Code of Conduct

What makes a company successful? A good product alone does not determine success or failure, nor is it solely decisive in a purchasing decision. A poor reputation or a lack of reputation can jeopardize a company's success. Business success therefore requires something more: conduct by board members, managing directors, managers, and all employees that complies with the law and regulations. This creates trust, credibility, reliability, and reputation. That something more also means integrity and each individual's personal responsibility for their actions.

Put less abstractly, the sum of all these qualities is the company’s values-based compliance culture. It also underpins the business success of the Deutsche Telekom Group (Deutsche Telekom). Business success does not take precedence over the law, nor does it take precedence over morals and integrity. How Deutsche Telekom achieves business success is therefore just as important as business success itself. The Code of Conduct provides guidance in this regard. It brings together two important aspects: the commitment to comply with the law and the specific requirements for acting with integrity. For Deutsche Telekom, it is both an internal commitment and a promise to the outside world. It also helps ensure that Deutsche Telekom is and remains transparent and understandable to everyone.

The Code of Conduct applies worldwide at Deutsche Telekom to members of the Board of Management, managing directors, managers, and all Deutsche Telekom employees. It also applies, for example, to temporary workers—people who are functionally treated as equivalent to employees. It provides an overview of Deutsche Telekom's values and the standards of conduct expected of its employees, and internal policies and rules provide further detail as needed. These values also include mutual respect, recognition, and appreciation in our day-to-day interactions.  When implementing the Code of Conduct, each Deutsche Telekom business unit observes applicable national laws and regulations and, on that basis, respects the country's individual culture.

However, it is not enough to formulate the Code of Conduct as guidance. It must be supported and reinforced by role models. Deutsche Telekom leaders have the primary role-model responsibility: they must credibly demonstrate lawful, ethical conduct and ensure that employees know and understand the Code of Conduct and the conduct requirements it describes.

However, the content and values of the Code of Conduct do not stop at internal boundaries. Deutsche Telekom therefore expects its suppliers and advisers to observe the conduct requirements set out in its Code of Conduct and works to ensure that they are also contractually required to comply with these conduct requirements.

Deutsche Telekom has therefore established the following content for its Code of Conduct.

Trust and fairness in business decisions guide Deutsche Telekom's dealings with its business partners. Employees' private interests and personal benefits do not influence business decisions.

Active corruption

To maintain the trust of customers, business partners, shareholders, and the public,  Deutsche Telekom firmly rejects all forms of corrupt conduct and avoids even the appearance of such conduct. Specifically, Deutsche Telekom employees may not offer, promise, or grant benefits to either public-sector officials or decision-makers at private-sector companies in Germany or abroad in order to obtain conduct or a decision favorable to Deutsche Telekom. Deutsche Telekom employees must also keep this in mind when giving gifts or extending invitations to business meals and events.

Passive Corruption

Deutsche Telekom employees do not allow benefits to be promised or offered to them, and they do not accept benefits if doing so could create or creates the impression for the benefit provider that employees may be influenced in their business decisions. In addition, Deutsche Telekom employees never request a personal benefit for themselves or a third party.

Public Contracts

The public sector is an important customer of Deutsche Telekom. Deutsche Telekom employees observe and follow the rules designed to prevent improper influence in public procurement procedures and to ensure fair competition.

Trade controls

Deutsche Telekom has international business relationships. As a result, it actively participates in the international exchange of goods and services and supports free global trade. Deutsche Telekom complies with relevant trade controls and applicable regulations governing import and export controls and embargoes.

Procurement

Deutsche Telekom's Procurement department and the entities it authorizes are responsible for professionally procuring goods and services on favorable terms for the benefit of Deutsche Telekom. It operates in accordance with the applicable laws and regulations of the countries where Deutsche Telekom does business. Bypassing Procurement may disadvantage Deutsche Telekom. Procurement is therefore responsible for all purchasing activities.

Suppliers

Deutsche Telekom maintains trusting and fair business relationships with its suppliers. In turn, Deutsche Telekom expects its suppliers to treat Deutsche Telekom with the same respect and integrity that Deutsche Telekom shows them.

Suppliers are often also customers. Deutsche Telekom does not derive any unfair advantage from this and, as a matter of principle, keeps its procurement and sales activities separate. Tied transactions require approval from the responsible procurement managers.

Competition

Deutsche Telekom and its employees are committed to fair competition in all business relationships. They ensure that they do not enter into any agreements with competitors, customers, or suppliers that restrict competition with respect to prices or market or territory allocations. This applies in particular to tenders. Business decisions are made independently and without exchanging sensitive information with competitors.  Deutsche Telekom neither spreads false information about competitors’ products and services nor seeks competitive advantages through other unfair or abusive means.

Transparent Financial Reporting

Financial reporting complies with local and international accounting standards and accurately reflects Deutsche Telekom's actual asset, financial, and earnings position.

Donations

As a responsible member of society, Deutsche Telekom fulfills its social responsibility in the countries where it operates. Based on the applicable legal framework, internal policies and rules, and its own financial resources, Deutsche Telekom supports a broad range of initiatives in education, science, culture, social causes, sports, and environmental protection. This support is provided through partnerships, cash and in-kind donations, and services. Deutsche Telekom does not make donations to obtain business advantages. Donations are not made to individuals, private accounts, or persons or organizations that could harm Deutsche Telekom's interests or reputation.

Political Contributions

Deutsche Telekom makes no monetary contributions to political parties or elected officials and does not provide them with benefits in kind that exceed what is legally permitted.

Money Laundering

Deutsche Telekom takes all necessary measures to prevent money laundering within its sphere of influence.

Sponsorship

Sponsorship is one of Deutsche Telekom's communications tools. Its sponsorship activities focus on sports, especially soccer, music, and social responsibility initiatives. All sponsorship activities must comply with applicable laws and the internal Sponsorship Policy. All sponsorship activities require appropriate, verifiable communications and marketing services from the sponsorship partner or event organizer and are managed transparently.

Avoiding other conflicts of interest

Deutsche Telekom expects the personal interests of its board members, managing directors, executives, and employees not to conflict with Deutsche Telekom's interests. 

Outside employment 

Outside employment must not conflict with Deutsche Telekom's interests. This applies, for example, and especially to outside employment with competitors. 

Equity investments 

Equity investments by Deutsche Telekom employees in Deutsche Telekom competitors or business partners that enable them to exert business influence are not in Deutsche Telekom's interests.

Private use of company property is permitted only if individual employment law, collective bargaining, or company policies, or company practice, allow it.

Deutsche Telekom takes a range of technical and organizational measures designed to ensure the confidentiality of personal data.

Data security

Data security is of central importance to Deutsche Telekom. It affects business success and public reputation. Deutsche Telekom therefore protects company, customer, business partner, shareholder, and employee data against unauthorized access, unauthorized or improper use, loss, and premature destruction using all available appropriate and reasonable technical and organizational measures. It does so in compliance with the applicable legal framework, national laws, and internal policies and regulations.

Data Protection

Deutsche Telekom recognizes the highly sensitive nature of the personal data entrusted to it by its customers, business partners, employees, and shareholders, and protects this data through careful and responsible handling. Deutsche Telekom implements a range of technical and organizational measures designed to ensure the confidentiality of personal data. Within the scope of their responsibilities, everyone is responsible for maintaining a high level of protection at Deutsche Telekom. Deutsche Telekom employees consistently comply with data protection requirements and, in particular, respect and uphold the extensive rights of the individuals whose data they collect, process, and use.

General confidentiality

In addition to technical and organizational data protection measures, every Deutsche Telekom employee is required to safeguard the company’s interests. For this reason, information originating from Deutsche Telekom and information about Deutsche Telekom are communicated only to authorized recipients. This applies to both internal and external recipients. Deutsche Telekom also maintains the confidentiality of information and protects business documents from access by unauthorized persons.

Insider information

To protect investors’ confidence in the proper functioning of the capital market, Deutsche Telekom employees comply with the rules governing the handling of insider information, particularly confidentiality obligations, the prohibition on recommendations, and the prohibition on insider dealing.

Deutsche Telekom expects all Board members, managing directors, leaders, and employees to act in accordance with the Code of Conduct.

Violations of conduct requirements, laws, internal policies, and rules can have serious consequences not only for the individual, but also for Deutsche Telekom. Therefore, culpable, intentional misconduct will not be tolerated.

Within the scope of applicable law, Deutsche Telekom consistently sanctions misconduct and violations without exception, regardless of the rank or position of those involved or affected.

To encourage people to report misconduct and violations, Deutsche Telekom fosters an environment and culture free from fear of negative consequences for making such reports.

If you have questions about applying the Code of Conduct in your day-to-day work, your manager is your first point of contact.

The „AskMe“ advisory portal is also available if you are unsure about compliance-related conduct. Serious misconduct must be brought to our attention so that it can be prevented in the future and addressed appropriately. For this purpose, we have the „TellMe“ whistleblower reporting procedure.

You can direct compliance-related questions about the Code of Conduct and internal policies to the „AskMe“ advisory portal.

Whistleblower reporting procedure "TellMe"

The group-wide „TellMe“ whistleblower portal serves as the central point of entry for reporting violations or suspected violations of laws, legal requirements, and internal policies and regulations.

A reporting person will not face any disadvantage as a result of submitting a report, provided they do not violate applicable law themselves. Reports should be made to the best of your knowledge and belief. However, anyone who carelessly or knowingly makes false, unfounded allegations or accusations must expect consequences.

However, employees should first consider speaking personally with their manager. Problems can often be resolved sustainably this way. If this is not an option, reports of misconduct can be submitted by mail, phone, or email.

You can also submit a report anonymously to “TellMe.” However, this option should be used only in exceptional cases if you fear serious personal, employment-related, disciplinary, or social disadvantages.

The information is treated in strict confidence and reviewed for plausibility by individuals who are specially trained for this purpose and bound by confidentiality.

In Brussels, Deutsche Telekom has registered with the public Transparency Register for lobbyists.

The Strategy of Deutsche Telekom describes the goals Deutsche Telekom aims to achieve.

The Deutsche Telekom Guidelines set the guardrails for how Deutsche Telekom's Strategy is to be implemented.

The Human Rights Code, through which Deutsche Telekom commits, among other things, to respecting and promoting human rights (including the ILO Core Labor Standards). In addition, the human rights- and environment-related risks we identified for the respective prior year, including the measures and expectations derived from them, are published here.

The Group Policy on Employee Relations, which governs the relationship between employees and Deutsche Telekom companies.

Deutsche Telekom’s Group Policies, such as the Group Policy on Accepting and Granting Benefits, the Sponsoring Policy, and the Global Procurement Policy.

Rules that are important for the employment relationship, such as works agreements and collective bargaining agreements in Deutsche Telekom’s Intranet

The German Corporate Governance Code, developed by the Government Commission, which serves as Deutsche Telekom’s benchmark for good and responsible Corporate Governance.