Corruption violates national and international law. We take a clear stance against any form of corruption in the public and private sector, whether this is active corruption in the form of bribery, or passive corruption in the form of bribe-taking. For this reason, our compliance management system is particularly geared towards preventing corruption.
Compliance management system
Our compliance culture is a key component for corporate governance based on integrity and respect. We have expressed our Group-wide commitment to complying with ethical principles and both legal and statutory requirements. We have incorporated this pledge in our Guiding Principles and our Code of Conduct.
We implemented a compliance management system with the aim of minimizing risks arising from systematic infringements of legal or ethical standards that could result in regulatory or criminal liability on the part of the Company, its executive body members, or employees, or result in a significant loss of reputation. The Board of Management considers its overall responsibility for compliance as a key leadership task. Our Chief Compliance Officer is responsible for the design and management of the compliance management system. Compliance officers implement the compliance management system and our compliance goals locally at the level of our operating segments and national companies.
Our compliance management system is based on the Compliance Risk Assessment (CRA), which we use to identify and assess compliance risks and introduce appropriate preventative measures. To this end, we have introduced a process to be carried out at regular intervals. The companies that will take part in the CRA are selected according to governance, based on the level of maturity of their compliance management system (maturity-based model). In the reporting year, the CRAs included 69 entities (61 companies and 8 central units) and covered 93.6 % (prior year: 98.1 %) of the workforce (according to the FTE figures for the fully consolidated companies and central units as of December 31, 2021). As a company listed on the United States stock exchange, T‑Mobile US uses its own methodology to carry out a risk assessment; it reports regularly on this risk assessment to the relevant bodies, which include representatives of Deutsche Telekom AG. The individual Group companies are responsible for conducting the CRA, with support and advice given from the central compliance organization. We have our compliance management system reviewed regularly by independent auditors, with particular attention paid to anti-corruption measures. Nine German companies were audited in 2020. A further 13 international companies were then assessed in 2021. A total of 22 companies were thus successfully audited in the 2020 and 2021 financial years. A further audit of companies yet to be selected is planned for 2024. The audits focused in particular on processes in the companies that are exposed to an increased risk of corruption, for example, in procurement, sales, events, donations, sponsorships, mergers and acquisitions, and human resources.
We regularly provide risk-oriented and target group-specific compliance and anti-corruption training. Employees can also obtain advice on compliance matters and on conduct based on our values and in line with the law on the AskMe advice portal.
Despite all precautions, we are not always able to prevent breaches of law or violations of regulations at the Company. Our TellMe whistleblower portal enables employees and external third parties to report potential breaches of compliance to the Compliance unit fully confidentially. In 2022, 81 compliance-related tip-offs were submitted via the TellMe portal (prior year: 87 tip-offs). Over the course of the year, 39 of these were confirmed to be cases of misconduct and dealt with accordingly. Within the scope of the legal framework available to us, we systematically pursue all tip-offs, including those that reach us via other channels, and implement commensurate sanctions in compliance with the relevant statutory provisions. We have introduced a Group-wide reporting process to control and monitor these activities.
With our Supplier Code of Conduct as an integral component of our General Terms and Conditions for Purchasing, we obligate our suppliers to, among other elements, refrain from any kind of corruption or conduct that could be interpreted as such. We select our business partners based on compliance criteria and, where required, conduct risk-oriented compliance business assessments. We have been offering regular e-learning training courses on compliance to our suppliers since 2014.
We will publish detailed information on our Supplier Code of Conduct in our 2022 CR Report at the end of March 2023.