Aspect: Anti-corruption

The following risks of corruption were identified as the most likely within the scope of the risk analysis:

  1. Favoring an employee or business partner’s employee or agent in terms of a specific future business decision resulting in unfair favoritism in competition.
  2. Employee formulates selection criteria in favor of a supplier/consultant so that the buyer does not have a choice. Employee influences an auction/bid in favor of a bidder and receives a benefit in return.
  3. Acceptance of a benefit aimed at securing a specific business decision.
  4. Employee/buyer agrees terms to the disadvantage of the company when awarding contracts for services. In return, he/she receives money or other benefits from the contractor/consultant.
  5. Granting a benefit to a public sector employee in order to cause him/her to act in a specific way.

Each year, we carry out a Group-wide compliance risk assessment (CRA) to determine compliance risks and develop tailored compliance measures. 94 Group companies conducted the CRA within a period of two years. In 2013, the CRA included 81 companies and thus covered around 95 percent (based on the number of employees).

Classroom training sessions were conducted on anti-corruption in 2012/2013. All members of the Group Board of Management and the first reporting level attended the training. We also conducted risk-specific classroom training sessions at the IT, Sales, Procurement, Services, Production, Technical Services, Marketing, Technology and Finance departments. More than 3,400 employees attended the training. Members of the Managing Boards and members of risk groups were trained internationally (3,800 participants). Almost 16,000 employees participated in an e-learning offer in Germany. This e-learning offer was rolled out at 26 companies internationally. Additional topic and risk-specific trainings were conducted in 2014. In the Delivery unit at T-Systems International, for example,1,221 employees in Germany and 1,120 employees internationally attended 72 classroom training sessions.

Business partners: Our business partners are required to accept the Deutsche Telekom General Terms and Conditions for Purchasing before entering into a business relationship with us. These include an anti-corruption clause. In addition, we ask our business partners questions regarding their compliance management systems as part of supplier self-assessment. Deutsche Telekom has been offering compliance training to external business partners and suppliers since September 2014. The training offer particularly focuses on small and medium-sized German business partners and suppliers. With classroom training offers and an online training program, Deutsche Telekom encourages its partners to conduct their business ethically and in compliance with relevant laws and regulations. The training addresses specific compliance-relevant topics such as corruption prevention, antitrust law and sustainability and introduces Deutsche Telekom’s compliance management system.

Deutsche Telekom engages in extensive compliance management activities to prevent and fight corruption Any violations we uncover during our investigation are punished appropriately. In some cases employment relationships have even been terminated for good cause. The total number of punished cases of corruption is confidential.

Aspect: Public policy

It is of paramount concern to Deutsche Telekom that its relationships with political decision-makers should be characterized by transparency and trust. This also extends to our refusal to support the work of any political party with donations.

Aspect: Anti-competitive behavior

Aspect: Compliance

Aspect: Grievance mechanisms for impacts on society

We do not currently have information regarding the percentage of new suppliers that have been evaluated based on sustainability criteria (e.g., though voluntary information, the EcoVadis platform or social audits). This information will be available once the supplier portal has been introduced throughout the Group. Rollout is scheduled to be completed by the end of 2016. The general requirement for any supplier relationship is passing a pre-qualification process, which includes 16 questions regarding sustainability.