Deutsche Telekom AG recently completed in 2020/21 a comprehensive human rights gap assessment for its central processes. This assessment reviewed how its current systems and practices perform against emerging requirements of human rights due diligence in Germany and Europe. It identified strengths and improvement opportunities of Deutsche Telekom AG's human rights approach.
Why we did a human rights gap assessment
Regulation and stakeholder interest for corporate human rights due diligence are on the rise. To name a few examples: at the time of writing, Germany is in the process of adopting a German Supply Chain Law in 2021; joining France, the UK, the Netherlands and the EU in establishing mandatory rules for human rights due diligence.
Deutsche Telekom is a leader in sustainability. This includes understanding and reducing negative impacts on the rights of people. This human rights gap assessment helped us identify our way forward in evolving Deutsche Telekom’s human rights approach in order to meet expectations of our stakeholders and address rising needs in the coming years.
The assessment showed that Deutsche Telekom AG operates in line with international requirements in multiple aspects of human rights due diligence. Some improvement areas were identified which shall be addressed to meet coming needs of future regulation and increasing challenges of the environment DTAG is operating in.
Examples of positive practices in Deutsche Telekom’s current due diligence systems:
- A large variety of risk assessments, which cover different aspects of human rights risks, such as compliance risk assessments, occupational health and safety assessments or digital security risk assessments. These are complemented by regular corporate social responsibility assessment, including human rights impact assessments in high-risk markets, employee reviews, or sustainable supply chain assessments.
- Good practices in the realm of digital risk, including high standards to protect the right to privacy, processes to address the ethics of artificial intelligence and an emerging digital responsibility program.
- Multiple grievance mechanisms are in place, ranging from the groupwide TellMe! System to specific mechanisms for privacy concerns or infrastructure deployment.
Examples of action areas that were identified:
- Analysis, update and check of the completeness and relevance of human rights risks assessed regularly, to include more industry-specific human rights risks
- Broadening of deep dives in certain key issue areas, such as procurement, digital responsibility, or grievance management
- Updates of key policy commitments to incorporate coming changes
- Increase of external communication
Deutsche Telekom sees human rights due diligence as a continuous process. The findings of this human rights gap assessments will guide its activities in the short, medium- and long-term. Currently, Deutsche Telekom AG is updating its Code of Human Right as part of the regular review cycle on our policies. We want to include new requirements and a broader range of human rights issue areas. In addition we updated our human rights engagement on our websites and incorporated more information such as our most recent human rights map.
How we did it
The project was conducted between June 2020 and April 2021 by management consultancy twentyfifty GmbH.
The gap assessment was
- based on international standards for corporate human rights due diligence, esp. the UN Guiding Principles for Human Rights and Business and the OECD Guidelines for Multinational Enterprises;
- informed by numerous interviews with internal stakeholders and the review of internal and external documents and processes;
- included a human rights map which was developed to show the ‘territory’ of relevant human rights themes for Deutsche Telekom AG.
Human rights at Deutsche Telekom
In its Code of Human Rights & Social Principles Deutsche Telekom AG's has committed to respect internationally recognized human rights in its operations and supply chains. Based on this commitment Deutsche Telekom AG implements human rights due diligence in line with the UN Guiding Principles on Business & Human Rights. Deutsche Telekom AG continuously evolves its approach and activities in line with changing expectations.