Clear rules

Stefan works at Deutsche Telekom – and he loves soccer. The head of a supplier company invites him to the top game of the season, offering expensive VIP seats in a sold-out stadium. But Stefan declines and watches the game, as always, from his usual place among fellow fans.

Fighting corruption

Fighting corruption and promoting the rule of law – these are key aspects of Sustainable Development Goal (SDG) 16 of the United Nations.

Am I allowed to do that?

After all, Stefan works in Procurement – and he makes decisions about which companies get contracts from Deutsche Telekom. He adheres to strict rules in this context. When a business partner offers him soccer game tickets, he does not let himself be influenced and politely declines. This is because, much like sport, the business world has clear rules. The situation isn’t always so straightforward, though. What is prohibited and what is a permitted, friendly gesture among business partners? Is an invitation to dinner okay? How expensive can a birthday present be for an important customer? Many Deutsche Telekom employees face questions such as these in their day-to-day work. The Compliance Team is there to offer them advice and support. Compliance means adhering to rules, be they applicable laws or internal company guidelines and policies. And it’s not just about bribery and corruption, but also about protecting business secrets and avoiding conflicts of interest, for example.

„As a leading European telecommunications provider, we have a special responsibility: to create trust in a digital environment, we need a value-oriented corporate culture in which compliance and integrity are inseparably linked.“

Dr. Marie von der Groeben, Chief Compliance Officer (CCO) Deutsche Telekom AG

Earning trust

We do not view digital ethics as a mainstream trend or an aspect of marketing. Our company has a vested interest in ensuring our products and services are trustworthy. After all, customers will only buy and recommend our products and services if they trust them.

That trust does not come cheap – we must earn it anew each day. The basis for this is that everyone, whether Board member or employee on the shop floor, obeys the law and applicable rules.

How we ensure compliance

To ensure compliance, we follow an approach comprising three elements: prevention, identification, and response.


In 2016 we introduced our “Compliance-based Corporate Culture” initiative, with a view to preventing misconduct from happening in the first place. With this initiative, we are offering all employees compliance training and online learning opportunities, for example – and thereby strengthening our compliance culture. Above and beyond this, our employees can take advantage of the “Ask me!” advice portal to get tips and help on the right way to act in uncertain situations.


Via our “Tell me!” whistleblower portal, anyone can report potential compliance violations anonymously. Tip-offs are treated as strictly confidential and are reviewed by specially trained employees.


We have clear rules on what is allowed and what isn’t. Misconduct is not tolerated. We thoroughly investigate every tip-off. If a suspicion is confirmed, we initiate appropriate measures.

Our “constitution”

What conduct do we expect from our employees? We have outlined this in our Code of Conduct. It is something like the constitution for Deutsche Telekom. The Code of Conduct applies to everyone in our Group, worldwide – whether Board member or employee. And because our responsibility does not end at our company gates, we also expect our suppliers and partners to observe the requirements stated in our Code of Conduct. In addition to this, Deutsche Telekom has other policies that set out rules on specific issues, such as our “Group Policy on Accepting and Granting of Benefits”. Among other things, it clarifies whether, and up to what value, gifts may be accepted. From Deutsche Telekom’s point of view, we also need to examine ethical issues that crop up in relation to digitalization. With regard to artificial intelligence (AI), for instance, the core challenge is to shape AI so that it is focused on people and guided by values, and thus improves people's lives, safeguards their fundamental rights and autonomy, and can expand their scope for action. That is why we became one of the first companies in the world to establish binding rules in the form of our AI guidelines, which define how we at Deutsche Telekom use AI responsibly and develop our AI-based products and services.

It all comes down
to the culture

We put high priority on having all of our employees comply with our values and rules of conduct, and with the applicable laws, at all times. Our understanding of what compliance means goes above and beyond straightforward legal compliance in our business activity, i.e., compliance with laws and internal regulations. It also focuses on the integrity of employees and governance bodies. We have introduced various measures aimed at strengthening our corporate culture within the area of compliance. These include online courses for managers; “1-minute videos” – short video clips, in a social media format, that inform about relevant compliance issues; and “SimpleShows” – short animated films about various relevant topics. Also, we are continuing our efforts, with the help of educational technology and special online courses, to make our managers more aware in this area, and better able to receive, address, and follow up on employees' tip-offs about misconduct.
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