Our process for identifying material CR topics

For some two decades now, we have determined the topics that are relevant for our sustainability strategy and for our reporting on the basis of a materiality process that we are continually refining. We review it annually to ensure that it is still up to date. In 2022, key factors influencing the refining of the process were changes to the requirements laid down in the GRI standards 2021 and the requirements stipulated in the EU Corporate Sustainability Reporting Directive (CSRD img), which will be relevant for our reporting as of the 2024 reporting year. To determine the key topics, we have adapted our list of sustainability topics to the European Sustainability Reporting Standards (ESRS).

Documents were scrutinized to analyze all topics along the value chain, based on sources such as studies, research findings, internal policies, and measures – including the external stakeholder img perspective. The value creation stages that were examined were: resource depletion, production by our suppliers, Deutsche Telekom’s business operations – divided into “administrative processes” and “network build-out and data centers,” the usage phase of our products and services by our customers, and disposal and recycling.

In this process, we identified the negative and positive impacts of our business activities on the environment, society, and human rights along the entire value chain, as well as financial sustainability opportunities and risks. We then assessed the positive and negative impacts based on the probability of their occurrence and the scope of their impacts on the environment, society, and human rights. Based on these results, we then held interviews with internal and external experts to close gaps in the analysis and verify the assessments of the positive and negative impacts from the analysis. In addition, to determine the financial materiality, the identified sustainability opportunities and risks were assessed in the internal interviews with regard to their probability of occurrence and their financial impact on our business. Finally, the overall results were validated in an internal workshop with management and potential strategic implications were discussed.

The results of this year’s materiality analysis will help us prepare for the upcoming reporting requirements from the CSRD. For reporting in our non-financial statement (NFS) pursuant to §§ 315c in conjunction with 289c 289e of the German Commercial Code (HGB), we used the results of this year’s materiality analysis to review the key topics described there. In contrast, this year’s analysis is the foundation for this CR report, to meet the changed requirements of the 2021 GRI standards.

Inaluk Schaefer

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Inaluk Schaefer

Reporting against standards


Global Reporting Initiative (GRI)

  • GRI 2-12 (General Disclosures)
  • GRI 2-14 (General Disclosures)
  • GRI 3-1 (Material Topics)

Results of the materiality analysis

To determine the key topics, we defined “materiality thresholds” for each of the impacts (financial as well as impacts on the environment, society, and human rights). A topic is considered material as soon as one of these thresholds is exceeded.

Topic Materiality img by impact Financial materiality GRI aspects Link
Energy consumption and mix Energy (GRI 302) Our approach to energy-efficient networks
Greenhouse gas emissions, scopes 1, 2, 3  Emissions (GRI 305)

Our approach to measuring our climate-protection progress

Our climate targets

Resources used & circular economy Materials (GRI 301) Our approach for a circular economy
Waste, disposal, and recycling methods Waste (GRI 306) Waste management and recycling
Health and safety Occupational health and safety (GRI 403) Our approach to health and occupational safety
Non-discrimination and diversity

Diversity and equal opportunity (GRI 405)

Non-discrimination (GRI 406)

Our approach to diversity and equal opportunity

Our approach to protecting human rights


Collective bargaining, freedom of association, and social dialog Freedom of association and collective bargaining (GRI 407) Our approach to shaping employee relations
Corruption und bribery Anti-corruption (GRI 205)

Our approach to integrity and compliance

Our approach to sustainable procurement


Protecting privacy/data protection Not material by GRI Our approach to data protection
Access to the information society Not material by GRI Promoting media literacy and democratic competence

As a result of our focus on the ESRS standards, the following topics from our prior materiality analyses will no longer be considered as independent topics in the new materiality analysis:

  • Network build-out
  • ICT img solutions to support climate protection
  • Climate change mitigation
  • Cyber security
  • Supply chain labor standards
  • Socially relevant applications of ICT products and services
  • Media literacy
  • Transparency and reporting
  • Service quality
  • Disruptive img technologies

These topics have been integrated in the new topics. For example, “ICT solutions to support climate protection” have a positive impact on the topics “Energy consumption and mix” and “Greenhouse gas emissions.” The topic “Network build-out” is a focus of the value creation stages “Networks and data centers” and was consequently taken into account in all topics.

As part of the materiality analysis, we also analyzed potential scenarios for financial materiality: Sustainable products can help mitigate existing social, economic, or ecological problems, for example. On the other hand, adverse environmental impacts, such as larger quantities of produced waste, can increase costs (in this case, costs for waste management). The results show that currently, climate-related topics, data protection, access to the information society, and individual aspects in the supply chain pose a financial risk to society, the environment, and human rights, as well as to us as a company. Harmful substances along the supply chain can impair human health, for example, and increasing legal requirements that we have to meet can increase costs. On the other hand, our products and services can help solve ecological and social challenges. For example, we offer solutions that help reduce energy consumption. Such challenges, therefore, pose opportunities for sustainable development, as well as market opportunities for us. For years now, these issues have been taken into account in Deutsche Telekom’s overarching risk-and-opportunity management process, and they are described in detail each year in our annual report.

Reporting against standards


Global Reporting Initiative (GRI)

  • GRI 3-1 (Material Topics)
  • GRI 3-2 (Material Topics)

Materiality as a basis for evaluation of ESG risks and opportunities

In the year under review, we once again used our materiality analysis as a starting point for identifying and evaluating financial risks and opportunities that arise in connection with our sustainability issues. In the Group, risks and opportunities are generally assessed using a standardized risk process. As a result, many topics are covered that are also highly relevant from a sustainability perspective. The complementary consideration of financial impacts in the framework of the materiality analysis also helps us take impacts on the environment, society, and human rights into account. If new findings arise in this process, they are incorporated in the standardized risk process.

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