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Here you can find KPIs for Deutsche Telekom's central compliance measures.

Deutsche Telekom stands for transparent and comprehensive compliance management. Therefore, we would like to provide you some information about targets, implemented activities and progresses achieved. We also offer information in our Annual Report and the Corporate Responsibility Report.

Prevent

We implement numerous measures to prevent and combat corruption. Our compliance management system is based on Compliance Risk Assessments (CRA), which we use to identify and evaluate compliance risks and to initiate suitable preventive measures. To this end, we have established an annual Group-wide process. The companies participating in the CRA are selected according to a maturity-based model.   

The CRA in the year under review comprised 80 companies - a coverage rate of just under 97 percent (based on the number of employees of the fully consolidated companies; at T-Mobile US there exists a different CRA system; as of September 2019).

Ask me! In order to prevent compliance risks, we set up "Ask me!" in 2008. The chart below shows the number of inquiries received, divided into specific issues.


Trainings

With regular training measures, we inform and sensitize our employees for compliance. In addition to classroom trainings, various interactive eLearning formats are available. For executives and management, tailored attendance training on compliance and anti-corruption is also conducted. Here, managers are shown their particular responsibilities and they are informed about trends and changes in case law.

Participants Compliance Trainings- international.

Participants Compliance Trainings- international.

In 2018 we started voluntary trainings for our employees under the motto "Speak Up!". They get to know communication techniques in order to openly and adequately address grievances and sensitive topics. We continued these training courses in 2019. A total of 3,300 employees have participated in it so far.

Identify

Strengthening and measuring our compliance culture is an essential part of our compliance management. We have been interviewing managers and employees regularly since 2013. For example, in 2019, we conducted an international employee survey on compliance for the second time under the umbrella of the "Compliance based Culture" initiative. The aim was to check after the last survey in 2017 how our compliance culture has developed since then. Research partners of the broad initial survey were the European School of Management and Technology (ESMT Berlin) and the Hertie School of Governance. More than 46,000 employees took part in the current survey. The results have continued to improve at a high level compared to 2017 and once again show a good compliance culture at Deutsche Telekom.

  • 98 percent of those surveyed accepted the rules of Deutsche Telekom and said they were not willing to behave unethically. The vast majority therefore stand by their own values and would not deviate from them even under pressure.
  • 88 percent stated, that their manager is a good role model regarding ethical behavior. 
  • Almost 90 percent stated that they feel well informed by the company how to behave appropriately at work and that they feel well prepared to deal with ethically questionable situations. 
  • A clear majority of respondents indicated that management leads by example regarding ethical behavior.
  • They identified weaknesses in the area of feedback culture. Some employees said they do not feel comfortable to speak out openly.

The weaknesses mentioned were discussed in management and led to a package of measures. The aim of the measures is to further strengthen the value-oriented compliance culture in the Group and to continue the positive trend in the future. Among other things, the virtual reality program “Managing Dilemmas” was introduced. It is intended to make it easier for employees to recognize critical situations and to behave correctly in these cases. In addition, the “Speak Up” culture was further fostered, among other things, by a new e-learning program.

We have been promoting group-wide cooperation for years with an annual meeting of representatives of all compliance departments of the national companies worldwide, the "International Compliance Days". New initiatives to promote compliance management are discussed there every year.

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. 

Since 2006, Deutsche Telekom's "Tell me!" whistleblower-portal has offered to all customers, employees, suppliers and all external parties the opportunity to report breaches of laws and internal rules and regulations at any time by e-mail, via the electronic whistleblower portal (BKMS), by mail or by telephone.

Confidentiality is guaranteed in accordance with legal requirements. Every incoming report - regardless of the way of reception - is checked and violations are pursued consistently.


Tip-offs "Tell me!"

2019

2018

2017

Reports (overall)

1.058

953

1.706

Compliance relevant tip-offs

122

137

146

thereof anonymous tip-offs

61

76

87

confirmed misconduct

38

46

43

in investigation

13

9

12

non-plausible/proven tip-offs

35

40

44

Hints: Most of the reports submitted in 2019 were related to fraud, breach of trust, embezzlement, theft, target manipulation and unfair sales practices, Tipp-offs reported to portals in a business unit are only counted for the central "Tell me!" portal if Group relevant.


Overview of information received about possible violations of laws or internal rules and regulations via Deutsche Telekom's "Tell me!" whistleblower-hotline

In 2019, Deutsche Telekom received 122 compliance-relevant tip offs via the whistleblower-hotline "Tell me!”. As of December 31, 2019, 27 hints were still undergoing plausibility checks, while 35 cases were found to be not valid after investigation. 60 plausible indications were investigated as compliance cases.

Tip-offs categorized by risk area as of the reporting date Dec. 31, 2019

Risk area

2019

Fraud/Breaches of trust

25

Target fraud, commision subsidies

20

Violation of policies

7

Breaches of procurement policies

2

Embezzlement, theft

2

Improper use of tangible & intangible assets

2

Obligation of employment contracts

11

Regulatory Affairs

10

DT Code of Conduct

7

Mobbing/Harassment

5

General equal treatment act/Discrimination

2

Breaches of other policies or laws

29

Note: For more information on data breaches, please click here.
For more information on human rights violations, please click here.


There were 60 plausible tip offs. After detailed investigation nine 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 2019.

14 of the 38 confirmed cases led to termination of the employment. In 15 cases, further measures were taken under labor law (written warning, admonition, personnel appraisal, et cetera). In five cases, consequences (instruction, duty-, procedural- and civil law measures, et cetera) were taken. In four cases no sanction could be carried out for factual or legal reasons (for example, one of the persons concerned had died before the sanction was imposed).

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Compliance

Principles, background and measures for compliance management at Deutsche Telekom.

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