We have clearly expressed our commitment to complying with ethical principles and current legal standards. This commitment has been incorporated in our Guiding Principles and Code of Conduct. We have put in place a compliance management system to anchor lawful and ethical conduct in all areas of the Group. The specific purpose of this system is to ensure compliance risks are successfully tackled and make sure rules and regulations are followed throughout the entire Group.
Responsibility for the compliance management system lies with top management. There is also a management position for compliance in every company of Deutsche Telekom. The Group-wide design, development, and implementation of the compliance management system falls under the remit of the Chief Compliance Officer of Deutsche Telekom AG and the Group Compliance Management unit she runs. We also have dedicated compliance officers (COs) at each of our operating segments and national companies. It is their job to ensure the compliance management system and our compliance goals are implemented on site.
At Deutsche Telekom, compliance means following the rules and always doing the right thing. Within the meaning of our five Guiding Principles and Code of Conduct, integrity – which necessarily encompasses compliance – forms the basis of all our business decisions and activities. It defines the behavior of all our employees when dealing with customers, employees and colleagues, investors, managers, and Deutsche Telekom’s general environment.
We have derived the following objectives for our compliance work:
In 2018, we once again had our compliance management system certified with a focus on anti-corruption measures. This is our way of ensuring that we can confront risks consistently and that we have established effective processes in the company. Since 2016 25 international companies have been were certified.
The certification focused on processes in Procurement, Sales, HR, and Mergers & Acquisitions, on the one hand, and on events, donations, and sponsorships on the other. The potential danger of corruption is greatest in these areas. Auditors investigated the efficacy of the compliance management system and verified it without any reservations. We document details regarding audit content and corporate departments that have undergone anti-corruption audits in our audit report.
If we are going to be successful in preventing and countering legal infractions and regulatory breaches, then we need to adopt the correct approach to assessing compliance risks. That is why our compliance management system is centered around an annual compliance risk assessment. To help us carry this out, we have put in place a Group-wide compliance management process, allocated responsibilities, and defined assessment criteria. The individual steps in the compliance risk assessment, all of which are documented transparently, are as follows:
Integrity, respect, and compliance with the law – these are the principles on which Deutsche Telekom’s business activities are based. Our Code of Conduct is the central reference framework for completely lawful and ethical conduct. It makes a significant contribution to our business success by providing a solid foundation for our business activities.
We aim to ensure the conduct of our employees in their day-to-day work is always ethical and lawful, which is why we implement the following measures across the entire Group:
We always investigate tip-offs about a breach of statutory or internal regulations when there is a sufficiently tangible description of the matter at hand. Among other things, we run a whistleblower portal called “Tell me!” as a means of accepting tip-offs.
Deutsche Telekom is party to proceedings both in and out of court with government agencies, competitors, and other parties. We have reported on what Deutsche Telekom views as key processes in the 2019 annual report.
We have created the “Tell me!” whistleblower portal to uncover non-compliance. Both our employees and external parties such as business partners and customers can use the portal to report misconduct – and can do so anonymously. We have introduced a Group-wide reporting process to control and monitor these activities.
In 2019, 122 compliance-related reports were made to Deutsche Telekom via the “Tell me!” portal (137 reports were made in the previous year). 27 of those are still being reviewed for plausibility and investigations are being made into 60 plausible reports (as of December 31, 2019). A total of 38 were confirmed as actual misconduct and were prosecuted accordingly. 13 cases are currently still being investigated.
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Hints: Most of the reports submitted in 2019 were related to fraud, breach of trust, embezzlement, theft, target manipulation and unfair sales practices. Tipp-offs reported to portals in a business unit are only counted for the central Tell me! portal if Group relevant.
In 2016 we started the Compliance-based Corporate Culture initiative with the intention of encouraging integrity and a constructive speak-up culture within our company. Based on an employee survey in the following year, a comprehensive set of measures was put together and then rolled out in 2018 and 2019.
In 2019, as part of the Compliance-based Company Culture initiative, we conducted our second ever international employee survey on compliance. The aim was to reassess how our compliance culture had developed since the last survey was conducted in 2017. The European School of Management and Technology (ESMT Berlin) and Hertie School of Governance were our research partners for the first, extensive study. Some 46,000 Deutsche Telekom employees took part in the latest survey – more than participated in the first. The initiative is supported by an expert committee created specifically for this purpose. The committee is comprised of Deutsche Telekom employees as well as representatives from non-governmental organizations, the business and scientific communities, and society.
The results have improved compared to 2017.
The weaknesses identified were the subject of intensive discussion on the Board of Management and a set of measures was developed to address them. The aim of these measures is to further reinforce the values-based compliance culture in the Group and carry forward the current, overwhelmingly positive trend. One of the measures was the introduction of the “Managing Dilemmas” virtual reality program. The aim behind this program is to make it easier for staff to identify critical situations and adopt the correct approach in these scenarios. A “speak-up culture” is also being promoted with measures such as the launch of a new e-learning program.
Different legal practices and cultural values in the countries where Deutsche Telekom is active represent a significant challenge for compliance. The increasingly dynamic development of global markets and intensified international competition also influence our compliance strategy.
In line with the Group’s international orientation, we discuss strategic issues with an international compliance advisory team twice a year. The team is a trend-setter of sorts for designing and implementing balanced compliance structures at Deutsche Telekom. We also promote Group-wide compliance cooperation through meetings of the representatives of all compliance organizations from our international subsidiaries.
We are working with other parties in national and international organizations and professional circles, which involves discussing compliance issues, among other things. We also actively contribute to the ongoing development of compliance, for example by giving specialist presentations and releasing publications.
Deutsche Telekom AG regularly contributes to national and international organizations that focus primarily on compliance issues. As a member of associations and organizations such as the Compliance & Integrity forum of ZfW (Center for Business Ethics) and BITKOM (Federal Association for Information Technology, Telecommunications, and New Media), we make use of the opportunity to exchange ideas and experiences related to compliance.
In 2018, with Group Compliance Management taking the lead, we introduced guiding principles for the ethical use of artificial intelligence (AI). These principles clarify how we at Deutsche Telekom aim to use AI responsibly and develop our AI-based products and services in the future. We do not claim that these guidelines constitute universally applicable rules on the responsible use of AI. Instead, we aim to continuously develop these guidelines in partnership with our employees and external stakeholders, anchoring them in our company.
In 2019, we carried out activities such as training and workshops on implementing the guidelines, held a conference on digital ethics, provided employees with comprehensive information through a range of formats, integrated the AI guidelines into contract-relevant provisions for our suppliers, and developed an internal test seal for ethical AI products. AI applications that satisfy our high standards carry the seal.