In 2022 Deutsche Telekom carried out a Human Rights Impact Assessment (HRIA) at its subsidiary Deutsche Telekom Services Europe Slovakia s.r.o.(DTSE Slovakia). One of the core elements of the assessment was the engagement with a diverse range of stakeholders and rightsholders (including DTSE employees and employees of on-site service providers).
Background
The German Supply Chain Act (GSCA) and related international frameworks such as the United Nations Guiding Principles on Business and Human Rights (UNGPs) expect businesses to put in place ongoing and systematic due diligence processes to proactively identify, prevent, mitigate and address human rights risks with which they may be involved directly or through their business relationships. We fully endorse the GSCA and the UNGPs and have integrated respecting human rights into our fundamental policies, especially the Guiding Principles and our Code of Human Rights & Social Principles. In addition, Deutsche Telekom also seeks to deepen its understanding of the risks and impacts on rightsholders across the breadth and depth of our operations and supply chains. One way in which the company achieves this is through deep-dive HRIAs at specific business units, identified through risk-based analysis. In 2022, we visited the DTSE subsidiary in Slovakia to carry out one such assessment. To ensure neutrality, the assessments were accompanied by the external human rights management consultancy twentyfifty GmbH.
Methodology
The assessment was divided into four phases:
- Phase 1: Set-up and preparation together with the DTSE subsidiary in Slovakia
- Phase 2: On-site assessment to identify good practices and human rights risks
- Phase 3: Analysis of the findings, report development and follow-up
- Phase 4: Collaboratively implementing and monitoring corrective actions
Results and Next Steps
The evaluation showed overall positive results with many systems and processes in place, a trustful employer relationship, an attractive working environment, a dedicated management team and a largely satisfied workforce.
An action plan was agreed taking forward the identified opportunities for improvement. DTSE Slovakia is working together with Deutsche Telekom to implement the improvement awareness of the existing grievance mechanisms. They focus especially on strengthening documentation process on working hours, awareness of groupwide complaints procedure and training of employees involved in local procurement activities on Deutsche Telekom’s global Supplier Code of Conduct. In addition, Deutsche Telekom is seeking to incorporate a human rights awareness program groupwide and to use this experience to continue to evolve the global human rights due diligence approach.
