Corporate Responsibility
Strategy, processes, and action
Our comprehensive due diligence program covering human rights and the environment serves to entrench the implementation of our Code of Human Rights (pdf, 203.7 KB) in practice within our company. We regularly analyze the risks and impacts our business activities have or could have on human rights and the environment. By doing so, we are able to prevent, mitigate, and stop negative consequences and take advantage of opportunities to make improvements. We review our due diligence processes at least once a year to ensure their efficacy and make changes wherever necessary.
The risks and impacts that we have identified and set as highest priority are published at least once a year on this website. Details of the program and the specific processes are provided below.
Risk management
Responsibilities
- Coordination: Group Corporate Responsibility at Deutsche Telekom AG is responsible for the Group-wide human rights strategy and coordinates the relevant due diligence processes.
- Implementation: Various different departments are responsible for structuring the functional area and implementing the processes, and thus play an important role in ensuring respect for human rights - e.g., HR, Procurement, Compliance, Risk Management, Legal.
- Monitoring: An office has been established to monitor the efficacy of the due diligence processes and in particular of risk management at Deutsche Telekom AG. This person reports directly to the Chair of the Board of Management of Deutsche Telekom AG and has further supporting functions.
- Overarching responsibility: The top management level – i.e., the Board of Management of Deutsche Telekom AG and the managing boards of the respective Group companies – is responsible for ensuring respect for human rights and compliance with environmental obligations.
Risk analyses
We strive to identify and avert human rights-related and environmental risks in connection with our business activities as early as possible. If violations occur, we take action to keep any negative consequences to a minimum wherever possible.
Regular risk analysis
To implement this for our global supply chain, we regularly look at the predisposition to risk of our relevant Group companies and more than 20,000 direct supplier companies. This involves the collection, analysis, and weighting of a wide range of external and internal information. These regular analyses enable us to focus our efforts on specific issues in order of priority.
Ad hoc risk analysis
We also activate our early warning system on an ad hoc basis, to examine relevant matters within our value chain as soon as we learn of them, for instance, in the lead-up to mergers and acquisitions. We can also perform ad hoc analyses in response to internal and external tip-offs and complaints received via our TellMe whistleblower portal, press releases, or in dialog with, e.g., political advocacy groups, employees’ representatives, associations, human rights defenders and their reports.
The findings from the risk analyses are regularly presented to top-level management and the Group Board of Management and thus are given due consideration in the course of company decision-making processes.
Preventative and remedial action
The findings from the risk analyses enable us to define early-stage measures to prevent the occurrence of human rights-related and environmental violations and to mitigate risks. We develop appropriate measures that are aligned with the risks identified.
Generally speaking, we try to take a dialog-based approach to defining and implementing measures. We actively engage in dialog with employees from different departments in our international and German Group companies, as well as with external networks and human rights experts, so as to ensure we consider a broad range of perspectives. The overriding goal is always to effectively mitigate or eliminate the identified risk or violation.
The degree of influence we can exert depends on the root cause of the risk or violation. If the cause comes from within our own Group companies, we can take immediate action and put an end to violations.
If risks/violations arise from our direct supplier companies, we seek dialog and work with them to develop suitable measures. For instance, if there is no direct contractual relationship with an indirect supplier company in the upstream value chain, we are reliant on them working jointly with our respective direct supplier company to take action. If other means of remedying the issue fail, we will consider terminating the contractual relationships with our supplier companies.
Training and risk-based control measures are essential for effective preventative and/or remedial action. We perform risk-based control measures on site at our Group companies as well as at direct and indirect supplier companies. In this regard, we support industry-wide initiatives working for collaborative auditing activities to establish greater transparency across a larger number of supplier companies and a stronger degree of influence, e.g, as a member of the „Joint Alliance for CSR – JAC“.
Complaints mechanism
We aim to act responsibly in all of our economic activities, everywhere and at all times.
But sometimes violations of human rights, environmental regulations, or other principles can occur that we may not see or be able to identify immediately. For this, we need help.
Our TellMe whistleblower portal and complaints system offers multiple ways to share critical issues concerning our business activities with us. You will find more information on the procedure here.
Documentation and reporting
We publish the following information on compliance with due diligence requirements affecting human rights and the environment. You can find an overview of all the documents here:
- Deutsche Telekom AG’s Code of Human Rights: Human rights strategy, due diligence processes, principles and expectations, complaints procedure [Part 1 of the policy statement on human rights pursuant to the German Act on Corporate Due Diligence in Supply Chains, LkSG].
- Annual report "LkSG": Findings from the annual risk assessment to supplement the Code of Human Rights with reporting on any prioritized human rights-related and environmental risks pursuant to the German Act on Corporate Due Diligence in Supply Chains (LkSG) for the respective financial year [Part 2 of the policy statement on human rights in accordance with the German Supply Chain Due Diligence Act].
- “BAFA” Report: Report for the Federal Office for Economic Affairs and Export Control (BAFA) in accordance with the German Act on Corporate Due Diligence in Supply Chains (LkSG) on the basis of the prescribed reporting form – available from 2024.
- Deutsche Telekom’s CR report: Report by Deutsche Telekom on all sustainability aspects within the meaning of Environmental and Social Governance (ESG) for the respective financial year, including audit findings.
Involvement of stakeholders and networks
Deutsche Telekom considers itself an active member of a global community and is committed to working with governments, industry, partners, and civil society to ensure it fulfills its human rights obligations.
We deal with human rights-related topics such as freedom of speech or discrimination as part of the following national and international initiatives: