Management & facts

Deutsche Telekom has made an explicit commitment to the UN Guiding Principles on Business and Human Rights published by the United Nations Human Rights Council in 2011. These guiding principles require that we systematically identify the impact our operations have on human rights; prevent and mitigate adverse impacts; and make restitution as necessary. In order to meet these requirements, we have developed an extensive program for the entire Group: We implement the UN Guiding Principles in an ongoing process that includes several interconnected measures and tools (see diagram).

Policy statement on human rights

In several basic policies, Deutsche Telekom commits itself to respecting human rights, the rights to privacy of the individual, and freedom of speech – and to safeguarding the right to conclude collective and works agreements and to guaranteeing diversity, equity and inclusion:

• Guiding Principles
• “Code of Human Rights & Social Principles”
• “Employee Relations Policy”
• “Diversity, Equity and Inclusion Group Policy”

Addressing complaints about potential human-rights violations

Anyone can use our Contact Point for Human Rights humanrights@telekom.com and our anonymous whistleblower portal “TellMe” to report tip-offs and make complaints. We look into every tip-off and report we receive and introduce countermeasures as soon as the information is identified as plausible. Information on how we handled the reports we received in 2022 can be found here. In addition, since 2013 we have also taken account of human rights aspects in due diligence activities conducted in the context of mergers and acquisitions.

Human-rights risk and impact analysis

In 2022, we continued the process, at Group Headquarters, of enshrining due diligence obligations pertaining to human rights within our various governance processes. This process included inclusion of human-rights and environmental risks within our annual Compliance Risk Assessment (CRA) – in preparation for the risk analysis that we will carry out in 2023, for the first time, in accordance with the Act on Corporate Due Diligence in Supply Chains (Lieferkettensorgfaltspflichtengesetz – LkSG). In addition, numerous workshops with Group Headquarters departments were carried out with a view to ensuring conformance – via suitable measures, and in all relevant business workflows – with new legal requirements such as the Supply Chain Due Diligence Act. In the 2022 financial year, we included a total of 68 units (61 companies and seven Group Headquarters units; not including T-Mobile US) within the CRA. The CRA enables us to identify human rights risks within our own business area, at early stages. All in all, we achieved a coverage rate of 91 percent (by FTE/full-time equivalents) of our fully consolidated companies. A total of 56 units confirmed that human rights issues have “medium to high relevance” for their business operations. Two national companies conceded that the Group’s “Code of Human Rights & Social Principles” regulation had not yet been promulgated throughout their workforces. One of the two companies has since initiated measures to enshrine the regulation throughout its operations, in a process that is to be completed in 2023. At the other of the two companies, the need for such measures was eliminated when it was converted, under company law, and in February 2023, into a non-controlling interest. In addition, T-Mobile US uses a different system for its risk assessment.

Human rights and employee relations at our national companies

As necessary, we carry out special auditing processes to assess employer-employee relations at our national companies. We do so to verify compliance with our Group Policy on Employee Relations and our “Code of Human Rights & Social Principles” policy statement. In this context, we also take into account the results provided by our Human Rights & Employee Relations Cockpit. We use the Cockpit to measure progress at our national companies on the basis of five indicators pertaining to human rights:

• Employee satisfaction (source: semi-annual pulse survey)
• Willingness to recommend Deutsche Telekom as an employer (source: semi-annual pulse survey)
• Health rate (source: Health, Safety, Environment (HSE) cockpit)
• Number of employees giving notice (source: HSE cockpit)
• Country-specific human rights risks (according to the Human Rights Risk Index from Maplecroft)

Based on each indicator, we classify the respective national company according to a traffic light system. The results are then discussed with the regional managers of the respective national company; if necessary, measures are agreed – such as “Human Rights Impact Assessments” (procedures that assess the actual and potential impact of corporate actions on human rights) or the “Employee Relations Policy Reviews” (reviews of compliance with the Group Policy on Employee Relations).

Effectiveness control regarding human rights in the supply chain

In order to ensure that human rights are also protected within our sphere of influence outside of our Group, we expressly require our suppliers to assume responsibility in this context. To this end, we supplemented our sustainable procurement strategy with supplier management, to improve sustainability performance in our supply chain and ensure respect for human rights. Among other activities, this includes audits of our suppliers. Detailed results of our Group-wide auditing program are available here.

Raising awareness; training; stakeholder engagement; and networks

To ensure that human rights are safeguarded in accordance with our Guiding Principles and our Code of Human Rights, we offer all employees, worldwide, suitable online training courses. These courses cover topics such as sexual harassment, freedom of speech, and corporate digital responsibility. We also use internal communication campaigns to provide information on important aspects of human rights, such as the aspect of anti-discrimination. Our Transgender Handbook, published in 2022, aims to encourage employees to simply be themselves at work. It points out ways to stand up against discrimination and helps us to strengthen diversity and inclusion in our corporate culture.  

We are also involved in numerous networks such as Global Compact and econsense. Together with other companies, policymakers, and civil society, we can draw attention to existing grievances and press ahead with solutions.

In 2022, we further intensified our public communication about our human-rights-related activities.

At Deutsche Telekom, the protection of human rights is firmly and formally established. In 2017, we revised our Social Charter , and developed it into the Code of Human Rights & Social Principles policy statement. The policy statement was adopted by our Board of Management in the same year. This update underscores our commitment to the aims set forth in the Federal Government’s 2016 National Action Plan on Business and Human Rights.

With the policy statement, we also underscore our commitment to

• The International Labour Organization’s (ILO ’s) Tripartite declaration of principles concerning multinational enterprises and social policy (MNE Declaration)
• The Convention on the Organisation for Economic Co-operation and Development (OECD )
• The UN Universal Declaration of Human Rights
• The UN Guiding Principles on Business and Human Rights and the United Nations Global Compact, and
• The UN Standards of Conduct for Business Tackling Discrimination against LGBTQI* people

Our Business Principles, Supplier Code of Conduct, guidelines on using artificial intelligence, our definition of digital responsibility formulated in 2022, our new Diversity, Equity and Inclusion Group Policy, and our New Work manifesto all pay heed to the respect of human rights in line with our policy statement. We also advocate for a pan-European supply chain act.

In the period from January 1 to December 31, 2022, we received five human-rights-related tip-offs through our Contact Point for Human Rights, our “TellMe” whistleblower system, and our reviews of compliance with our “Employee Relations Policy”.

• The inquiries and tip-offs received related to topics such as discrimination, sexual harassment, and employment conditions.
• Of course, all tip-offs were treated confidentially.

A key element of the assessment process for employer-employee relations at our national companies involves regular audits  in the framework of the Human Rights Impact Assessment (HRIA), a process for estimating the actual and potential effects of our business activities on human rights. It covers working conditions in our own business area and at our suppliers’. These comprehensive, systematic audits ensure that human-rights-related risks are identified and violations can be avoided. In 2022, we conducted HRIAs on site at three Deutsche Telekom Services Europe (DTSE) companies in Romania, Slovakia, and the Czech Republic. As part of these audits, we also included a digital ethics dimension for the first time, based on a framework that we formulated on the occasion of our Digital Responsibility initiative in 2022. It focuses on the development of human-centered technology, building on a humanistic system of values. With this step, we have created an additional framework for satisfying human-rights-related requirements in our products and services, alongside our existing policies and guidelines (such as those governing the use of artificial intelligence, for example). Since 2019, we have also been holding local workshops at our national companies to provide training and raise awareness about human rights issues.

Deutsche Telekom has made an express commitment to the UN Guiding Principles on Business and Human Rights adopted by the United Nations Human Rights Council in 2011, and it has enshrined these principles in its Code of Human Rights & Social Principles.

Compliance Risk Assessment
In 2022, we added human-rights-oriented and environmentally oriented risk assessment to our annual Compliance Risk Assessment (CRA). In the 2022 financial year, a total of 68 units (61 companies and seven Group Headquarters units; not including T-Mobile US) took part in human-rights-oriented risk assessment. This corresponds to a coverage rate of 91 percent (in terms of full-time equivalents (FTE )) of our fully consolidated companies. 56 units confirmed “medium to high relevance” of human rights topics for their business activities. Two national companies conceded that they had not yet announced the Group-wide Code of Human Rights & Social Principles policy statement within their companies. One of the two companies has since initiated measures to enshrine the regulation throughout its operations, in a process that is to be completed in 2023. At the other of the two companies, the need for such measures was eliminated when it was converted, under company law, and in February 2023, into a non-controlling interest. In addition, T-Mobile US uses a different system for its risk assessment.

Human-rights-related tip-offs
In 2022, we received five human-rights-related tip-offs through our Contact Point for Human Rights, our “TellMe” whistleblower system, and our reviews of compliance with our “Employee Relations Policy”.

Assessments & Review

• In 2022, a “Human Rights Risk Assessment” was carried out at three companies, located in Romania, Slovakia and the Czech Republic, of Deutsche Telekom Services Europe (DTSE).
• Also in 2022, “Employee Relations Policy” reviews were carried out, in connection with “Human Rights Impact Assessments,” at DTSE companies in Romania, Slovakia and the Czech Republic.

Impacts on human rights are also measured with our Human Rights & Employee Relations Policy Cockpit. To this end, the national companies collect data related to five human rights  indicators and evaluate them according to a traffic light system.