Here you can find KPIs for Deutsche Telekom's central compliance measures.
Our compliance culture is an essential part for corporate governance geared towards integrity and appreciation. We are committed to ethical principles as well as to the law throughout the Group. We have anchored this in our guidelines and our Code of Conduct. We also provide further compliance information in the Annual Report and the Corporate Responsibility Report.
Prevent
Corruption violates national and international law. We reject all forms of corruption – both bribery as active corruption and corruption as passive corruption – in the public and private sectors. Our compliance management system (CMS) is therefore particularly geared towards preventing corruption.
We have implemented a compliance management system with the aim of minimizing risks from systematic violations of legal or ethical standards that could lead to regulatory or criminal liability of the company, its board members or employees or to significant reputational damage. The Executive Board assumes its overall responsibility for compliance as a key management task. Our Chief Compliance Officer is responsible for the design and management of the compliance management system. At the level of our operating segments and national companies, compliance officers implement the compliance management system and our compliance targets locally.
The Compliance Risk Assessment (CRA) is one basis of our compliance management system. It enables us to identify and assess compliance risks and initiate appropriate preventive measures. For this purpose, we have set up a process that has to be run through regularly. The companies participating in the CRA are selected according to a maturity-oriented model, depending on governance.
In 2023, the previous CRA methodology was changed and a "Focus CRA" was carried out. The Focus CRA is a further development of the existing CRA approach. The aim of the new approach is to review the effectiveness of the control environment in selected compliance risk areas. The approach was piloted in 2023. The focus was on our purchasing processes. 10 international (EU and TSI) and one national (OSD) company participated in this Focus CRA pilot project. The selection was risk-based; the focus was on international companies with their own purchasing. The respective Group companies are responsible for the implementation of the CRA. In doing so, she supports and advises the central compliance organization, which also manages the overall process. In the future, such focus CRAs will alternate with the broader standard risk assessments according to the previous methodology.
As a U.S.-listed company, T-Mobile US conducts a risk assessment using its own methodology, on which it regularly reports to the relevant committees (where also representatives of Deutsche Telekom AG are members).
We regularly have our compliance management system with a focus on "anti-corruption" audited by independent auditors. The audits focused in particular on processes that are exposed to an increased risk of corruption: e.g., in the areas of purchasing, sales, events, donations, sponsoring, mergers & acquisitions and personnel.] A further examination of companies is planned for 2024. To the audit reports.
AskMe – To prevent compliance risks, we operate an employee helpline for our employees, the consulting portal AskMe, for questions about value- and legally compliant behavior or other compliance issues.
The following diagram shows the number of inquiries received by topic.
Information and Training of Employees
On our intranet, we offer our employees comprehensive information about compliance. In addition, we regularly train and sensitize our employees through compliance training and other compliance information such as newsletters or mailings. Classroom training and various eLearning formats on compliance topics are available. The training content sensitizes managers to their special role and responsibility. In 2023, we conducted face-to-face training sessions with the Executive Board and top management, in which the best course of action in typical compliance dilemma situations was discussed and developed together on the basis of case studies.
Participants Compliance Trainings - group-wide
Our eLearning offer on compliance is established and also addresses the value-based, integrity and cultural aspects of compliance.
In 2023, we rolled out the new eLearning "Basic Knowledge Compliance" (T-Mobile US has its own training). This deals with the principles of compliance, code of conduct, conflicts of interest and anti-corruption and includes a self-check for decisions in difficult situations (ICARE-Check). Since the rollout at the end of August 2023 until the end of the year 2023, 56% of employees have already completed the eLearning Basic Knowledge Compliance. The campaign will continue in 2024. This eLearning as well as other compliance trainings such as anti-corruption or digital ethics are accessible to approximately 160,000 employees. The eLearning is reviewed every 24 – 36 months for up-to-dateness, revised if necessary and rolled out again.
At T-Mobile US, more than 95% took part in a Business Integrity Training, which is divided into different episodes.
The company culture is fundamental for all teams - it determines the way we treat each other, how we work together. Particularly in the case of upcoming changes, the compliance culture, which aims to behave in accordance with the law and with integrity, is therefore always considered and shaped. In order to implement this for all employees, Compliance is actively involved in the further development of the Group-wide "Living Culture" as well as the implementation of the Leadership Anchors. We obtain information on the compliance culture through relevant statements in the employee survey.
As the world becomes increasingly complex and we are all confronted with new challenges and regulations every day, it is more important than ever to sharpen the inner compass of our employees so that they can act confidently and with integrity in different situations. For this purpose, we have developed the
ICARE-Check, a self-test with five simple questions. It provides guidance to all employees on how to make a responsible decision in difficult situations.
Detect
Our whistleblower portal TellMe offers all customers, employees, suppliers and all other externals the opportunity to report violations of laws and internal regulations at any time by e-mail, electronic whistleblower portal (BKMS), mail or telephone – also anonymously. Confidentiality within the framework of the statutory provisions is guaranteed. Every incoming report – regardless of the input channel – is carefully checked and violations are consistently investigated.
A regular exchange between Group Compliance and the international business units has been taking place regularly for years. During the meetings of representatives of all compliance departments of the national subsidiaries worldwide, the "International Compliance Days", current trends, the compliance strategy and the further development of the compliance management system (CMS) are discussed.
In addition, best practice examples are discussed in regular worldwide virtual meetings. Through the exchange, all units can learn from each other and make targeted improvements for their CMS.
Respond
Confirmed cases of misconduct will be sanctioned consistently, in a manner appropriate to the facts and culpability, and in accordance with the relevant legal provisions.
Tip-offs about possible violations of laws or internal rules and regulations via Deutsche Telekom's whistleblower-hotline TellMe
Hint: Tip-offs reported to portals in a business unit are only counted for the central TellMe portal if Group relevant.
In 2023, Deutsche Telekom received 85 compliance-relevant tip offs via the whistleblower-hotline TellMe. 4 hints were still undergoing plausibility checks, while 20 cases were found to be not valid after investigation at the end of 2023. 61 plausible indications were investigated as compliance cases.
There were 61 plausible tip offs. After detailed investigation 17 of these suspected cases could not be confirmed. For 15 suspected cases the investigations had not yet been completed by the end of 2023.
10 of the 29 confirmed cases led to termination of the employment. In 26 cases, further measures were taken under labor law (written warning, admonition, et cetera). In 3 cases, other consequence (sensitization, disapproval) was taken.
Tip-offs categorized by risk area
In 2023, the majority of compliance-relevant hints related to the violation of asset interests.
Note: For more information on data breaches, please click here.
For more information on human rights violations, please click here.
