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2022 Corporate Responsibility Report

Further development of the Compliance organization

Dynamic challenges in our market environment, increasing regulatory requirements, and changes in the working world require continual adjustments to our compliance management system. We also keep the knowledge of our Compliance staff up to date with requirement-based, situation-related training courses and cross-company interchange formats, among other measures. In addition to professional development, these courses cover topics such as agility img, modern working, and tools and processes.

To adapt our Compliance organization to the increasing demands of our internal and external customers and to agile img working methods, the Group Compliance organization has been structured according to an agile organizational model and has been working with agile methods since 2021. This organization continued to evolve in 2022, with a focus on customers, processes, and digitalization.  

This ongoing development of our Compliance organization is intended to contribute to our customer-centric, lawful, sustained success as a company. Our compliance strategy focuses on our target vision of a leading digital compliance management system (leading digital CMS). 

In this vision, the CMS supports the following: 

  • Integrating compliance requirements in business processes as seamlessly as possible 
  • Showing the Group-wide status of the CMS and existing compliance risks at all times, transparently and up to date 
  • It actively takes up and addresses new developments in the business and regulatory domains and uses the insights gained for continuous improvement

The key components of leading digital CMS are culture, trust, and simplicity. 

  • Culture is the foundation of how we work together. Compliance cannot succeed without a good, open corporate culture in which every individual is willing to take responsibility, admit mistakes, and point out risks. 
  • Trust goes in two directions: The Compliance function serves as a trusted advisor, which develops solutions for dealing with compliance risks together with the business units. Conversely, the Compliance unit also returns this trust by only defining binding guidelines, where deemed necessary under risk aspects.  
  • Simplicity means that we want to make it as simple as possible for everyone at the company to follow the rules and implement compliance requirements. This means formulating the rules clearly and simply, for instance, and limiting them to what is essential.

To achieve the objective of a leading digital CMS, we have defined specific measures that we are implementing step by step. We achieved initial successes with it in 2022

  • We created the Compliance Digital Transformation cluster to consolidate digitalization know-how and drive forward the ongoing development and digitalization of compliance processes. 
  • Digitalization starts with a critical analysis of existing processes. Over the past year, we have identified significant simplifications in our compliance toolkit that intensify cross-functional collaboration with all risk owners with regard to the compliance risk assessment, and also designed a digital compliance reporting tool.  
  • To address “trust,” “culture,” and “simplicity” overall, we developed the ICARE check, a simple self-test with five questions for critical situations. The test is intended to help all employees master difficult situations and judge whether they should obtain advice before deciding on how to proceed further. 
  • We also supplemented our classroom training courses with dilemma situations from everyday business. Joint, interactive discussion of situations from everyday business that often make it difficult to find the right answer has resulted in a trusting, open dialog in the training courses, contributing to both the “culture” and “trust” elements.
  • Together with colleagues from the Board of Management department for Technology and Innovation, we initiated the Digital Ethics squad, to ensure together that we also act in accordance with our requirements of compliance and integrity in the digital world and when using artificial intelligence, and are prepared for new European frameworks like the EU AI Act. 
  • In addition, we responded to new statutory requirements, making changes to our compliance risk assessment and our TellMe whistleblower portal, within the framework of a project headed by Corporate Responsibility to implement German Supply Chain Act.