Human rights impact assessments

Human rights impact assessments give us insights into the local and group-level impacts, risks and opportunities, and for people affected by our daily operations.

Region Eurasia

In 2015, Telia Company commissioned the independent non-profit organization BSR to undertake human rights impact assessments (HRIAs) of the companies in region Eurasia as part of ensuring local human rights due diligence and a responsible exit from the region. BSR undertook these HRIAs between October 2015 and May 2016 using a methodology based on the UN Guiding Principles on Business and Human Rights. No assessment was carried out for Ncell in Nepal, as a divestment was announced in December 2015.

General conclusions

The six stand-alone HRIA reports identified actual and potential human rights impacts, risks and opportunities for each company related, for example, to security and privacy, freedom of expression and children’s rights. BSR’s HRIA summary report drew the following general conclusions:

  • On group level, Telia Company has made substantial progress in addressing human rights since the last impact assessment was undertaken in 2013.
  • On the local level, each subsidiary has undertaken proactive action to respect human rights, with many company leaders displaying a strong commitment to international standards of business conduct.
  • The regional corruption and human rights context presents significant systemic challenges to applying Telia Company’s human rights infrastructure.
  • Active and engaged ownership is a pre-condition for advancing respect for human rights in local markets.
  • Ownership transparency has a material influence on human rights leverage.
  • Law enforcement disclosure reports are influential.
  • Some significant challenges, for example direct government access to networks (e.g. SORM), are similar across former Soviet republics.
  • Diplomacy, collaboration and advocacy present the most promising opportunities for sustained impacts over time.
  • The amount of space available for civil society organizations is a key variable in the extent of human rights leverage.
  • Increased dialog with local stakeholders on topics such as telecommunications policy reform and economic development may help establish a more supportive policy context.
  • Significant human rights challenges remain and the prospects of addressing them will depend on the human rights commitment of the purchasing entity or entities.

Recommendations and next steps

The summary report presents recommendations in three categories: Company-specific “management and mitigation plans” to integrate human rights into local company management by current and future owners, a “responsible divestment plan,” and how Telia Company can improve its group-wide human rights approach.

The responsible divestment plan included, among other, the following recommendations:

  • Undertaking pre-sale due diligence on potential purchasing entities.
  • Attaching human rights conditions to sales conditions.
  • Undertaking post-sale activities designed to enhance respect for human rights after Telia Company’s exit.

The group-wide approach recommendations were:

  • Establishing a single human rights policy.
  • Identifying likely remedy options for potential human rights grievances.

Local challenges differ between markets, but are in essence connected to complexities in the local operating environment, resources and prioritizations. Each local company, guided by region and group experts, is developing an action plan based on BSR’s recommendations that will be embedded in local business operations. Quarterly updates on the execution of these action plans will be presented at local governance, risk, ethics and compliance (GREC) meetings and monitored by group experts. As to the responsible divestment recommendations, the main challenges on the group level are connected to the complexity of the divestment processes.

The local BSR HRIA report and insights on the local human rights context were shared with AKFED during the divestment process (to be finalized) of Tcell in Tajikistan.

Lithuania and Sweden

We further commissioned BSR to carry out HRIAs for operations in Lithuania and Sweden, which were finalized in September and December respectively. Some of the general conclusions were:


  • Telia Company's group policies and instructions are well understood and implemented.
  • The current geopolitical situation may cause increased human rights risks for local operations related, for example, to limiting freedom of expression for national security reasons.
  • Social attitudes, which are sometimes reinforced by discriminatory laws, constrain a number of human rights protections, especially in the area of non-discrimination.
  • There are opportunities to increase multi-stakeholder dialog and collaboration, as well as to push the boundaries of transparency.
  • Telia (and Telia Company) may face new human rights dilemmas in the media industry arising from offering new media content.


  • Sweden’s status as an established liberal democracy is the source of significant human rights protections and substantially reduces the severity of Telia’s human rights risks.
  • While many meaningful protections are in place, there are a number of shortcomings in the privacy oversight and protections in Sweden’s legal framework governing law enforcement and national security.
  • There are opportunities for Telia to address human rights deep in the local supply chain.
  • Telia’s efforts to comply with the General Data Protection Regulation (GDPR) will significantly enhance privacy protection.
  • Telia’s success in big data analytics and other adjacent market opportunities will rely on users’ trust that Telia will protect and use personal data fairly.
  • There are opportunities for Telia to comment on government policies and proposals in ways that address human rights risks and opportunities, as well as to lead by example on human rights.

Recommendations and next steps

The HRIA reports outlined recommendations in customer privacy, freedom of expression, anti-discrimination and vulnerable groups, labor rights and public policy. These recommendations include proactive engagement with the government on regulatory issues regarding freedom of expression and customer privacy, undertaking discrimination awareness and unconscious bias trainings, paying particular emphasis on non-discrimination of vulnerable groups, and enhancing responsibility over the supply chain.

Telia in Lithuania and Sweden will prepare action plans for implementing BSR’s recommendations in 2017 and onwards. We are looking into possibilities to undertake HRIA in other markets in region Europe with a slightly modified methodology that might not involve full-scale stakeholder engagement and extended country visits.

More information

BSR's summary report of HRIAs in region Eurasia is available at


On group level, Telia
Company has made
substantial progress in

addressing human rights since the last impact assessment was undertaken in 2013.