government and private
demands to hand over user information.
Online safety 3.3 Do you have controls or programmes in place

measures to improve online safety for children and other
vulnerable groups? (yes/no)
Guidance:
Disclose if the company has any controls or programmes in place to improve online safety for children and other
vulnerable groups. Other vulnerable groups might include women, girls, the LGBTQ+ community, those with physical
disabilities or illnesses, care leavers, people with mental health difficulties, those with addictions, homeless people,
abuse survivors, those in poverty, ex-offenders, ex-service personnel and minority groups.
* We anticipate that our definition of ‘data breach’ will align to that used by SASB, which is currently under consideration.
** We are considering aligning our definition of personally identifiable information (PII) to the European Commission’s definition of ‘personal data’. See: What is personal data?

Supply chain
Topic KPI Alignment
Sustainable 4.1a Do you have a sustainable procurement policy in ISO 20400:2017

procurement place? (yes/no)
policy 4.1b If yes, how many of the following elements does
it cover?
a. Organisational governance
b. Human rights
c. Labour practices
d. Environment
e. Fair operating practices
f. Consumer issues
g. Community involvement and development
Guidance (based on ISO 20400:2017):

• 4.1a: Disclose if the company has a sustainable procurement policy in place.
• 4.1b: Disclose how many of the seven core subjects of sustainable procurement (as defined by ISO 20400) are
covered:
a. Organisational governance: decision making processes and structures;
b. Human rights: due diligence, human rights risk situations, avoidance of complicity, resolving grievances,
discrimination and vulnerable groups, civil and political rights, economic, social and cultural rights,
fundamental principles and rights at work;
c. Labour practices: employment and employment relationships, conditions of work and social protection, social
dialogue, health and safety at work, human development and training in the workplace;
d. The environment: prevention of pollution, sustainable resource use, climate change mitigation and adaptation,
protection of the environment, biodiversity and restoration of natural habitats;
e. Fair operating practices: anti-corruption, responsible political involvement, fair competition, promoting
sustainability in the value chain, respect for property rights;
f. Consumer issues: fair marketing, factual and unbiased information, fair contractual practices, protecting
consumers’ health and safety, sustainable consumption, consumer service and support, and complaint and
dispute resolution, consumer data protection and privacy, access to essential services, education and awareness;
g. Community involvement and development: community involvement, education and culture, employment
creation and skills development, technology development and access, wealth and income creation, health,
social investment.
Supplier 4.2a Percentage of suppliers screened against the GRI 308-1; GRI 414-1 (partially)
assessments sustainable procurement policy using company-
defined and documented assessment procedure,
4.2b Percentage of suppliers assessed against the

sustainable procurement policy through site visits,
Guidance (based on GRI 308-1 and GRI 414-1):

• 4.2a: Disclose the percentage of all active suppliers that have been screened against the sustainable procurement
policy using company-defined and documented assessment procedure. Supplier screening can include formal or
documented process that applies a set of performance criteria as one of the factors in determining whether to
proceed in a relationship with a supplier.
• 4.2b: Disclose the percentage of all active suppliers that have been assessed against the sustainable procurement
policy through physical site visits within the previous two years. Assessments can be informed by audits,
contractual reviews, two-way engagement, and complaint and grievance mechanisms.

For more information, please go to:
GSMA ESG website

Contact the team

betterfuture@gsma.com
with subject header
‘ESG Consultation’
#BetterFuture #ESG
This initiative has been in part funded by

the Swedish International Development
Cooperation Agency, Sida, and is supported
by the GSMA and its members. Sida does not
necessarily share the views expressed in this
material. Responsibility for its contents rests
entirely with the authors.

EY refers to the global organization, and may refer to one or more, of the member
firms of Ernst & Young Global Limited, each of which is a separate legal entity.
Ernst & Young Global Limited, a UK company limited by guarantee, does not
provide services to clients. Information about how EY collects and uses personal
data and a description of the rights individuals have under data protection
legislation are available via ey.com/privacy. EY member firms do not practice law
where prohibited by local laws.
gsma.com ey.com/en_uk/tmt
Tel: +44 (0)20 7356 0600 ey.com/en_uk/climate-change-sustainability-services
Fax: +44 (0)20 7356 0601
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ESG Metrics

Yale Center for Business

ESG Metrics for Mobile 2

Mobile operators: External experts:

Airtel ESG Book

ESG Metrics for Mobile 3

The value of the industry KPIs 12

The industry ESG framework 16

ESG KPIs for the mobile industry 18

Category 2: Digital inclusion 24

Category 3: Digital integrity 27

Category 4: Supply chain 30

Appendix: Detailed guidance on the industry KPIs 35

ESG Metrics for Mobile 4

John Giusti Praveen Shankar

ESG Metrics for Mobile 5

% of mobile operators reporting on the following topics2:

96% 96% 92% 84%

60% 52% 20% 52%

1. ‘Sixth global institutional investor survey’, EY, 2021

ESG Metrics for Mobile 7

ESG Metrics for Mobile 8

Attitudes towards ESG are shifting

Management attitudes to ESG and long-term value4

86% 83% 76%

3. ‘Sixth global institutional investor survey’, EY, 2021

32% 36% 26% 6%

Strongly agree Agree Neither agree or disagree Disagree

Considering more than before how the internet impacts well-being

5. ‘TMT’s dual role in building a sustainable future’, EY, 2022

Measuring and communicating ESG performance is critical

With these complex forces in play, the industry’s ability to

8. ‘Sixth global institutional investor survey’, EY, 2021

ESG Metrics for Mobile 12

The value of aligned, industry-specific

To start on the path towards meaningful disclosures,

ESG Metrics for Mobile 13

Building upon universal ESG reporting

ESG Metrics for Mobile 14

KPI criteria and overview

ESG Metrics for Mobile 15

The industry ESG framework

Mobile industry KPIs

Emissions Network coverage Data protection Sustainable supply chain

Science-based targets Population covered by Customer data incidents Sustainable procurement

Energy Affordability Digital rights

Waste reduction Digital skills Online safety

Stakeholder Capitalism Metrics Themes

ESG Metrics for Mobile 16

Benefits to the industry and stakeholders

The KPIs demonstrate the value that can be created when

4. Strengthened client and customer

ESG Metrics for Mobile 17

ESG KPIs for

ESG Metrics for Mobile A

Today, 48 operator groups representing 62 per cent

Waste hierarchy GUIDELINES

Reuse in another location.

Repair any defects