Telecom ESG Scorecard: Data privacy, e-waste, digital inclusion

The numbers are staggering. Over 150 million active phone lines, 93 percent population coverage, and a sector that has become the backbone of Nigeria’s digital economy .

But as the telecommunications industry has grown from 305,000 subscribers in 2001 to a ubiquitous presence in nearly every facet of Nigerian life, a new set of questions has emerged that no amount of subscriber growth can answer. What happens to the mountains of electronic waste generated by constantly upgrading networks? Who bears the cost when sensitive customer data is breached or mishandled? And for the millions still on the wrong side of the digital divide, is connectivity truly delivering inclusion or merely amplifying exclusion? These are the questions that define the Telecom ESG Scorecard, and for operators across Nigeria, the window for voluntary, narrative-driven answers is closing fast.

The regulatory architecture to hold telecom companies accountable is already taking shape. The Nigerian Communications Commission has signalled its intention to introduce a revised corporate governance code that will mandate sustainability reporting for all operators, moving beyond the 2016 framework to require detailed disclosure on environmental impact, social performance, and governance practices .

Dr. Aminu Maida, the NCC’s Executive Vice Chairman, has been unequivocal: Sustainability is no longer optional but essential for long-term success, and telecom operators must now provide stakeholders with verifiable data on carbon emissions, resource usage, labour practices, and data privacy . This is not a distant regulatory threat; it is an imminent compliance reality.

The first and most visible dimension of telecom ESG is environmental responsibility, and here the footprint is substantial. Networks require energy, vast amounts of it, to power base stations, data centres, and transmission equipment. MTN Nigeria’s 2024 Sustainability Report reveals the scale: over one million gigajoules of energy consumed annually, with Scope 1 and 2 emissions totalling more than 101,000 tonnes of CO2 equivalent . Yet the same report shows what is possible when environmental commitment moves beyond rhetoric.

Since 2021, MTN has achieved an 11 percent reduction in emissions against its baseline, expanded the deployment of solar-powered sites, and launched West Africa’s first eco-friendly SIM cards, reducing plastic waste at the point of customer acquisition .

Leading operators globally are demonstrating even greater ambition. Deutsche Telekom, Europe’s most valuable telecommunications brand, has committed to achieving climate neutrality across its entire value chain by 2040, with a science-based target validated by the Science Based Targets initiative . The company reduced its total energy consumption by 7.6 percent in a single year through green investments in more efficient network technologies and the replacement of legacy equipment, while meeting 100 percent of its Group-wide power requirements through renewable sources . In Thailand, True Corporation has expanded solar power generation to over 10,000 base stations, achieving a 13 percent increase in renewable energy usage and a 10 percent reduction in CO2 emissions across its network .

The waste dimension of environmental responsibility is equally critical. Telecommunications equipment has a finite lifespan, and the pace of technological change means that phones, routers, and network infrastructure are constantly being replaced. Deutsche Telekom took back 14.5 million used mobile devices and fixed-network equipment in a single year, professionally refurbishing nearly one million routers and set-top boxes for reuse . The company removed nearly 1,580 metric tonnes of copper cables from its German network and recycled them for further use, returning up to 90 percent of recovered copper to the commodity market . True Corporation achieved 100 percent electronic waste processing, ensuring that all operational waste meets the highest environmental standards . In Chile, WOM recovered 14 tonnes of electronic devices and reconditioned more than 80 percent of its electronic equipment, marking a milestone in responsible waste management .

For Nigerian operators, the e-waste challenge is immense but not insurmountable. The CelcomDigi merger in Malaysia offers a practical model. By collapsing duplicate legacy networks into a single, more efficient infrastructure, the company reduced its total site count from 24,000 to approximately 18,000, dismantling redundant equipment and working with waste management partners to ensure that non-usable parts are refurbished or disposed of in accordance with e-waste regulations . This approach simultaneously improves network efficiency, reduces energy consumption, and addresses the waste problem at its source.

The second pillar of telecom ESG is data privacy and cybersecurity, an area where the stakes have never been higher. As Dr. Maida warned at the 2024 Annual Corporate Governance Conference, data breaches can have dire consequences for both individual companies and the sector as a whole . Telecom operators manage vast amounts of sensitive information, from personal identities to financial transaction data, and the governance frameworks that protect this data must be robust, comprehensive, and continuously updated. The NCC’s revised code will prioritise data security through comprehensive internal policies and compliance protocols, recognising that consumer trust is the foundation upon which the entire digital economy rests .

Leading operators are already embedding these principles into their governance structures. CelcomDigi’s ESG performance scorecard tracks progress on privacy control framework implementation, aiming for 100 percent completion for high-risk data processing functions . MTN Nigeria reported zero data breaches in 2024, maintaining ISO 27001 certification and demonstrating that rigorous security practices are achievable even in challenging operating environments . True Corporation has gone further, adopting the GSMA’s Responsible AI Maturity Roadmap and becoming the first Thai company to implement a framework explicitly emphasising fairness, transparency, and privacy in the deployment of artificial intelligence systems . The company’s CyberSafe initiative, a free cybersecurity system powered by its network, flags seven million suspicious links daily and protects over 50 million users without requiring registration or app downloads .

The third pillar is digital inclusion, the social dimension that speaks most directly to telecommunications’ foundational purpose. Connectivity is not an end in itself; it is a means to participation in the modern economy, access to education and healthcare, and the exercise of fundamental rights. MTN Nigeria’s 2024 report shows progress: 90.1 percent broadband penetration, 47.7 million data subscribers, and N3.5 billion invested in corporate social investment programmes that reached over 660,000 people across education, health, and empowerment initiatives . Yet the gap between coverage and meaningful inclusion remains vast. Connectivity without affordability is exclusion. Access without digital literacy is wasted potential. Inclusion without safety is vulnerability.

Deutsche Telekom’s approach to digital participation offers a comprehensive framework. The company works to enable all people to participate in the digital era through affordable rates and devices tailored to persons with tighter budgets, and through programs that assist and encourage people to learn how to use digital media competently . Its Teachtoday initiative, Scroller programme, and Telekom Seniors’ Academy promote media literacy across all age groups, while its “No hate speech” campaign raises awareness about basic democratic values online, reaching nearly 900 million media contacts . The “ShareWithCare” initiative educates parents about the risks of sharing children’s photos online, using an AI-generated deepfake public service message that reached 250 million people internationally .

True Corporation’s digital inclusion metrics are equally impressive. Its digital literacy programme has empowered 350,000 vulnerable individuals with essential online skills, while its online learning platforms reached 32 million people in a single year . The company has collaborated with all sectors to advance education, providing equal opportunities for Thai youth in over 10,000 schools to access digital learning resources, and nurturing over 5,400 innovators resulting in 112 patents . CelcomDigi has committed to engaging 500,000 community members and tracking customer satisfaction improvements as core social KPIs .

For Nigerian operators, the digital inclusion challenge requires moving beyond infrastructure to impact. It means measuring not just how many people have access to your network, but how many are meaningfully using it to improve their lives. It means tracking digital literacy outcomes alongside subscriber numbers, and ensuring that the most vulnerable populations—women, rural communities, persons with disabilities—are not left behind. MTN’s commitment to 50 percent female workforce representation by 2030 and its EDGE Move Certification for gender equality are steps in the right direction . But the work of inclusion is never complete.

The governance dimension underpins all three pillars. Without robust board oversight, transparent reporting, and accountability mechanisms, ESG becomes window dressing. The NCC’s revised code will require telecom operators to demonstrate board composition, diversity, effectiveness, and compliance, with the clear message that good governance is not merely a regulatory obligation but a strategic necessity for sustainable business success . MTN Nigeria’s governance structure, with board-level oversight via seven committees and quarterly sustainability updates to the Social, Ethics, and Sustainability Committee, provides a model . CelcomDigi’s integration of ESG KPIs into executive performance measurement and its commitment to 100 percent employee pass-rates in integrity programme assessments demonstrate the seriousness with which leading operators approach governance .

The questions every telecom operator must now confront are not about the quality of their sustainability narrative. They are about the integrity of their institutional performance. What is your e-waste recycling rate, and can you verify it? How many data breaches occurred last year, and what systemic changes have you made to prevent future incidents? What percentage of your customers have digital literacy sufficient to protect themselves from online scams? Where are your network’s emissions trending, and do you have a credible pathway to net zero? These are not questions that can be answered with glossy brochures. They demand evidence, verification, and accountability.

The telecom sector has been the engine of Nigeria’s digital transformation, connecting millions and enabling an entire ecosystem of innovation and economic activity. But with that power comes responsibility. The networks that carry our calls, our messages, and our money must be networks we can trust  to protect our data, to minimise environmental harm, and to ensure that the digital future includes everyone, not just the privileged few.