Compliance Maturity Model

Deutsche Telekom established a comprehensive compliance management system as early as 2009. In 2013, we expanded the system to include the maturity-oriented approach. The goal was to continue preventing violations and minimizing risks while tailoring the scope of compliance measures and requirements to each affiliate’s business model. This creates room for day-to-day operations and ensures appropriate compliance across our affiliates.   

Our maturity-based compliance management approach reflects our belief that a corporate group like Deutsche Telekom, with numerous and diverse investments, needs tailored compliance solutions for each type of company. Subsidiaries in emerging markets and those offering new products or partnering with start-ups require different support than, for example, our international business customer operations. Large, multinational investments require substantially more sophisticated and formal compliance management, including extensive training, detailed processes for identifying and addressing misconduct, and regular reporting to the Board of Management and Supervisory Board. For very small investments with lower risk exposure, oversight of management or a commitment to corporate principles may, for example, be sufficient.

Based on the business area, economic development, and each investment's risk exposure, we have therefore defined graduated minimum compliance requirements of increasing rigor for our investments. These requirements clearly specify how compliance management is established, designed, and monitored in each case. Although this represents a departure from the „one-size-fits-all“ approach, we continue to ensure the level of protection needed for each investment and meet formal requirements (e.g., IDW PS 980). At the same time, we are increasing acceptance of compliance within our investments.

This innovative management approach has already proven effective in our business operations. It enables us to integrate acquired companies even more consistently, increase transparency around the compliance requirements to be met, and make those requirements more efficient. Since 2018, we have managed this model through an IT platform that reviews compliance with the applicable requirements each year.