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 spot among his 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?

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 tickets to a soccer game, 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 for an important customer be? 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 following the rules and acting with integrity. And it’s not just about bribery and corruption, but also about protecting business secrets and avoiding conflicts of interest, for example.

Earning trust

Our customers’ trust lays the foundation for our business success. That trust does not come cheap – we must earn it anew each day. Our customers know they can trust us, because we act with integrity and ensure compliance as a matter of course. That not only applies to our everyday operations, but is also taken into consideration when we are developing and using new technologies.

How we ensure compliance

To minimize compliance-related risks, we operate a compliance management system comprising three basic elements – prevention, identification, and response.


Throughout the Group, we support staff with numerous measures that enable them always to act with integrity and in accordance with the law in their day-to-day work. We offer all employees compliance training and online learning opportunities, for example – and thereby strengthen our compliance culture. What’s more, our staff can use the AskMe advice portal to ask questions about proper conduct. We also operate central compliance processes such as the Compliance Risk Assessment to identify, evaluate, and mitigate compliance risks.


Via our “TellMe” 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. Furthermore, we use the findings from our compliance processes for the continuous improvement of the compliance management system.

Our rules

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 equally to everyone at the company – be they board members, managers, or employees. It is supplemented by further policies that flesh out the behavioral requirements set out in the Code of Conduct. Among other things, for example, our “Group Policy on Accepting and Granting of Benefits” describes whether, and up to what value, gifts may be accepted. At Deutsche Telekom, we also examine ethical issues that crop up in relation to digitalization. This applies, for example, to the use of artificial intelligence (AI). The core challenge as we see it is shaping AI in a way that it is focused on people and guided by values so that it improves people’s lives, safeguards their fundamental rights and autonomy, and can expand their scope for action. To ensure this is the case, we became one of the first companies in the world to establish binding rules in the form of our AI guidelines, which include specifications relating to the responsible use of AI and the development of AI-based products and services.

As set out in our Supplier Code of Conduct, we also expect our suppliers and partners to conduct themselves with integrity and meet compliance requirements.

It all comes down
to the culture

We expect all our employees to act with integrity and in accordance with the law. Besides being set out in the Code of Conduct and our in-house policies, this is also reflected in our corporate values. Our Guiding Principle “Act with respect and integrity” makes specific reference to this requirement. We use various measures and tools to continuously strengthen our corporate culture. These include interactive training for managers and employees, regular online courses, newsletters, videos about the importance of compliance and how to act in difficult situations, “Tone from the Top” messages, and annual activities to coincide with Anti-Corruption Day.
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