Environment, Health & Safety Compliance

Part of delivering valuable services is our commitment to pursue safety and environmental responsibility as our employees carry out their jobs. Focusing on complying with applicable environment, health and safety (EHS) laws and regulations, we actively pursue ways to keep our employees safe and preserve our natural resources.

For more information, see our Global Reporting Initiative Index.

In 2023, AT&T’s EHS strategy focused on streamlining data collection and improving data analysis to better safeguard the health and safety of our employees and to limit our environmental impact. These efforts included: 

• Designing and implementing a new governance process to keep senior leaders of AT&T’s management team more apprised of EHS performance and compliance status for their respective business units. 
• Strengthening business unit EHS governance by establishing a comprehensive set of EHS data to align with business unit goals.
• Simplifying the EHS data-gathering process and improving data accuracy. 
• Pulling EHS-related data from across the business into EHS data-visualization tools and dashboards that provide business units with real-time access to compliance performance. 
• Expanded access to and use of data within our Compliance Data Management System and other EHS data platforms to improve EHS data tracking and performance measures.
• Promoting awareness and utilization of EHS tools and providing training to use them effectively.
• Establishing an Internal Operating Procedure for conducting virtual site reviews across EHS programs and enhancing the feedback loop with appropriate stakeholders.

Governance

We believe everyone at AT&T has a role to play in protecting our environment and upholding safety standards. From our part-time workers to our CEO, employees are responsible for annually reviewing our Code of Business Conduct and understanding its provisions, including its EHS-related components. EHS considerations, from protecting employee health to minimizing and recycling waste, are integrated into our business processes. We also encourage our suppliers and contractors to integrate EHS considerations into their processes through our contract language and our requirement to adhere to the AT&T Principles of Conduct for Suppliers. 

Board of Directors: The highest level of oversight of AT&T activities, including those of our EHS organization, is provided by the Board of Directors. For more information about the Board of Directors and its committees, please see our Investor Relations website. 

Individuals responsible for the management and oversight of EHS within our business include:

• Assistant Vice President—EHS: This position leads our EHS Management System and reports to the Senior Vice President of Global Workplace Security.  
• EHS Leadership Team: This team of leaders from across our EHS department periodically evaluates EHS programs based on data collected from reviews, audits and new regulatory requirements. Based on this analysis, they develop strategies to improve our EHS Management System and compliance programs as part of organizational goals and EHS plans.  
• EHS Governance Team: Working closely with the EHS leadership team, this group coordinates cross-functional engagement with EHS goals, compliance and action planning. In addition to developing strategies to improve the EHS Management System and compliance with EHS, they provide EHS-related information and updates to key business unit stakeholders throughout the year.
• Compliance: Our Chief Compliance Office organization assists the EHS leadership team in managing key EHS risks, providing risk oversight and holding monthly calls to discuss current and emerging EHS issues.
• Business Unit Stakeholders: This group is composed of senior leaders from across AT&T’s business units and periodically evaluates strategic annual goals set by EHS and business units. They also assess applicable corrective actions to minimize risk to our company.
• Business Unit Management: Individual business units maintain direct managerial responsibility for EHS within those units. 

Environment, Health & Safety Management System

AT&T adopted an Environment, Health and Safety Management System attested to the principles of the International Organization for Standardization (ISO) 14001 and the Occupational Health and Safety Assessment Series (OHSAS) 18001. Details on our EHS Management System are listed below. 

EHS Policies, Planning, Implementation & Evaluation

The EHS Management System provides a framework for AT&T to systematically manage our environmental risks and health and safety hazards, as well as foster compliance with external and internal objectives. This system helps us improve our operations and performance while maintaining the highest commitment to the health and safety of our employees and protection of the environment. It consists of the following elements:

• Environment, Health and Safety Policy: Our Environment, Health and Safety Policy reflects our responsibility to comply with EHS laws and regulations, and our policy to continuously improve our management systems and achieve other nonregulatory EHS goals. This policy commits all AT&T business units and operating companies worldwide to operate in an environmentally responsible manner and to protect the health and safety of our employees and the public. 
• Planning: Our Business Continuity Preparedness Handbook provides an overview of best practices to facilitate proactive planning and ongoing enforcement for various event scenarios. We proactively identify potential hazards, risks and environmental impacts associated with our operations. When a new process or task is identified, an internal AT&T EHS professional with knowledge of the work activity performs a hazard assessment and determines what personal protective equipment (PPE), if any, should be required. We maintain assessment results in an online system that helps us design and prioritize programs and processes to prevent or mitigate the potential hazards and risks identified. First emphasis is given to engineering and administrative controls, and PPE required as necessary where those controls do not eliminate the need. Responding to certain events requires careful planning and special procedures to allow for a safe working environment for the employee. Our Emergency Preparedness and Response Program includes guidelines for business units performing event scenario work, training requirements, and how our EHS organization supports post-event operations. This program is intended to work along with other company processes including the Global Emergency Management Center (GEMC), Network Emergency Operations Structure, Organizational Business Continuity Plans (OBCP), site Building Emergency Action Plan (BEAP) instructions and EHS Incident Management. 
• Annual Targets: Each year, our EHS team partners with business unit representatives to establish strategic objectives and tactical goals along with strategies for reducing incidents, such as release of hazardous materials, and health and safety incidents such as motor vehicle accidents. Internal annual targets vary across business units, but an example could be “Reduction in Days Away, Restricted Duty, or Transfer Duty (DART) Rate Year-over-Year with ≤0.50 Year End.” Progress is reviewed at least quarterly with the business units, with attention to determination of root cause for deviations and management to prevent ongoing and future occurrence. We also track the number of hours our employees spend on training to assist in mitigating health and safety incidents.   
• Implementation: We implement annual EHS plans by setting targets and deadlines, assigning responsibility and accountability for EHS performance, and defining roles and responsibilities within the EHS organization and responsible business units. We provide EHS information and resources both within and outside the enterprise by training AT&T employees and communicating EHS expectations to our vendors and contractors. For example, mandatory EHS Compliance overview is built into onboard training for new hires and specific EHS trainings, geared toward functional responsibilities, are incorporated into our business units’ annual plans. We encourage managers to directly engage with and hold their teams accountable for supporting employee participation in EHS program development activities. We are also optimizing several modules within our Compliance Data Management System to improve data tracking and gain efficiencies through programs and process improvements. We also are implementing a new Document Management System to facilitate better tracking of document owners, revision history, change management and archiving of superseded documents.
• Evaluation: We evaluate EHS performance with varying frequency, from monthly to quarterly, depending on the business unit and type of work performed. Our evaluations analyze key performance measures and metrics covering most of our company and review business operations that impact EHS. If we identify incidents of noncompliance with laws or company standards, we have formal systems in place to identify corrective actions and track these actions until they are completed.
  • In 2023, AT&T completed more than 3,000 internal Environmental Site Assessments (ESAs) at 2,868 locations in California. ESAs are focused on compliance with environmental regulations, such as hazardous material storage and air emissions.
  • Monitoring for health and safety performance is outlined in each business unit’s annual EHS plan. AT&T conducts internal health and safety observation and competency checks. The subject and frequency of these reviews are based on risks, focusing on groups that have the greatest opportunity for improvement. Corporate EHS monitors the effectiveness of department-specific plans and works with each business unit to drive improvement.
  • In 2023, we worked to establish an Internal Operating Procedure for conducting focused reviews of specific EHS programs and enhancing the feedback loop with appropriate stakeholders.
  • We evaluate our Emergency Preparedness and Response Program every two years. This evaluation includes role playing different EHS scenarios and documenting and resolving any identified gaps.
• Employee & Stakeholder Reporting: We maintain a toll-free number (800-KNOW-EHS) for employees, contractors and the public to call regarding EHS-related issues such as hazardous material spills and employee health and safety incidents. Each call is managed by an EHS representative, documented in our EHS Incident Tracking System, and tracked to resolution. Response times vary depending on the type of incident and regulatory requirements. Incidents that are not handled within expected time frames are escalated to leadership.
• Communicating about EHS: We developed and deployed a new communications platform, providing two-way engagement about health, safety and environmental content and campaigns for our audiences. We also designed a new governance readout summary that highlights business units’ quarterly regulatory performance and goal progress. 

Environment, Health & Safety Inspections

AT&T is subject to environmental inspections performed by government agencies to assess compliance with applicable EHS laws and regulations. Enforcement actions and total fines for 2023 are as follows:

• Government Agency Environmental Inspections: AT&T underwent 3,520 environmental inspections by government agencies in 2023, resulting in seven enforcement actions that also resulted in a penalty. Each matter was resolved and any abatement or corrective action implemented to provide for closure.  
• Government Agency Health & Safety Inspections: We underwent 11 health and safety inspections by government agencies in 2023, resulting in two enforcement actions and a penalty. In 2023, we paid a total of $31,500 in fines.⁷
• Hazardous Material Spills: We sustained 410 spills of hazardous materials in 2023, which generated approximately 12 metric tons of waste; 23 of those spills required reporting to a regulatory agency.⁸
• Internal Operation Reviews: We evaluate our EHS performance through regular reviews and internal assessments of our operations. The frequency of these assessments depends on the level of risk identified after evaluating the potential for personal injury, property damage and community or financial impact. We also perform a quarterly analysis of alleged violations cited during regulatory inspections to identify trends and better understand the fundamental reason for the occurrence of an incident.

Occupational Health & Safety

AT&T places a high priority on the safety of its customers, workers and communities, even as we begin deploying next-generation technologies to keep customers connected. We have a rigorous radio frequency (RF) safety program and are committed to responsible RF management at our wireless facilities to comply with Federal Communications Commission (FCC) RF exposure limits. As we coordinate with state and local officials to deploy small cells, for example, AT&T is committed to working with communities to provide the best possible service in the most responsible way. 

Our goal is for safety and environmental responsibility to be part of every employee’s standard operating procedure. If an accident occurs in the workplace, our policy is to respond swiftly, as detailed below: 

• Injury Investigation: Hospitalizations and fatalities associated with a work-related incident are automatically reported to AT&T Corporate EHS Field Support. Field Support then undertakes an investigation, analysis and subsequent development of a corrective action plan if certain qualifying factors are identified during the investigation. The analysis identifies key contributing factors and assigns corrective actions at varying levels (e.g., local, organizational or policy-related) to prevent the recurrence of similar incidents.
• Injury Reporting: We track key metrics to evaluate performance and report incidents as required. Our 2023 performance is outlined below:
  • In 2023, AT&T’s Occupational Safety and Health Administration (OSHA) total recordable incident rate was 1.43 per 100 employees.³ This rate is lower than the most recent (2022) employee average published by the Bureau of Labor Statistics for the telecommunications industry, which was 1.9 per 100 employees.⁹
  • In 2023, AT&T had one work-related incident that resulted in a fatality, 1,337 incidents resulting in lost time and 251 incidents that resulted in job restrictions or transfer. In 2023, our DART rate, which is also known as Lost Time Incident Rate, was 1.26 per 100 employees.³¹⁰

• We will continue to incorporate environmental compliance into business unit leadership’s responsibilities, in addition to the health and safety responsibilities they already carry. Driving accountability into the business units this way will help enhance our reporting and meet our goal of consistently communicating measures of EHS performance. As part of this effort, we developed a master list of strategic objectives to align with applicable business unit tactical goals.
• Regulatory requirements continue to change over time. To pursue AT&T’s compliance status with the latest regulations, we’ve engaged a vendor to monitor regulatory changes that impact EHS, providing us a weekly report of potential agenda items. Corporate EHS subject-matter experts determine applicability to allow the appropriate parties within AT&T to be notified and react to implement the changes. 
• We continue to identify and implement reporting tools to optimize EHS data analytics and increase access to EHS compliance data.

• AT&T Business Continuity Preparedness Handbook
• AT&T Code of Business Conduct
• AT&T Environment, Health and Safety Management System
• AT&T Environment, Health & Safety Policy
• AT&T Investor Relations website
• AT&T Principles of Conduct for Suppliers