Aspect 4: Respecting human rights
We place high priority on respecting human rights. This applies not only to our Company, but also to our business partners and our approximately 25,000 suppliers in more than 150 countries – whom we explicitly place under the same obligations.
There are still places in the world where human rights are not a given. As part of our global procurement activities, we can be exposed to country- and supplier-specific risks. These include, for example, inadequate local working and safety conditions. Violations cause severe damage to those affected and can result in reputational damage and negative financial consequences for companies.
For further information, please refer to the section “Risk and opportunity management.”
As a responsible company, we have made an express commitment to upholding the UN Guiding Principles on Business and Human Rights adopted by the United Nations Human Rights Council in 2011 (Ruggie Principles). The obligation to respect human rights is anchored in our core regulations – i.e., our Guiding Principles and our Code of Human Rights & Social Principles policy statement, both of which have been approved by the Group Board of Management and by the managing bodies in Group companies. This underscores our commitment to protecting human rights and to the goals of the German National Action Plan on Business and Human Rights (NAP) adopted by the Federal Government in 2016. At the same time, the code embodies our commitment to complying with the principles laid down by the International Labour Organization (ILO), the Organisation for Economic Co-operation and Development (OECD), the Universal Declaration of Human Rights, and the UN Global Compact. In addition to these voluntary commitments, we also recognize the minimum social safeguards which, in line with the provisions of the EU taxonomy, are necessary conditions for the taxonomy alignment of economic activities. This means that we comply with the legal requirements of the German Act on Corporate Due Diligence in Supply Chains, which will apply as of 2023 reporting year. We also require our suppliers to comply with all our guidelines related to human rights.
In order to implement our voluntary commitments and the legal requirements, we have introduced a comprehensive program for minimizing risks, which we are constantly updating. The core elements of the program are regular risk analyses in our own business area and at our suppliers’; a policy statement on human rights; awareness-raising among employees, suppliers, and business partners; a mechanism for lodging complaints; and reporting.
Regular reviews (Human Rights Impact Assessments, HRIA), which focus on respect for human rights and on the working conditions at our Company and at our suppliers, are a key component of the program. These systematic, comprehensive assessments allow us to ensure that human rights risks are identified and infringements can be prevented. Within the Group, we also focus our attention on preserving the right to collective agreements, and on ensuring diversity and equity. We publish the results of these assessments on our website. In 2022, we carried out HRIA assessments in three of our national companies: in Romania, in Slovakia, and in the Czech Republic. The aspect of digital ethics was included in these assessments for the first time. As part of our Digital Responsibility initiative, in 2022 we formulated our mission for the development of human-centered technology based on humanist values. This provides an additional frame of reference that supplements our existing guidelines, e.g., regarding our approach to artificial intelligence.
We will publish detailed information on this in our 2022 CR Report at the end of March 2023.
Employees and external third parties could raise concerns and make complaints, anonymously if necessary, in the 2022 financial year through our point of contact for human rights issues, humanrights@telekom, and via the TellMe whistleblower portal. We look into all tip-offs received, including those that reach us outside of these channels, and introduce countermeasures, provided the information is identified as plausible. In 2022, five tip-offs relating to human rights were received via the point of contact and the whistleblower portal (prior year: 7). Not all of these tip-offs were deemed plausible. As we received two tip-offs regarding a Greek supplier during the reporting year, we carried out an extensive on-site audit. A team of experts visited a total of ten sites unannounced to check for potential violations of working conditions and compliance requirements. No violations were found. Within three months of receipt of the tip-offs, a comprehensive investigation had been carried out and concluded in dialog with all those concerned.
In addition, we conduct an annual formal review of compliance with our Employee Relations Policy. During the reporting year, these reviews were carried out as part of the of HRIAs in Romania, Slovakia, and the Czech Republic. Following a review of this type, the results are discussed with the regional manager of the national company in question.
At Group Headquarters, we pushed forward in 2022 with the process of anchoring human rights due diligence in the different governance processes. Part of this involved including human rights and environmental aspects in the annual Compliance Risk Assessment. This provides the opportunity for us to identify risks in our own business area at an early stage. In addition, we held numerous workshops with the functional units at Group Headquarters to ensure that the new legal requirements resulting, for example, from the Act on Corporate Due Diligence in Supply Chains, are taken into account.
Our perception of ourselves as a company that acts in a socially and ecologically sustainable way includes assuming responsibility along our entire value chain. We have been working to improve sustainability throughout our supply chain for many years. Our strategy for sustainable procurement practices is embedded in our procurement processes (excluding T‑Mobile US). The heads of the CR and Procurement units are jointly responsible for its implementation. An escalation process calls for decisions to be made at Board of Management level in severe cases.
The Sustainable Procurement Group, a working group that has had an international focus since 2021, supports our national and international procurement units in implementing the sustainability requirements. At the same time, the group aims to promote discussion among employees in procurement. Our sustainability principles and their application in procurement are set out in the Procurement Practices in the Global Procurement Policy. In addition, there is a policy giving purchasing officers an overview of the CSR criteria that are to be taken into account at each stage of the procurement process. A CSR e-learning tool is available Group-wide to our employees in procurement providing training videos on the issue of sustainability in the procurement process.
As a rule, we require our suppliers to accept the principles of our Supplier Code of Conduct and meet the associated requirements. Nonetheless, we cannot guarantee that all of our suppliers are up to the standard. To minimize risks and support suppliers in further developing their sustainability performance, we use a comprehensive risk management system for suppliers. The preliminary step involves a risk assessment for all material groups based on a defined set of CSR criteria. In addition, we carry out a comprehensive risk analysis for all suppliers in every category. Specialized companies assess our suppliers with regard to financial, CSR and compliance risks (excluding T‑Mobile US). Sustainability performance is given a weighting of 20 % when we are selecting suppliers through invitations to tender. In this way, we can find out at an early stage if there is any increased risk with regard to specific sustainability aspects at any of our suppliers.
Sustainability assessments and reviews are additionally conducted for selected suppliers of product groups in high-risk categories. Depending on their individual sustainability performance and risk classification, we use a range of instruments, for instance, the information system EcoVadis, mobile employee surveys, and on-site supplier audits (social audits). Our focus here is not only on our direct suppliers but also, wherever possible, on downstream suppliers. We increase the effectiveness of our audits through our cooperation with the Joint Audit Cooperation (JAC), which currently consists of a large number of multinational telecommunications companies. In 2022, we carried out a total of 98 audits (prior year: 88) 83 social audits (prior year: 71) and 15 mobile surveys (prior year: 17), of which 40 (prior year: 34) at our direct and 58 (prior year: 54) at our indirect suppliers. Since 2010, we have carried out 910 audits (prior year: 812) within the framework of the JAC.
We work in close cooperation with our strategically important suppliers on improving their sustainability performance, for example, in terms of environmental protection, working hours regulations, and occupational health. This is done primarily as part of the development program we initiated for suppliers. Since 2018, we have been implementing this program on the basis of a voluntary industry-wide approach known as the Sustainable Development Programme (SDP). In 2021, the SDP was migrated to the JAC. Alongside Deutsche Telekom, which heads the project, Telefónica, Swisscom, and Orange are working together to refine the SDP on an ongoing basis in accordance with the JAC sustainability targets. In the reporting year, four further suppliers (two of Deutsche Telekom and two of Swisscom) were included in the JAC (prior year: four). Since the launch of the program in 2014, a total of 33 suppliers have completed the SDP, achieving measurable ecological, social, and economic progress. For example, in 2022 one supplier saved over 3 metric tons of new plastics by reusing recycled materials.
Sustainability in procurement is measured based on the following ESG KPIs: the Procurement Volume Without CR Risk ESG KPI – for which the target is 95 % by 2025 – measures the procurement volume from direct business partners on whom an established external service provider carried out checks in the reporting period for negative reports in the media and found no irregularities. It also includes suppliers for whom irregularities were identified, but where corresponding corrective action was taken. The share of this procurement volume subjected to a risk assessment amounted to 99.6 % in 2022 (prior year: 99.7 %). The Procurement Volume Verified as Non-Critical ESG KPI – target for 2025: 60 % – by contrast, measures the share accounted for by suppliers checked for social and ecological criteria by means of dedicated reviews – e.g., through EcoVadis, the CDP, social audits, supplier visits, or our Supplier Development Programme. In 2022, the share of these CR-verified suppliers was 64.1 % (prior year: 60 %). In each case, the calculation is based on the Group-wide procurement volume that is already uniformly mapped to a large extent (excluding the Network Capacity category and T‑Mobile US), but on different levels of supplier relationships.
Detailed information on our supplier management and measures preparing for the implementation of the Act on Corporate Due Diligence in Supply Chains will be published in our 2022 CR report at the end of March 2023.