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Process for determining significant topics

For some two decades now, we have determined the topics that are relevant for our sustainability strategy and for our reporting on the basis of a materiality process that we are continually refining. In 2022, key factors influencing the refining of the process were changes to the requirements laid down in the GRI standards 2021 and the requirements stipulated in the CSRD, which will be relevant for our reporting as of the 2024 reporting year. However, since the CSRD will have the effect of changing the materiality criteria, we selected the topics for the present NFS based on the results of the 2021 materiality analysis, which we reviewed in the reporting year to ensure it was fully up to date. To review the key topics, we performed a document analysis in order to explore aspects such as existing legislation and the expectations of our stakeholders, for example, the capital markets. We then supplemented this with interviews with internal and external experts. In doing this, we considered both the negative and the positive impact of our business activities on the environment and on society along the value chain, and in a further step, we assessed our financial sustainability opportunities and risks. We then held an internal workshop to validate the results and to discuss potential strategic implications. This review process did not identify any new topics for the NFS in 2022. Consequently, there is no need to include further issues in the NFS for 2022. Although the two topics of “collaboration with employees’ representatives and trade unions” and “occupational health and safety” are not considered to be key topics, we continue to include them in our reporting. The key topic of “service quality” constitutes a central aspect of customer satisfaction.

For further information on customer satisfaction, please refer to the sections “Group strategy” and “Management of the Group.”

The issues are assigned to the aspects as shown below and can be found in the corresponding sections of the NFS:





1. Environmental concerns

– Climate protection
– Resource conservation

2. Employee concerns

– Collaboration with employees’ representatives and trade unions
– Diversity, equity, and inclusion
– Occupational health and safety

3. Social concerns

– Network access and digital responsibility
– Connect the unconnected
– Data privacy and data security

4. Respecting human rights

– Labor standards in our own business area and at our suppliers

5. Fighting corruption

– Compliance management system

We will publish detailed information on the materiality process in our 2022 CR Report at the end of March 2023.

As part of our comprehensive risk and opportunity management system, we determine existing and potential risks and opportunities arising from environmental, economic, or social aspects, and from our corporate governance. As part of this process, we take into account the results of the financial assessment of the sustainability risks and opportunities in the materiality analysis. Topics such as climate protection, suppliers, and reputation involve potential risks, which we have outlined in the section “Risk and opportunity management.” We maintain this practice to provide the transparency our stakeholders expect, even if the risk assessment has found that these topics do not need to be rated as “very likely severe” in the meaning of § 289c (2) and (3) and § 315c HGB. The present NFS focuses on these risks and opportunities in relation to the relevant aspects.

For further information, please refer to the section “Risk and opportunity management.”