Data and facts

Our compliance culture is a key foundation for corporate governance centered on integrity and respect. Across the Group, we are committed to ethical principles and to upholding the law. We have embedded these commitments in our policies and our Code of Conduct. We also provide further compliance information in our Annual Report, among other places.

Prevention

Corruption violates national and international law. We reject all forms of corruption—both bribery as active corruption and accepting bribes as passive corruption—in the public and private sectors. Our Compliance Management System (CMS) therefore focuses in particular on preventing corruption. We have implemented a Compliance Management System to minimize the risks arising from systematic violations of legal or ethical standards that could result in administrative or criminal liability for the Company, members of its governing bodies, or employees, or cause significant reputational damage. The Board of Management fulfills its overall responsibility for compliance as a key leadership responsibility. Our Chief Compliance Officer is responsible for designing and managing the Compliance Management System, with a focus on anti-corruption. At our operating segments and National Companies, Compliance Officers implement the Compliance Management System and our compliance objectives locally. 

A cornerstone of Deutsche Telekom's compliance management system is the Compliance Risk Assessments (CRA), which enables us to identify and assess compliance risks and initiate appropriate preventive measures. To support this, Deutsche Telekom has established a process that is carried out regularly. Companies are selected to participate in the CRA based on risk.

Group Compliance provides centralized support for local implementation and a consistent methodology. This methodology assesses risks based on their likelihood of occurrence and potential impact. Existing preventive measures are taken into account when managing risks. Where needed, additional mitigating measures are developed. 

In 2025, the CRA, with a focus on the German Supply Chain Due Diligence Act (LkSG), was conducted at 51 Subsidiaries in Germany and abroad. The regularly conducted, broad-based standard CRA was carried out in 2024 at Deutsche Telekom AG and 101 additional Subsidiaries in Germany and abroad. The next risk assessment is planned for 2026.

As a U.S.-listed company, T-Mobile US conducts a Risk Assessment using its own methodology and regularly reports on it to the relevant governing bodies, which also include representatives of Deutsche Telekom AG. 

We regularly have independent auditors audit our compliance management system, with a focus on "anti-corruption," in accordance with IDW Auditing Standard 980. In addition to general compliance processes, the audits focus in particular on processes exposed to an elevated risk of corruption, for example in procurement, sales, events, donations, sponsorships, mergers & acquisitions, and human resources.

Following an IDW PS 980 audit of Deutsche Telekom AG and eight other Subsidiaries in Germany in 2024, twelve international Subsidiaries were audited under this standard in 2025. In addition to compliance processes, the audits again focused in particular on processes exposed to an elevated risk of corruption. As in the previous audits, the effectiveness of the compliance management systems focused on "anti-corruption" at all audited international Subsidiaries was confirmed. More about the audits.

AskMe - To help prevent compliance risks, we offer our employees an employee helpline, the AskMe compliance advisory portal, where they can ask questions about conduct that aligns with our values and the law, as well as other compliance matters. We answer inquiries that fall within Group Compliance's area of responsibility directly through the portal. We forward inquiries that other departments are responsible for to those departments. 

The following overview shows the number of inquiries received by the AskMe advisory portal, broken down by topic. 

Information and Training for Employees

In our Intranet, we provide our employees with comprehensive information on compliance. In addition, we regularly train and raise awareness among all our employees (full-time and part-time) through compliance training and other compliance information, such as newsletters or mailings. In-person training and various eLearning formats on compliance topics are available. Among other things, employees learn how to prevent violations and reduce exposure to unethical opportunities. For new employees, compliance training is part of the onboarding process. We regularly provide specially tailored in-person training on compliance and anti-corruption for managers and management. The training content raises managers' awareness of their particular role and responsibility. 

Participants in Compliance Training – Group-wide

Our eLearning offerings on compliance are well established and also address the values-based, integrity-related, and cultural aspects of compliance.

In 2023, we rolled out the eLearning course „Basiswissen Compliance“ (T-Mobile US has its own training). It covers the compliance fundamentals of the Code of Conduct, conflicts of interest, and anti-corruption, and includes a self-check for decisions in challenging situations (ICARE Check). From the rollout at the end of August 2023 through the end of 2025, 89 percent of employees completed the eLearning course „Basic Knowledge of Compliance“ We will continue the campaign in 2026. We review the eLearning course for currency every 24 – 36 months, revise it where needed, and roll it out again. This eLearning course and other compliance training courses, such as anti-corruption training, are available to approximately 130,000 employees (excluding T-Mobile US). To ensure employees have sufficient skills for working with artificial intelligence (AI) in accordance with the EU AI Act, we provide the eLearning course „Digital Ethics,“ as well as Promptathons, AI Learning Journeys, LexSessions (learning from experts), etc. 

More than 91 percent of T-Mobile US employees completed Business Integrity Training, which is divided into different modules.

Our corporate culture is essential to every team - it shapes how we treat one another and how we work together. Especially when change is ahead, we always consider and help shape a compliance culture that promotes lawful conduct and integrity. 

We gain insights into our compliance culture from the various questions in our employee survey; we also analyze the free-text fields for their relevance to compliance.

As the world becomes increasingly complex and we all face new challenges and regulations every day, it is more important than ever to sharpen our employees’ inner compass so they can act confidently and with integrity in different situations. To support this, we developed the ICARE Check, a self-assessment with five straightforward questions. It gives all employees guidance on how to reach a responsible decision in difficult situations.