Compliance: acting lawfully and fairly

Our compliance culture is an essential building block for corporate management geared towards integrity and appreciation. Throughout the Group, we are committed to the law and ethical principles that we have anchored in our internal regulations.

We deal with the topic of compliance in more detail in our Sustainability Statement 2024 and on our website.

How we understand compliance

Compliance risks are risks arising from systematic violations of legal or ethical standards that could lead to regulatory or criminal liability of the company, its board members or employees, or to significant damage to its reputation. To minimize these risks, we have set up a compliance management system (CMS). It is based on three building blocks: culture, trust and simplicity.

Culture

Culture is the basis of our cooperation. Compliance cannot be successful without a good and open corporate culture in which each individual is willing to take responsibility, deal constructively with mistakes and point out risks.

Trust

Trust goes in two directions: Our compliance team provides trustworthy advice and works together with the business units to find solutions for dealing with compliance risks. Conversely, however, trust also means that compliance requirements are only made where it is necessary from a risk point of view.

Simplicity

Simplicity means that we want to make it as easy as possible for everyone in the company to follow the rules and implement compliance requirements. This includes that rules should be clear and simple and reduced to the essentials.

Compliance in a dynamic business environment

Increasing regulatory requirements, new digital business models, intensified international competition – all of these are influencing our compliance strategy. That’s why we have to constantly review, develop and adapt our CMS. Our goal: We want to build a “Leading Digital Compliance Management System” (Leading Digital CMS). By this we mean a CMS that

• integrates Compliance requirements into business processes as seamlessly as possible,
• shows existing compliance risks up-to-date and transparent at all times and
• actively embraces and addresses new developments in the business and regulatory area and uses the findings for continuous improvement.

Compliance management: digital into the future

Under the heading “Compliance Digital Transformation”, we are further developing our compliance processes with the help of IT tools and AI applications. The aim is to make these processes even more efficient. This is supported by the “ICARE Check” – a simple self-test with five questions for critical situations. The test is designed to help our employees navigate difficult situations and assess whether advice should be sought before deciding how to proceed.

Networking for success

We regularly discuss strategic compliance issues with the compliance officers in our international Group companies – in the year under review, for example, at Deutsche Telekom’s International Law & Integrity Meeting 2024 in Bratislava.

Other examples of compliance work across divisional and company boundaries include:

• There is a regular exchange between central and decentralised compliance departments.
• At the international level, virtual “Compliance Community Calls” are also held on compliance strategy and current projects. Compliance officers from decentralized units will also present their business areas and challenges there.
• We also enter into dialogue with other companies and expert circles on compliance issues.
• Finally, we contribute to the further development of compliance standards and management systems with specialist lectures, publications and other contributions.

Involvement in anti-corruption initiatives

We are actively involved in national and international associations and organizations that focus on compliance issues – such as the German Institute for Compliance (DICO e.V.). For years, we have taken the United Nations’ International Anti-Corruption Day on December 9 as an opportunity to draw attention to the issue of bribery and corruption within the Group.

Looking ahead

Responsibility, vigilance and dialogue within and outside Deutsche Telekom characterize our work on the topic of compliance. With the goal of a Leading Digital CMS in mind, we remain a reliable partner for our stakeholders and promote our culture of integrity and transparency.