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Aspect 5: Fighting corruption

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 (CMS) 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 CMS 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 CMS. Compliance officers implement the CMS and our compliance goals locally at the level of our operating segments and national companies.

Our CMS 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 take part in the CRA are selected using a risk-based approach according to the level of maturity of their compliance management system (maturity-based model).

The CRA methodology was adjusted in the reporting year and a focus CRA carried out. The focus CRA is a further evolution of the existing CRA approach. Under the new approach, the goal is to assess the effectiveness of the control environment in selected compliance risk areas. We piloted this approach in 2023, with the main focus being on our procurement processes. Ten international companies (the Europe and Systems Solutions operating segments) and one national company (Germany operating segment) participated in this focus CRA pilot project. The companies were selected according to risk, with a focus on international companies with their own procurement organization. Each of the Group companies was responsible for performing its own CRA. The central compliance organization managed the overall process, providing support and advice at all stages. Going forward, these focus CRAs will be alternated with the broader-based standard risk assessments using the existing methodology.

As a U.S.-listed company, T‑Mobile US conducts a risk assessment using its own methodology, on which it regularly reports to the relevant bodies, which also include representatives of Deutsche Telekom AG.

We regularly engage external auditors to audit our compliance management system in accordance with Auditing Standard 980 laid down by the Institute of Public Auditors in Germany (Institut der Wirtschaftsprüfer in Deutschland e.V. – IDW) focusing on the fight against corruption. A total of 22 domestic and international companies were therefore successfully audited in the 2020 and 2021 financial years and the effectiveness of their respective CMS verified. Alongside compliance processes, the audits focused in particular on processes that are exposed to an increased risk of corruption, for example, in procurement, sales, events, donations, sponsorships, mergers and acquisitions, and human resources. A further IDW AuS 980 audit of Deutsche Telekom AG and of selected Group companies is planned for the 2024 and 2025 financial years.

We regularly provide risk-oriented and target group-specific compliance and anti-corruption training. We rolled out an e-learning course on the fundamentals of compliance, including the fight against corruption, for all Group employees nationally and internationally (excluding T‑Mobile US) in the reporting year; it is available in 14 languages. 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 and, if needed, anonymously. We systematically investigate all tip-offs to the extent allowed by law – including those that reach us through other channels. We take actions against misconduct that are appropriate to the facts and degree of fault in line with the relevant laws and regulations. We have introduced a Group-wide reporting process to control and monitor these activities. In 2023, 85 compliance-related tip-offs were submitted via the TellMe portal (prior year: 81 tip-offs). Over the course of the year, 29 of these were confirmed to be cases of misconduct and dealt with accordingly.

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 requirements, 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 integrity checks and/or compliance business assessments. We have also been offering e-learning on compliance to our suppliers since 2014.

We will publish detailed information on our Supplier Code of Conduct in our 2023 CR Report.