Maturity-oriented compliance: tailor-made Compliance Management

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The maturity-oriented approach of Deutsche Telekom creates tailored solutions considering the specific characteristics of Deutsche Telekom and its subsidiaries.

Over the last years, Deutsche Telekom has established a comprehensive compliance management system. We expanded our Compliance Management and introduced the maturity-oriented approach in 2013. The aim was to continue to prevent violations and to minimize risks in the future – but at the same time to adjust the scope of the compliance measures and requirements depending on the relevant business model and area of the subsidiary. In this way, we create spaces for operational businesses and ensure adequate compliance in our subsidiaries.

Our maturity-oriented Compliance Management follows the assumption that a company like Deutsche Telekom with its numerous and diverse subsidiaries needs customized compliant solutions for each type of entity. Subsidiaries on new markets with new products or cooperation with start-ups need other support than for example international corporate businesses. On the hand, big multinational subsidiaries require a complex and formal Compliance management including intensive training, specific processes to detect and track misconduct as well as regular reports to the Board of Management and the Supervisory Board. Small subsidiaries on the other hand, which are less exposed to risks are in need of controls by the management or just a strong commitment to the company principles for example.

We therefore defined gradually increasing minimum requirements for Compliance Management according to the business area, the economic development and risk exposure of the subsidiary. We also defined how the relevant Compliance Management is to be set up, structured and monitored precisely. Although this represents a departure from the "one-size-fits-all" approach, we continue to ensure the necessary protection level of all subsidiaries and to meet formal requirements (including German Assurance Standard 980 or US Guiding Principles). At the same time, we increase the acceptance of compliance, as we reduce unnecessary reporting.

This anticipatory management approach has already proved itself in our business practice successfully. For instance, there is a greater consistency in incorporating acquired entities, we have increased the transparency of compliance requirements to be fulfilled and made them more efficient. Since 2018, we have been steering this model with the help of an IT system.