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Human rights and supply chain: living responsibility

“Act with respect and integrity” is part of our guidelines and thus an obligation for all employees of the Group. We are committed to respecting and promoting human rights in every place where we operate, including in our supply chains and with our business partners. To this end, we have implemented a human rights and environmental due diligence process.

More detailed information on human rights can be found in our Sustainability Statement 2024 (ESRS S1 and ESRS S2) and on our website.

Milestones achieved, ongoing projects and goals

The protection of human rights and environmental concerns has been part of our business activities and corporate governance for more than two decades. Initially driven by our voluntary commitment, our actions are also regulated by law, especially with regard to the supply chain. As part of our human rights and environmental due diligence process, we regularly analyze the risks and impacts of our business activities with regard to human rights and environmental concerns. We use the analysis results to avoid, minimize or end negative effects. They also enable us to make targeted improvements.

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Where we come from

  • 2000

    We become a founding member of the UN Global Compact and – as one of the first ICT companies – emphasize our commitment to compliance with social and environmental standards and their disclosure.

  • 2003

    In our “Social Charter”, we commit ourselves to acting responsibly.

  • 2007

    We are implementing a code of conduct for our suppliers.

  • 2010

    Together with two other European telecommunications companies, we are establishing the international industry initiative “Joint Audit Cooperation” (JAC) (since 2023: Joint Alliance for CSR) for the sustainable development of suppliers in the ICT industry.

  • 2016

    We are implementing a comprehensive human rights and environmental due diligence process.

  • 2017

    We are further developing the “Social Charter” into the Declaration of Principles “Human Rights Code and Social Principles”. With this update, we are reaffirming our commitment to the goals of the “National Action Plan for Business and Human Rights” of the German Federal Government.

  • 2023

    For the first time, we are conducting a risk analysis for 248 Group companies and around 20,000 direct suppliers in accordance with the requirements of the German Supply Chain Due Diligence Act (LkSG). We publish the results in our “Annual Report LkSG 2023”. We are also adapting our “Human Rights Code”.

Where we stand in the reporting year

  • 2024

    134 Group companies are implementing the “Human Rights Code” and thus updating their human rights policy statement. In addition, we are publishing a legal report on the implementation of due diligence obligations in accordance with the LkSG in 2023 (BAFA report).

Where we want to go

  • 2025–2027

    Other Group companies are introducing the “Human Rights Code”. We are preparing for the further development of human rights due diligence processes in accordance with the European Supply Chain Act (CSDDD) and are examining participation in industry initiatives in order to minimize identified human rights risks even more effectively.

Key figures: human rights and environmental protection in procurement

With the help of implemented measures and the processes behind them, we aim to minimize human rights and environmental risks in the supply chain. We use various ESG KPIs to monitor and manage progress.

You can find out more about sustainable supply chains on our

website

ESG KPI “LkSG Supplier Risk Score”

As part of the legal requirements (Supply Chain Due Diligence Act/“LKSG”), we developed a new ESG KPI, the “LkSG Supplier Risk Score”.

This ESG KPI assesses the risk of human rights and environmental violations in relation to direct suppliers of the Deutsche Telekom Group (excluding T‑Mobile US).

The number of our suppliers with purchasing volume in the reporting period was assessed by an established external service provider according to a standardized methodology of LkSG violations that may occur.

In the 2024 financial year, 75 % (2023: 76 %) of our direct suppliers were classified as low-risk in terms of environmental and/or human rights risks. The proportion of direct suppliers classified as at increased risk was assessed at 25 % (2023: 24 %).

ESG KPI “LkSG Supplier Risk Score”

Share of low-risk suppliers (in %)

ESG KPI „LkSG Supplier Risk Score“ – Share of low-risk suppliers (in %) (graphic)
Due to legal requirements, the ESG KPI “Procurement volume without CR risk” was adjusted to the ESG KPI “LkSG Supplier Risk Score”.

ESG KPI “Purchasing volume verified as non-critical”

This ESG KPI measures the proportion of our purchasing volume from suppliers that have been audited for social and environmental criteria – for example, in the course of EcoVadis, CDP, social audits or supplier visits. The target value by the end of 2025 is 60 %. The share was 69.73 % in 2024.

We calculate this ESG KPI based on the audited Group-wide purchasing volume from the uniform purchasing reporting system (excluding T‑Mobile US).

ESG KPI “Procurement Volume Verified as Non-Critical”

in %

ESG KPI Procurement Volume Verified as Non-Critical (graphic)

In addition to human rights-related issues, climate protection is also highly relevant in our supply chain. In this context, we determine the ESG KPI “CDP Supply Chain Program”, which we report here in the CR report under Environmentally friendly products and services.

Audited purchasing volume

The share of the audited purchasing volume fell slightly from 22.3 % in the previous year to 21.1 % in 2024. At the same time, the share of purchasing volume covered by EcoVadis rose slightly to 45.0 %.

Share of our audited procurement volume

in %

150 150 1 22 44 98 12 88 1 21 38 76 13 1 23 60 37 2 21 40 1 21 45 2024 2023 2022 d, f 2021 d 2020 d Percentage of procurement volume addressed by EcoVadis Percentage of procurement volume covered by prequalification Percentage of audited procurement volume Percentage of procurement volume from developing and emerging countries Number of audits conducted Number of workshops conducted a, c a, e a b f
a Includes social and mobile audits carried out both internally and externally. Based on procurement volumes at Group Procurement.
b Includes social and mobile audits carried out internally and externally. (Both within Deutsche Telekom and via the Joint Audit Cooperation (JAC)). Audits also include follow-up audits.
c Until 2020: Percentage of procurement volume addressed by E-TASC.
d Excl. T-Mobile US and from 2020 without the category Network Capacity.
e From 2021, the value for pre-qualification will no longer be displayed.
f From 2022, the value for the number of workshops held will no longer be displayed.

Audits: results 2024

Through our auditing program, we regularly review the working conditions at the production sites of our suppliers (excluding T‑Mobile US). In the reporting year, we carried out the following audits:

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150 audits

divided between 62 direct (Tier-1) and 88 indirect (77 Tier-2 and 11 Tier-3) suppliers (11 surveys, 115 on-site social audits as part of the industry initiative Joint Alliance for CSR (JAC), 24 audits as part of the Validated Assessment Program of the Responsible Business Alliance)
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Suppliers in 31 countries

(Focus: Asia)

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Manufacturers

from the IT hardware, software and services sectors as well as networks and end devices

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661 abnormalities

(2023: 890, with the same number of audits) detected in relation to supplier requirements

These abnormalities are divided as follows: 292 abnormalities in the area of occupational safety and health protection, 123 abnormalities in working hours, 75 abnormalities in environmental protection, 70 abnormalities in wages and compensation, 43 abnormalities in ethics, 39 abnormalities in working conditions, nine abnormalities in discrimination, eight abnormalities in freedom of association, and two abnormalities in disciplinary actions.

All identified abnormalities were recorded in a plan for corrective and preventive actions. We are monitoring the timely implementation of the defined measures.

The results of the audits are included in the annual risk analysis in accordance with the LkSG. During the year, a committee of central departments discusses the results of the audits that we have carried out as part of the JAC initiative. Any abnormalities found must be mitigated or remedied as part of the established audit management.

You can find out more about the audits at our suppliers and as part of the JAC initiative in our

Sustainability Statement 2024

Looking ahead

At almost 70 %, the share of our purchasing volume verified as non-critical in the year under review was once again above our target value for 2025, almost ten percentage points. We will continue to check our suppliers for LkSG risk criteria in the future and want to optimize our human rights due diligence processes despite current uncertainties regarding regulatory developments.

Deep Dive for experts

Management & Frameworks

  • We have concretized our commitment to respecting and promoting human rights and environmental concerns in our Declaration of Human Rights Principles. It consists of two parts: our Human Rights Code and the LkSG Annual Report. The principles and expectations described in the Code of Human Rights apply equally to our employees as well as to our suppliers and business partners. We continuously review the associated due diligence obligations and adapt the Code as necessary. The last update was in 2023. In the Annual report LkSG, we publish annually the human rights and environmental risks we have prioritized, including measures and expectations derived from them.
  • We place the consideration of our principles and values along the supply chain above the Code of conduct for suppliers. Suppliers of solutions that incorporate artificial intelligence (AI) also confirm the requirements of our AI Guidelines for digital ethics.
  • Both the Human Rights Code and the Code of Conduct for Suppliers are based on the requirements of the German LkSG.
  • T‑Mobile US currently does not fall within the scope of the LkSG and has its own Human Rights Statement and Supplier Code of Conduct. In addition, the T‑Mobile US Responsible Sourcing Policy applies to the procurement of goods that use raw materials that are potentially mined in conflict-affected or high-risk regions. As a U.S.-listed company, T‑Mobile US also conducts a company-specific risk assessment using its own methodology.
  • With the whistleblower portal “TellMe” and – where relevant – the T‑Mobile US “Integrity Line”, we offer all employees and outsiders the opportunity to report violations of legal provisions and internal company regulations – anonymously if desired. This also includes references to human rights or environmental risks and violations.
  • Further information on the fulfilment of our due diligence obligations can be found in the reporting to the supervisory authority in accordance with LkSG (BAFA report) on our website.

Relevant standards

  • Global Reporting Initiative (GRI)
    • GRI 407-1 (Freedom of association and the right to collective bargaining)
  • GSM Association (GSMA) Indicators for Telecom Providers
    • GSMA-SUP-02 (Supplier assessment)
CDP
An initiative by institutional investors that aims to promote dialog between investors and companies on climate change issues. The project counts the world’s largest companies among its members. The companies disclose data on their greenhouse gas emissions and climate protection strategies. The CDP collects and publishes the data on an annual basis.
Glossary
LkSG – Act on Corporate Due Diligence in Supply Chains (Lieferkettensorgfaltspflichtengesetz)
A German act requiring companies to implement human rights and environmental due diligence in their supply chains.
Glossary