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Compliance: acting lawfully and fairly

Deutsche Telekom is committed Group-wide to compliance with applicable law and to the ethical principles set out in its internal regulations. These principles guide us in our daily actions and form the binding framework for our decisions.

We deal with the topic of compliance in more detail in our Sustainability statement 2025 and on our website.

How we understand compliance

Deutsche Telekom has implemented a compliance management system (CMS) to minimize risks from systematic violations of legal or ethical standards. These risks can lead to administrative or criminal liability of the company, its board members or employees or cause significant damage to their reputation. The CMS 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 and every individual is willing to take responsibility, deal constructively with mistakes and point out risks.

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Trust

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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 focused on those areas 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.

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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 is 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). A Leading Digital CMS

  • integrates compliance requirements into business processes as seamlessly as possible,

  • shows existing compliance risks in an up-to-date and transparent manner,

  • and actively embraces new regulatory or business developments, addresses these changes 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.

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Success with networking

The compliance officers in the international Group companies exchange views on strategic compliance topics. In 2025, Deutsche Telekom’s International Compliance Days took place in Budapest.

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

  • There is a regular exchange between central and decentralized compliance departments.

  • At the international level, virtual “Compliance Community Calls” are held on compliance strategy and current projects. The central and decentralized compliance officers take part in this.

  • Deutsche Telekom’s compliance officers are also part of cross-company expert groups on compliance issues and contribute to the further development of compliance standards and management systems with specialist lectures, publications and other contributions.

Involvement in anti-corruption initiatives

Deutsche Telekom is 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 make our compliance management fit for the future. On this basis, we are continuously developing our CMS and strengthening our culture of integrity and transparency.

Deep Dive for Experts

Management & Frameworks

  • Our compliance management system (CMS) is based, among other things, on the Compliance Risk Assessment (CRA), a procedure that can be used to identify and evaluate compliance risks and initiate appropriate preventive measures. The companies participating in the CRA are selected on a risk-based basis.

  • Deutsche Telekom regularly has its CMS audited by independent auditing firms in accordance with the Institute of Public Auditors’ Auditing Standard 980 (IDW PS 980) for its effectiveness against corruption. After audits at Deutsche Telekom AG and eight of its subsidiaries in 2024, further audits of twelve international subsidiaries followed in 2025. In addition to compliance processes, the focus was on other activities with an increased risk of corruption (e.g., in the areas of purchasing, sales, events, donations, sponsoring, mergers & acquisitions and human resources). As in the previous audits, the effectiveness of the CMS with a focus on anti-corruption was once again confirmed by all audited companies.

AI – Artificial Intelligence
AI describes the ability of a machine or software to imitate human capabilities, such as logical thinking, learning, and planning. Generative Artificial Intelligence (also known as GenAI) – as a branch of artificial intelligence – is used to generate new content, such as text, images, music, or videos.
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