Here you can find KPIs for Deutsche Telekom's central compliance measures.
Our compliance culture is an essential part for corporate governance geared towards integrity and appreciation. We are committed to ethical principles as well as to the law throughout the Group. We have anchored this in our guidelines and our Code of Conduct. We also provide further compliance information in the Annual Report and the Corporate Responsibility Report.
Prevent
Corruption violates national and international law. We reject all forms of corruption – both bribery as active corruption and corruption as passive corruption – in the public and private sectors. Our compliance management system (CMS) is therefore particularly geared towards preventing corruption.
We have implemented a compliance management system with the aim of minimizing risks from systematic violations of legal or ethical standards that could lead to regulatory or criminal liability of the company, its board members or employees or to significant reputational damage. The Executive Board assumes its overall responsibility for compliance as a key management task. Our Chief Compliance Officer is responsible for the design and management of the compliance management system. At the level of our operating segments and national companies, compliance officers implement the compliance management system and our compliance targets locally.
The Compliance Risk Assessment (CRA) is one basis of our compliance management system. It enables us to identify and assess compliance risks and initiate appropriate preventive measures. For this purpose, we have set up a process that has to be run through regularly. The companies participating in the CRA are selected according to a maturity-oriented model, depending on governance. The CRA in the year under review comprised 69 units (61 companies and 8 central divisions), resulting in a coverage ratio of 93.6 percent (after FTE/full-time equivalents of fully consolidated companies and central divisions; As of December 31, 2022) (previous year: 98.1 percent).
As a U.S.-listed company, T-Mobile US conducts a risk assessment using its own methodology, on which it regularly reports to the relevant committees (where also representatives of Deutsche Telekom AG are members). [The respective Group companies are responsible for the implementation of the CRA; the central compliance organization supports and advises them. We regularly have our compliance management system with a focus on "anti-corruption" audited by independent auditors. Most recently, nine German companies were audited in 2020; further audits in 13 international companies followed in 2021. A total of 22 companies were successfully audited in the 2020 and 2021 financial years. A further examination of companies still to be selected is planned for 2024. The audits focused in particular on processes in companies that are exposed to an increased risk of corruption: e.g., in the areas of purchasing, sales, events, donations, sponsoring, mergers & acquisitions and personnel.] To the audit reports.
AskMe – To prevent compliance risks, we operate an employee helpline for our employees, the consulting portal AskMe, for questions about value- and legally compliant behavior or other compliance issues.
The following diagram shows the number of inquiries received by topic.
On our intranet, we offer our employees comprehensive information about compliance. In addition, we regularly train and sensitize our employees through compliance training and other compliance information such as newsletters or mailings. Classroom training and various interactive eLearning formats on compliance topics are available. For executives and management, specially tailored face-to-face training courses on compliance and anti-corruption are carried out. The training content illustrates the special responsibility of the managers.
Participants Compliance Trainings- international
In 2022, we conducted face-to-face trainings with the Executive Board and top management, in which the best course of action in typical compliance dilemma situations was evaluated on the basis of case studies.
The corporate culture plays an important role in all teams - it determines the way we interact with each other, how we work together. Especially in the case of upcoming changes, the compliance culture, which aims at legally compliant and honest behavior, should therefore always be considered and shaped. In order to implement this for all employees, Compliance is actively involved in the cooperation and development of the Group-wide "Living Culture".
We obtain our insights into the state of compliance culture by interviewing employees and subsequently evaluating the answers to compliance-relevant questions.
As the world becomes increasingly complex and we are all confronted with new challenges and regulations every day, it is more important than ever to sharpen the inner compass of our employees so that they can act confidently and with integrity in different situations. For this purpose, we have developed the ICARE-Check, a self-test with five simple questions. It provides guidance to all employees on how to make a responsible decision in difficult situations.
Identify
Our whistleblower portal TellMe offers all customers, employees, suppliers and all other externals the opportunity to report violations of laws and internal regulations at any time by e-mail, electronic whistleblower portal (BKMS), mail or telephone – also anonymously. Confidentiality within the framework of the statutory provisions is guaranteed. Every incoming report – regardless of the input channel – is carefully checked and violations are consistently investigated.
A regular exchange between Group Compliance and the international business units has been taking place regularly for years. During the meetings of representatives of all compliance departments of the national subsidiaries worldwide, the "International Compliance Days", current trends, the compliance strategy and the further development of the compliance management system (CMS) are discussed.
In addition, best practice examples are discussed in regular worldwide virtual meetings. Through the exchange, all units can learn from each other and make targeted improvements for their CMS.
Respond
Confirmed cases of misconduct will be sanctioned consistently, in a manner appropriate to the facts and culpability, and in accordance with the relevant legal provisions.
Tip-offs about possible violations of laws or internal rules and regulations via Deutsche Telekom's whistleblower-hotline TellMe
Hint: Tip-offs reported to portals in a business unit are only counted for the central TellMe portal if Group relevant.
In 2022, Deutsche Telekom received 81 compliance-relevant tip offs via the whistleblower-hotline TellMe. At the end of the reporting year 8 hints were still undergoing plausibility checks, while 9 cases were found to be not valid after investigation. 64 plausible indications were investigated as compliance cases.
There were 64 plausible tip offs. After detailed investigation 12 of these suspected cases could not be confirmed. For 13 suspected cases the investigations had not yet been completed by the reporting date of 31 December 2022.
15 of the 39 confirmed cases led to termination of the employment. In 23 cases, further measures were taken under labor law (written warning, admonition, et cetera). In 1 case, other consequence (sensitization) was taken.
Tip-offs categorized by risk area
In 2022, the majority of compliance-relevant hints related to the violation of asset interests.
Note: For more information on data breaches, please click here.
For more information on human rights violations, please click here.
