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  • 2018 Corporate Responsibility Report

Preventing and fighting corruption

We take many different actions and measures to prevent and fight corruption. The compliance risk assessment forms the foundation of our compliance management system. It helps us identify and evaluate compliance risks and develop appropriate preventive measures. We have established an annual process for this purpose Group-wide. It identifies responsible officers and defines clear assessment criteria that are documented in a traceable manner. The companies that will take part in the compliance risk assessment are selected using a model centered on how developed and complete their compliance programs are. 72 companies participated in the assessment process in 2018. It thus covered just under 98 percent of employees.

Our Group risk map is a key component of the compliance risk assessment that we use to assess risks that are particularly significant to our company. The risk map enables Deutsche Telekom's companies with their various business models to conduct systematic risk analyses. It currently covers 27 core risk categories ranging from corruption and anti-trust law violations to violations of the Group Code of Conduct. Each national company can add additional categories specific to their business needs. This involves defining which specific threat each risk poses to the national company and stating which measures have already been implemented to mitigate this risk. If necessary, additional measures are developed to reduce the risks to a manageable level. Responsibility for conducting the compliance risk assessment lies with the respective national company. Our central compliance organization provides support and advice in these matters.

The national companies' managing boards are informed of the results of the compliance risk assessment. Subsequently, the compliance program for the following year is defined, including specific measures and responsibilities. The managing board then passes a formal resolution to approve the program. The compliance program measures are monitored closely.

Investigation of suspected corruption based on clear criteria
Deutsche Telekom has specified clear criteria for investigating suspected cases of corruption. We start investigations if a violation of legal or internal regulations is reported with a sufficient degree of detail. Any tips that meet this requirement are investigated thoroughly. Any violations we uncover are punished appropriately. In some cases employment relationships have even been terminated for good cause. Claims for damages may also be asserted. Any weaknesses identified in the internal control system during the investigation are systematically analyzed and remedied.