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Governance [1] July, 2023

Lobbying and Trade Associations - Climate Alignment

Public Affairs and TransparencyWe see ourselves as a dialog partner in an ever more complex digital world and are actively involved in political debat...

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.

Trade association Company involvement with association General description of association and climate position Alignment
B.A.U.M e.V. Membership Association of companies in Germany, committed to environmental oriented management and behaviour. The network is engaged in: (1) awareness raising on problems and chances of environmental protection and questions on sustainable development within companies, institutions, politics, and population in Germany, (2) the distribution and further development of an integrated system of preventative ecological oriented management, and (3) the introduction of methods and measurements on environmental management and sustainable development. B.A.U.M. also launched the "Wirtschaft pro Klima" initiative. Aligned
BDI - Bundesverband der Deutschen Industrie e. V. Member of the Executive Committee,
Timotheus Höttges, CEO, Deutsche Telekom AG
In the last years the BDI position advanced with respect to the general support for climate regulations and the EU Green Deal. Due to the heterogeneity regarding industries, there are sometimes differences with respect to regulatory details, e.g. regarding timelines and exceptions.  Despite the progress made, we are still not fully aligned with the BDI position with respect to speed and ambition level of climate change mitigation activities. Partially aligned
Bitkom e.V.

Member of the Executive Committee and Vice-President,
Michael Hagsphil, SVP Global Strategic Projects and Marketing Partnerships, Deutsche Telekom AG

Generally, Bitkom is supporting climate related positions, especially with respect to the enabling role of digital technologies and solutions, but as Bitkom is dominated by production companies, the interests, e.g. with respect to extension of product lifetimes are sometimes different from the interest of telecommunication service providers as DT. Partially aligned
econsense - Forum Nachhaltige Entwicklung der Deutschen Wirtschaft e.V. Membership Econsense is the sustainability network of German business. The goal of the organisation is to actively shape the transformation to a more sustainable economy and society with its members. Econsense is associated with the BDI (Bundesverband der Deutschen Industrie) but formally independent and based on voluntary membership.  Aligned
ETNO - European Telecommunications Network Operators’ Association Member of the Executive Board,
Jakob Greiner, VP European Affairs, Deutsche Telekom AG
ETNO is an industry association of fixed net telecommunication providers in Europe. ETNO is currently developing a sustainability strategy with strong focus on climate protection and the impacts of telecommunications on climate to address EU political organizations, as mainly the EU Commission. ETNO is involved in various EU policy consultations with respect to "Fit for 55", circular economy and EU taxonomy. Aligned
European Green Digital Coalition Membership

The European Green Digital Coalition (EGDC) was formed by 26 CEOs of ICT companies (including Deutsche Telekom) who signed a Declaration to support the Green and Digital Transformation of the EU on Digital Day 2021. The Declaration builds on the EU Council conclusions of December 2020 on Digitalisation for the benefit of the environment and recognises the ICT sector as a key player in the fight against climate change. With the signature of the Declaration, the 26 CEOs formed the EGDC, committing on behalf of their companies to take action in the following areas:
(1) investing in the development and deployment of green digital solutions with significant energy and material efficiency that achieve a net positive impact in a wide range of sectors;
(2) developing methods and tools to measure the net impact of green digital technologies on the environment and climate by joining forces with NGOs and relevant expert organisations;
(3) co-creating, with representatives of others sectors, recommendations and guidelines for green digital transformation of these sectors that benefits environment, society and economy.

Aligned
GeSI - Global Enabling Sustainability Initiative Member of the Board / Vice-Chair,
Melanie Kubin-Hardewig, VP Group Sustainability Management, Deutsche Telekom AG
GeSI aims to fulfil four major objectives: 1) Raise awareness of ICTs and related technologies’ role in addressing the causes and effects of climate change; 2) Showcase innovative initiatives being undertaken by the ICT sector in the interests of environmental sustainability, and promote the exchange of best practices between the public and private sectors; 3) Mobilize political will to better reflect the role of ICTs in the outcomes produced by the major conferences on climate change and sustainable development; 4) Encourage governments to include ICTs and related technologies as key elements of their national climate change policies, across all industry sectors. Bolstering collaboration on these main objectives, GeSI seeks to synergize the messages being expressed by actors in the ICT field; the message that ICTs can enable low-carbon economies, and that 21st century governments, regulators and businesses cannot afford to exclude ICTs from policy or business initiatives to green our global economy. GeSI communicates with policymakers and key stakeholders to explain the significant contribution that ICT can play in addressing climate change globally and facilitating low-carbon development. GeSI wants the contribution of ICT to be recognised and integrated in government policies to achieve sustainability goals – at national, regional, and global level. Our role is to inform policymakers about ICT and climate change, to drive the sustainability debate and participate in joint initiatives. Additionally, GeSI drives the implementation of TCFD and Science Based Targets within the ICT industry. In 2021 GeSI officially launched the "Digital with Purpose" movement to drive the industry more sustainable. Aligned
Global Compact Caring for Climate Membership Launched by the UN Secretary-General Ban Ki-moon in 2007, "Caring for Climate" is the UN Global Compact and UN Environment Programme's initiative aimed at advancing the role of business in addressing climate change. It provides a framework for business leaders to advance practical solutions and help shape public policy as well as public attitudes. Chief executive officers who support the statement are prepared to set goals, develop and expand strategies and practices, and to publicly disclose emissions. Aligned
GSMA – GSM Association

Member of the Board,
Dominique Leroy,Board Member for Europe, Deutsche Telekom AG

The GSMA is committed to:
• achieving carbon neutrality for all operations year on year (Scope 1, 2 and 3)
• a carbon emission reduction target for scope 1 and scope 2 emissions in line with the 1.5ºC trajectory and for scope 3 in line with the “well below 2ºC” trajectory, following a science based approach, using a baseline year of 2019
• achieving net zero emissions by 2050
• disclosing emissions, targets and progress year on year
https://www.gsma.com/aboutus/who-we-are/sustainability/ [2]

Aligned
International Chamber of Commerce (ICC) Membership ICC is the only accredited global business organization at the UN. With the "Green Economy Roadmap" ICC emphasises the responsibility of business and companies for a sustainable development according to the Rio Convention of the UN. ICC is especially supporting climate protection activities such as regularly attending COP side events. Due to the heterogeneity of ICC the position is not always as ambitious as the DT climate protection policy & targets. Partially aligned

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