Compliance Policies

To achieve the goal of lawful and rule-compliant corporate governance, Deutsche Telekom has implemented various compliance-related policies that provide all employees with a binding framework for action.

These include: 

Code of Conduct

Our Code of Conduct provides guidance for everyone across the Telekom Group. It links our commitment to complying with laws and regulations with our specific expectations for ethical conduct through our six Guiding Principles. Together with the Human Rights Code, the Code of Conduct and the Guiding Principles define the framework for ethical and integrity-based business practices, helping protect everyone involved from unethical conduct. Sustainable business success requires legally and statutorily compliant conduct by board members, managing directors, leaders, and all employees. Leaders serve as role models by credibly demonstrating legally sound and ethical conduct. For this reason, conflicts of interest should be avoided, among other things. 

Deutsche Telekom rejects corruption in every form. This includes, in particular, the rejection of acceleration and facilitation payments as well as improper kickback payments. 

Benefits Policy

This anti-corruption policy governs the acceptance and provision of benefits in dealings with business partners in the public and private sectors. It sets out value limits and conduct guidelines. The policy provides that benefits may be accepted or provided only where they do not present a risk of corruption. For each benefit, an employee must assess whether it is appropriate; whether there is no intent to influence and no conflict of interest; the business purpose; transparency; and its potential impact. In defined cases, value limits and internal approval requirements also apply to ensure legal certainty and clear guidance for Deutsche Telekom and its employees.

Donation Policy

Building on its corporate responsibility strategy, Deutsche Telekom aims to lead by example as a responsible company in the international competitive environment. The Group’s donation practices also contribute to this goal. As a responsible member of society, Deutsche Telekom supports education, science, culture, social causes, sports, and the environment through monetary donations and, in exceptional cases, in-kind donations and donations of services, within its legal and financial means. To this end, the Donation Policy defines requirements and parameters for lawful, binding, and transparent procedures for assessing and handling donations. In particular: Donations must not be misused for corrupt purposes. 

In addition, the German Political Parties Act prohibits Deutsche Telekom from making donations to political parties. This prohibition is also reflected in the relevant internal rules. 

Sponsorship Policy

Sponsorship is an important part of our communications strategy and marketing, as well as a key way to engage with our customers. It spans a range of areas, including sports, culture, social causes, the environment, and media. Deutsche Telekom’s lasting business success also depends on the support of socially relevant stakeholder groups and on recognition as a "Good Corporate Citizen." Sponsorship therefore serves both advertising and public relations objectives in the interests of the company. 

The Sponsorship Policy specifies Deutsche Telekom’s sponsorship strategy and establishes the decision-making process for specific sponsorship activities. 

In particular, the following applies: Sponsorship benefits must not be misused for corrupt purposes.

Policy on the Engagement of Sales Intermediaries and Lobbyists 

Deutsche Telekom’s competitiveness depends to a significant extent on Deutsche Telekom and its board members, managers, and employees acting lawfully and with integrity in business dealings. Lawful and ethical conduct is an essential foundation for the trust of customers and business partners and is therefore an indispensable requirement for all Deutsche Telekom employees. Deutsche Telekom expects the same lawful and ethical conduct from external individuals who serve Deutsche Telekom in an advisory capacity. 

Against this background, the Group Policy on the Engagement of Sales Intermediaries and Lobbyists sets out a multi-step prevention framework comprising: risk assessments and the careful selection of sales intermediaries and lobbyists, appropriate contract design, careful monitoring of sales intermediaries and lobbyists, and documentation. 

Antitrust Policy

The Antitrust Policy aims to prevent violations of antitrust law. For both public-policy reasons and its own interests, Deutsche Telekom opposes restrictions on competition, as free competition is essential to strong performance. 

Event Policy

The Event Policy sets out clear criteria for planning, conducting, and following up on events. It specifies value limits for leisure-oriented events and expressly refers to compliance with the Benefit Policy to prevent corruption through event invitations.

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Digital Ethics AI Guidelines

Respecting human rights is a key part of our approach to artificial intelligence. Our Digital Ethics AI Guidelines are guided by international standards, including the UN Guiding Principles on Business and Human Rights and the EU Charter of Fundamental Rights. They address, in particular, protecting privacy and data rights, preventing discrimination, using AI transparently, and ensuring human oversight.

We implement the Digital Ethics AI Guideline through binding governance structures to ensure it is applied consistently. We also consider developments in the technical and European legal framework, such as the EU AI Act, so we can continuously refine our approach.