ESRS G1 – Business conduct

ESRS 2 SBM-3 G1 – Material impacts, risks, and opportunities and their interaction with strategy and business model

No material impacts on society and the environment arising from our business conduct were identified in the double materiality assessment.

The following overview illustrates Deutsche Telekom’s material topic-specific risks and opportunities and their financial effects on our financial position, financial performance, and cash flows.

Risks and opportunities that represent a top risk in the next two years are described in the “Risk and opportunity management” section.

ESRS G1‑1 – Business conduct policies and corporate culture

The bedrock of our corporate culture is our values. We have incorporated these in our Guiding Principles, comprising customer focus, integrity and compliance, teamwork, and entrepreneurship. The Guiding Principles are the basis for our internal cooperation, but also for engagement with our customers, shareholders, and the general public. All managers and employees at Deutsche Telekom have an obligation to fill these values with life. Building on this, the Codes of Conduct of Deutsche Telekom and T‑Mobile US serve to make our Guiding Principles even more tangible. They define the rules for our daily work – both internally and externally. In doing so, they bridge the gap between the Guiding Principles and the many different policies in the Group as well as the legal regulations.

The management bodies are responsible for the business conduct of the individual Group companies at the highest level. We use regular employee surveys to evaluate and refine our corporate culture. These include questions on the corporate culture and how our employees perceive this culture in their everyday work. Where employees, business partners, or third parties are concerned that conduct does not comply with laws, our corporate culture, or internal policies, they can report this via our whistleblower portal – even anonymously if desired. This also includes tip-offs regarding human rights-related and environmental risks, as well as legal violations in our global supply chain. It can involve the actions of our employees in internal business units of Group companies, as well as those of our suppliers or business partners. For the investigation of internally or externally reported suspicions, we have implemented internal processes in which suspected violations are initially substantiated and, if necessary, further clarified in accordance with legal requirements. We have defined internal processes for reporting substantiated incidents to internal committees and supervisory bodies, depending on defined relevance thresholds.

In accordance with the applicable regulations, we have set up a whistleblower portal. We provide information to our employees about the whistleblower portal on the intranet, on the Company’s website, as part of compliance training, and in targeted awareness campaigns. We ensure that any reports received are handled by suitably qualified staff. For more information on how we measure the impact of our whistleblower portal, please refer to the section “ESRS S1‑3 – Processes to remediate negative impacts and channels for own workforce to raise concerns.” To protect whistleblowers we have implemented prevention measures in accordance with the national requirements. Deutsche Telekom has procedures in place to investigate any incidents connected to business conduct – including cases of corruption and bribery – promptly, independently, objectively, and lawfully.

We take a risk-based approach in our anti-corruption training: The frequency and content of the training courses vary depending on employees’ degree of exposure to compliance risks, including corruption and bribery. The Basic Knowledge Compliance e-learning is therefore geared towards all Deutsche Telekom employees. The e-learning is reviewed every 24 to 36 months, revised if necessary and rolled out again to ensure it is up to date. In addition, members of management bodies of operational entities are required to take part in classroom training every three years. Other e-learnings, for example on human rights, supplement the offering. We also communicate the principles of our business conduct and corporate culture in all internal media, including the intranet and mailings, and at townhall meetings. T‑Mobile US provides multiple enterprise-wide trainings focused on T‑Mobile US’s Code of Business Conduct each year. People managers receive additional training on the Code of Business Conduct and their responsibilities in upholding the Code. These trainings are refreshed each year. New employees receive New Employee Orientation training that covers all topics included in the Code of Business Conduct. Additionally, deeper dives into certain Code topics are assigned to individuals or specific business units based on potential risk exposure for the roles. These trainings are reviewed and updated on a regular cadence. Specialized Code training is given (either face-to-face or via video) to the executive body.

The policies in place at Deutsche Telekom to fight corruption and bribery are geared in particular towards the functions within the Group that are most at risk in terms of corruption and bribery. These include primarily the management bodies of our operational entities. In addition, each Group company can define further risk areas (e.g., procurement or sales) depending on the specific risk situation.

ESRS G1‑3 – Prevention and detection of corruption and bribery

We strive to avoid any risk that could question our integrity and cause harm to others. Deutsche Telekom has implemented a CMS that is particularly focused on preventing corruption. The CMS is implemented 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. T‑Mobile US has employed a risk-based approach to preventing corruption. T‑Mobile US has processes in place to assess its anti-corruption risk and the risk management activities in place to mitigate this risk.

To be able to live up to our responsibility, it is important that we are made aware of any misconduct that could have an impact on compliance. Deutsche Telekom offers all employees as well as outsiders an opportunity to report violations of legal requirements and internal policies with the TellMe whistleblower portal and, where relevant, the T‑Mobile US Integrity Line – even anonymously if desired. If requested, all reports will be treated in confidence to the extent permitted by law. Every report will be thoroughly examined, suspicions will be investigated, and any breaches rigorously pursued up. In regular compliance training sessions, we inform employees about the particular whistleblower portals.

Deutsche Telekom also expects its suppliers to comply with applicable law, observe social, ethical, and environmental standards as well as act sustainably. We also expect our suppliers to require the same of their subcontractors. We support our suppliers with a specially developed e-learning to help them act correctly. T‑Mobile US also uses compliance training to inform employees about its Integrity Line. T‑Mobile US has similar expectations as Deutsche Telekom for our suppliers. These expectations are outlined in the Supplier Code of Conduct of T‑Mobile US.

The CMS as a whole, its individual elements such as the whistleblower portals, and our training sessions are regularly evaluated, updated, and adjusted as necessary.

The Board of Management takes overall responsibility for compliance as an essential 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 compliance work pursues the following targets in particular:

• Promoting a compliance culture and ethical conduct
• Identifying, analyzing, and assessing compliance risk at an early stage
• Integrating preventive actions in business processes early and permanently, to prevent breaches of compliance
• Responding consistently to any breaches of compliance
• Minimizing liability risks for the Company
• Being viewed as a dependable partner by customers and business partners

The Chief Compliance Officer is part of the Law & Integrity department assigned to the Board of Management department for Human Resources and Legal Affairs. This means that Deutsche Telekom’s Compliance unit is organized independently from sales units. T‑Mobile US’ Board of Directors Nominating & Corporate Governance committee has oversight and responsibility for our Compliance and Ethics program. The Chief Compliance Officer of T‑Mobile US is responsible for designing and managing the Compliance & Ethics program of T‑Mobile US, and the compliance objectives of the program are similar to Deutsche Telekom’s.

We inform employees through various channels about strategies and processes of the company with which we prevent, detect, investigate, and prosecute allegations or incidents related to corruption and bribery. These channels include intranet postings, mailings, and compliance training sessions.

Deutsche Telekom’s training concept requires that all employees take the Basic Knowledge Compliance e-learning. This addresses the basic principles of compliance, the Code of Conduct, conflicts of interest, and anti-corruption and includes a self-check for decisions in difficult situations. As per our training concept, the management teams of the operational entities are deemed functions-at-risk. The Basic Knowledge Compliance e-learning is geared towards all employees and thus all functions-at-risk. In addition, we periodically conduct classroom training sessions on corruption and bribery with the members of management of the operational entities (training duration: 30–60 minutes, every three years). Where a Group company has classified other functions as at risk, they will also be included in the training program. Functions-at-risk are thus fully covered (100 %) by the training program.

We do not conduct specific compliance training sessions for Supervisory Board members. Where Deutsche Telekom employees are members of supervisory bodies, they receive general compliance training. T‑Mobile US provides annual compliance trainings to its executive team and Board of Directors (including directors with supervisory role).

ESRS G1‑4 – Incidents of corruption or bribery

In the 2024 financial year, Deutsche Telekom was not convicted of violating anti-corruption or anti-bribery laws.