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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

Deutsche Telekom annually reports to the CDP questionnaires 'Climate Change' and 'Supply Chain Program'. CDP, formerly the Carbon Disclosure Project, runs a global disclosure system that enables companies, cities, states and regions to measure and manage their environmental impacts.
In 2022, we once again made it onto the “A List” of CDP’s most important international climate protection ranking – one of just 288 companies worldwide to do so out of more than 15 000 that were scored.

We’re working closely together with our suppliers to reduce our carbon footprint during the manufacturing and usage phases of our products, too. For the fifth time, CDP has awarded us the title of “Supplier Engagement Leader” in recognition of our achievements. Out of 18 600 participating companies, more than 650 made it onto the Supplier Engagement Leaderboard.

Our annual reporting on Deutsche Telekom`s climate performance through CDP's global disclosure system:
2022 CDP Climate Change Response
2023 CDP Climate Change Response

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

2019: 51%
2020: 66%
2021: 51%
2022: 33%

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 19.7% in 2022. 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 over 31,000 employees in the Group in 2022, which is around 22% of the workforce. A significant increase in this number is planned for 2023 and 2024.

For around two decades, we have been identifying the issues relevant to the orientation of our sustainability strategy and our reporting on the basis of a materiality process which we continuously develop and review annually to ensure it is up to date. Decisive for the further development in 2022 were changed requirements of the GRI Standards 2021 as well as the requirements of the EU Corporate Sustainability Reporting Directive (CSRD), which will become relevant for our reporting from the reporting year 2024. In accordance with the CSRD requirements, the topics were assessed according to the principle of double materiality.
In the course of a document analysis, all topics along the value chain were analyzed on the basis of sources such as studies, research results or internal guidelines and measures - and thus the perspective of external stakeholders was included.

The following shows how the integration of regulatory requirements from the CSRD affected the materiality analysis.

The initial situation: Material topics according to materiality analysis 2021

An overview of which sustainability topics from the 2021 materiality analysis are also relevant from the perspective of regulatory requirements according to CSRD is presented in the materiality matrix. In the materiality matrix, the material topics are prioritized according to the level of their impact on Telekom and their impact on society.

As a result of our focus on the ESRS standards, the following topics from our prior materiality analyses will no longer be considered as independent topics in the new materiality analysis:

• Network expansion
• ICT solutions that contribute to climate protection
• Limiting the effects of climate change
• Data security
• Supply chain labor standards
• Socially relevant applications of ICT products and services
• Media literacy
• Transparency and reporting
• Service quality
• Disruptive technologies

These topics have been integrated in the new topics (see figure below). For example, “ICT solutions that contribute to climate protection” have a positive impact on the topics “Energy consumption and mix” and “Greenhouse gas emissions.” The topic “Network expansion” is a focus of the value creation stages “Networks and data centers” and was consequently taken into account in all topics. As a result, the topic of network expansion is essential over individual topics, for example, in "Greenhouse gas emissions".

Responsibility within the Group for the materiality analysis and external audit
The materiality analysis is part of our non-financial statement and has thus been subjected to a limited assurance engagement by an external auditing firm. The Company's management is responsible for the preparation of the non-financial statement in accordance with §§ 289c to 289e, 315c in conjunction with 289c to 289e HGB. The Board of Directors is thus the highest body that signed-off the materiality analysis (see “Independent assurance report Non-financial Reporting”, CR report 2022, page 188).

ESG targets are part of the remuneration of all executives (ex US) and non-tariff employees and have been part of the Long-Term and Short-Term Incentive for our Board members for some years.
We started to integrate ESG steering into our financial steering and planning processes. As well, ensuring a holistic management system for compliance and risk management based on legal requirements is an important governance aspect in the ESG framework.

With our WeGrow, DTs modern performance management system that enables ongoing development dialog between managers and employees (incl. civil servants), also focuses on our employees’ personal development.

A dialogue between manager and employee takes place at least twice a year in order to create clarity about current and foreseeable future work tasks of the current year as well as expected results (in terms of time and quality) and goals.
Employee's strengths and development needs are be discussed and and a comitment on appropriate measures will be agreed. The employee's desired direction of development can also be considered and discussed. All agreed measures will be put into a development plan or/a goal plan.

For annual assessment and target management are DT´s guiding principles the main categories for adequate behaviour of the staff (employees and managers). The guiding principle "Act with respect and integrity" contains the narrative that "Respect and integrity are key to our success and our compliance commitment. We foster ethical awareness and strengthen value-based behavior to act appropriately in any situation. We embrace responsibility as part of our society and speak up on important issues such as tolerance, diversity, fairness and environment."

The Values Based Competency assessment and the performance assessment is based on the Group Competence Model.
It uses a 4-level assessment scale and follows guiding questions. (For Executives the Leadership anchors need to be considered).
Guiding questions for Value Based Competency:

• He / she is strong in collaboration (e.g. across silos).
• He / she accepts and gives constructive feedback and actively requests it.
• He / she is strong in communication.
• He / she acts with respect and integrity.
• He / she promotes diversity and inclusion

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 2022 => 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

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.  

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 10 years and over 2000 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)
• 2,7 % 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.

Emerging risks are difficult to predict as their development is highly uncertain. They are external risks occurring beyond our influence or control such as natural factors, geopolitical tensions, new technologies, or macroeconomic factors. These risks are newly identified risks expected to have long-term impact on our business (at least three to five years). Although they may have already affected our business today, their importance is expected to significantly increase and they can potentially and significantly be harmful to a large part of our operations.

In order to protect our company and our customers against such risks, we need to act early and effectively to identify and assess such risks and if necessary, adapt our strategy and/or business models to reduce their effects. The tasks of our risk management system, which systematically identifies these emerging risks, evaluates their potential impact on our company and derives mitigation measures to respond to such emerging risks for Deutsche Telekom (DTAG) in a comprehensive way.

The following most significant emerging risks are expected to have long term impact on DTAG:

Technological Risk - Cyberattacks

Cyberattacks are an external and rapidly growing risk. As the speed of digital transformation, machine learning and computing power will grow exponentially, the methods of attack are becoming more specialized and efficient and are outpacing improvements in security. Thus, this development eventually leaves more available points of vulnerability in our business that can be impacted by such attacks. Therefore, the importance of the risk of cyberattacks is significantly increasing to us.
The impact is significant and specific to our company:

• the need for more sophisticated infrastructure in order to prevent autonomous and artificial intelligence supported cyberattacks requires shifts in business strategy and further investments
• compliance of any increasing legal requirements for data storage and protection may impact our business strategy and investments
• the gap between existing and expected employee skills in cybersecurity may affect business progress
• new extortion techniques becoming more common in attacks, such as cryptocurrency payouts, leading to financial losses
• reputation effects: our customer bases decreases because they may lose trust in the quality of our communication services.

Our mitigation measures include:

• upgrading to more-robust IT-control environments
• enhancing protection against common attack types
• using machine-learning techniques (artificial intelligence) for the detection of network penetration
• response improvement for warding off detected attacks
• raising customer awareness about cyberattacks
• providing better malware detection and improving user authentication techniques.

Environmental Risk - Extreme Weather

The ongoing climate change is expected to accelerate the intensity and frequency of extreme weather conditions, such as flooding and droughts that negatively affect our operations. The climate change impact is difficult to predict as its mitigation requires global efforts.
The impact is significant and specific to our company:

• disruption of network and infrastructure due to
  - damage to our base station sites, network nodes or other infrastructure
  - damage to data centers, radio towers, office buildings and our sales stores
  - reduction of stability of our power supplies
• longer network outages
  - eventually affect management of restoring operations, which may fall back to Deutsche Telekom and damage our reputation
  - lead to customer complaints and in long-term decreasing customer satisfaction and reduced revenues
• additional investments will be necessary to modify our processes, harden our infrastructure and repair damages
• the cost for insurance coverage for such events is expected to steadily increase over time and could also result in substantial property and liability losses.

Our mitigation measures include:

• improving methods of predicting when and where possible future disasters could occur including scenario analyses and physical risk assessment
• identifying weaknesses in our radio towers and other infrastructure
• implementation of a business continuity management including improving business-continuity and disaster-recovery plans for scenarios where such failure events could occur
• installing backup power to all critical network elements in order to avoid network outages or reduce downtime
• modernization of network to be better protected from storm conditions, changes in temperature, and high winds.
• regular assessments to ensure sophistication and resilience of infrastructure facilities.

Economic Risk - Infectious Diseases
We cannot predict the outbreak of a pandemic. However, historical data shows that over the past few decades regional and global pandemics occur more frequently over time. A new disease or virus can quickly spread, become a pandemic, and drastically hamper global economic growth. It can affect multiple industries and global supply chains, and it can have a major impact on the ways in which we live and work.
The impact is significant and specific to our company by:

• increasing delays from our suppliers, payment delays and defaults from our business customers and consumers; thereby increasing our level of bad debt
• related restrictions on public life could force our stores to close and affect or sales and services to customers. customer growth could be dampened as it becomes difficult to acquire new customers
• related travel restrictions could reduce our roaming-traffic volume and revenues
• social contact restrictions leading to home-schooling and working from home could overload our networks and reduce its efficiency; at the same time our employees face higher stress levels; due to working from home companies could see a need to reduce their orders of IT services and equipment
• in the case of a severe pandemic restrictions could temporarily or permanently reduce our workforce.

Our mitigation measures include:

• monitoring relevant developments by our Group Situation Center enabling crisis management and task forces
• issuing pandemic guidelines
• provides suitable hygiene and health & safety equipment for sales stores, offices and our network infrastructure locations
• ramping up and stabilizing our networks to accompany additional peak loads of voice and data traffic
• protecting our customers and employees by allowing remote working
• focus on online sales and customer service.

Sensitivity analyses are conducted in our annual impairment tests, on Deutsche Telekom assets, on changes in interest and currency rates, on the increase of benefit obligations (salary and pension rates), on cash flows and on goodwill, intangible assets, inflation effects and energy effects and on climate change. Stress Testing is conducted within Group Controlling as part of our scenario analysis for various current topics, which also consider the risk assessment methodology and risk containment. In our annual report 2022 see details (page 152) how we consider climate risks & other sustainability risks in our risk management process.

As there is currently no comprehensive definition of lobbying expenses, we are guided by the applicable transparency requirements and publish the lobbying expenses
in Germany at federal level (in accordance with the “Act Introducing a Lobbying Register for the Representation of Special Interests vis-à vis the German Bundestag and the Federal Government [Lobbying Register Act – Lobbyregistergesetz”] -> https://www.bundestag.de/resource/blob/870452/41e5c2f593b16c960d86c0041a377862/Gesetz-EN-neu-data.pdf) and in the federal states of Baden-Württemberg and Bavaria (according to the Transparency Register Act [TReg]in Baden-Württemberg -> https://www.landtag-bw.de/files/live/sites/LTBW/files/dokumente/WP16/Drucksachen/9000/16_9883_D.pdf and the Bavarian Lobby Register Act [BayLobbyRG] -> https://www.gesetze-bayern.de/Content/Document/BayLobbyRG/true), in Brussels (in accordance with the "Agreement between the European Parliament and the European Commission on the transparency register for organizations and self-employed individuals engaged in EU policy-making and policy implementation" -> https://eur-lex.europa.eu/legal-content/de/TXT/?uri=uriserv:OJ.L_.2014.277.01.0011.01.ENG ) and in Washington for T-Mobile USA (in accordance with the "Lobbying Disclosure Act [LDA]" -> https://lobbyingdisclosure.house.gov/ldaguidance.pdf ).

We are guided by the principle of respecting the independence and integrity of our political interlocutors. For this reason, we welcomed the creation of the lobbying and transparency registers at European level and in Germany from the outset and accordingly registered as one of the first companies (EU) or on time (on February 28th, 2022 in Germany).

Lobbying expenditures 2022 in accordance with applicable transparency rules

 [1] https://www.lobbyregister.bundestag.de/suche/R002346/7991?backUrl=%2Fsuche%3Fq%3D%2522Deutsche%2BTelekom%2BAG%2522%26page%3D1%26pageSize%3D10%26sort%3DREGISTRATION_DESC

[2] https://www.landtag-bw.de/home/der-landtag/transparenzregister/eintrage/d/deutsche-telekom-ag.html
[3] https://www.bayern.landtag.de/typo3temp/assets/lobbyregister/DEBYLT027F.pdf
[4] https://ec.europa.eu/transparencyregister/public/consultation/displaylobbyist.do?id=60052162589-72&locale=en#en
[5] https://lda.senate.gov/filings/public/filing/search/?registrant=T-Mobile&registrant_country=&registrant_ppb_country=&client=&client_state=&client_country=&client_ppb_country=&lobbyist=&lobbyist_covered_position=&lobbyist_conviction_disclosure=&lobbyist_conviction_date_range_from=&lobbyist_conviction_date_range_to=&report_period=&report_year=2021&report_dt_posted_from=&report_dt_posted_to=&report_amount_reported_min=&report_amount_reported_max=&report_filing_uuid=&report_house_doc_id=&report_issue_area_description=&affiliated_organization=&affiliated_organization_country=&foreign_entity=&foreign_entity_country=&foreign_entity_ppb_country=&foreign_entity_ownership_percentage_min=&foreign_entity_ownership_percentage_max=&search=search#js_searchFormTitle
[6] https://www.bundestag.de/resource/blob/870452/41e5c2f593b16c960d86c0041a377862/Gesetz-EN-neu-data.pdf
[7] https://www.landtag-bw.de/files/live/sites/LTBW/files/dokumente/WP16/Drucksachen/9000/16_9883_D.pdf
[8] https://www.gesetze-bayern.de/Content/Document/BayLobbyRG/true
[9] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021Q0611%2801%29
[10] https://lobbyingdisclosure.house.gov/ldaguidance.pdf
*) The various disclosures are not directly comparable with each other, as they refer to the legal requirements applicable in each case. If lobbying expenses are to be specified in a range according to the specifications of the respective register, the upper value of the range is given.

Trade associations are the cornerstone of our public relations activities. Deutsche Telekom does not make any donations to political organizations, political parties, or elected officials on principle.

* Total amount according to the individual amounts reported in the lobby/transparency registers of Germany (federal level, Baden-Württemberg, Bavaria / each since 2021), EU (Brussels) and USA (Washington / since 2020) - see also https://www.cr-report.telekom.com/crwissen/transparency-disclosures-lobbying-expenditures.
** DT does not make any donations to political organizations, political parties, or elected officials on principle – see also https://www.telekom.com/en/company/topic-specials/special-public-and-regulatory-affairs/detail/public-affairs-and-transparency-611136.
*** Trade associations are the cornerstone of the public relations activities by DT. The numbers listed above mean "LESS THAN 5 Mio. EUR per year" (value may vary slightly year-on-year; this is the maximum of an approximate value) – see also https://www.cr-report.telekom.com/2022/management-facts/strategy/political-advocacy#atn-19548-19551.

We keep our goal of reducing our carbon footprint in mind when planning and operating our data centers. To achieve this goal, we take a two-step approach. It starts with optimizing energy consumption at each data center site and then continues with improving processes throughout the global data center landscape.

Our aim is to increase the share of renewable energy on a yearly basis. Therefore our reported target is to increase our share in comparison to the previous year.

As a large corporation, Telekom assumes responsibility for environmental protection. Uniform environmental standards ensure that resource-saving behavior is anchored in all processes and in the daily behavior of employees. To this end, the Group has implemented an HSE (Health, Safety and Environment) management system in all fully consolidated companies.
There are internationally recognized standards for environmental protection in companies, such as the ISO standards (standards of the International Organization for Standardization, ISO for short). These form the basis for environmental management at Telekom. This ensures that environmental policy is implemented uniformly throughout the Group.

Telekom in Germany has been working in accordance with the international standard ISO 14001 for environmental management systems since 1998. Compliance with the ISO standard enables, among other things, resources to be used more efficiently, energy to be saved and waste to be avoided. Employees help to further increase environmental friendliness with their own suggestions.

Telekom's commitment goes far beyond the issue of climate protection: Since 2010, a uniform Group-wide HSE management system has been in place. HSE stands for the three main topics of health, safety and environment. The international standards for occupational health and safety, environmental management and quality management serve as the basis for this.
Employees and experts from all Deutsche Telekom national companies regularly exchange information and jointly develop a comprehensive management system. Internal and external audits are conducted regularly to verify that the requirements of the HSE management system are consistently implemented in the company's day-to-day operations.

Here you can find the manual for our central Health, Safety and Environment Management System (HSE MS) of Deutsche Telekom Group. This means that it covers 100% of all Deutsche Telekom units.