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Deutsche Telekom AG communicates its values and ethical standards within its Code of Conduct.

Additionally, it has several policies to further clarify the broad umbrella of values described in the Code of Conduct. A list of some of these Compliance policies can be found on the Deutsche Telekom AG Website.

One of these policies is the “Group Policy on Avoiding Corruption and other conflicts of interest”. Which gives employees guidance on avoiding corruption and other conflicts of interest. This includes a prohibition of granting and receiving benefits in chapter 5.1:

“The acceptance and granting of benefits in connection with Deutsche Telekom’s business activities are subject to substantial restrictions in light of the applicable corruption-related statutory offenses. This affects not only the acceptance and granting of benefits in the public sector, but also in private-sector business transactions, and it applies to a great extent to international cases as well.”

And it also includes the following section on the handling of conflicts of interest in chapter 4:

“4. Avoiding conflicts of interest/transparency
(1) Members of executive bodies, managers and employees share the goal of increasing the Group’s value. This goal can be achieved only if Deutsche Telekom is able to build and maintain permanent and worthwhile business relationships with customers and business partners. To maintain a permanent and worthwhile business relationship, all of Deutsche Telekom’s employees must act lawfully and with integrity in business transactions and orient their professional conduct exclusively toward the common good and economic benefit of Deutsche Telekom, its customers and business partners.
(2) Situations in which the business and personal interests of employees overlap and can thus conflict with each other (conflict of interest) jeopardize the ability to achieve the common goal. The top priority is therefore to prevent conflicts of interest from arising in the first place whenever possible. All employees are therefore required to keep their personal interests separate from those of the Company.
(3) If conflicts of interest are nevertheless unavoidable in individual situations, employees shall in their own interest disclose them to their supervisors and document such cases to avoid legal disadvantages.”

An overview of the contents can be seen in the following:

According to a study by the Korn Ferry Institute, 4.3 million technical positions in the technology, media and telecommunications industry will remain unfilled worldwide in 2030. However, the implementation of our Group strategy requires highly trained employees,
many with technical, digital and IT skills. In times of skills shortages, we are therefore not only competing with companies in our industry, but especially with companies from the tech and software sector as well as the automotive industry, which have a strong demand for technical and digital skills. In response, we are investing more in recruiting, developing and retaining talent with these skills. The results of these efforts are proving successful:
We were able to increase the share of digital experts in our Group to 22% in 2023. This means that the originally planned value of 17 % by 2024 has been significantly exceeded

As a basis for the necessary skills transformation, we have created instruments such as the Global Job Architecture (GJA), strategic personnel planning and strategic skills management.
In terms of future skills, the skill management system makes existing and missing skills visible at the individual level with the support of a digital tool,
development plans can be continuously adapted by means of targeted, individual qualification measures. One focus is on the topics of artificial intelligence, cloud computing, data science and analytics as well as software development and cyber security. To this end, the skills management process was successfully carried out for nearly 43,000 employees in the Group in 2023, which is around 31% of the workforce.

We want to offer every customer the best service experience! To achieve this goal millions of customer feedbacks are collected and evaluated each year by quality management. Customer satisfaction and solving the customer's problem in the first contact are our top priorities.

Our surveys are carried out either directly after a contact (for example in the hotline, in a store, during a field service call or after online inquiry by mail or chat) or after a completed process (for example, after a deployment).

If the customer tells us in a survey that his or her concern has not yet been solved, a callback offer is made to the customer in order to clarify his or her concern. The results of the customer surveys are also used to continually increase the competence of our consultants.

Regular test wins in comparative tests conducted by leading trade journals are proof of the excellent quality of our customer service.

Our goal is to constantly improve customer satisfaction (KPI`s):

• Since sustainability and climate change are important issues for Deutsche Telekom, efforts to address these issues are managed at the top level of the company. Our CEO, along with the other members of the Deutsche Telekom Board of Management, has responsibility for addressing climate-related issues throughout the entire Group. This extends to our climate strategy, our climate targets, and our climate-related opportunities and risks.
• The Deutsche Telekom Board of Management is informed annually concerning the current status of the company’s climate target achievement and regarding other company-related climate issues. Climate indicators (ESG KPI “Energy Intensity,” ESG KPI “Carbon Intensity”) also form part of the quarterly report submitted to the Board of Management. As of January 1, 2022, the CEO has this responsibility.
• Overall responsibility for Corporate Responsibility (CR) lies with our Board of Management, which deliberates and decides on the key strategic guidance and objectives. The Supervisory Board advises and oversees the Board of Management in this task.
• The Board of Management is informed every quarter about the status of the most important sustainability KPIs in the Group Performance Report. The Supervisory Board is also regularly updated by Group Corporate Responsibility (GCR) about the sustainability strategy and the progress that has been made in implementing it. Furthermore, a training workshop on the role of the Supervisory Board as part of new sustainability requirements was held in 2023.
• In addition, a new Strategy, ESG, and Innovation Committee was created from the Supervisory Board, subsuming the former Technology and Innovation Committee, to take account of the correlation between innovation and ESG topics and our strategy.
• Among other things, the topic of the Climate Target Transition Plan to achieve the climate targets was discussed there. Other climate issues have already been dated.

We offer our employees competitive, performance-based pay oriented to the relevant local markets. Our remuneration policies are structured to guarantee equal pay for men and women and do not discriminate.
Executive compensation at Deutsche Telekom is based on our Group-wide Global Compensation Guideline. We also offer our employees additional benefits such as our company pension scheme.
As part of our Group-wide employee survey, we regularly ascertain how satisfied our employees are with their pay and also conduct other surveys on specific topics and in specific units.

Detailed information:

- Note for value "Executive Level" (Board Remuneration) Public Source: DT Remuneration Report 2023 => page 21

- Further employee levels

• Calculation is only for Germany
• Management level: MG 2 and MG 3 and high exempt levels AT3 and AT4
• Non-Management level: Tarif employee's Group 1-10

As one of the world’s leading providers in the telecommunications and information technology industry, we are subject to all kinds of uncertainties and change. In order to operate successfully in this ongoing volatile environment, we anticipate potential developments at an early stage and systematically identify, assess, and manage the resulting risks and opportunities. We therefore consider a functioning risk and opportunity management system to be a central element of value-oriented corporate governance.

Comprehensive Risk and Opportunity Management
Our Group-wide risk and opportunity management system covers strategic, operational, regulatory, legal, compliance, and financial risks and opportunities for our consolidated and major non-consolidated entities.
The risk culture, i.e., the way we deal with risks and opportunities, is a key component of a risk management system and must be embedded in all parts of the company. Its aim is to flesh out the Risk Policy, and to do so, it includes the basic attitudes in relation to risks and forms the basis and the framework for everyday business, for making the right risk-oriented decisions. Part of this is optimizing the risk-returns profile. This does not necessarily mean reducing risk; rather, it means an assessment of risks and opportunities, taking the risk-bearing capacity into account.

The risk culture is closely interlinked with Deutsche Telekom’s corporate culture and requires a positive, transparent approach to risks and opportunities. A successful approach to risks and opportunities, however, does not solely depend on adhering to rules and regulations or implementing processes and structures. The way we deal with risks and opportunities is even more important, with the “tone from the top” being a decisive factor.
The principles of our risk culture are:

• Responsibility for risks: Everyone is a risk manager! This statement is the essence of our risk culture and fundamental to it. Every employee must know the risks in their area of responsibility, and must actively manage these within their day-to-day work.
• A receptive attitude to risks and opportunities: Addressing opportunities and risks openly sets the scene for a working environment in which opportunities can be seized while risks are minimized.
• Transparency and cooperation regarding risks: This facilitates the early detection of risks and enables improvements to be made in the timely implementation of countermeasures.
• Decision-making based on risks and opportunities: To ensure business success, it is essential for material risks and opportunities to be taken into consideration when making business decisions.
• Long-term risk monitoring: Risk mitigation and the continuous monitoring of suitable countermeasures result in the reduction of risks in the long term.

The risk strategy is developed based on the company strategy and, in particular, the finance strategy, and the targets defined therein. The risk strategy is further specified by the risk appetite. The risk appetite is the level of risk that is accepted or justifiable in order to achieve the company targets. The parameters for the risk appetite at Deutsche Telekom are capital market-based indicators (such as EBITDA After Leases and the level of debt). The specific amounts of these indicators and the associated risk tolerances are set each year for four years in the Integrated Planning and Management Process.

The aim of risk identification is to systematically and comprehensively recognize and describe risks in all functional areas of a company. When analyzing risk, it is important to consider the cause of risk and the effect of risk.

After the risks have been identified, they must be assessed by the risk owner. The risk owner retains responsibility for the risk. There are two options for this: quantitative and qualitative assessment.

Regarding the risk situation and individual risks identified, the following four response options can be distinguished: Risk avoidance, Risk reduction, Risk transfer and Risk acceptance.

The risks and risk handling are summarized in the risk reporting, which is submitted to the decision-makers in the company and/or the relevant supervisory bodies. This also ensures transparent monitoring of the development of individual risks, as well as of the overall risk situation. Recording interdependencies and consolidated issues correctly is an essential requirement for properly ascertaining Deutsche Telekom’s overall risk position using a Monte Carlo simulation (risk aggregation).

International Standards
Our risk and opportunity management system is based on the globally applicable risk management standard of the International Standards Organization (ISO). ISO standard 31000 “Risk management – Principles and guidelines” is regarded as a guideline for internationally recognized risk management systems. Our Groupwide risk management policy serves as the basis for a uniform risk management methodology.

Organizational Responsibility
In his function as Chief Risk Officer, the Head of Group Controlling is responsible for comprehensive risk governance, which is managed by a central department (Group Risk Governance, GRG) from within his area. He reports directly to the Chief Financial Officer.
Group Risk Governance is responsible for the risk and opportunity management system and the associated reporting system, in particular the Group risk report. The unit provides a standardized framework, reporting process, methodology and training for the entire Deutsche Telekom Group.

Decentralized Risk Assessment and Mitigation - Centralized Risk Consolidation
Each Group segment has designated contacts who identify, assess, and continuously monitor risks. Management takes potential opportunities into account in the annual planning process and continuously develops them further during business operations. All operating segments as well as the Group Headquarters & Group Services segment are connected to the central risk and opportunity management system of the Group via their own risk and opportunity management.

In accordance with the German Stock Corporation Act (AktG), the Audit and Finance Committee of the Supervisory Board of Deutsche Telekom AG monitors the effectiveness of the internal control system and the risk management system. GRG also reports to the Audit Committee and responds to all inquiries regarding the integrity of the risk management system.

Risk Management Training
Deutsche Telekom offers a comprehensive web-based training on risk management that is accessible to all directors, managers and employees. At Deutsche Telekom everyone is a risk manager. That is why this web-based training is completely barrier-free and available in multiple languages ensuring that everyone, regardless of their language proficiency or physical ability, can benefit from this training. This training recently won the Comenius EDU Media Award, a symbol of quality and excellence for digital education. The training provides directors, managers and employees with the necessary knowledge and skills to identify, assess, and mitigate risks effectively within their respective roles.

Description of the program

Bologna@Telekom is the part time study program of Deutsche Telekom and offers to employees in parallel to their regular work a scholarship of 50% of tuition fees for selected Bachelor and Master-degree-courses. Bologna@Telekom is running for more than 15 years and over 2310 about employees have started in business-related part-time courses. Some facts underline the meaning of the program for the emplyees. With a graduation rate of 70% the program is very successful.

Participants can be of any age. 20% of participants started Bologna@Telekom after 9+ years working at Deutsche Telekom. –The program overall is an important example on group level and delivers an impact in refer to diversity, career development, business related content, lifelong learning and employee retention. 31 % of the graduates are female, 15% of the graduates are managers and 59% of the Bologna@Telekom graduates changed job family. That means the alumni tend to move to the job family that fit their field of study. More and more Bologna@Telekom students are interested in subjects with digital focused content. The share of STEM students in Bologna@Telekom is increasing. The study time of 3.7 years in average shows the high motivation of the Bologna@Telekom students.

Benefits of the program:

All selected academic courses are following the business and skill demand of Deutsche Telekom (e.g. Software Development, Business informatics, Digital Transformation, Sales). On the other hand, the programs ensure a huge impact on the personal development of each student in fostering self- organization, digital collaboration, teamwork and work-life- and learn balance. So, the company benefits from graduates with future oriented knowledge, strong self-management and learning competencies and a high retention rate.

Quantitave impact of business benefits:

As major results we can point out, that since start of Bologna@Telekom:

• 59 % of the graduates changed their job role so Bologna@Telekom is an excellent example for upskilling (in a current position) and reskilling (on a new position)
• 2,9 % of FTEs participating in the program
• Evaluations have shown, that graduates valued the development of personal experience very high
• The program contributes to our employer attractiveness and employee retention as only 9% of the participants left the company.
• With a product consumer index of 8.92 customer satisfaction in 2023 was excellent.

At Deutsche Telekom, the percentage of open positions filled by internal candidates (internal hires) are:

2020: 66%
2021: 51%
2022: 33%
2023: 51%

Objective of this Group Policy

Deutsche Telekom is committed to honest, lawful conduct in the face of competition. Corruption is prohibited by laws all over the world. Deutsche Telekom does not tolerate corruption or the undue influence of business decisions and any violations of the prohibition on corruption shall be sanctioned in accordance with the applicable laws. Benefits in the form of gifts, hospitality (food and beverages), and events are common in the course of business and legally permitted, provided they are socially acceptable and not used to unduly influence business decisions. The objective of this Group-Policy (Policy) is to eliminate any risk of corruption in dealing with benefits. This Policy is mandatory for all employees of Deutsche Telekom.

The development of future-proof skills for our employees and the strengthening of an increasingly digital learning culture are top priorities for us. In the reporting year, employees in Germany and the European subsidiaries invested an average of 4.6 working days per employee in their continuing education. In 2023, we advanced our "welearn" (formerly known as “youlearn”) learning culture initiative, which had been established since 2019, aligning it more closely with the Group's strategic objectives. With the theme "Time to Focus on Tech & Digital Skills," welearn specifically targeted the acquisition of technical and digital proficiencies, yielding significant results: 52% of the 3.8 million learning hours invested by employees in Germany and European national companies were dedicated to technical and digital skill development.
Deutsche Telekom has solidified its digital learning framework, boasting a robust digital learning utilization rate of approximately 73%. Leveraging the intelligent "Percipio" learning platform, often likened to the "Netflix of learning," and integrating providers like "Coursera" with content from esteemed universities, over 164,000 employees access a diverse array of digital and contemporary learning resources.
Additionally, the employee-driven "Learning from Experts" (LEX) initiative, launched in 2018, has emerged as the company's largest peer-to-peer learning community, fostering informal learning channels. In 2023, more than 5,650 online sessions were conducted, facilitating the exchange of expertise among colleagues.

Inclusion thrives on partnership. Barriers in the work environment and in people´s minds can only be removed together. Following this thought, Telekom has updated its Actionplan of 2016. The new Actionplan 2.0 is aligned with the challenges of our current time. It helps to fill the framework of the new Group Inclusion Agreement with participation of all employees. 

In 2023, we did an in-depth analysis of biodiversity-related impacts and dependencies based on the parameters of the ENCORE tool. In own operations, no high dependency on water resources (ground water, surface water, water quality) has been identified. Thus, water-stress areas are not of concern for our operations.

The MagentaHome business unit has developed the open, cross-manufacturer Smart Home platform and the MagentaZuhause App. This gives customers the opportunity to combine devices from different companies easily and individually and to control them via app.

With the free MagentaZuhause App, customers can easily control smart devices from different manufacturers and intelligently network them with routines. In combination with LEDs, smart plugs, cameras and radiator thermostats, the home can easily become a smart home. The app helps to make everyday life more comfortable, increase security and save energy. For example, smart lighting that switches on automatically when someone comes home, or smart heating that adapts to the habits of the residents and saves energy. With the MagentaZuhause App, our customers stay connected to their home. Even when they are on the move.

Checking the home network, activating and sharing the guest Wi-Fi and optimising the Wi-Fi are just some of the many home network management options with the MagentaZuhause App.

In addition, our customers can monitor their energy needs, minimize unnecessary consumption, thereby reducing costs and contributing to a greener future.

Wi-Fi or IP devices can be connected directly to the app and no longer require a Smart Home gateway. This makes it easier to get started in the connected home. In addition, the app can also be used to control MagentaTV content - even by voice.

Customers can choose from several hundred different smart home devices. These include products from partners such as Philips Hue, WiZ, LEDVANCE, Gardena, Sonos, IKEA and D-Link. With a smart home-capable Telekom router, customers also have the option of using it as a smart home gateway in order to use wireless technologies beyond WLAN.

At the iF Design Award 2023, the MagentaZuhauseAapp was awarded in the category "User Experience - Product UX".

The MagentaZuhause App offers a high level of protection - as attested by the independent institute for IT security, AV-TEST GmbH. The security test 01/2023 repeatedly concludes that the app prevents manipulation by external parties and that communication is secure.

The Digital Ethics Squad deals with the further development, support and implementation of the topic of "digital ethics" in the Deutsche Telekom Group, also with a view to the upcoming AI regulation of the EU. We develop and support governance for digital ethics (strategy, development, framework conditions, processes...) also within the framework of corporate digital responsibility. 

Our team is made up of colleagues from Group Compliance, T-Labs, DT Service, L&I Legal Services, Group Privacy, L&I GPRA, L&I Patent & Brand, VTI Tel-IT. The squad also works closely networked and on an ad hoc basis with experts from the GPRA, VTI-SEC, MMS, COM, TD GK, TSI Cloud Strategy, TSI health, Risk Management, GST, Legal Tech areas as well as contacts from the international units. 

We analyse the developments in the economy and legislation as well as the current situation in the Group in order to meet the upcoming EU requirements for the use of artificial intelligence (AI). We are working on proposals for a systematic and appropriate implementation of the legal EU requirements in the Deutsche Telekom Group in order to exploit opportunities, build trust and avoid liability. To this end, we are working with VTI to establish a mandatory assessment for all AI applications in the Group. 

If you have any questions or suggestions regarding digital ethics, mailto:Digital-Ethics@telekom.de

Public Affairs and Transparency
We see ourselves as a dialog partner in an ever more complex digital world and are actively involved in political debate – responsible, fair, and based on facts. Deutsche Telekom engages directly with policy makers as well as indirectly via trade associations, the latter being the cornerstone of the public relations activities by Deutsche Telekom Group.
For the management of our lobbying activities and trade association memberships, our guiding principle is to respect the independence and integrity of our political interlocutors. We do not make any donations to political organizations, political parties, or elected officials on principle. Our lobby work is characterized by accurate, objective preparation of the facts at hand. When we avail ourselves of scientific support, we always do so transparently.

Code of Conduct and Compliance
We have made a public written commitment to ethical standards of behavior and enshrined these in our strict, extensive compliance program (Code of Conduct), including Deutsche Telekom’s guidelines political contributions. Our Code of Conduct is the central governance framework for lawful and ethical conduct. Integrity, respect, and compliance with the law and internal policies and regulations – these are the principles on which Deutsche Telekom’s business activities are based.
Deutsche Telekom’s code of conduct and compliance policies sum up the values of Deutsche Telekom and define what kind of behavior is required by those who work for it. The Code of Conduct applies to all board members, managing directors, executives and employees of the Deutsche Telekom worldwide. Additionally, it applies to people to who are viewed as equivalent to employees in functional terms, e. g. to temporary agency employees.
Telekom has a holistic compliance management system (CMS) in place to ensure conduct with integrity and in compliance with the law throughout the Group at all times and to successfully counter compliance risks.

Supporting the Paris Agreement
We are helping to mitigate climate change and contributing to compliance with the Paris Climate Agreement. We are a member of the Science Based Targets Initiative and have developed a science-based reduction target for Deutsche Telekom to make our contribution for limiting global warming. Additionally, Deutsche Telekom has committed to conduct engagement activities in line with the goals of the Paris Agreement. Deutsche Telekom supports regulations promoting the transition towards a 1.5° world e.g. via industry associations and by supporting various pledges with respect to the support of the Paris Climate Agreement 2015.

Alignment of our political engagement with the Paris Agreement
Deutsche Telekom has a process in place to ensure that political engagement activities are consistent with the overall climate change strategy. Due to intensive cooperation between Group Corporate Responsibility, Group Corporate Communications and Group Public and Regulatory affairs we ensure that our engagement within industry associations is in line with group climate strategy and policy. Therefore, sustainability experts are representing DT in various associations, as e.g. within the GeSI Board or as Cahir of the ETNO Environmental Working Group.
We reviewed whether public policy engagements and lobbying are aligned with the Paris Agreement and found many of our trade association’s positions and lobbying activities are aligned with the aims of the Paris Agreement.

 In some instances, our trade associations’ policy positions and lobbying activities may not fully align with our positions on issues, including the Paris Agreement’s goals and other sustainability topics. For those trade associations where we determined we are only partially aligned on issues relating to climate, to mitigate any misalignment, we expect to engage further with these trade associations to understand their positions better, work to influence change and finally, assess whether our membership should continue. Additionally, as we work to mitigate any misalignment related to climate, it is essential to consider other factors relevant to company interests, such as safety or diversity and inclusion. We believe that having a seat at the table with our trade associations allows us to communicate our views and influence the dialogue and activities in a manner that aligns with our commitment to sustainability and the long-term interests of our shareholders and other stakeholders, including around transparency and reporting.

In future reports, we may look to provide updated information on alignment with climate change aims and, where there is any misalignment, information on mitigating efforts.

Physical risks

Extreme weather conditions as a consequence of climate change will have a negative impact on our business processes and networks, leading to incidents or even network outages. Potential failure of network infrastructure may arise due to damaged secondary infrastructure (power outages, e.g.) or failed cooling equipment. Another risk is the possible damage to or failure of the network due to damage to the network infrastructure itself, which may occur as a result of extreme heat, heavy rain and inland flood.
Among the effects of breakdowns is their massive impact on the management of rescue operations, for example, sometimes even rendering such emergency efforts entirely impossible.

In contrast to the physical risks due to climate change, we identified the increasing use of energy-efficient technologies (in grid operation, e.g.) and the growing demand for climate-friendly products and services as significant climate-related opportunities. For instance, we are offering our customers more and more sustainable products and services. The basis for these is Deutsche Telekom’s “green network”, which is powered 100 percent by renewable energies. More Details

Physical risk assessment

In various workshops with experts from technology, purchasing, strategy and risk management, we defined the material climate-related risks and opportunities and carried out an initial weighting. We considered the consequences for our business activities that could result from the physical impacts of progressing climate change.
We analyzed - on an initial exemplary basis - 500 Deutsche Telekom AG sites for mobile and fixed line equally weighted in Germany with regard to the physical climate risks. These risks are the basis for adaptation plans regarding physical climate risks. The initial analysis covered about 80 % of our existing operations (based on revenue share). Such an analysis shall be extended similarly also to other countries and based on vulnerability and criticality in the future. In the future, all (100 %) new operations will undergo a risk assessment regarding physical climate risk incl. plans for adaptation to physical climate risks. 

The climate risk analysis was prepared using the "Climate Change Edition" of the "Location Risk Intelligence" software from reinsurer Munich Re. The analysis comprises eight indices (see graph). We consider the risk exposure for the respective locations of fixed line and mobile technical sites (network operation, data center and office buildings) in three climate scenarios of the Intergovernmental Panel on Climate Change (IPCC): RCP 2.6 means 2°C or below 2°C; a business-as-usual scenario (RCP 4.5), in which the global temperature increase will be more than two degrees, and a four-degree scenario (RCP 8.5). In addition to the climate scenarios, we also examine the risk exposure in different time frames: current, for the year 2050, and for 2100. 

The results from this assessment are used to develop a climate change adaptation plan with mitigation measures that consider context-specific factors and different assets (network operation, data center and office buildings).

Adaptation measures for physical risks

We understand physical risk adaption as anticipating the adverse effects of climate change and taking appropriate action to prevent or minimize the damage they can cause. Our action plans consider all material risks that have been identified through our climate risk assessment. By considering context factors such as characteristics of your sites (region, proximity to rivers, …), we ensure tailored made action plans instead of “one size fits all” approach.

More specifically, we have implemented the following actions:

Beyond that we ensure to mitigate our own possible impact on climate change by implementing ambitious climate strategy and measures for mitigating climate change in the first place. More Details.