Independent practitioner’s report on a limited assurance engagement on non-financial reporting

INDEPENDENT PRACTITIONER’S REPORT ON A LIMITED ASSURANCE ENGAGEMENT ON NON-FINANCIAL REPORTING

To Deutsche Telekom AG, Bonn

Engagement

We have performed an assurance engagement on the consolidated non-financial statement of Deutsche Telekom AG, Bonn/Germany, (hereafter referred to as “the Company”), which has been combined with the non-financial statement of the Company, and which is contained in the combined management report of the parent and the group, for the financial year from January 1 to December 31, 2022 (hereafter referred to as “combined non-financial statement”). As requested, we have performed a reasonable assurance engagement on the indicators “energy consumption” and “CO₂ emissions (Scope 1 and 2)” presented in the combined non-financial statement (hereafter referred to as the “indicators”) and a limited assurance engagement on all other disclosures contained in the combined non-financial statement.

Our engagement does not cover the external sources of documentation and expert opinions stated in the combined non-financial statement nor the references to the United Nations Sustainable Development Goals (SDG) marked with the SDG symbol.

Responsibilities of the Executive Directors

The executive directors of the Company are responsible for the preparation of the combined non-financial statement in accordance with Sections 289c to 289e, 315c in conjunction with 289c to 289e German Commercial Code (HGB) and Article 8 of Regulation (EU) 2020/852 of the European Parliament and the Council of June 18, 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (hereafter referred to as “EU Taxonomy Regulation”) and the delegated acts adopted thereon, as well as with the interpretation of the wording and terminology contained in the EU Taxonomy Regulation and the delegated acts adopted thereon by the executive directors, as is presented in section “Compliance with the EU taxonomy transparency requirements” of the combined non-financial statement (hereafter referred to as “interpretation”).

These responsibilities of the executive directors of the Company include the selection and application of appropriate methods regarding the combined non-financial statement and the use of assumptions and estimates for individual non-financial presentations and disclosures of the Group which are reasonable under the given circumstances. In addition, the executive directors are responsible for such internal control as they have determined necessary to enable the preparation of a combined non-financial statement that is free from material misstatement, whether due to fraud (i.e. fraudulent combined non-financial statement) or error.

Some of the wording and terminology contained in the EU Taxonomy Regulation and the delegated acts adopted thereon are still subject to considerable interpretation uncertainty and have not yet been officially clarified. Therefore, the executive directors have laid down their own interpretation of the EU Taxonomy Regulation and of the delegated acts adopted thereon in section “Compliance with the EU taxonomy transparency requirements” of the combined non-financial statement. They are responsible for the reasonableness of this interpretation. As there is the immanent risk that indefinite legal concepts may allow for various interpretations, the legal conformity of the interpretation is prone to uncertainty.

The preciseness and completeness of environmental data of the combined non-financial statement, which include the indicators, is subject to inherent restrictions resulting from the way in which the data was collected and calculated and from the assumptions made.

Independence and Quality Assurance of the Audit Firm

We have fulfilled the requirements of German professional law on independence and further professional rules of conduct.

Our audit firm applies the national statutory rules and professional pronouncement – especially the Professional Charter for German Public Auditors and Sworn Auditors (BS WP/vBP) as well as the Quality Assurance Standard: Quality Assurance Requirements in Audit Practices (IDW QS 1) promulgated by the Institut der Wirtschaftsprüfer (IDW) – and therefore maintains an extensive quality assurance system comprising documented rules and measures in respect of compliance with professional rules of conduct, professional standards and relevant statutory and other legal requirements.

Responsibilities of the Independent Practitioner

Our responsibility in each case is to express a conclusion on the indicators “energy consumption” and “CO₂ emissions (Scope 1 and 2)” presented in the combined non-financial statement based on our work performed within our reasonable assurance engagement as well as to express a conclusion on all other disclosures contained in the combined non-financial statement based on our work performed within our limited assurance engagement.

We conducted our work in accordance with the International Standard on Assurance Engagements 3000 (Revised): “Assurance Engagements Other than Audits or Reviews of Historical Financial Information (ISAE 3000 (Revised))”, issued by the IAASB. This standard requires that we plan and perform the assurance engagement so that we

• obtain reasonable assurance to conclude whether the indicators presented in the combined non-financial statement of the Company for the period from January 1 to December 31, 2022 have been stated by the executive directors, in all material respects, in accordance with Sections 315c in conjunction with 289c to 289e HGB, and
• obtain limited assurance to conclude whether matters have come to our attention to cause us to believe that all other disclosures contained in the combined non-financial statement of the Company, with the exception of the external sources of documentation and expert opinions stated therein and the references to the United Nations Sustainable Development Goals (SDG) marked with the SDG symbol, have not been prepared, in all material respects, in accordance with Sections 289c to 289e, 315c in conjunction with 289c to 289e HGB, and the EU Taxonomy Regulation and the delegated acts adopted thereon, as well as with the interpretation by the executive directors presented in section “Compliance with the EU taxonomy transparency requirements” of the combined non-financial statement.

The procedures performed in that part of our engagement to obtain limited assurance are less in extent than for a reasonable assurance engagement; consequently, the level of assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed. The choice of assurance work is subject to the practitioner’s professional judgement.

Within the scope of our assurance engagement, which we mostly performed between October 2022 and February 2023, we performed, among others, the following procedures and other work:

• Gaining an understanding of the structure of the sustainability organisation of the Group, and of the stakeholders’ engagement,
• Inquiries of relevant personnel involved in the preparation process about the preparation process, about the internal controls relating to this process and about disclosures in the combined non-financial statement,
• Identification of potential risks of material misstatement in the combined non-financial statement,
• Analytical evaluation of selected disclosures in the combined non-financial statement,
• Comparison of selected disclosures with corresponding data in the consolidated and annual financial statements and the combined management report,
• Evaluation of the presentation of the combined non-financial statement,
• Evaluation of the process to identify taxonomy-eligible and taxonomy-aligned economic activities and the corresponding disclosures in the combined non-financial statement.

In addition to the above, we performed the following procedures and other work within the scope of that part of our assurance engagement performed to obtain reasonable assurance regarding the indicators presented in the combined non-financial statement of the Company:

• Evaluation of the design and implementation of the systems and processes for determining, processing and monitoring the disclosures relating to the indicators,
• Risk evaluation,
• Tests of details on a sample basis.

The determination of the disclosures in accordance with Article 8 of the EU Taxonomy Regulation requires the executive directors to interpret indefinite legal concepts. As there is the immanent risk that indefinite legal concepts may allow for various interpretations, the legal conformity of the interpretation, and hence our related examination, is prone to uncertainty. This uncertainty, in particular, also affects the quantification of performance indicators in measuring and/or evaluating these performance indicators.

Practitioner’s Conclusion

We conclude that the indicators “energy consumption” and “CO₂ emissions (Scope 1 and 2)” presented in the combined non-financial statement of the Company for the period from January 1 to December 31, 2022 have been stated by the executive directors, in all material respects, in accordance with Sections 315c in conjunction with 289c to 289e HGB.

Based on the work performed and the evidence obtained, nothing has come to our attention that causes us to believe that all other disclosures in the combined non-financial statement of the Company for the financial year from January 1 to December 31, 2022 have not been prepared, in all material respects, in accordance with the Sections 289c to 289e, 315c in conjunction with 289c to 289e HGB as well as the EU Taxonomy Regulation and the delegated acts adopted thereon, as well as with the interpretation by the executive directors presented in section “Compliance with the EU taxonomy transparency requirements” of the combined non-financial statement.

We do not express a conclusion on the external sources of documentation and expert opinions stated in the combined non-financial statement nor on the references to the United Nations Sustainable Development Goals (SDG) marked with the SDG symbol.

Restriction of Use

We issue this report as stipulated in the engagement letter agreed with the Company (including the “General Engagement Terms for Wirtschaftsprüfer and Wirtschaftsprüfungsgesellschaften (German Public Auditors and Public Audit Firms)” as of January 1, 2017 promulgated by the Institut der Wirtschaftsprüfer (IDW)). We draw attention to the fact that the assurance engagement was performed for the purposes of the Company and the report is solely designed for informing the Company about the findings of the assurance engagement. Therefore, it may not be suitable for another than the aforementioned purpose. Hence, this report should not be used by third parties as a basis for any (asset) decision.

We are responsible solely to the Company. However, we do not accept or assume any responsibility to third parties. Our conclusion was not modified in this respect.

Düsseldorf, February 21, 2023

Deloitte GmbH
Wirtschaftsprüfungsgesellschaft