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

LIMITED AND REASONABLE ASSURANCE REPORT OF THE INDEPENDENT PRACTITIONER REGARDING THE COMBINED NON-FINANCIAL STATEMENT FOR THE FINANCIAL YEAR FROM 1 JANUARY TO 31 DECEMBER 2023

 

To Deutsche Telekom AG, Bonn/Germany

Engagement

We have performed a limited and reasonable 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 1 January to 31 December 2023 (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 German Commercial Code (HGB), Sections 315c in conjunction with 289c to 289e HGB and Article 8 of Regulation (EU) 2020/852 of the European Parliament and the Council of 18 June 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 thereunder, as well as with the interpretation of the wording and terminology contained in the EU Taxonomy Regulation and the delegated acts adopted thereunder 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 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 thereunder 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 thereunder in the 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 firm applies the national statutory rules and professional announcements – particularly of the “Professional Charter for German Public Auditors and German Sworn Auditors” (BS WP/vBP) and of the Quality Management Standards promulgated by the Institut der Wirtschaftsprüfer (IDW), and accordingly maintains a comprehensive quality management system that includes documented policies and procedures with regard to compliance with professional ethical requirements, professional standards as well as 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 (ISAE) 3000 (Revised): Assurance Engagements Other than Audits or Reviews of Historical Financial Information, 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 for the period from 1 January to 31 December 2023 have been stated by the executive directors, in all material respects, in accordance with Sections 289c to 289e, Sections 315c in conjunction with 289c to 289e HGB; we do not, however, provide a separate conclusion for each indicator; 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, 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 HGB, Sections 315c in conjunction with 289c to 289e HGB, and the EU Taxonomy Regulation and the delegated acts adopted thereunder, as well as the interpretation by the executive directors disclosed in the 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 2023 and February 2024, we performed, among others, the following assurance procedures and other work:

  • Gaining an understanding of the structure of the Group’s sustainability organisation and stakeholders engagement,
  • Inquiries of relevant employees involved in the preparation of the combined non-financial statement about the preparation process, about the internal control 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.

In determining the disclosures in accordance with Article 8 of the EU Taxonomy Regulation, the executive directors are required to interpret undefined legal terms. Due to the immanent risk that undefined legal terms may be interpreted differently, the legal conformity of their interpretation and, accordingly, our assurance engagement thereon are subject to uncertainties. This uncertainty, in particular, also affects the quantification of performance indicators in measuring and/or evaluating these performance indicators.

Practitioner’s Conclusions

We conclude that the indicators “energy consumption” and “CO2 emissions (Scope 1 and 2)” presented in the combined non-financial statement for the period from 1 January to 31 December 2023 have been stated by the executive directors, in all material respects, in accordance with Sections 289c to 289e, 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 for the financial year from 1 January to 31 December 2023 have not been prepared, in all material respects, in accordance with the Sections 289c to 289e HGB, Sections 315c in conjunction with 289c to 289e HGB and the EU Taxonomy Regulation and the delegated acts adopted thereunder, 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 or 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 1 January 2017 promulgated by the Institut der Wirtschaftsprüfer (IDW)). We draw attention to the fact that the assurance engagement was conducted for the Company’s purposes and that the report is intended solely to inform the Company about the result of the assurance engagement. Consequently, it may not be suitable for any other purpose than the aforementioned. Accordingly, the report is not intended to be used by third parties for making (financial) decisions based on it.

We are liable solely to the Company. We assume no responsibility with regard to any third parties. Our conclusion was not modified in this respect.

 

Düsseldorf/Germany, 21 February 2024

Deloitte GmbH
Wirtschaftsprüfungsgesellschaft

 

Signed:
Dr. Tim Hoffmann
Wirtschaftsprüfer
(German Public Auditor)

Signed:
Dr. Matthias Schmidt

Sustainable Development Goals (SDGs)
Goals that form the core of the 2030 Agenda, which the member states of the United Nations adopted in 2015 to ensure sustainable global development. The aim is to enable economic development and prosperity – in line with social justice and taking account of the ecological limits of global growth. The Agenda applies equally to all nations of the world. The 17 SDGs define goals to reduce poverty and hunger, promote healthcare and education, enable equality, protect the environment and climate, and make consumption sustainable.
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