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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. This materiality process takes into account the applicable requirements of the German Commercial Code (Handelsgesetzbuch – HGB). We continuously refine our materiality analysis. In 2023, key factors influencing the refining of the process were 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 2022 materiality analysis, which we reviewed in the reporting year to ensure it was fully up to date. In the course of a document analysis, among other points, we explored existing and forthcoming legislation, selected competitors, and the expectations of our stakeholders, e.g., the capital markets. We also considered the results of existing materiality analyses from four national companies (T‑Mobile US, T‑Mobile Polska, Hrvatski Telekom, and OTE) in order to incorporate a geographically and socially broad-based international perspective. In doing this, we considered both the negative and the positive impact of our business activities on the environment and on society along the entire value chain. In a further step, we assessed our financial sustainability opportunities and risks. The results were then validated in an internal workshop with participants from various functional units. The participants also contributed the concerns of various external stakeholders, whose views they are able to cover well due to their activities. This review process identified energy consumption in the supply chain and transportation as an additional key issue. Although the two topics of “collaboration with employees’ representatives and trade unions” and “occupational health and safety” are no longer 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
– Energy consumption in the supply chain and transportation
– 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 2023 CR Report.

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. The issues of climate protection, human rights due diligence (Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz)) and reputation, which we explain in the “Risk and opportunity management” section, are not to be classified as “very likely severe” within the meaning of § 289c (2) and (3) and § 315c HGB. We maintain the practice of reporting on these matters in order to also meet the transparency requirements of our stakeholders. 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.”