MTN : FY 21 Transparency Report

MTN Group Limited

Transparency Report for the year ended 31 December 2021

Contents

ABOUT THIS REPORT

• 01 Scope and boundaries

• 01 Reporting standards and guidelines

• 01 Data collection process

• 02 Who we are and where are we going

• 03 Where we operate and how we performed

INTRODUCTION

• 04 Our operating context

• 05-07 Material digital human rights matters in our operating environments

• 08 Trade-offs to be managed in protecting digital human rights

• 09 MTN digital human rights strategic framework

MTN DIGITAL HUMAN RIGHTS POLICY

10-12 Key principles of MTN's digital human rights policy

13 Case study - South Sudan

STRENGTHENING MTN'S DIGITAL HUMAN RIGHTS DUE DILIGENCE

14 14-16

Rights and incident management

Digital human rights due diligence framework

• 17 Roles, responsibilities and governance framework

• 18 Impact management

• 19 Case study - eSwatini

REDEFINING DIGITAL HUMAN RIGHTS GOVERNANCE STRUCTURE

20-21 Responsible advocacy

DEFINING A HUMAN RIGHTS ADVOCACY APPROACH

• 22 Disclosure and performance management

• 23 Case study - Zambia

MARKETS REPORT

• 24 Categories of requests from authorities and NGOs

• 25 Overview of trends in transparency reporting

• 26 Afghanistan

• 27-28 Benin

• 29 Cameroon

• 30 Congo - Brazzaville

• 31 Côte d'Ivoire

• 32 eSwatini

• 33 Ghana

• 34 Guinea-Bissau

• 35 Guinea-Conakry

• 36 Liberia

• 37 Nigeria

• 38-39 Rwanda

• 40 South Africa

• 41 South Sudan

• 42 Sudan

• 43 Uganda

• 44 Zambia

is to enable the benefits of a modern connected life for everyone

Navigating this report

Throughout our Transparency Report, the following icons are used to show the connectivity between our Ambition 2025 strategic priorities, our capitals, our material matters and value creation for our stakeholders.

Our material

stakeholders:Our capitals:

Other icons:

ESG at the core

LA Limited assurance obtained

www.mtn.com

Our reporting suite

Material matters:

2025 strategic priorities:

In the year we took a step change in our approach to ESG, placing it at the core of our strategy. This aligns with our work to advance the United Nations Sustainable Development Goals through our business activities and our support of governments, communities and customers. The SDGs target a sustainable society with a plan to end poverty, protect the planet and ensure equality for all by 2030. We are committed to bridging the digital divide, furthering financial inclusion to advance the attainment of the goals. For details of how we determine the SDGs on which we have the greatest impact, see page 45.

MTN focus

Indirect impact

These reports are available on, or on request from Group Investor Relations [e-mail].

Annual Financial Statements

Tax Report

King IVTM Report

Five-Year Review

Detailed statements, analysis of the Group's financial results and the full Audit Committee report.

MTN's approach to tax and dealing with uncertain tax positions; views on specific tax risks; and our total tax contribution.

MTN's application of the King IVTM principles.

Comprehensive view over five years of the income statement; statements of financial position and cash flows; performance per share; as well as key non-financial information.

Sustainability Report

MTN's detailed environmental, social and governance performance.

Integrated Report

Our primary communication to stakeholders, aiming to enable them to make an informed assessment of our performance and prospects and the value we create through our activities.

GRI Report

Structured disclosure on the impacts of the Group's activities.

DRIVING SUSTAINABLE ECONOMIES

CDP Report

Global environmental disclosure, reporting on risks and opportunities in climate change, water security and deforestation

About this report

This report aims to provide insight into how MTN approaches governance of digital human rights, privacy and freedom of expression.

In addition, it also provides an overview of our human rights commitments and policies, which inform our human rights framework and the processes we follow when responding to requests from governments and non-governmental entities.

Lastly it details the legal regime, authorities empowered under local legislation and requests we received last year in each of the countries we operate in, unless the country's legislation prohibits us from doing so.

Scope and boundaries Timeframe

This report covers the period commencing 1 January 2021 and ending 31 December 2021. Where possible, data for the period 1 January 2020 to 31 December 2020, is also provided.

Markets covered

This report covers our operating companies within the following markets:

• • Afghanistan, Benin, Cameroon, Congo-Brazzaville, Côte d'Ivoire, eSwatini, Ghana, Guinea-Bissau, Guinea-Conakry, Liberia, Nigeria, Rwanda, South Africa, South Sudan, Sudan, Uganda, and Zambia (collectively, the 'markets').

• • MTN Yemen and MTN Syria were excluded from 2021 reporting due to data collection challenges and MTN's phased exit from the Middle East. Botswana and Iran are not included in this report due to MTN having majority indirect and minority ownership holding, respectively.

Due to legal restrictions in some countries in which we have a presence, certain markets are prevented from publicly disclosing certain information. Where this is the case, we have omitted this information from the report given the rule of law. In addition, there are instances where we do not detail the number of requests received from non-governmental entities for reasons of requests not being received by the markets in question.

Reporting standards and guidelines

The frameworks used to guide the report content and presentation

The reporting principles followed in the compilation of this report are aligned with the Global Reporting Initiative and the Integrated Reporting Framework. The report content has been informed by the disclosure requirements of the Ranking Digital Rights Index, the Global Network Initiative (GNI), and the GSMA Human Rights Guidance for the Mobile Industry. Also, this report seeks to meet the expectations for transparency set out by the United Nations Global Compact (UNGC) and United Nations Guiding Principles on Business and Human Rights.

Data collection process

How the data for the report was collected

This report was compiled using information collected by MTN Group from each of the markets, with the assistance of Webber Wentzel to safeguard the integrity of the information.

In preparing this report, MTN relied on its internal policies and relevant documents as well as the policies, legislation and regulations of the specific markets. In select markets, data request numbers from the previous reporting cycles have been revised due to the maturing data verification processes. The MTN markets provided detailed and updated information, where there were legal updates concerning:

• • The laws applicable to their market and how these laws protect the digital human rights of the market's subscribers.

• • Where a law does not have a descriptive name in a country, we have included a one-line description of that law in the report.

• • The regulators, authorities, courts and/or state bodies in each territory that exercise jurisdiction over the market (each an 'authority').

• • The requests received by the markets from the authorities and the way the markets have responded to these requests (in particular, whether the markets have complied with, partially complied with, or denied requests).

• • The requests received by the markets from private individuals, private companies, or attorneys or third parties authorised on their behalf (each a 'non-government entity') and how the markets have responded to these requests.

The legal framework and authorities referred to in each market are accurate as at 31 December 2021.

Feedback

We welcome feedback on this report and are committed to listening to our stakeholders about our sustainability and human rights efforts. Please address all feedback to Group Sustainability:[e-mail].

Who we are and where we are going

is to enable the benefits of a modern connected life for everyone

MTN is a pan-African mobile operator with the strategic intent of 'Leading digital solutions for Africa's progress'. Inspired by our belief that everyone deserves the benefits of a modern connected life, we provide a diverse range of voice, data, digital, fintech, wholesale, enterprise and API services to more than 272 million customers in 19 markets.

We were established in South Africa at the dawn of democracy in 1994 as a leader in transformation. Since then, we have grown by investing in sophisticated communication infrastructure, developing new technologies and by harnessing the talent of our diverse people to now offer services to communities across Africa and the Middle East.

MTN Group Limited is a publicly owned entity creating shares traded on the JSE. At the end of 2021 our market capitalisation was R321.7 billion (US$20 billion).

How we define value

For us, value is progress in achieving our strategic intent and delivering on our purpose to enable the benefits of a modern connected life for everyone in our footprint.

272m subscribers	122m active data users
57m active MoMo users	11m active ayoba users
R172bn in service revenue	16 390 skilled MTNers^
Africa's largest fixed and mobile network: invested capex of R32.7bn
Economic value of ~R115bn added across our markets	Reduction of ~16% in GHG emissions (targeting 47% reduction by 2030 and Net Zero by 2040)
Rural broadband coverage ~83% (targeting 95% by 2025)	Women are 39% of our workforce (targeting 50% by 2030)

Our asset realisation programme

Where we operate and how we performed

Our geographic footprint is wide, stretching over 19 markets on two continents, therefore robust operational oversight is critical. We secure this through a management structure that reflects almost equal contributions of around a third to Group earnings of each of our operations in South Africa and Nigeria and that of our regions - SEA, WECA and MENA - combined.

Changes in our portfolio

Our ARP was launched in 2019 with an aim to realise assets that were viewed as not long-term strategic assets. In February, we completed the sale of our 20% shareholding in BICS. In October, IHS Towers listed and started trading on the New York Stock Exchange. We will look to sell our 26% interest when market conditions are conducive.

Another important element of our ARP is broadening local participation. We listed by introduction in Rwanda. We also listed in Uganda, selling down ~13% of our shareholding and in Nigeria we sold down a further ~3% of our shareholding.

Portfolio transformation

In 2020, we announced our intention to exit the Middle East operations over the medium term in line with our pan-Africa focus and to simplify our portfolio and reduce risk.

In August 2021, we exited Syria. Given regulatory actions and demands that made operating there untenable, we abandoned the operation. We also exited our operation in Yemen through a transfer of our shareholding. This brought the number of MTN operations to 19 from 21. We continue to explore options to exit Afghanistan in an orderly manner.

Our portfolio at 1 April 2022

▲ Localisations ≠ Not long-term strategic assets

MTN Nigeria ▲ 75.6%

SEA

MTN Uganda ▲

MTN Rwanda ▲

MTN Zambia ▲ MTN South Sudan Mascom Botswana Δ MTN eSwatini Δ

WECA

MTN Ghana ▲ MTN Cameroon MTN Côte d'Ivoire MTN Benin

MTN Guinea-Conakry MTN Congo-Brazzaville LonestarCell (MTN Liberia) MTN Guinea-Bissau

MENA MTN Sudan

MTN Afghanistan ■ MTN Irancell ■ Δ

aYo

IHS Group ≠

Iran Internet Group ≠ Δ

Middle East Internet Holding ≠ Δ

■ Exiting in an orderly manner over the medium term

Δ Equity accounted