Governance

The Supplier Code of Conduct requires the supplier to ensure compliance with applicable laws, regulatory provisions, and contractual obligations by appropriate means for the effective implementation and maintaining of a compliance framework. This means the obligation by the supplier to implement a compliance management system appropriate for its risk exposure.

Deutsche Telekom adheres to highest ethical standards as reflected in Deutsche Telekom’s Code of Conduct. This means in particular DT complies with all applicable law and regulation and takes appropriate measures to ensure observation and effective implementation of compliance processes. DT’s Board of Management is fully committed to these ethical standards and expects the same from all employees throughout the group. 

The compliance with ethical standards is one of the components assessed regularly:

Deutsche Telekom conducts a regular group wide Compliance Risk Assessment to identify, and evaluate compliance risks and derive risk-oriented measures to prevent breaches of laws and regulations. In 2022, we added human-rights-oriented and environmentally oriented risk assessment to our annual Compliance Risk Assessment (CRA).

The analogue transmission of phone-calls through PSTN-Technology is past tense. We have migrated all lines - in Germany as well as in European NatCos - to IP-Technology and with that created the basis for fast internet-connections and more complex applications.

Together with satellite company Inmarsat, Deutsche Telekom is offering the fastest inflight broadband service for European travelers.

The European Aviation Network (EAN) has been developed by Inmarsat and Deutsche Telekom in partnership with leading European companies such as Thales, Nokia, Airbus, and Cobham. It marks a paradigm shift in the airline passenger experience, with incomparable speeds, uninterrupted coverage and significantly lower latency than any other inflight Wi-Fi network in the continent.

The award-winning connectivity solution has been available to over 85 million passengers to date, travelling on more than 650.000 flights throughout Europe, covering key destinations such as London, Madrid, Barcelona, Geneva and Rome. EAN has now been activated in 275 aircraft and is currently available with British Airways, Iberia, Vueling and Aegean Airlines.

Since the the Computerhilfe Plus service launch in 2016, the demand for support in matters related to digital security has continued to grow. That’s why we introduced the Digital Schutzpaket (Digital Protection Package) in 2018 and added the Digital Schutzpaket Business (Business Digital Protection Package) to this product at the end of 2019. The Digital Protection Package combines all relevant security services in one product and offers a central point of contact for all topics related to home networks and Wi-Fi, internet, and social media. A service number provides access to Deutsche Telekom experts for support on protecting the home network from external attacks, or help on the secure use of the internet, social networks, and passwords. In the event of data loss, we look after recovering files where possible. Other service components include financial protection from fraudulent use of bank details, fraud in private online trading, and protection and effective countermeasures against cyberbullying or insults on the internet. For business customers, reputation protection is also included, which supports the deletion of unstable negative ratings and provides tips on maintaining online reputation. ID-Alarm helps customers protect their digital identity and alerts them when stolen login data is found.

With our global data privacy organization, we are constantly working to provide a transparent and high level of data privacy in all our companies. As far as legally possible, the companies of the Deutsche Telekom Group have also committed themselves to the Binding Corporate Rules Privacy (BCRP), which are intended to ensure a uniformly high level of data privacy for our products and services. Violations of behavioral requirements, legal provisions, internal guidelines (such as the Binding Corporate Rules Privacy BCRP) and regulations can have serious consequences not only for individuals personally, but also for Deutsche Telekom. Therefore, on the basis of the Deutsche Telekom Code of Conduct, reproachable deliberate misconduct will not be tolerated. Deutsche Telekom sanctions such misconduct and violations consistently and without exception within the framework of the legal provisions, without taking into account the rank and position of the acting and affected person.

Machines and products are constantly becoming smarter. The technologies that make these developments possible are bundled under the term Internet of Things, or IoT.
IoT can help ideally coordinate the processes of various devices, vehicles, and entire industrial facilities. This increases industrial productivity and ensures efficient logistics, thus helping reduce energy consumption and conserve resources.
We also support the German federal government’s Industry 4.0 initiative through our involvement in IoT. The initiative’s objective is to maintain Germany’s competitive edge in the technology sector.

T-Systems has been developing and operating Daimler’s Connected Car platform (Daimler vehicle backend) worldwide since 2013. The platform is the technical basis for the Live Traffic service, which provides drivers with real-time traffic information, Live Traffic prevents about 30 percent of traffic jams per vehicle. This means the approximately 24 million vehicles equipped with Live Traffic consumed about 26 million liters less fuel. This translates into CO2 savings of around 65,000 metric tons.

DT does not tolerate any irregular behavior.

The case in SA is not new. We are dealing with it since 2017 and it has been the subject of several public reports in Germany and South Africa. Most recently in the German business weekly Wirtschaftswoche (2021) or in the “Welt” (2022).

The case has been consistently and thoroughly investigated by T-Systems South Africa. Two years ago, we divested ourselves of the South African business.

A state commission has examined the events in great detail. So far, it has not made any recommendation to investigate or prosecute the TSSA itself or individual TSSA employees.

As a matter of principle, we do not comment on ongoing proceedings; this also applies to those of the Frankfurt public prosecutor's office.

With the internal policy “Binding Corporate Rules Privacy (BCRP)”, the Deutsche Telekom Group is creating a standardized and high level of data privacy worldwide, applicable to the processing of personal data. Any breaches of rules, legal obligations, or of internal policies (like the Binding Corporate Rules Privacy BCRP) and regulations may have serious consequences not only for the individuals committing them, but also for Deutsche Telekom. Therefore based on the “Code of Conduct of Deutsche Telekom, deliberate misconduct will not be tolerated. Without any exception, Deutsche Telekom will severely sanction any such misconduct or violation against legal provisions. In doing so Deutsche Telekom will take no account of the employee’s rank or position within the company.

Every two years we conduct our employee survey in order to obtain feedback from our employees, discover weaknesses, and implement suitable actions to eliminate those weaknesses. The analysis on team level and of other criteria (e.g. function, executives vs. leader vs. employee, gender, age group) support the derivation of fitting concrete improvement actions on all levels. Around 80% of all employees participated in the last employee survey, the share of men and woman - where gender was specified - complies approximately with gender proportion in the group (participation rate man around 65%, women around 31% and diverse around 1%).

In addition to the employee survey, we also gauge employee satisfaction every six months through a pulse survey. This helps us obtain a current snapshot of the mood at the company and verify whether the introduced actions have been successful. This lets us make quick adjustments if necessary. The pulse survey in May 2021 saw a 77% response rate among the group.

How can international corporations put sustainability strategies into practice across borders? Deutsche Telekom employs CR managers for the relevant business segments and national companies to reach this goal. They use the CR Manager Network to regularly share best practices and discuss new challenges, thereby jointly promoting essential CR issues. The central Group Corporate Responsibility (GCR) department is responsible for managing the network. In the year 2021, the CR Manager Network encompassed more than 100 CR Manager from 34 subsidiaries based in 20 countries across the globe. 

The participants are regularly invited to virtual meetings and capacity building calls by Group Corporate Responsibility. In 2021, content and likely implications of the EU Green Deal were discussed as well as progress within the #GreenMagenta programs and the new strategic stream "Positive impact on society" defined by the EU segment. Furthermore, the network members could gain insights into issues like Impact measurement and the future of a greener mobility.

Stakeholder dialogues within Deutsche Telekom have to adhere to the “Guide to successful stakeholder management”: following the definition of the targets of the engagement (1) and the scope and boundaries for influence (2), relevant stakeholders are selected based on the assessment of their respective affectedness and influence (3) on the project/ issue in question. Basis of this selection is Deutsche Telekom’s stakeholder universe. Timing (4) and format (5) of the engagement have to be selected in accordance with the aforementioned targets, scopes and needs of the stakeholders affected. A check for risk and opportunity is integrated in each of these five steps. 

Every two years we conduct our employee survey in order to obatin feedback from our employees, discover weaknesses, and implement suitable actions to eliminate those weaknesses. The analysis on team level and of other criteria (e.g. function, executives vs. leader vs. employee, gender, age group) support the derivation of fitting concrete improvement actions on all levels. Around 76% of all employees participated in the last employee survey, the share of men and woman - where gender was specified - complies approximately with gender proportion in the group (participation rate man around 67%, women around 32% and for the first time diverse around 1%).

In addition to the employee survey, we also gauge employee satisfaction every six months through a pulse survey. This helps us obtain a current snapshot of the mood at the company and verify whether the introduced actions have been successful. This lets us make quick adjustments if necessary. The pulse survey in November 2020 saw a 77% response rate among the group.

We are helping shape the digital health care system with numerous pilot projects.
• We are involved as a project partner in developing a solution for antibiotic treatment consultation at the St. Georg Hospital in Leipzig. The primary goal is to enable fast, secure data exchange between doctors, patients, and health insurers. The State of Saxony sponsored the project with over 1.2 million euros at the beginning of 2017. It will initially run until mid-2019.
• The main objective of the “Psychological Trauma Telehealth Network for Saxony (Tele-NePS)” project is to sustainably improve the integrated treatment chain for post-traumatic stress disorders. The goal is to enable those affected to access the treatment network, make expertise universally available, and guarantee cross-institution documentation and coordination. The EU and the State of Saxony will be funding the project, which will run until 2020, with 1.4 million euros.
• Under the auspices of a 10-year partnership, we are helping Kliniken Essen-Mitte (KEM) to drive forward the digitalization of its hospitals. By January 1, 2019, we had replaced the existing hospital information system with our iMedOne solution at two of the clinic’s locations.

The Deutsche Telekom Group is subject to special statutory restrictions regarding donations to political parties and holders of offices due to the Federal Republic's stake in the company:

Donations to political parties

• The Deutsche Telekom Group is not permitted to make donations to political parties, as the government's stake in the Deutsche Telekom Group is currently over 25 %. The calculation of the government's stake includes both the stake held by the Federal Republic and the stake held by the Reconstruction Loan Corporation [KfW]. Donations for this purpose include both monetary payments and non-cash benefits.
• So-called genuine sponsoring does not represent a donation, i.e., a donation in return for a demonstrably adequate consideration. The consideration may, for example, be advertising for the company or its products at party conferences. The consideration must be adequate – i.e., at usual market level – in proportion to the benefit. Genuine sponsoring as part of party events does not represent a donation to the party as defined by the Political Parties Act and is thus generally permitted in the Deutsche Telekom Group.

Donations to holders of offices

• The Deutsche Telekom Group is also not permitted to make monetary donations to members of the Bundestag, where the government's (Federal Republic and Reconstruction Loan Corporation [KfW]) stake in the company is over 25 %. Non-cash benefits to members of the Bundestag are also generally not permitted.

Donations to holders of public offices

• Donations shall not be offered, promised or granted to holders of public offices for the performance of the duties of such offices or for specific actions performed while in such offices.

Measures must also be taken to ensure that the Deutsche Telekom Group only makes correct, politically unimpeachable donations in the political arena. Those acting on behalf of the Deutsche Telekom Group therefore observe the applicable legal framework conditions for donations and benefits in the political arena in Germany and abroad. In addition, the Deutsche Telekom Group has defined various additional procedures and processes that must be followed in connection with sponsoring party conventions, event invitations and the procedure in each individual case.

Sponsoring of party conventions

• The Deutsche Telekom Group is only permitted to sponsor a party convention by granting a political party a monetary payment or non-cash benefit if the donation is in return for a demonstrably adequate (i.e., at usual market level) and permitted consideration.
• The consideration may, for example, be that Deutsche Telekom is permitted to carry out valuable advertising activities and PR measures/ sales promotion at the party convention (presentation space, etc.).
• Inquiries regarding the sponsoring of party conventions must be treated in a uniform and politically balanced manner. This requires conduct that is coordinated throughout the Group in addition to the legal review of each individual case. The Deutsche Telekom Group does not support any extremist political parties.

Invitations to events

• Deutsche Telekom is only permitted to issue invitations to events that are subject to charge to political parties in the case of genuine sponsoring. The same applies to members of parliament unless these non-cash benefits are granted “for participation in events to present the position of the Bundestag or that of (one of) the parliamentary groups within the Bundestag“. Invitations to holders of domestic and foreign public offices, foreign members of parliament and holders of offices in international organizations should be refrained.

Information und decisions on individual cases

• Before donations are made in the political arena each individual case must be reviewed. Legal interpretation or issues of doubt (including those reaching beyond the legal aspects discussed above) should be submitted to DT Law & Integrity, and political issues of doubt to DT GPRA for a decision.