„Good leadership is essential to me. I expect business to be done in a compliant manner at Deutsche Telekom.“ (Timotheus Höttges, Chief Executive Officer Deutsche Telekom AG)
In order to implement the goal of law-abiding corporate governance, Deutsche Telekom has implemented various policies with compliance relevance, which provide all employees with a binding framework for action.
These include, but are not limited to:
Code of Conduct
Our Code of Conduct is the guiding framework for all people in the Telekom Group. It links our claim to compliance with the law and our special requirements for ethical conduct with our six Guiding Principles. The Code of Conduct and the Gi, together with the Human Rights Code, define the framework for ethical and honest business practices and thus protect all parties involved from unethical behaviour. After all, sustainable business success requires legally and legally compliant behavior on the part of board members, managing directors, executives and all employees. Managers have a role model function by credibly exemplifying legally impeccable behavior with integrity. For this reason, conflicts of interest are to be avoided, among other things.
Deutsche Telekom rejects any kind of corruption. This includes, in particular, the rejection of acceleration and facilitation payments as well as impermissible kick-back payments.
Benefits policy
This anti-corruption policy regulates the acceptance and granting of benefits in relation to business partners from the public and private sectors. It contains value limits and guidelines of conduct. The policy stipulates that benefits may only be accepted or granted if there is no risk of corruption. For each benefit, an employee must check the appropriateness, the absence of an intention to influence and a conflict of interest, the interest of the service, transparency and the possible impact. In addition, there are value limits and internal approval requirements in defined cases to ensure legal certainty and action for Deutsche Telekom and its employees.
Donation Policy
Deutsche Telekom's goal is to take on a pioneering role as a responsible company in the competitive international environment on the basis of its corporate responsibility strategy. The Group's donation behavior also contributes to this. As a responsible member of society, Deutsche Telekom promotes education, science, culture, social concerns, sports and the environment within the scope of legal and economic possibilities through monetary donations and, in exceptional cases, donations in kind and services. To this end, the Donation policy defines guidelines and framework conditions for a lawful, binding and transparent approach to the assessment and handling of donations. In particular, donations must not be misused for corruption purposes.
In addition, it follows from the German Political Parties Act that Deutsche Telekom is not allowed to make donations to political parties. This is also reflected in corresponding internal regulations.
Sponsorship Policy
Sponsorship is an important part of our communication concept and marketing, as well as a crucial tool for interacting with our customers. Sponsorship covers various areas such as sports, culture, social affairs, the environment and the media. For long-term economic success, Deutsche Telekom also depends on the support of socially relevant reference groups and their recognition as "Good Corporate Citizens". Sponsorship therefore pursues both advertising and public relations goals in the interest of the company.
The Sponsorship Policy specifies Deutsche Telekom's sponsorship strategy and defines the decision-making process for specific sponsorship measures.
In particular, sponsorship services must not be misused for corruption purposes.
Group policy for engaging sales intermediaries and lobbyists
Deutsche Telekom's competitiveness depends to a large extent on Deutsche Telekom and its board members, executives and employees behaving lawfully and with integrity in their business dealings. Lawful conduct and integrity are an essential basis for the trust of customers and business partners and is therefore an indispensable requirement for all Deutsche Telekom employees. To the same extent, Deutsche Telekom requires that external persons who act in an advisory capacity for Deutsche Telekom behave lawfully and with integrity.
Against this background, the Group policy for engaging sales agents and lobbyists contains a multi-stage prevention concept consisting of: risk assessment and careful selection of sales agents and lobbyists, appropriate contract drafting, careful monitoring of sales agents and lobbyists, and documentation.
Group policy on antitrust law
The Antitrust policy pursues the goal of preventing violations of antitrust law. Deutsche Telekom opposes competition restrictions for regulatory reasons and in its own interest, since free competition is the guarantor of performance.
Event Policy
The Event Policy provides clear criteria for the planning, implementation and follow-up of events. Value limits for leisure-oriented events are specified and explicit reference is made to the observance of the benefit policy to avoid corruption through event invitations.
Digital Ethics AI Guidelines
The protection of human rights is an essential part of our approach to dealing with artificial intelligence. Our Digital Ethics AI Guidelines are based on international standards such as the UN Guiding Principles on Business and Human Rights and the EU Charter of Fundamental Rights. In particular, they address the protection of privacy and data rights, the avoidance of discrimination, the transparent use of AI and the assurance of human control.
The implementation of the Digital Ethics AI Guideline is carried out through binding governance structures to ensure consistent application. In doing so, we take into account developments in the technical and European legal framework, such as the EU AI Act, in order to constantly sharpen our approach.