ESRS S1 – Own workforce

ESRS 2 SBM-3 S1 – Material impacts, risks, and opportunities and their interaction with strategy and business model

The table below shows the material impacts of our business activities on society and the environment that we have identified through the double materiality assessment.

We provide overarching information on how material impacts, risks, and opportunities interact with our strategy and business model in section “ESRS 2 SBM-3 – Material impacts, risks, and opportunities and their interaction with strategy and business model.”

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.

Employees affected by material impacts only include persons in our own workforce who are directly employed by Deutsche Telekom. Freelancers and workers from temporary employment agencies are not considered and not reported, since – in relation to internal, active workforce – they only account for a small number of people.

ESRS S1‑1 – Policies related to own workforce

Working conditions (social dialogue, freedom of association, the existence of works councils and the information, consultation, and participation rights of workers) Across the globe, Deutsche Telekom is committed to freedom of association and collective bargaining and complies with the relevant national legislation. As the underlying laws and contracts vary from country to country, we manage co-determination matters locally.

Our approach to managing the material impacts in relation to social dialogue and freedom of association is enshrined in our Code of Human Rights. This Code outlines our values and standards, which are set forth in greater detail in our policies, instructions, and processes, creating our framework for action. The principles and expectations described in the Code are also aimed in equal measure at our employees and at our suppliers and business partners. We commit to respect and promote human rights and environmental matters everywhere we operate, including in our supply chains and at our business partners.

Our principles and expectations formulated in the Code include the following:

• Protection of freedom of association and the right to collective bargaining
• Promotion of occupational health and safety at work
• Prohibition of unequal treatment in employment
• Payment of adequate living wage
• Zero-tolerance approach to violence, discrimination, or harassment of any sort
• Training and skills development
• Prohibition of child labor, forced labor, and all forms of slavery as well as human trafficking.

Our Supplier Code of Conduct, which we describe in section “ESRS S2‑1 – Policies related to value chain workers,” requires our suppliers and business partners to comply with the principles and values set out there. These are based on the Code of Human Rights.

The Code of Human Rights can be accessed on our website by all Deutsche Telekom employees, their representatives, and external parties.

For further information on our Supplier Code of Conduct, please refer to section “ESRS S2‑1 – Policies related to value chain workers.”

The Code of Human Rights is an integral part of our policy statement on human rights. Since 2017, the Group Board of Management’s commitment to respecting human rights in accordance with internationally recognized human rights standards has been manifested in the “Code of Human Rights & Social Principles”. Because our focus topics in social and environmental matters may change as our Company evolves, we continuously review our related due diligence and amend the Code as needed. This was last updated in 2023. Content such as the existing Employee Relations Policy as well as additional information on shaping employee relations and employee concerns were integrated. The current structure of the revised Code of Human Rights is in line with the requirements of the German Act on Corporate Due Diligence in Supply Chains (Lieferkettensorgfaltspflichtengesetz – LkSG) and describes the implementation of our human rights and environment-related due diligence processes, including the internal complaints mechanism. The revised and externally published Code of Human Rights started to be adopted by the involved Group companies in 2023. The updated Code of Human Rights is required to be implemented by all Group companies over which Deutsche Telekom AG exerts a controlling influence as defined by the LkSG and which carry out relevant business activities that are established on a permanent basis and not limited to holding investments. A total of 144 Group companies meet these criteria. By December 31, 2024, 134 Group companies had implemented the updated Code of Human Rights.

T‑Mobile US does not fall under the scope of the LkSG and applies its own Human Rights Statement that also addresses the above-mentioned principles and expectations. T‑Mobile US expects its own workers as well as all its affiliated companies, business partners, suppliers, and stakeholders to comply with this commitment. All T‑Mobile US employees and external parties can access its Human Rights Statement on the T‑Mobile US website.

The Code of Human Rights is based on our human rights strategy. This strategy is implemented by GCR, for which the Chair of the Board of Management is responsible. Monitoring implementation of the rules set out in the Human Rights Statement by T‑Mobile US is the responsibility of the senior management of Human Resources, Corporate Social Responsibility, and Legal Affairs at T‑Mobile US.

The Code of Human Rights is our commitment to internationally recognized human rights and environmental law benchmarks, such as the United Nations International Bill of Human Rights, the core labor standards of the International Labour Organisation (ILO), the Guidelines for Multinational Enterprises of the Organisation for Economic Co-operation and Development (OECD), and the United Nations Guiding Principles on Business and Human Rights. In addition to this, we also commit to the minimum social safeguards which, in line with the provisions of the EU Taxonomy, are necessary conditions for the taxonomy alignment of economic activities. The minimum social safeguards require a management system that can monitor compliance with the benchmarks referred to above. We accordingly perform human rights due diligence using a risk-based management system encompassing both the Group (Deutsche Telekom excluding T‑Mobile US) and our supply chain and that we use to monitor compliance with social and environmental standards. We also maintain a process of trust-based dialogue with employees’ representatives and trade unions. Deutsche Telekom created the roles of human rights officer and LkSG officer in order to monitor the effectiveness of the LkSG management system. Where required to under national regulations, Group companies have appointed monitoring roles in the same form for their business areas. A company’s own business activities are defined in § 2 (6) of the LkSG as “any activity of the company to achieve its business objective” and are the same as Deutsche Telekom’s “own business activities” referred to consistently elsewhere in the Annual Report. T‑Mobile US performs a risk assessment using its own methodology.

For further information, please refer to the section “ESRS S2‑4 – Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions.”

If, on the basis of our performed risk analysis, we establish that a violation of our human rights obligations has already occurred or is imminent, our processes provide for taking immediate remedial action. These aim to prevent or end the violation or to minimize its extent.

For further information, please refer to the section “ESRS S1‑4 – Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions.”

Since 2016, Deutsche Telekom has had a program in place to ensure compliance with its human rights and environment-related due diligence. This program is aligned with the international benchmarks specified above. We conducted a human rights impact analysis as part of the program. This was based on the international benchmarks and involved both external and internal experts. The analysis allowed us to identify groups of individuals that may be positively or negatively impacted by our business activities and to take their interests into consideration when preparing the Code of Human Rights. They include employees in our Group companies, employees at our direct and indirect suppliers, individuals at our customers, children and young people, as well as people in affected communities. When carrying out our due diligence processes, we therefore pay special attention to the interests of particularly vulnerable groups such as children, young people, women, migrant workers and other members of national or ethnic, religious or linguistic minorities. We are constantly refining our procedures for identifying vulnerable groups. We review them at least once a year after conducting our annual human rights and environmental risk analysis.

Working conditions (health and safety) Occupational health and safety is firmly incorporated in our structures through certified management systems as well as suitable policies and guidelines. This helps us address the material impacts on the health and safety of our employees caused by office-based activities and by network development activities such as civil engineering. To do this, we use an integrated management system for health, safety, and environment (HSE). It is based on the international standards ISO 45001 and ISO 14001 and takes into account the Luxembourg Declaration on Workplace Health Promotion in the European Union and the United Nations Global Compact. Some of our Group companies use an integrated HSE quality management system that also covers the ISO 9001 international standard for quality management. Some of the Group companies are not covered by an umbrella certificate because they have their own certifications. In the Code of Human Rights, we also commit to providing occupational health and safety in the workplace for our employees that is at least equal to the level required by applicable law, and we are continuously working to further improve our working conditions.

Our HSE management system contributes to making sustainability a component of all our business processes and of our employees’ everyday lives. It helps us to systematically plan, implement, and improve our HSE processes. It also assists us in bidding on new projects in which potential commercial customers require their suppliers to provide HSE certificates. The general responsibilities, duties, and programs for health and safety management are defined in our manual for the management system for quality, health, safety, and environmental protection. The manual serves to harmonize our management systems across the Group and align them in a targeted manner. The HSE management system supports health management by positively influencing the health of our employees. Deutsche Telekom also uses the management system to reduce the number of accidents at work. This system enables us to develop an action plan for occupational health and safety to further improve employees’ safety, keep employees healthy, and to improve their performance. To ensure that the requirements of ISO 45001 are met, we regularly carry out internal audits at selected locations and engage independent external certification authorities to conduct annual reviews.

The HSE management system is applicable throughout the Group and covers all our activities, products, and services: fixed network/broadband, mobile communications, internet, internet-based TV products and services, as well as information and communication-related solutions for business customers of Deutsche Telekom. Our HSE responsibility also extends to monitoring of outsourced processes.

The Board of Management department for Human Resources and Legal Affairs has overarching responsibility for managing occupational health and safety. Information about Deutsche Telekom’s HSE management system is documented centrally in the intranet, where it is accessible to all employees (Deutsche Telekom excluding T‑Mobile US). T‑Mobile US employees are provided with the relevant documents by central HSE certification management in Germany. In accordance with the requirements of ISO 45001, all employees can participate actively in designing our occupational health and safety actions.

Equal treatment and opportunities for all (diversity; employment and inclusion of persons with disabilities; gender equality and equal pay for work of equal value). Fostering diversity, equity, and inclusion (DE&I) is an integral part of our corporate identity. We offer all employees – irrespective of age, ethnic origin and nationality, gender and gender identity, physical and mental abilities, religion, faith and belief, sexual orientation, and social origin – a wide range of development opportunities. Moreover, we do not tolerate any form of direct or indirect violence, discrimination, or harassment in the workplace. Our Diversity, Equity, and Inclusion (DE&I) Policy, which was revised and implemented throughout the Group in 2021, and our Code of Human Rights constitute important cornerstones for promoting the various aspects of diversity and eliminating discrimination.

The DE&I Policy applies to all our employees. This also includes people who are functionally equivalent to employees, for example temporary agency workers. The Deutsche Telekom Group units are responsible for implementing the Policy in their own organizations. At least every three years, the responsible HR department reviews the provisions of the Group policy to determine whether they need to be amended or adapted, and revises them if necessary. When the Policy was prepared and updated, the interests of our own workforce were taken into account through repeated consultation with selected employees. Besides the fundamental international human rights benchmarks, the Policy complies with the requirements of the EU anti-discrimination directives and applicable local laws in the countries in which we operate. Ultimate responsibility for implementing the Policy lies with the Board of Management department for Human Resources and Legal Affairs.

The DE&I Policy can be downloaded from Deutsche Telekom’s website.

In addition to the DE&I Policy, we actively promote accessibility, equality, and the inclusion of people with disabilities through a comprehensive portfolio of actions. Our aim is not just to provide them with a secure livelihood, but also to continuously promote their career advancement. To make our working environment even more inclusive and implement our DE&I Policy in the business units, we are developing both area-specific and cross-divisional action plans. These address all dimensions of diversity.

For further information on the implementation of selected actions, please refer to the section “ESRS S1‑4 – Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions.”

ESRS S1‑2 – Processes for engaging with own workforce and workers’ representatives about impacts

We pursue dialogue-oriented employee relations throughout the Group and engage in trust-based, constructive collaboration with employees’ representatives and trade unions. We manage co-determination matters locally. The Group Board of Management is generally involved in issues of particular importance.

Works councils, central works councils, and the Group Works Council represent the interests of employees in Germany. Our social partner representing the employees’ interests on a European level is the European Works Council (EWC). Even in non-European nations like the United States, all of our employees enjoy the right to form and join trade unions. We also have executive staff representation committees and representatives of persons with disabilities at unit, company, and Group level. The employees’ representation bodies represent the employees in different committees, such as at the meetings of the health and safety committee for occupational safety and occupational medicine matters.

Our employee surveys are a key participation format and indicator of the relationship between the Company and our workforce. These surveys are carried out in all Group companies at least every two years. The results of the surveys help us to identify weak points and determine where there is room for improvement. We use the engagement score, which we determine based on the findings of the most recent surveys at the time, as a benchmark for employee satisfaction (Deutsche Telekom excluding T‑Mobile US).

For more information on our non-financial performance indicator for employee satisfaction (engagement score), please refer to the section “Management of the Group.”

T‑Mobile US conducts its own employee survey (“Our Voice Survey”), which is sent at least annually to all employees. The survey measures sentiment across six key areas of employee engagement that span belonging, well-being, career development, culture, and leadership support.

We also involve our workforce – for example our employee networks – when preparing policies and guidelines or when developing learning and upskilling formats. We are working with our employee networks to identify and break down systemic barriers – for example, by asking how inclusive our recruitment processes are. This aims to ensure that all employees are continuously included in these processes. Furthermore, our employees are involved in numerous initiatives aimed at promoting a low-carbon society.

Unless otherwise stated, we engage with people from our workforce on both an ongoing and an ad hoc basis.

ESRS S1‑3 – Processes to remediate negative impacts and channels for own workforce to raise concerns

To provide or contribute to remediation of negative impacts on people in our own workforce, we set up a complaints mechanism incorporated in our risk management system. As soon as a due diligence breach is identified in the annual or ad hoc risk analysis, our processes provide for taking immediate remedial action, as outlined under “ESRS S1‑1 – Policies related to own workforce.” The effectiveness of these actions is reviewed annually or on an ad hoc basis. If necessary, adjustments are made to the complaints mechanism or the action taken.

Deutsche Telekom offers all employees an opportunity to report violations of legal requirements and internal policies with the TellMe whistleblower portal and the T‑Mobile US Integrity Line – anonymously if they so choose. Reports about human rights or environment-related risks can also be shared.

Risks of physical or mental violence among employees, in contact with customers, or in a private context can also be reported to the Threat Management unit. In addition, employees at our Germany sites can report grievances/complaints to the works council or to designated representatives. Other local channels are also available to our own workforce so that employees can raise their concerns or needs directly to Deutsche Telekom and have them addressed. A digital portal is available in Germany for reporting accidents and near misses, and we are currently evaluating whether this channel could be deployed throughout the entire Group. We diligently investigate all grievances/complaints and instigate suitable actions based on our findings.

Both the TellMe complaints mechanism and T‑Mobile US’ Integrity Line can be easily accessed through our website and via the websites of the Group companies. The rules of procedure for the TellMe portal are currently available in twelve languages. To ensure that not only our employees but also business partners and third parties are able to access the complaints mechanism, we accept reports both by phone via a toll-free, international service number as well as via email, post, or online submission through the relevant portal. All employees can find information about the availability and use of the above-mentioned channels on the intranet.

Incoming tip-offs and grievances/complaints that relate to people from our own workforce are recorded dividing them into the topic areas “human rights” (including the right to freedom of association), “occupational health and safety,” and “discrimination.” The effectiveness of TellMe is reviewed once a year in line with the requirements of the LkSG. We also perform ad hoc reviews if the Company is expecting a significant change in or expansion of the risk situation in its own business area or at direct suppliers. This may be necessary, for example, when launching new products, projects, or a new business area. The effectiveness assessment includes the continuous evaluation of feedback from whistleblowers, the review of the implementation and accessibility of the complaints mechanism, and the risk-based evaluation of stakeholder engagement, e.g., through employee surveys. We also involve employees’ representatives and works councils when necessary in relation to our own business operations.

You can find further information on the way we track and monitor the grievances/complaints that have been raised and addressed under “ESRS G1‑1 – Business conduct policies and corporate culture.” There, we also discuss to what extent our employees are aware of the mechanism and trust in it if they wish to report concerns or needs and have them investigated. We also describe the strategies we have in place regarding the protection of individuals that use them against retaliation in this section.

ESRS S1‑4 – Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

Working conditions (social dialogue, freedom of association, the existence of works councils and the information, consultation, and participation rights of workers) We rely on close cooperation with employees’ representation bodies so as to mitigate any negative impacts on our own workforce in countries where there are no trade unions. We appreciate and make use of the dialogue with both company-based and unionized employees’ representatives. It is crucial in this context that employees are aware of their right to freedom of association and that this is not restricted by the employer.

In July 2023, we updated our existing human rights training and made it available in additional languages to raise employee awareness of the right to freedom of association and collective bargaining, health and safety, and other matters. This training also addresses aspects of diversity, equity, and inclusion. The human rights training is designed to do more than just impart basic knowledge to our employees. It enables them to apply their new knowledge in practical decision-making scenarios directly in the context of Deutsche Telekom. For example, employees are informed as part of their training that grievances, such as an infringement of the right to freedom of association, can be reported through the TellMe whistleblower portal, regardless of circumstances specific to a particular country. The overarching target of the human rights training is to empower employees to actively protect themselves and others in their own working environment. The training is available in fourteen languages on Deutsche Telekom’s online training platform. Employees of T‑Mobile US do not have access to the platform. They receive annual training on T‑Mobile’s Code of Business Conduct, including how to report grievances.

We monitor the effectiveness of the updated human rights training by measures such as recording the number of employees who have taken part in the training since it became available on a six-month basis. We also evaluate employee feedback and analyze participation rates, access options, and any language barriers.

As part of the LkSG management system, we carry out annual risk analyses (Deutsche Telekom excluding T‑Mobile US), also for the internal business units in the included Group companies. The analyses are designed to enable us to derive targeted follow-up actions and therefore effectively eradicate or mitigate risks.

For further information on the risk analysis under the LkSG, please refer to the section “ESRS S2‑4 – Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions.”

T‑Mobile US conducts quarterly enterprise-wise risk assessments that consider a range of factors, including operations and social risks that impact its own workforce. The results are regularly reported to the relevant bodies, including representatives of Deutsche Telekom AG.

As part of the processes for identifying and assessing material impacts, risks, and opportunities as described in section “ESRS 2 IRO-1 – Description of the processes to identify and assess material impacts, risks, and opportunities,” we have carefully addressed the potential and actual material negative impacts of our business activities on our own workforce. This was done quantitatively as well as qualitatively. We have not identified any further areas in which our practices could have a material negative impact on our own workforce that go beyond the topics described in section “ESRS 2 SBM-3 – Material impacts, risks, and opportunities and their interaction with strategy and business model.” For this reason, we refrain from describing further approaches beyond the actions already reported on in this section.

The processes for monitoring our LkSG management system described under “ESRS S1‑1 – Policies related to own workforce” apply to ensure compliance with our due diligence obligations. No specific budget is allocated for managing material risks arising from social dialogue and freedom of association. In general, the actions described in this topical standard do not require any significant operating or capital expenditure.

Working conditions (health and safety) Our focus in the area of health and safety is on providing and implementing mitigation and prevention measures. If it is not possible to avoid or eliminate sources of danger, we follow the hierarchy of occupational safety and health measures. This hierarchy is structured as follows:

1. Safety-related actions to ensure physical separation between the source of danger and our workforce (e.g., barriers or covers on machines)
2. Organizational measures (e.g., restricting or prohibiting access to the danger zone)
3. Use of personal protective equipment (e.g., helmets, safety shoes, or hearing protection)
4. Behavior-related actions (e.g., instructions, for example in connection with fire safety or the use of ladders, or operating instructions)

A range of occupational health and safety standards apply across the Group. They govern the safe and ergonomic configuration of buildings and vehicles, among other aspects. In addition to services available to all employees, there are also target group-specific actions for occupational health and safety. These include driver safety training for certain areas of work or special safety training for employees who are deployed to work at cell tower sites. In addition to preventing accidents, these actions aim at promoting the health and productivity of employees.

We also have an extensive range of options available for our employees in offices to counteract lack of movement. For many years, our offices in Germany, for example, have been equipped exclusively with height-adjustable desks to create an ergonomic working environment. In addition, our health program in Germany includes course options for regular exercise. The health promotion program also includes courses on nutrition, stress prevention, and mindfulness. The programs are generally open to all employees. Furthermore, our Employee and Executive Advisory Service provides support in the area of psychosocial health. Offered in different languages, the service extends to advice in cases of discrimination and other misconduct, overwhelming situations in life and extreme events as well as crisis prevention. We are currently examining the extent to which we can enhance our digital health promotion offerings, which are available to all employees across the Group, regardless of location or time. Our activities to promote health awareness and health literacy among our employees not only help the individual employees and safeguard long-term business success, they also have a positive impact beyond the boundaries of the Company. For example, we also make selected preventive healthcare services available to the families of our employees.

For further information on our actions to mitigate negative impacts on both our own workforce and the workers in the value chain, see the section on civil engineering work related to network development activities in the section “ESRS S2‑4 – Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of these actions.”

We determine risks to health and safety on a regular basis. To enable a safe working environment, we prepare risk assessments for all types of jobs and derive appropriate measures from them. In line with the PDCA cycle (plan, do, check, act), which is a key tool for continuously developing and improving our management systems, we systematically review and measure the effectiveness of our actions. We regularly investigate how occupational health and safety are integrated into management and leadership activities and derive improvement actions as needed. To do so, we review the results of our employee survey, evaluating stress prevention measures under collective agreements, competitor benchmarks, and other relevant indicators. External experts check that mandatory actions such as fire safety instructions or risk assessments are carried out regularly and successfully. In addition, we receive monthly reports from our service providers regarding which and how many occupational health and safety services, products, and programs are being made use of, and we use this information to manage our actions.

In the Group companies, health & safety managers are responsible for specific processes and offerings that take into account legal requirements and conditions at operational level. The budget for occupational health and safety at the individual companies is calculated based on the employees’ working hours. We use this data to predict the minimum amount we expect to need for the coming year. We also provide financial resources for in-depth actions or voluntary services to promote health in the workplace. However, the actions described above do not require significant operating or capital expenditure.

Equal treatment and opportunities for all (diversity; employment and inclusion of persons with disabilities; gender equality and equal pay for work of equal value). We provide our employees with competitive, performance-related remuneration that is aligned with the overall conditions of the relevant national labor markets. With our Global Compensation Guideline for executives, collective agreements, and other provisions under collective and works agreements, we aim to ensure a transparent and gender-neutral pay structure and remuneration at Deutsche Telekom excluding T‑Mobile US. These arrangements are designed to ensure that remuneration at Deutsche Telekom is based on the type and scope of the work performed and the requirements of the relevant position, irrespective of the diversity characteristics described in section “ESRS S1‑1 – Policies related to own workforce.” This aims to counteract the potential material negative impacts on our own workforce in connection with the gender-specific pay gap in the ICT industry. T‑Mobile US is implementing the following actions to enable gender-neutral pay, including: equal pay for equal performance (irrespective of gender or origin), regular review of salary packages, and legal salary transparency through disclosure in job advertisements.

We compiled a report on equal pay and equality for the first time for 2016 in order to comply with the legal requirements of the Act to Promote Transparency of Wage Structures among Women and Men in Germany. The report is updated every five years. The most recent report, which is for the 2021 financial year, has been published in the Company Register. We have agreed action plans with our segment heads to increase the proportion of women in management positions, with the aim of supporting the work-life balance by means such as flexible working hours, hybrid working models, or part-time employment. We also want to support the cultural transformation with regard to work-life balance through training and workshops, to improve chances for equal participation of women in the labor market.

We describe our goal of increasing the proportion of women in management positions in section “ESRS S1‑5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities.”

We constantly monitor the increasing demand for skilled workers, particularly IT and tech experts, and compete for the best talents. We continuously evaluate experience reports and feedback to obtain a better understanding of the well-being of our female talents and to assess how they rate us as a company. We manage the risk of any potential staff shortages that could arise as a result of the gender pay gap in the ICT industry by organizing targeted recruitment initiatives emphasizing diversity, equity, and inclusion. We use partnerships and events to specifically address female talent, promote generational change between male managers who will soon be retiring and female junior managers (mentoring), and increasingly fill management positions with female talents. We also work closely with universities and service providers to find joint ways of providing even more support for women in technical professions. We evaluate the quality of our programs in feedback sessions and on the basis of the results of our employee survey, and we regularly review how we can further advance diversity, equity, and inclusion in dialogue with our partners. The increasing demands of employees on employers are identified by operational risk management and considered by the competent HR department: To address these challenges, we are continuously strengthening Deutsche Telekom and T‑Mobile US as attractive employer brands and proactively seeking out new specialist staff and talent worldwide. All aspects outlined above are part of operational risk management.

By offering a wide variety of training options, we also aim to promote a common understanding of diversity, equity, and inclusion within Deutsche Telekom and to raise awareness for unconscious bias among our employees. We also endeavor to break down barriers that exist in the use of products and technology. In 2024, we rolled out our first entirely barrier-free training, the “DE&I Baseline” e-learning. We developed the training program together with external experts and our employee networks. It includes personal stories of employees linked to all relevant diversity dimensions and is available to all employees in eleven languages on Deutsche Telekom’s online training platform. A diversity glossary comprising over 100 terms related to diversity, equity, and inclusion, published both internally and externally, complements the training. T‑Mobile US employees do not have access to the platform, but do receive training opportunities that likewise integrate the topics of diversity, equity, and inclusion.

In 2024, we additionally placed a special focus on promoting multipliers for diversity, equity, and inclusion within our own workforce. To do so, we increased the involvement of our employee networks, among other aspects. They play an important role in raising awareness among our employees of the diversity dimensions referred to in section “ESRS S1‑1 – Policies related to own workforce.”

Deutsche Telekom also has various initiatives in place to ensure an inclusive working environment. These help us to make the working environment accessible for people with disabilities, adapt workplaces accordingly, and provide technical assistance. The IT and application landscape will also be improved in terms of internal and external accessibility. In addition to the overarching Group activities, the units introduced own actions tailored to their operations. They are designed to raise awareness for the needs of persons with disabilities and to meet the specific requirements of the job in question. One such example is driver safety training for field staff who are wheelchair users or with hearing difficulties.

Detailed information on our actions and initiatives to advance diversity, equality, and inclusion will be disclosed in our DE&I Report, which we plan to publish for the first time in the future for Deutsche Telekom excluding T‑Mobile US.

We measure the effectiveness of our initiatives to advance material positive impacts on diversity, equity, and inclusion within our own workforce using the standard processes described in section “ESRS S1‑2 – Processes for engaging with own workforce and workers’ representatives about impacts.”

We use the processes of risk analysis under the LkSG to determine which actions are necessary and appropriate to manage certain actual or potential negative impacts on our own workforce.

For further information, please refer to the section “ESRS S2‑4 – Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions.”

The central diversity team is responsible for managing the material impacts relating to our work to advance diversity, equity, and inclusion. Area-specific contact persons were also appointed for the individual segments and countries. A central budget for Group-wide actions and local budgets for country-specific actions are available to implement the individual actions. The Competitive Workforce (CWF) department is responsible for implementing actions to manage material negative impacts in connection with gender equality and equal pay. The actions described above do not require additional significant operating or capital expenditure. Unless specified otherwise, all actions described in connection to this standard to mitigate negative impacts and advance positive impacts are ongoing and have no defined end date.

ESRS S1‑5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

We carry out actions designed to steadily increase the proportion of women in management positions at Deutsche Telekom. In this way, we address the main impacts and risks that arise for us in connection with gender equality within our workforce. The Board of Management of Deutsche Telekom AG has set itself the goal of increasing the proportion of women in management positions to 30 % by 2025. Progress will be measured against the prior-year figure.

We map the current percentage in the new sustainability reporting in section “ESRS S1‑9 – Diversity metrics.”

We have not set any further specific time-bound or outcome-oriented targets for mitigating the negative and advancing the positive impacts on our employees. We review the effectiveness of our policies and actions related to our own workforce in the context of the LkSG risk process and regularly report the results to the Board of Management of Deutsche Telekom AG.

ESRS S1‑6 – Characteristics of the undertaking’s employees

The figures in the “Other” and “Not reported” categories are identical because our HR master data system currently cannot distinguish between these two categories. To ensure that the totals are added up correctly, the corresponding figure is therefore only shown in the “Other” line.

The figures in the “Other” and “Not reported” categories are identical because our HR master data system currently cannot distinguish between these two categories. To ensure that the totals are added up correctly, the corresponding figure is therefore only shown in the “Other” column.

A total of 26,617 employees left the Company during the reporting period. Employee turnover was at 13.3 %.

For further information on the development of personnel costs and the average headcount, please refer to note 25 “Average number of employees and personnel costs” in the notes to the consolidated financial statements.

ESRS S1‑8 – Collective bargaining coverage and social dialogue

The Group-wide coverage rate in 2024 was 45.8 %. We have collective agreements in place in the European Economic Area (EEA).

In 2004, an agreement was concluded for the first time on the establishment of the European Works Council (last amended in 2019). It represents the interests of our employees within the countries of the EU and the EEA.

ESRS S1‑9 – Diversity metrics

The combined categories “Other” and “Not reported” were also included in the query, but are not relevant to determine the composition of upper management.

ESRS S1‑12 – Persons with disabilities

In 2024, the percentage of persons with disabilities at Deutsche Telekom was 5.8 %.

Irrespective of country-specific legal requirements, we have established a uniform definition of disability to enable coordinated action and reporting across the Group: A person has a disability if they have physical, mental, cognitive, or sensory impairments that, in interaction with attitudinal and environmental barriers, may hinder or prevent their equal participation in society.

ESRS S1‑14 – Health and safety metrics

Almost all Deutsche Telekom employees, or 95.5 % of the workforce, are covered by a health and safety management system. In 2024, there were 0 fatalities attributable to work-related injuries. The number and rate of recordable work-related injuries was 890 and 2.5 %, respectively. The number of days lost to work-related injuries and fatalities from work-related accidents was 13,944.

ESRS S1‑16 – Remuneration metrics (pay gap and total remuneration)

The average unadjusted gender pay gap between female and male employees in 2024 was 14.5 %. The average adjusted gender pay gap was 7.7 %. We determined the average unadjusted gender pay gap as the weighted average of the unadjusted pay gap of the Group companies included in this report. For the average adjusted gender pay gap, we first determined the pay gap for each pay group for each Group company (as per the applicable definition in the company concerned) and then calculated the weighted average.

The annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual) is 491 to 1.

For these remuneration metrics, we calculated the individual total remuneration of the employees as the sum of the fixed and variable (short- and long-term) gross cash remuneration received in the reporting period. To calculate the gender pay gap, it was converted into hourly pay, and for the total annual remuneration ratio, it was converted into a full-time annual equivalent.

In addition to the gross cash remuneration, we included all and any relevant remuneration in kind, share-based payments, and pension commitments in the total remuneration of the highest-paid individual. By contrast, the total remuneration of the other employees does not include remuneration in kind, share-based payments, or pension commitments. This simplification does not materially impact the reportable remuneration metrics.

ESRS S1‑17 – Incidents, complaints, and severe human rights impacts

In 2024, 15 incidents of discrimination, including harassment, within our own workforce were reported through the TellMe and Integrity Line channels described in section “ESRS S1‑3 – Processes to remediate negative impacts and channels for own workforce to raise concerns.” In addition, seven complaints related to other social factors or aspects were received through these channels from our own employees. We have not paid any fines, penalties or damages in connection with the aforementioned incidents and complaints. No severe human rights incidents connected to our own workforce (e.g., forced labor, human trafficking, or child labor) were reported in 2024.