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  • 2019 Corporate Responsibility Report

Clear rules

Stefan works at Telekom - and he loves football. The manager of a supplier invites him to the top game of the season - expensive VIP seats in the sold-out stadium! But Stefan cancels - and follows the game as usual from his regular place in the fan curve.

Fighting corruption

Fighting corruption and promoting the rule of law – that is the main content of Sustainable Development Goal (SDG) 16 of the United Nations.

Am I allowed to do that?

Because Stefan works in Procurement – and he makes decisions about which companies get contracts from Deutsche Telekom. And he has strict guidelines he must adhere to. His decision cannot be influenced by a business partner offering him soccer tickets. Like in sport, clear rules apply in business life. The situation isn’t always that clear: What is prohibited – and what is a permitted, a friendly gesture among business partners? Is an invitation to dinner okay? How expensive may a birthday present be for an important customer? Many Deutsche Telekom employees face questions like these during their everyday work. The Compliance Team is there to offer them advice and support. Compliance – that means adhering to rules: applicable laws, but also internal company guidelines and policies. And it’s not just about bribery and corruption but also about protecting business secrets and avoiding conflicts of interests, for example.

Claudia Mackert, Chief Compliance Officer (CCO) Deutsche Telekom AG

“There’s no harm in asking! The Compliance Team helps resolve any doubts about what is and is not allowed in everyday working life. Not asking can damage trust in Deutsche Telekom and cost our company a great deal of money.”

Earning trust

When companies break laws and rules, they lose trust, their good reputation and their business success. In our industry, Deutsche Telekom is the brand that customers trust most – that’s according to the current “Reader’s Digest” study “Trusted Brands 2019”. That trust does not come cheap – we must earn it anew each day. The basis for this is that everyone, from the Board of Management to each individual employee, complies with applicable laws and rules.

How we ensure compliance

To ensure compliance, we follow an approach comprising three elements: prevention, identification and response.


To prevent misconduct from happening in the first place, we carry out compliance training for all employees and thus strengthen our compliance culture. And when doubts about proper conduct arise in specific job situations, our consultation service “Ask me!” will provide help.


Using our whistleblower portal “Tell me!”, anyone can report potential compliance violations anonymously. The tip-offs are treated as strictly confidential and investigated by specially trained employees.


We have clear rules on what is allowed and what isn’t. Misconduct is not tolerated We thoroughly investigate every tip-off. If a suspicion is confirmed, we initiate appropriate measures.

Our “constitution”

What conduct do we expect from our employees? We have outlined this in our Code of Conduct. It is something like the constitution for Deutsche Telekom. The Code of Conduct applies to everyone worldwide – whether Board member or employee. And because our responsibility does not end at our company gates, we also expect our suppliers and partners to observe the requirements stated in our Code of Conduct. In addition to the Code of Conduct, Deutsche Telekom has additional policies that define rules for specific topics: for instance, our “Group Policy on Accepting and Granting of Benefits”. Among other things, it clarifies whether and up to what value gifts may be accepted. As a telecommunications company, we must also deal with new ethical issues that arise due to technological progress. In 2018, we set up our own binding guidelines for the use of artificial intelligence (AI). To ensure that they are implemented in our everyday work, we also offer a special “Digital Ethics” training course and have introduced an internal seal to indicate ethically sound AI.


In Germany alone, some 3,000 employees attended Speak Up training courses by the end of 2019.

It all comes down
to the culture

It’s so easy to say: These are our rules – please follow them and observe proper conduct at all times. But how do we manage to always maintain that in everyday business? It’s not enough to write down rules of conduct: An appropriate corporate culture is needed. A corporate culture in which an open and honest exchange of opinions is lived in the sense of a speak-up culture – and where every employee knows that they are taken seriously and that they can openly address grievances and delicate issues at any time. To promote this, we launched the “Compliance-based Corporate Culture” initiative and have been offering our employees training courses under the motto “Speak Up!” for two years now. The course teaches them communication techniques to openly address problems. We also support our managers, for instance with special ethics training courses in which difficult business decisions are simulated and discussed. In addition, the managers are trained to be more receptive to reports from employees about misconduct, to inquire further and to fully investigate the reports.

Ethical excellence

Deutsche Telekom was named one of the world’s most ethical companies for the second time in 2019. The Ethisphere Institute analyzes and rates companies based on five criteria: ethics and compliance program, culture of ethics, corporate citizenship and responsibility, governance, and leadership and reputation. We are one of four honorees worldwide in the telecommunications services sector and the only German company to receive the award.