Through our interactive benchmarking tool, important facts and figures of our national companies can be analysed and compared.
Supplier compliance
With our Supplier Code of Conduct, we place our suppliers under an obligation to uphold the principles and values anchored in our Code of Conduct and in the Code of Human Rights & Social Principles. As of 2020, suppliers of solutions involving artificial intelligence (AI) must also comply with the requirements of our Digital Ethics Guidelines on AI. Deutsche Telekom suppliers are also under the obligation to do everything necessary to prevent active and passive forms of corruption. We expect our suppliers to impose the same requirements on their subcontractors too.
The Supplier Code of Conduct forms part of our General Terms and Conditions for Purchasing, but does not, of course, supersede the laws and regulations of countries in which our suppliers operate. Rather, it is designed to facilitate compliance with these laws and regulations and ensure that legal requirements are implemented faithfully and effectively. Since 2014, we have offered online compliance training for our suppliers.
When selecting business partners, we conduct compliance business assessments based on the risk of compliance violations. In addition to suppliers, and development and joint venture partners, this applies in particular to certain groups of consultants, such as sales agents. We have created a separate policy for partnerships with them (Consultant Policy).
Reporting against standards
- Principle 10 (Work against corruption in all its forms of, including extortion and bribery)
ESG KPI “Procurement Volume Without CR Risk” KPI
The ESG KPI 95 percent by 2025 – measures the procurement volume from direct business partners for whom, in the period under review, checks by an established external service provider turned up no negative media reports. It also includes suppliers for whom such reports were identified and who took suitable action to correct the issues involved. The procurement volume so assessed for risks accounted for a 99.6 percent share of the total relevant volume in 2022 (previous year: 99.7 percent). This ESG KPI, along with the ESG KPI “Procurement Volume Verified as Non-Critical”, is calculated with respect to the reviewed Group-wide procurement volume shown in the Group’s standardized procurement-report system (not including the category “Network Capacity” and not including T-Mobile US).
“Procurement Volume Without CR Risk” – for which the target is

ESG KPI “Procurement Volume Verified as Non-Critical” KPI
The ESG KPI 2025: 60 percent – measures the share accounted for by suppliers checked for social and ecological criteria by means of dedicated reviews – e.g., via EcoVadis , the Carbon Disclosure Project (CDP ), social audits , supplier visits, or our Supplier Development Program. In 2022, such CR-verified suppliers accounted for a share of 64.1 percent (previous year: 60 percent). This ESG KPI, along with the ESG KPI “Procurement Volume Without CR Risk”, is calculated with respect to the reviewed Group-wide procurement volume shown in the Group’s standardized procurement-report system (not including the category “Network Capacity” and not including T-Mobile US).
“Procurement Volume Verified as Non-Critical” – target for

Supply chain management
To be able to enter into a business relationship with us, suppliers have to register on our supplier portal and undergo a qualification process. The data provided gives us comprehensive information on our suppliers, including on their sustainability goals. Suppliers themselves also receive detailed information via the Supplier Code of Conduct on Deutsche Telekom’s sustainability requirements and efforts, which they must accept during the onboarding process.
As a rule, our supplier management runs through a five-step process. The aim is to minimize risks in the supply chain and encourage our suppliers to improve their practices.
Global Reporting Initiative (GRI)
- GRI 2-6 (General Disclosures)
- Principle 1 (Support and respect for internationally proclaimed human rights)
- Principle 2 (No complicity in human rights abuses)
- Principle 3 (Uphold freedom of association and the right to collective bargaining)
- Principle 4 (Elimination of all forms of forced and compulsory labor)
- Principle 5 (Abolition of child labor)
- Principle 7 (Support a precautionary approach to environmental challenges)
- Principle 8 (Undertake initiatives to promote greater environmental responsibility)
- Principle 9 (Encourage the development and diffusion of environmentally friendly technologies)
Escalation process
If a supplier cannot meet the sustainability requirements anchored in our Supplier Code of Conduct to our satisfaction or there are specific transgressions, we initiate our risk escalation process.
Our procurement organization is primarily responsible for this process – with support and advice from Group Corporate Responsibility, Compliance, and Legal Affairs. We hold discussions with the supplier to make our requirements clear to them. If the discussions held on various levels do not lead to the desired outcome, the responsible decision-makers consult with each other to reach agreement about how to proceed with the supplier. In the worst case, this could lead to the business relationship with the supplier being terminated.
Everyone who identifies irregularities in our supply chain regarding compliance with laws, internal guidelines, and standards of conduct, can report these – and can do so anonymously if they wish – using our TellMe portal.
Incidents in which a supplier fails to comply satisfactorily with provisions of the Supplier Code of Conduct – or even engages in out-and-out misconduct – can amount to critical CSR issues. We work together with suppliers (and services providers), and carry out special on-site audits, in the interest of identifying any critical issues.
Every time a critical issue is identified, a risk manager is assigned to the issue. The risk manager’s task is to analyze the risk event and put together a risk team.
In each case, the risk manager must determine whether measures, oriented to the critical CSR issue, need to be defined with regard to the relevant supplier. If measures do not need to be defined, the process up to that point must be duly documented, and the process is then stopped.
If measures are deemed to be necessary, they have to be defined, and a risk plan has to be prepared. In the process, the risk manager is supported by the company’s procurement and sustainability areas.
The risk plan has to be approved by the company’s procurement department.
If the risk plan is approved by the company’s procurement department, the risk manager can proceed with the next steps in the process. If the risk plan is not approved, the process starts over, from the beginning.
If the risk plan has been approved, it is communicated and implemented by the risk manager. The success of the risk plan is reviewed, and duly documented.
If the risk has been successfully reduced, the process is stopped. If the risk has not been adequately reduced, the process starts over, from the beginning.
Risk monitoring
In Procurement, we work with a comprehensive supplier risk monitoring scheme. We first conduct a risk assessment of all material groups on the basis of the CSR sets of criteria defined by Group Corporate Responsibility. We then subject suppliers to a comprehensive risk analysis. Specialized companies evaluate all suppliers with regard to financial, CR, and compliance risks.
Suppliers that present especially high levels of risk are also monitored with regard to global risks (e.g., natural disasters, political risks). For this purpose, we use EcoVadis
and carry out special audits on location. Our aim is to address deficits together with the supplier and take appropriate corrective action. Only if no solutions are possible do we have to cut ties with suppliers.2022 supplier sustainability reviews (excl. T-Mobile US) KPI
In 2022, we conducted a total of 98 supplier reviews – 83 of which were on-site reviews (social audits ) and 15 mobile surveys. 40 direct and 58 indirect suppliers were involved in the checks.
For the on-site reviews, we let the supplier know the approximate time of our visit in advance (“semi-announced auditsocial audits).
”). This is necessary to make sure that relevant contacts in key functions are present for the audit. The mobile surveys give our suppliers’ employees the opportunity to provide anonymous information about the social and ecological situation at their company. The surveys are primarily used to gain an initial impression of the local working conditions in order to then initiate further measures as needed, such as specific on-site reviews (Number of reviews | Number of findings | Number of completed finding | |
---|---|---|---|
Social audits (by external audit firms) | 83 | 549 | 464 (224 findings from 2022 and 240 outstanding findings from previous audits ) |
Mobile surveys * | 15 | - | - |
EcoVadis2014–2022) | (275 | - | - |
CDP | supply chain **207 | - | - |
Total | 580 | - | - |
* Mobile surveys with selected suppliers, in particular to assess the situation of workers at the operating sites |
Auditing procedures
We focus our audit250 of our 25 000 or so active suppliers. Together, they cover around 80 percent of our procurement volume. These audits give us transparency about the risks in large parts of our supply chain.
activities on strategically important and particularly risky suppliers. They are routinely audited every two to three years. This group includes roughlyThe majority of the audits are conducted within the scope of Joint Audit Cooperation (JAC). The audits cover the following areas:
The JAC Guidelines require, among other things, that our suppliers:
- Pay a fair wage that enables employees to enjoy a decent standard of living;
- Respect the right to freedom of association and collective bargaining, and provide a healthy, safe working environment and
- Do not exceed a 48-hour working week and a weekly maximum of twelve hours’ overtime, and grant at least one free day after six consecutive days of working.
Compliance with all these requirements is reviewed regularly during our on-site audits. This also includes inspection of the features and quality of the working, sleeping, and cafeteria areas.
Deutsche Telekom does not require its suppliers to obtain external environmental or social certification. But if suppliers cannot show any environmental and social responsibility certificates, we do expect equivalent management systems to be used. Our auditing experience shows, however, that the majority of our relevant manufacturing suppliers have an external certificate or equivalent management systems.
Verification of important social and ecological aspects as well as fundamental human rights during our audits is in line with internationally recognized guidelines and standards such as the ILO
core labor standards, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises.Reporting against standards
- Principle 1 (Support and respect for internationally proclaimed human rights)
- Principle 2 (No complicity in human rights abuses)
- Principle 3 (Uphold freedom of association and the right to collective bargaining)
- Principle 4 (Elimination of all forms of forced and compulsory labor)
- Principle 5 (Abolition of child labor)
- Principle 7 (Support a precautionary approach to environmental challenges)
- Principle 8 (Undertake initiatives to promote greater environmental responsibility)
- Principle 9 (Encourage the development and diffusion of environmentally friendly technologies)
- Principle 10 (Work against corruption in all its forms of, including extortion and bribery)
2022 audit results KPI
In the audit83 on-site audits were carried out in 2022.
program, which has been established and is controlled at Group level, a total ofAs in previous years, we concentrated our auditing activities on suppliers in Asia, Europe, Latin America, Oceania, and Africa.
Audited suppliers included manufacturers in the areas of IT hardware, software and services as well as networks and devices.
All violations identified in the course of such audits enter into a correction and measures plan, and the timely implementation of measures is regularly monitored. In the audits carried out in the period under review, no serious transgressions in the areas of working conditions and other basic human rights – such as discrimination, forced labor, and child labor – were found. In addition, no cases of bribery or corruption, and no critical violations of general compliance rules, such as rules governing the right to intellectual property, were found.
- Of the 83 suppliers we audited in 2022 (eleven of which were in accordance with the validated audit processes of the Responsible Business Alliance ), around 43 percent (36 audits) were direct suppliers and 57 percent (47 audits) were tier 2, 3, and 4 suppliers – that is, indirect suppliers.
- The audits carried out in 2022 revealed a total of 549 violations of Deutsche Telekom’s supplier requirements. These findings break down as follows: 231 cases regarding occupational health and safety, 67 cases regarding working hours, 104 cases regarding environmental protection, 23 cases regarding working conditions, 51 cases regarding wages and remuneration, 53 cases regarding corporate ethics, eight cases regarding freedom of association, four cases regarding disciplinary measures, and eight cases regarding discrimination. In addition, the violations included 36 transgressions that needed to be addressed on a priority basis and an additional 286 serious findings. A total of 464 violations were corrected in 2022, including several open improvement measures from previous years. Examples of critical violations in 2022 and improvement measures can be found in the table below. As in previous years, most violations (42 percent) were linked to occupational health and safety (2021: 43 percent), followed by violations linked to the environment at 19 percent (2021: 16 percent). At 12 percent, working hours constituted the third biggest issue (2021: 18 percent).
Areas | Findings at suppliers | Initiated improvements | Status (end of 2022) |
---|---|---|---|
Environment | One plant had failed to present documentation on assessment of services providers with regard to proper disposal of hazardous waste. | The plant has since prepared checklists for auditing of services providers with regard to proper disposal of hazardous waste, and it is carrying out relevant reviews. | complete |
The responsibility for disposing of hazardous waste was delegated to a qualified, certified company that carries out the necessary record-keeping. The waste-oil container (lubricants) in question did not have a GHS label, however, and it was being kept outside, next to the building, in an uncovered area. A check showed that the waste-oil container contained various types of oils, such as lubricants and cutting compounds. | Now, GHS labels are being applied to all waste containers, and all waste containers are being kept in an outside area, next to the building, that is covered and where the containers will not be damaged by being exposed to rain. | complete | |
Business ethics | The supplier had no risk-analysis procedure. | Risk analysis was carried out with regard to corruption risks. | complete |
Forced labor | Employment contracts of agency workers contained unlawful terms and specified unlawful positions. The standard employment contracts of these workers were incomplete – for example, they lacked job titles and validity periods. Furthermore, the plant concluded no open-ended employment contracts with workers who had been with the company for more than 10 years, and it failed to obtain the consent of workers for this policy. | A new contract was signed with the employment agencies. The workers’ salaries are being paid by our company, and the relevant agency fee is paid to the employment agency on a monthly basis. All workers receive proper instruction in relevant aspects of labor law. New workers have to confirm the job titles specified in their employment contracts. In each case, employment contracts include the worker’s job description, place of work, and contract term (duration). Workers who have been with the company for more than ten years have received open-ended employment contracts. Workers have received proper instruction regarding legal requirements pertaining to prevention of occupational illnesses, and additional agreements regarding occupational-illness risks have been concluded with affected workers. | complete |
Occupational health and safety | The plant failed to carry out evacuation drills in workers’ sleeping quarters. | The plant has carried out an evacuation drill in workers’ sleeping quarters. The drill was approved by the auditor. | complete |
On-site inspections revealed that the workshop’s eye-wash station consisted of a pressure-actuated unit that only had a capacity of five liters, and thus did not comply with the applicable requirements. | A permanent eye-wash station with a capacity of 53 liters was installed. | complete | |
Two soldering workers on the assembly line wore active-charcoal masks instead of dust-tight masks. The plant corrected this error on site. | Training courses on workplace safety and health were carried out for managers. In addition, workers at the site received new protective equipment. | complete | |
Working hours | The worker’s monthly working time exceeded the legally permitted maximum. | The plant has prepared a plan for gradual reduction of work time and overtime, to ensure that the monthly working time complies with national laws. | complete |
Wages & salaries | One plant failed to pay workers the legally mandated overtime allowances. | The plant has since prepared procedural documents relative to its social responsibility; introduced a “procedure for controlling working time” and a “procedure for controlling salaries and remuneration”; and continually improved working conditions with the help of the said procedural documents. Also, attendance-records policies have been revised, with a view to precise recording of daily presence and overtime hours. The plant is now paying overtime allowances in strict conformance with attendance records and the “overtime-management system,” and in keeping with the applicable laws and regulations. | complete |
|
Supplier Development Program
We collaborate as partners with our suppliers to make sure they are able to meet our high sustainability criteria.
Since 2018, we have continued the former Deutsche Telekom supplier development program as an industry approach (Sustainable Development Program, SDP). In 2021, the SDP was transferred to the Joint Audit Cooperation (JAC). Alongside Deutsche Telekom in charge of project management, Telefónica, Swisscom, and Orange are working together to continually refine the SDP concept in accordance with the JAC sustainability targets.
We expect more JAC member companies to join the program in the near future. The diagram shows the areas in which we audit the suppliers participating in our program. Based on these audits, we work with the respective supplier to develop a plan for remedying any issues. All activities and findings are documented so that we can assess the effectiveness of the measures employed.
Expenditure analysis 2022
Our suppliers come from various industries and countries. To capture the diversity of our more than 25 000 suppliers, the following graphic depicts the types of suppliers we commission; the overview includes the share of our expenditure (capex and opex) attributable to them and their geographical distribution.
2022 | ||||||
---|---|---|---|---|---|---|
Supplier Category | Proportion of Spend % | Number of Consolidated Suppliers | Number of domestic subsidiary suppliers | Number of foreign subsidiary suppliers | Number of critical subsidiary suppliers | Number of risky subsidiary suppliers |
Building, facilities, furniture and rel. services | 3.5% | 2 292 | 563 | 1 969 | 53 | 2 |
Civil Works | 18.2% | 4 868 | 4 435 | 1 297 | 168 | 0 |
Consulting,contracting, temp. labour and service center | 2.7% | 1 174 | 336 | 1 002 | 27 | 0 |
Electrodomestic appliances | 0.0% | 104 | 35 | 78 | 4 | 0 |
Enduser communication technology and equipment | 22.1% | 1 071 | 347 | 911 | 42 | 0 |
Energy, fuel, gas, water | 0.4% | 148 | 45 | 107 | 4 | 0 |
FinancialServices,insur,fees,investig,cert | 1.0% | 864 | 216 | 824 | 17 | 2 |
Fleet and travel | 0.6% | 671 | 234 | 472 | 35 | 2 |
Food and catering | 0.1% | 365 | 78 | 309 | 22 | 0 |
HR services, training and translation | 0.7% | 2 654 | 1 157 | 1 780 | 67 | 2 |
Information technology | 17.5% | 5 192 | 1 907 | 4 552 | 151 | 1 |
Logistics and mail | 0.9% | 592 | 256 | 419 | 9 | 1 |
Marketing, media, content, print, fairs | 8.7% | 5 425 | 2 473 | 3 469 | 152 | 3 |
Network capacity | 5.6% | 1 051 | 147 | 1 436 | 40 | 1 |
Network infrastructure | 13.8% | 2 286 | 892 | 1 998 | 76 | 2 |
Office equipment, office technology and stationery | 0.2% | 786 | 403 | 433 | 14 | 0 |
Service platforms | 1.3% | 735 | 282 | 540 | 24 | 0 |
Sim cards | 0.1% | 39 | 25 | 24 | 2 | 0 |
Tools and protection equipment | 0.3% | 537 | 199 | 353 | 13 | 0 |
Undefined/Undefined | 2.2% | 224 | 107 | 109 | 6 | 0 |
TOTAL | 100% | 748 | 10 | |||
Unique consolidated suppliers: 20 943 | Unique local/subsidiary suppliers: 28 272 | In total with no regards to the corresponding category | In total with no regards to the corresponding category |
Definitions and examples
- Consolidated supplier = Group level
- Domestic subsidiary of the supplier = Subsidiaries of the corresponding company located in Germany
- International subsidiary of the supplier = Number of supplier subsidiaries which are located outside of Germany
- Consolidated suppliers are uniquely counted at Group level; local suppliers are multiple counted in case of different business operations/locations
- Critical supplier: Supplier with compliance, financial, and resilience risks
- CR risky supplier: Adherence/Compliance risks to defined ethical, ecological, and social requirements
ESG KPI “CDP Supply Chain Program” KPI
Since as early as 2016, we have been disclosing our activities to bring on board suppliers as part of CDP ’s supplier engagement rating. This rating assesses how well companies have been able to integrate the topic of climate protection into their supply chain. In 2022, we were awarded an A rating, as in the previous year. This has secured our place on the Supplier Engagement Leader Board. An important step in achieving this was calculating the supplier-specific emission intensities based on supplier responses to the CDP Supply Chain Program. This involved calculating the ratio between a supplier’s overall emissions (Scopes 1 and 2 and Scope 3 for the upstream supply chain) and the supplier’s overall sales.
The ESG KPI 2022, over 52 percent of the procurement volume was covered by the CDP Supply Chain Program.
“CDP Supply Chain Program” indicates the degree to which our procurement volume from carbon-intensive suppliers is covered by the CDP Supply Chain Program. In

Supplier relationship KPI
The percentage of audited procurement volume increased slightly from 20.6 percent in the previous year to 21.1 percent in 2022. At the same time, the percentage of procurement volume covered by EcoVadis increased sligthly to 39.7 percent.

- Criterion 1 (Strategy)
- Criterion 3 (Objectives)
- Criterion 4 (Depth of the Value Chain)
- Criterion 6 (Rules and Processes)
- Criterion 17 (Human Rights)
- Principle 1 (Support and respect for internationally proclaimed human rights)
- Principle 2 (No complicity in human rights abuses)
- Principle 5 (Abolition of child labor)
European Federation of Financial Analysts Societies (EFFAS)
- V28-04 (Supply Chain)
Responsible procurement of raw materials
We require our suppliers to protect the environment and use resources responsibly. This requirement is enshrined both in our “Code of Human Rights & Social Principles” and in our Supplier Code of Conduct, which sets out requirements that must generally be accepted by all suppliers.
In the case of relevant material/product groups, the use of hazardous materials and conflict materials is checked and assessed as part of the supplier and product selection. In the case critical suppliers in particular, we request disclosure of information about their activities (via EcoVadissocial audits. In these audits, we check whether our suppliers use an environmental management system, including a waste management system, and review how they manage their energy and water consumption.
and CDP ) and we perform supplier audits in the form ofIn addition, we always check whether there is a management system in place to address the issue of conflict resources. When selecting suppliers and products, we review and evaluate, for example, the use of hazardous and conflict materials as well as rare-earth metals – especially in light of the OECD
Due Diligence Guidance for Responsible Supply Chains.In the period under review, we have readjusted the requirements placed on our suppliers and tightened them up significantly, particularly in relation to environmentally-responsible action, including against the background of the Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz – LkSG). Since then, contributions to environmental protection and climate change, responsible waste management, and the handling of persistent organic pollutants that only degrade very slowly in the environment, have been enshrined in our Supplier Code of Conduct along with a ban on manufacturing any products containing mercury. Since 2022, these criteria are being used for selected tenders and incorporated into the supplier selection process with a weighting of up to 20 percent.
Reporting against standards
- Principle 7 (Support a precautionary approach to environmental challenges)
- Principle 8 (Undertake initiatives to promote greater environmental responsibility)
- Principle 9 (Encourage the development and diffusion of environmentally friendly technologies)
Our approach to sustainable procurement
Our contribution to the SDGs
Our Group-wide procurement strategy and derived guidelines take full account of the issue of sustainability. These guidelines affect the entire procurement process. The strategy is put into action using internal and external performance indicators and management tools.
Corruption and bribery may cause long-term economic losses, prevent fair competition and needs-based investment, destroy jobs, and accentuate poverty and inequality in the population. As part of the impact analysis of our materiality assessment process, we have also analyzed in detail our suppliers' sustainability performance. We identified a moderate risk here for the issues of corruption and bribery.
We are therefore committed to promoting, among other things, the responsible procurement of minerals and do our utmost to substitute conflict materials. We also offer our suppliers e-learning courses on Compliance.
Supplier Code of Conduct
Our Supplier Code of Conduct forms part of our General Terms and Conditions for Purchasing and must therefore be accepted by our suppliers. In line with our own Group Policies, ethical, social, and ecological principles as well as fundamental human rights are enshrined in the Code of Conduct:
With our Supplier Code of Conduct, we have furthermore made a commitment to complying with the internationally recognized norms and standards such as the ones set forth by the International Labour Organization (ILO), the Organisation for Economic Co-operation and Development, the Universal Declaration of Human Rights, and the UN Global Compact:
Furthermore, it also includes requirements relating to additional relevant issues such as data protection, corruption, and artificial intelligence. For our strategically important and particularly risk-prone suppliers, we have on-site audits conducted regularly by external auditors to verify compliance with the Supplier Code of Conduct. We also updated our Supplier Code of Conduct in 2022 based on the requirements set out in the German Act on Corporate Due Diligence Obligations for the Prevention of Human Rights Violations in Supply Chains.
Global Procurement Policy
Our sustainability principles for Procurement are set out in the Group’s Global Procurement Policy.
Procurement guidelines
The Procurement guidelines provide specific instructions for procurement in Germany and serve as recommendations for our national companies.
Other policies
The Group Policy on Avoiding Corruption, the Statement on Extractives, and the list of prohibited materials are binding for our suppliers, too.
Implementation in the company
Steering tools
The ESG KPIs are an important steering tool for Procurement.
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Global Reporting Initiative (GRI)
GRI 205 3-3 (Management of material topics)
Global Compact