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Act responsibly. Enable sustainability.

Clear rules

Stefan works at Deutsche Telekom – and he loves soccer. The head of a supplier company invites him to the top game of the season, offering expensive VIP seats in a sold-out stadium. But Stefan declines and watches the game, as always, from his usual place among fellow fans.

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?

After all, Stefan works in Procurement – and he makes decisions about which companies get contracts from Deutsche Telekom. He adheres to strict rules in this context. When a business partner offers him soccer game tickets, he does not let himself be influenced and politely declines. This is because, much like sport, the business world has clear rules. The situation isn’t always so straightforward, though. What is prohibited and what is a permitted, friendly gesture among business partners? Is an invitation to dinner okay? How expensive can a birthday present be for an important customer? Many Deutsche Telekom employees face questions such as these in their day-to-day work. The Compliance Team is there to offer them advice and support. Compliance means adhering to rules, be they applicable laws or internal company guidelines and policies. And it’s not just about bribery and corruption, but also about protecting business secrets and avoiding conflicts of interest, for example.

Manuela Mackert, Chief Compliance Officer (CCO) at Deutsche Telekom AG

“There’s no harm in asking! We help clear up any doubt about what is and is not allowed in everyday working life. Staff can turn to the “Ask me!” portal if they have any questions or feel unsure. We need to be aware that it is not just a question of liability on the part of each individual. It’s also about our company’s reputation.” 

Earning trust

We do not view digital ethics as a mainstream trend or an aspect of marketing. Our company has a vested interest in ensuring our products and services are trustworthy. After all, customers will only buy and recommend our products and services if they trust them.

That trust does not come cheap – we must earn it anew each day. The basis for this is that everyone, whether Board member or employee on the shop floor, obeys the law and applicable rules.

How we ensure compliance

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


In 2016 we introduced our “Compliance-based Corporate Culture” initiative to prevent misconduct from happening in the first place. With this initiative, we offer all employees compliance training and online learning opportunities, for example, and thereby strengthen our compliance culture. Above and beyond this, our employees can take advantage of the “Ask me!” advice portal to get tips and help on the right way to act in uncertain situations.


Using our whistleblower portal “Tell me!”, anyone can report potential compliance violations anonymously. Tip-offs are treated as strictly confidential and reviewed 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 this, Deutsche Telekom has other policies that set out rules on specific issues, such as our “Group Policy on Accepting and Granting of Benefits”. Among other things, it clarifies whether and up to what value gifts may be accepted.

From Deutsche Telekom’s point of view, we also need to examine ethical issues that crop up in relation to digitalization. With regard to artificial intelligence (AI), for instance, the core challenge is to shape AI so that it is focused on people and guided by values, and thus improves people’s lives, safeguards their fundamental rights and autonomy, and can expand their scope for action. That is why we became one of the first companies in the world to establish binding rules in the form of our AI guidelines, which define how we at Deutsche Telekom use AI responsibly and develop our AI-based products and services.


In Germany alone, around 3,000 employees took part in “Speak Up!” training courses in 2019. Owing to the coronavirus pandemic, no “Speak Up!” sessions were held in 2020.

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? Writing down a code of conduct is not enough. This calls for a corporate culture involving an open, honest exchange of opinions in the sense of a speak-up culture – where employees know that they are taken seriously and can openly address grievances and delicate issues at any time. To encourage such open dialog, we offer our employees “Speak Up!” training courses as part of our Compliance-based Company Culture initiative. 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. The managers are also trained to be more receptive to reports from staff members about misconduct, to inquire further, and to systematically investigate the reports.