A responsible supply chain



A responsible supply chain

Our approach

Our approach aims to raise social and environmental standards throughout the supply chain by working with our direct suppliers to improve their performance with respect to Corporate Social Responsibility and their own supply chain management, while increasing our own efficiency. Integrating our CSR standards in our procurement practices helps us to preserve our reputation and make a real difference in the communities where our suppliers operate.

The procurement policy is an important element in Proximus' corporate involvement. The Procurement team wants to ensure that its suppliers provide products and services in such a way that they meet and even exceed the legal requirements, by integrating social, environmental, ethical and sustainable aspects. We also ask our suppliers to promote the same CSR principles with their own partners.

Proximus' supplier selection process is based on a number of predefined criteria within the framework of the "Business Principles of Procurement". Currently, these selection criteria also include CSR requirements, detailed in the "CSR clause".

Our code is based on the following international standards:

Clause of a responsible supply chain (CSR)

The Code of Ethical Procurement has been developed to promote safe and fair working conditions and to take account of environmental and social issues.

  1. Compliance with the laws
  2. Child labor
  3. Forced labor
  4. Health and safety
  5. Freedom of association
  6. Discrimination
  7. Disciplinary practices
  8. Working hours
  9. Salaries
  10. Individual conduct
  11. Environment

This code is appended to existing and new contracts in the form of a mandatory addendum for suppliers to sign, as confirmation of their commitment.

A consistent approach in the industry

Since 2010, we have been using an external platform (EcoVadis) which offers our suppliers a tool that enables them to measure their degree of compliance with the principles of CSR and to avoid duplication. This platform makes it possible to:

A common audit approach

In September 2011, Proximus became a member of the JAC (Joint Audit Cooperation), which, besides Proximus, is also made up of Deutsche Telecom, Orange, Telecom Italia, KPN, Swisscom, Telenor, TeliaSonera, Verizon and Vodafone.  The CSR audits are performed by third parties on the suppliers' premises.

The results of the audits are shared between the JAC members, which ensures their cost-effectiveness. However, confidentiality agreements mean that access to these results is limited to the JAC members and to individual audited suppliers.

Our local presence

Close to 90% of our suppliers are located in Belgium and our supplier database includes several sheltered workshops.


Integrating CSR as a procurement and selection criterium

CSR qualification process

Our aim to raise the CSR standards of our suppliers is reflected in the qualification process set out below.

Implementation strategy & evaluation criterias

Supplier CSR risk management
Activity & country risk JAC CSR Audit & CAP’s
All preselected suppliers RSE Ecovadis Scorecard
< 45 reassessment invitation Y+ 1
>=45 reassessment invitation Y+ 2
>= 65 reassessment invitation Y+ 3
Severe Activity risk >= 125k €
CSR high performers (>=65) (3y)
CSR good performers (>=45) (2y)
CSR low performers (>=65) (3y)
Other risks (Product…) (Buyer advice)
Contract not ending Year Y or Y+1
Preselection by Proximus with risk based approach
All existing & new suppliers

Contracting process :

  • CSR Clause
All potential suppliers

RfX process:

  • Home-made CSR questionnaire
  •  CSR EcoVadis scorecard (buyer decision)

Process & KPI’s

Process KPI
1. General procurement organization
  • Total amount of annual purchases (KPI GRI G4-12);
  • Total amount of annual local purchases (from Belgium) (KPI GRI G4-12);
  • % of annual expenditure per country/Total annual purchases (KPI GRI G4-12);
  • Number of suppliers per type/Total number (KPI GRI G4-12);
  • Number of Belgian suppliers/Total number of suppliers (KPI GRI G4-EC9);
  • Number of suppliers per country/Total number of suppliers (KPI GRI G4-EC9).
2. Procurement process via RfX
All suppliers fill in the [CSR Pre-Qualif Questionnaire] (fast internal evaluation with light checks so evaluation limited to a max. score of 30%)  
For those suppliers who so desire (optional), a more reliable score is allocated to them, the max. score being 100% if they submit to a professional external evaluation (EcoVadis scorecard)  
CSR has a weighting of 10% in the selection of the supplier  
3. Contractual process
It is obligatory for Proximus' [CSR clause] to be mentioned in the contract % of contracts documented as containing a CSR clause
4. Annual risk management process of our supplier portfolio
4.1 CSR scorecard (self-assessment through EcoVadis questionnaire)
  • A risk approach determines which suppliers are potentially high-risk (taking account of various factors such as the total annual procurement amount >= €125 k, the industrial activity, the CSR characteristics of the product/service to be acquired, the systematic presence of our top suppliers regardless of the risk level, etc.)
  • Number of suppliers actually evaluated by EcoVadis during the annual campaign;
  • % of suppliers evaluated by EcoVadis out of the total number of suppliers covered by Proximus’ annual CSR campaign (success rate).
  • Suppliers selected for the annual campaign are requested to get themselves evaluated by Proximus through EcoVadis (Evaluation procedure)
  • Number of suppliers per sector of industrial activity (ISIC) per risk level/total number of suppliers (KPI GRI G4-12);
  • Number of suppliers with a potential impact on social aspects and Safety & Hygiene (KPI GRI G4-LA14);
  • Number of suppliers with a potential impact on the environment (KPI GRI G4-EN32).
  • An EcoVadis scorecard is in principle valid for 1 year (but see also "frequency of assessment" below)

Frequency of assessment :

  • Annual assessment of all our "top suppliers", regardless of the score obtained
  • Suppliers who have obtained a score of < 45 at the end of a campaign are requested to get themselves re-assessed the next year (after having applied corrective actions allowing improvement).
  • Assessment every 2 years of our suppliers who have obtained a score between 45 and 64
  • Assessment every 3 years of our suppliers who have obtained a score of >= 65
% and number of suppliers considered as being medium-risk and high-risk (score < 45%) out of the total number of suppliers assessed during the annual campaign.
4.2 CSR audits (on-site)
Based on the type of activity and location of the production activities, suppliers common to the members of the JAC (10 telecom operators) are the subject of on-site audits, mainly in Asia (China and India), by each member of the JAC. The results are shared between the JAC members.
  • Number of on-site audits performed annually by the JAC
  • Number of on-site audits performed at Proximus' expense in the framework of the JAC (Joint Audit Corporation: an association of telecom operators performing audits of the factories of shared suppliers mainly in Asia)
  • Corrective actions (action plan) are required, where applicable.
  • Number of CAPs (corrective action points) closed during the year out of the total number of CAPs that year

Annual assessment of suppliers (CSR campaigns)

To ensure that our supplier assessment programs comply with our own values, our commitments towards our own customers and market expectations, we assess our suppliers through EcoVadis. EcoVadis uses a software platform dedicated to the supply chain, facilitating the social and environmental performance management of the suppliers with the aim of reducing CSR risks and giving support to sustainable innovation.

If you are one of our suppliers, please read the sustainable procurement brochure (FR) to understand our CSR assessment approach and the EcoVadis solution.

Integrating CSR in our selection of products and services

We are integrating CSR in the selection criteria of our calls for tender.  We give it a weighting of at least 10%. 

We add sustainability criteria (including responsible sourcing of minerals) in our calls for tender, which include as standard a section dedicated to CSR (assessment of a company's overall CSR performance, including an evaluation on the sustainability of its products and services).

Integrating CSR in our daily activities

We identify incidents and request that our suppliers take the measures that are necessary.

The CSR criterion is part of our purchasing plans and is integrated in our score cards for our suppliers ("Vendor Performance Management" scorecards).

We meet our strategic and non-strategic suppliers for CSR benchmarking in order to share best practices.

Our annual objectives and commitments as regards CSR are set out in the Proximus annual report. Interim reports are regularly presented to the CSR management committee and the Proximus Management Committee.

Investment Recovery & Waste

Within the Proximus Group, specialized teams work towards the environmental and economic optimization of surplus and waste flows. They have a profound knowledge of environmental legislation, Waste Electrical and Electronic Equipment (WEEE) directives and the global market for surplus sales.

Surplus Asset Model

The Proximus Group has been using the Surplus Asset Model for some years now. Inspired by the "Lansink scale", this model shows how the Group divides its surplus assets into four main flows: surplus new material, surplus used material, recycled material and waste. This approach also ties in with the WEEE directive.

Use of this model ensures that the financial interests are in line with environmental interests.  For example, avoiding waste is good for the environment and saves us money at the same time.

If there is a certain surplus after all, we try to re-use the materials in question (internally or externally).

The other options are recycling, incineration (with and without energy recuperation) and finally, landfill.

The lower down in this model the materials are, the less worthwhile they are for Proximus from an environmental and financial perspective.

We encourage our suppliers to consider the end of life of the materials during the design and selection phases.

The RoHS directive (restricting the use of hazardous substances)

The Royal Decree of 12 October 2004 published in the Belgian Official Gazette of 20 October 2004, amended by the Royal Decrees of 14 June 2006 (published on 22 June 2006), 10 December 2007 (published on 18 December 2007) and 2 July 2009 (published on 17 July 2009) on restricting the use of certain hazardous substances in electrical and electronic equipment, imposes three obligations on the producer:

First obligation

Since 1 July 2006, it has been prohibited to market new IT or telecommunication equipment, games or entertainment equipment containing lead, mercury, cadmium, hexavalent cadmium, polybrominated biphenyls (PBBs) and polybrominated diphenyls (PBDEs).


What is meant by IT and telecommunication equipment?

Second obligation

Producers are required to take such measures as are necessary to make available to users of electrical and electronic equipment for private use, through user manuals, the necessary information relating to:

The producer and the distributors are required to make this information available to potential buyers in all points-of-sale.

Third obligation

The producer is required to adequately display the following information on electrical and electronic equipment marketed after 13 August 2005.

Definition of "producer":

  1. any person who manufactures and sells electrical and electronic equipment in Belgium under his own brand;
  2. any person who resells under his own brand, in Belgium, equipment produced by other suppliers (the reseller is not considered to be the "producer" if the brand of the producer as defined in point 1, is displayed on the equipment);
  3. any person who imports electrical and electronic equipment professionally in Belgium or markets it in another EU member state.

Chemical substances and mixtures - REACH & CLP regulations

General information

In the framework of the implementation of GHS (Globally Harmonized System) relating to chemical substances and mixtures, suppliers must comply with:

These regulations also apply to the manufacturer from whom they purchase chemical products, substances and mixtures that will be delivered in Belgium.

To this end, manufacturers or their authorized agents must comply with the obligation of registration for chemical substances used in their manufacturing process (even if the manufacturer is established outside the EU).

The manufacturers or their authorized agents must comply with the labelling obligation as provided for in the CLP regulation.

Suppliers must provide Proximus with the SDS (Safety Data Sheet) as indicated in the REACH regulation by no later than 15.11.2010 for chemical substances delivered to Proximus and no later than 31.12.2014 for the mixtures and substances that they contain which have been delivered to Proximus. This obligation also applies to chemical substances and mixtures intended to be emitted by the articles. These Safety Data Sheets must contain scenarios of exposure to determine uses that have not been provided for. Where applicable, the suppliers of chemical substances and mixtures must report to Proximus any uses not provided for.


REACH is the acronym of Registration, Evaluation, Authorization and Restriction of CHemical substances. REACH is a European regulation introducing a new European policy on the management of chemical substances.

Its main aim is to better protect health and the environment while strengthening competition and innovation in the European Union.

Companies must make information available relating to each substance that they wish to produce or import in volumes in excess of one ton per year. This rule applies to both new and existing substances.

(Pre)registrations, evaluations, authorizations and limitations are linked to this regulation. It is the responsibility of the producers and importers to take these steps.

Throughout the whole chain, Proximus acts only as a user of the devices in which these substances and/or preparations are integrated.


On 20 January 2009, a new regulation on labelling and classification entered into force. It is known under the abbreviation CLP, which stands for Classification, Labelling and Packaging (of substances and mixtures).

This CLP regulation replaces the provisions relating to the classification and labelling of substances (Title XI of the REACH regulation). Due to the fact that it replaces the classification and labelling system, the CLP regulation is the instrument required for the implementation of the REACH regulation.

The classification of chemical products makes it possible to identify dangers that chemical products may pose to human health and the environment. This is therefore an essential parameter in the REACH process, since numerous provisions of this regulation are based on this classification and labelling or refer to it.

The CLP regulation was published in the Official Journal of the European Union on 31 December 2008 and entered into force on 20 January 2009.

However, it provides for a transition period during which the two classification and labelling systems, the existing and the new one, will coexist. This new system entered into effect on 1 December 2010 for pure substances and will be mandatory for mixtures as from 1 January 2015.

For substances dating back to before December 2010 and which are still on the market, the old regulation remains in force until 1 December 2012. The same applies to mixtures, but the situation must be regularized by 1 June 2017.

The classification and labelling system to be adhered to is the sole responsibility of the producer and/or importer.