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Responding department: HR – Group Employment Policies and Relations Management - Group Relations Management International

Stock Exchange Symbol: (DTE:Xetra)

Does your company have a publicly available commitment to respect human rights?

Yes, the commitment to respect human rights is implicitly and explicitly enshrined in DT’s foundational policies, such as the Code of Conduct, the Guiding Principles and the Social Charter. The Code of Conduct is the basic framework for all employees of the DT Group for ethical behavior in line with the laws and the five Guiding Principles of our company which include the commitment to respect and integrity. It is a self-commitment as well as a promise to society. 

The Social Charter outlines ten social principles and expresses DT’s commitment to international human rights standards as enshrined in the International Bill of Human Rights, the ILO Core Conventions, the OECD Guidelines and the Global Compact. In this sense, it can be described as our stand-alone human rights policy. It is applicable to employees, suppliers and other relevant stakeholders. Besides, it also highlights our commitment to environmental protection and sustainability. It was revised in 2013 in order to better reflect recent developments concerning the responsibilities of business towards social principles, such as with the adoption of the United Nations Guiding Principles on business and human rights (UN GPs).

Some of the major changes included the establishment of a corporate contact point for human rights, the explicit reference to the International Bill of Human Rights and the commitment to strive to meet international standards with regard to lacking national standards. Besides those foundational policies, there are further specific policies which also contribute to the respect to human rights.

The Employee Relations Policy defines the core elements of the relationship between DT and our employees worldwide, covering issues such as employee development, health and sustainability, diversity, fair remuneration, work-life balance, prohibition of discrimination and cooperation with social partners.

With our group-wide Diversity Policy, we recognize and encourage the diversity of our stakeholders also as a way to contribute to the success of the Group and our value-oriented strategy on a sustained basis.

The recently updated Binding Corporate Rules on Privacy outline DT’s pledge to the protection of personal data of customers, employees and other individuals connected with the DT Group.

In the Corporate Responsibility Policy, we highlight our commitment to corporate governance on the basis of corporate responsibility toward society and to play a pioneering role in the areas of sustainable action at international level, connected life and work, integrating people in the information society and leading the way to a low carbon society.

DT’s suppliers have to declare themselves willing to observe, respect and apply our Social Charter. Contracts with suppliers also contain a Corporate Responsibility clause in our General Terms and Conditions for Purchasing and oblige suppliers to observe DT’s sustainability requirements. This is accompanied by self-assessments and check-ups. Further statements which our business partners should consider are the Coltan Statement from 2005, as well as the Statement on Extractives, published in 2009, in light of the social risks linked to extracting raw material. To show commitment concerning the protection of the health of customers and users when using mobile communications in light of electromagnetic fields, DT has an Electromagnetic Field Policy (EMF-Policy). We also provide information for our users and customers on mobile communications and safety, see [link].

Link to the Code of Conduct: [link]

Link to the Guiding Principles: [link]

Link to the Social Charter: [link]

Link to the Employee Relations Policy: [link]

Link to the Binding Corporate Rules Privacy: [link]

Link to the Coltan Statement: [link]

Link to the Extractives Statement: [link]

How are human rights governed in your company?

The responsibilities for the Global Compact Principles are allocated to the different board members. The overall responsibility to comply with all Global Compact Principles is allocated to the CEO. Corruption, for instance, is allocated to the board member for Data Privacy, Legal Affairs and Compliance, as well as the board member for Finance. The main responsibility for human rights and labor norms is allocated to the board member of Human Resources. A corporate contact point for human rights was set-up in the Human Resources department of Group Employment Policies and Relations Management (in particular the Group Relations Management department) which has the overall steering responsibility for the Social Charter, DT’s human rights policy. This was one of the reasons why the responsibility for this topic was allocated to this function as well. Since its official establishment in October 2013, this corporate contact point has been responsible for all internal and external inquiries on human rights, together with the points of contact in the group units. It is also responsible for the planning and implementation of a human rights program in alignment with the UNGPs. Our company’s business practices are built upon the above mentioned policies, the Code of Conduct, the Guiding Principles and the Social Charter concerning ethical and human rights considerations. They apply group-wide to all employees, suppliers and other relevant stakeholders as a behavioral guidebook and is therefore of high relevance. As a telecommunication enterprise, DT also promotes human rights by enabling people to connect across the world, through access to information and the promotion of freedom of expression in the form of access to telecommunication services. Our business strategy aims at reaching the best customer experience which is also influenced by acting as a responsible corporate citizenship. One of DT’s strategic business models is on developing healthcare ICT solutions to connect healthcare players with each other securely and digitally.

How are human rights managed within your company?

General management program:

For managing the corporate responsibility to respect human rights, DT adopted a strategic human rights due diligence action plan or program framing our human rights activities in

alignment with the UN GPs (see [link]). This falls within the responsibilities of the corporate contact point for humanrights. Since the establishment of the contact point, we have implemented activities concerning policy commitment to human rights (see question above), grievance mechanism for human rights complaints (see below), human rights risk and impact assessment, integration of a human rights perspective, monitoring, tracking, evaluation, communication, reporting as well as stakeholder engagement, training and awareness-raising (see below).

(1 + 2) Identifying and assessing impacts:

Concerning the assessment of actual and potential human rights impacts, we have integrated a human rights lens into our Employee Relations Policy reviews which monitor the implementation and effectiveness of the Employee Relations Policy in DT operations. As a result of the alignment with the UN GPs, besides the monitoring of employee satisfaction surveys, we integrated a human rights dimension to identify high risk countries from a human rights perspective which together with other criteria form the basis for the decision on where a review might be conducted. When a review candidate is selected, the human rights situation of a country is analyzed by looking at human rights reports on the country. For the review itself, questions on human rights are addressed at the managerial level in the respective country as well as in separate interviews with employees as rights-holders. If during those reviews, negative human rights impacts are identified, they are addressed in a follow-up action plan and its implementation is monitored. In one case, for example, a project had resulted in excessive extra work for employees over a considerable period of time. On the basis of the evaluation, the resource allocation in the project was adjusted, decreasing the extra workload. We systematically monitored the implementation and effectiveness of these measures. In 2014, DT has undertaken a first stand-alone human rights impact assessment in a country where DT operates. Through consultations with various stakeholders and separate rights-holder interviews undertaken conducted by a third party, the actual and potential human rights impacts of the business activities in a certain country context were identified. The specific measures for a follow-up plan are to be decided in the first quarter of 2015.

(3) Importance signaled to business partners:

As described above in the part on the policy commitment, DT has a number of policies and statements which describe our expectations from suppliers (Social Charter, CR clause). To meet our corporate responsibility worldwide, we use various methods to ensure minimum social and environmental standards among our shared suppliers, such as the prequalification questionnaire or the E-TASC (Electronic Tool for Accountable Supply Chains) information system to enable careful supplier selection, also in terms of human rights, as well as the Social Audits to check compliance with the outlined standards. DT also supports the sustainable shaping of supplier relationships in industry initiatives like the Joint Audit Cooperation formed with other telecommunication companies in 2010 (link: [link]).

To promote the capacity or positive development of DT’s suppliers, there are online training tools or workshops organized to promote sustainability. For suppliers and business partners in Germany, on-site seminars are offered as well as e-learning courses in German and English with the topics of compliance, Code of Conduct, corruption, antitrust law, data protection and the Social Charter.

For more information on DT’s sustainable supply chain management, see [link] and also in the CR Report 2013 [link] (e.g. p. 126).

(4) Training:

New employees should conduct an e-learning tool for raising awareness on ethical behavior,including reference to the Code of Conduct, legislation and internal policies and compliance basics. In addition, there are attendance trainings or e-learning courses for employees on anticorruption.

A training on the implications of human rights in the ICT sector and the activities of the contact point for human rights was given for the employees working in the department where the contact point is allocated. As part of the activities of the networking initiative econsense and CSR Europe, webinars on embedding human rights into different departmental functions was provided to representatives from the Procurement, Risk Management and Human Resources departments. For the latter, DT HR representatives worldwide participated in this webinar. Through consultations with several different departments such as Lawful Interception and corporate functions such as the Data Privacy Officer or Youth Media Protection Officer that may have influence on the corporate responsibility to respect human rights, department representatives are made aware of human rights implications of their business activities. In 2015, more awareness-raising or training measures are planned.

(5) Tracking of effectiveness:

The implementation of measures followed upon the conduct of the reviews and impact assessment is monitored by the corporate contact point. In addition to this, Deutsche Telekom annually verifies the observance of the Basic Social Principles set forth in the Social Charter by all group companies. This is a large exercise that raises awareness on human and labor rights topics and makes all of our companies look into these topics more closely once every year. In some cases we have been made aware of potential issues with links to human and labor rights (e.g. discrimination cases) which may otherwise not have been reported. You can find a short summary here: [link].

To measure and manage the sustainable procurement performance, the Sustainable Procurement CR KPI is used. It measures the ratio between the procurement volume of suppliers whose compliance with social and environmental criteria has been verified through self-assessments, E-TASC or social audits and total procurement volume. DT’s actions on sustainable supply chain management are also measured through the above mentioned Social Audits which verify the compliance of the suppliers with the required standards. If violations have been found, corrective measures are set-up and monitored.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Deutsche Telekom developed a stakeholder involvement strategy in 2011 to help the company structure its relationship to its stakeholders on the basis of a stable, reliable foundation. Our aim is to take the issues put forward by our stakeholders seriously and to ensure that top quality standards are applied in our stakeholder involvement approach. We reviewed and partly redesigned the strategy in 2013, focusing on measures that are relevant to suppliers and investors – in addition to employees, customers and NGOs, who continue to play a key role in our strategy: [link]

Stakeholders are engaged through multiple ways by DT, ranging from providing information to stakeholders to engaging with them in a dialogue or through other forms of participation. Each year, topics are identified that are fundamental to sustainable business development in consultation with DT’s stakeholders in the materiality mapping process which is an integral part of the Corporate Responsibility reporting process.

As mentioned before, through the Employee Relations Reviews, employees are engaged as rights-holders. For the above mentioned human rights impact assessment, various stakeholders are engaged on human rights issues, ranging from government representatives to civil society organizations and suppliers as well as employees, contracted workers and community organizations.

DT also conducts stakeholder dialog days on human rights issues. In 2013, a stakeholder dialog day was held on the topic of raw materials and human rights with stakeholders from governmental organizations, research institutes and NGOs. Regular discussions on this specific topic also take place. In March 2014, the sixth Sustainable Procurement Dialog Day with various stakeholders focused on the supply chain and human rights. In one of three working groups, we organized a break-out session on how effective human rights due diligence for Deutsche Telekom and especially in the supply chain could look like ([link]). Together with different stakeholders, we discussed that effective human rights due diligence requires transparency and awareness-raising on the topic as well as collaboration between all relevant stakeholders. Further dialog-based approaches such as the Cyber Security Summit or the dialog with investors on sustainability issues are undertaken.

Telekom also relies on high social and environmental standards from its worldwide suppliers and regularly inspects these on-site. Apart from these checks, a cooperative partnership with suppliers is of key importance. This is one reason why the program "Together for Sustainability" was initiated for the purpose of sustainable supplier development. As part of this program, at the 7th Stakeholder Dialogue Day in 2014, DT discussed the importance of sustainability for the economic success with suppliers and partners in Shenzhen, China (see: [link]).

One participatory form of engaging with stakeholders is the Data Privacy Advisory Board which has been in place for six years and comprises experts of education, industry and politics as well as non-governmental organizations such as the Chaos Computer Club. It is mandated to provide advice to the company on data protection for different business models. Only recently its mandate was extended for another two years ([link]).

In addition, DT has a long standing partnership with BAGSO, the German association of senior citizens’ organizations, and launched a Technology Ambassadors initiative together with the German Federal Ministry of Education and Research. In our cooperation with the German NGO ‘Lebenshilfe’, we conduct Media Literacy Workshops and training on usage of mobile phones and internet with people who have a mental handicap and thus contribute to our area of action ‘Connect the Unconnected’ [link only in German: [link]] Furthermore, we have well-established cooperations and partnerships with NGOs and associations, that the following shows our broad-based involvement: [link]

[List of Memberships and collaborations].

Stakeholder engagement is also undertaken by our local subsidiaries, a few examples are listed here:

- Slovak Telekom via Endowment Fund Telekom with Pontis Foundation has long been supporting the hearing-impaired community with sign language courses or the employee grant program which helps to improve life in the community.

- Telekom @ school: Since 2000, all 34,000 general education and vocational schools in Germany have been connected to the Internet free of charge. Telekom @ School enables the latest E-learning tools, enabling efficient and forward-looking working and learning processes. These connections are currently being upgraded to up to 16 megabits and continue to be offered free of charge: [link]

- In Greece, for example, COSMOTE's Surfing the World Program provides free wireless broadband internet access to schools in remote mountain areas and islands where fixed internet was not available. The necessary 3G equipment is installed in schools to give pupils and teachers high-speed internet access. In 2013, more than 500 students and tutors, at 18 schools all over Greece, benefited from the on-going program through donations of equipment. In total, from the beginning of the programme, COSMOTE has installed wireless internet to more than 130 schools and more than 4,000 pupils and teachers benefited.

- Our "Yes, I can!" initiative supports social projects in Germany in which children and young people are able to experience and develop their individual skills. The aim is to promote their confidence in their own abilities and to empower them for everyday life.

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Health (including workplace health & safety, prevention of pollution)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Sexual harassment
  • Freedom of association and trade union rights· Freedom of expression and/or right to privacy / digital rights
  • Conflict minerals
  • Product misuse
  • Women
  • Children (including child labour)
  • Racial and ethnic minorities

Others:

  • Reduction of CO2 emissions, waste reduction & recycling
  • Capacity building in the supply chain
  • Youth media protection

Actions on health

The protection of the health and safety of our employees is of high importance to DT. The Health and Safety Management (H&S) unit also ensures compliance with statutory health and safety regulations at national level with a network of physicians, occupational safety officers and trained experts. At international level, DT uses group-wide, centrally controlled management systems such as Occupational Health and Safety Assessment Series (OHSAS) norm 18001 to uphold minimum standards. With its early-warning cockpit which was introduced in 2010, DT analyses different anonymized key figures, including the results of the general employee surveys concerning health. It analyses the stresses and strains, the work intensity, the  disturbances and disruptions at work but also key figures such as team work. This early warning cockpit has helped DT to improve its health quota since its implementation. In 2014, DT was awarded the Corporate Health Award for its health-care management by the German newspaper Handelsblatt, TÜV Süd and EuPF Research Sustainable Management, a research firm with focus on health.

Actions on conflict minerals

One of the focus topics as a provider of electronic devices is the topic of conflict minerals.

Some metals in ICT products are extracted from ores, some of which are found in the eastern part of the Democratic Republic of Congo where working conditions are often inhumane. With the profits of the resource extraction, civil wars are financed. As DT does not produce own products, we purchase from international manufacturers. We therefore require our suppliers to refrain from using any conflict minerals. In addition, DT supports industry initiatives to address sustainable sourcing challenges, such as the Conflict Free Sourcing Initiative (CFSI). We aim at identifying conflict resources and prevent trade and production involving those resources.

Actions on 'other' issues

In general, companies have to respect all human rights. Nonetheless, human rights impacts of companies vary between different industry sectors and business activities. Having our potential human rights impacts as an ICT enterprise in mind, we have identified different human rights priorities for different potentially affected groups or rights-holders. In broad categorizations, employees & external workforce, supply chain workers, customers and users as well as communities are potentially affected groups whose human rights could be affected in different ways by DT’s business operations.

Youth Media Protection

As a telco provider, we are taking responsibility to protect children and youth from unsuitable media. DT is therefore, for instance, member in the CEO coalition to make the Internet a better place for kids as well as in the industry-wide ICT Coalition for the Safer Use of Connected Devices and Online Services by Children and Young People in the EU. DT adopted a commitment to implement EU-wide set of measures throughout the European group units. We report about progress made in the DT Review Report which is published on the ICT Coalition website. To improve transparency and demonstrate responsibility, each national entity should appoint a Child Safety Officer. This officer is coordinating child online safety internally and serves as a central point of contact for external requests, e.g. by non-governmental organisations and authorities. [link] [link]

Since 2008, DT participates in the global GSMA, an industry initiative of mobile operators which also focuses on the fight against online child abuse. Furthermore, we closely cooperate with partners from the economy, politics, society such as law enforcement authorities and NGOs on youth media protection. Our youth media protection appointee for Germany is notified and involved in all issues concerning the protection of minors in the creation planning and design of new projects. The appointee for the protection of minors also arranges employee training courses on youth protection matters to increase sensibilities for the subject of youth protection and create knowledge multipliers.

For further information on youth protection measures, see also:

Principles for the Safer Use of Connected Devices and Online Services by Children and Young People in the EU == Implementing Measures by Deutsche Telekom Group, Jan 2013 [link] 

ICT Coalition - Implementation Questionnaire, 11 Oct 2013 [link]

Contact for youth protection [link]

Media competency for parents and children [link]

Youth protection on the Internet - measures by Deutsche Telekom [link]

Youth protection measures for mobile services [link]

Youth protection measures for mobile services

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Internal and external communication on the company’s human rights activities is undertaken in multiple ways. Internally, a biannual report on the activities of the contact point for human rights is sent to the Board Member in charge of Human Resources. Information is also provided via the Intranet or the Telekom Social Network on certain occasions.Externally, a section on the activities is integrated into the Annual Financial Report as well as the Corporate Responsibility Report and to some extent in the Human Resources Report. DT’s 2013 CR Report fully complies with the G3 guidelines of the Global Reporting Initiative. This also applies to the GRI Telecommunications Sector Supplement in the 2003 pilot version that is applicable to companies in the telecommunication industry. GRI reviewed compliance with both catalogues of requirements and awarded the highest application level “A+”. The CR report also serves as a communication on progress report as part of the United Nations Global Compact to show that we implement the Global Compact principles into practice. An overview on DT’s activities concerning the implementation of the UN GPs is also provided on the website of the company ([link]).

On this website, a summary of incoming human rights inquiries in the reporting period is also provided. Furthermore, the results of the Social Performance Report which monitors the compliance of the group units with the Social Charter is published on our website ([link]).

As part of the work of the contact point for human rights at DT, we respond to questions and inquiries addressed to us.External communication is also undertaken upon request by Socially Responsible Investors for their rating profiles, for SRI Calls and in SRI Roadshows. Other forms of communication or dialogue include the break-out session on human rights at DT’s Sustainable Procurement Dialog Day in March 2014 where the activities on human rights and a stakeholder and rightsholder map were discussed with participants. For information on DT’s privacy protection measures, an annual data privacy and data security report which documents all relevant processes at the Group is published. In addition, present up-to-date measures for improving data privacy and for advice on how to handle personal data securely is provided at the website ([link]).

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

Any internal or external stakeholder or affected group of persons may contact the corporate contact for human rights via email to report any human rights concern ([email protected]). Human rights violations can be addressed by anyone (internal, external, stakeholder or rights-holder) to DT’s whistleblower portal via mail, post, telephone or via a special email inbox which ensures anonymity. We also analyzed the whistleblower portal according to the effectiveness criteria for human rights outlined by the UN GPs. Besides, in each group unit, grievances can be reported to the responsible Compliance Officers.By consulting employees and other rights-holders in the above mentioned Employee Relations Reviews and human rights impact assessments, DT tries to ensure that grievances from affected groups are heard. In one case, for example, a project had resulted in excessive extra work for employees over a considerable period of time. On the basis of the evaluation, the resource allocation in the project was adjusted to decrease the extra workload.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

DT participates in the following external and collaborative human rights initiatives:

Global e-Sustainability Initiative: [link]
o DT is member and chairmanship is headed by DT Sustainability Officer Luis Neves

o own committee on human rights

Econsense: [link]
o DT is a member in different working groups, e.g. on sustainable supply chains and human rights

Global Compact: [link]
o Participant
o Global Compact LEAD
o Member of the learning group of the German Global Compact Network focusing on human rights

Global Industrial Relations Network (GIRN): [link]
o Participant
o Working group on corporate social responsibility topics, including human rights

Joint Audit Cooperation: [link]
o Founding member

Conflict-Free Sourcing Initiative (CFSI): [link]
o Member

For a further overview on DT’s cooperations, especially with humanitarian and social organisations, see here: [link]

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

Dedicated activities on human rights were very much influenced by the UN GPs. Although many efforts had been in place beforehand which had already contributed to the respect to human rights responsibility through health and safety measures or diversity promotion, youth media protection activities and many more, the UN GPs provided practical advice on how to deal with the topic of human rights within the greater business context. One of the key elements for DT has been the preparation towards the establishment of a corporate contact for human rights in the Human Resources function and the final official set-up with the revision of the Social Charter, DT’s human rights policy, in October 2013. With this dedicated contact point for human rights, a program was planned and realized for implementing the UN GPs requirements. As part of these requirements, cooperation was started with the Compliance department with the effect that there is close cooperation concerning cases with human rights relevance. In addition, a number of corporate functions and departments of human rights relevance, such as the Lawful Interception unit or the Data Privacy Protection Officer have been made aware of the existence of the corporate contact point of human rights and the importance of the topic.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

One of the major internal challenges to implementing the corporate responsibility to respect human rights is that DT is a highly dispersed and diversified corporation with multiple subsidiaries in over 50 countries worldwide. Hence, it is difficult to always ensure corporate oversight or leverage over local issues. Therefore, it is crucial to set “anchors” in the organization acting like ambassadors with a human rights perspective. This goes hand in hand with the topic of awareness raising. In addition, the length and complexity of supply chains is a major challenge as well as the problem of balancing economic interests with social responsibility requirements.

Externally, different political systems, legal jurisdictions and practices require local adaptation but also impede the implementation of harmonized standards and practices. Especially challenging is operating in a country where human rights are at risk but where withdrawing from the country may not help the situation on the ground. Additionally, at some instances it is difficult to exerting leverage over customers and other business partners. For properly implementing human rights due diligence, it would be useful to also get guidance on rights-holder engagement for different sectors with useful tools and best practice examples.Additionally helpful is the support of credible stakeholder initiatives with a constructive dialogue between civil society organizations and companies.