What characterizes usBirgit BohleCode of ConductDr. Claudia JunkerWhat makes a company successful? A good producton its own will not tip the scales toward success,nor is it the only element in a customer’s decision tobuy. A company’s reputation can also influence thisdecision. Business success requires something extra.Board members, managing directors, executives andemployees working for Deutsche Telekom (employees)are expected to behave in a manner that complies withthe legal obligations thus creating essentials such astrust, credibility, reliability and good reputation.That something extra also comprises integrity and eachemployee’s personal responsibility of his or her own actions. In less abstract terms, all these qualities togetherconstitute the company’s value based culture of compliance. This is a factor that also influences the success ofDeutsche Telekom Group (Deutsche Telekom). Businesssuccess does not stand above legal obligations nor isit unrelated to morality or integrity. The way DeutscheTelekom achieves business success is at least as important as the very success itself, and the Code of Conductprovides the framework of orientation for this. It combines two essential aspects. All employees are expected to comply with legal obligations and to behave withintegrity. For Deutsche Telekom, the Code of Conductis the combination between internal demands and thepromise to outside at the same time. It also ensures thatDeutsche Telekom remains a transparent and traceableenterprise for everybody.The Code of Conduct applies to all board members,managing directors, executives and employees of theDeutsche Telekom worldwide. Additionally it applies topeople to who are viewed as equivalent to employees infunctional terms, e. g. to temporary agency employees.It summarizes the values of Deutsche Telekom and defines what kind of behavior is required by those whowork for it. Whenever necessary, the basic principles ofthe Code of Conduct are specified in greater detail ininternal policies and regulations. This understandingof values requires all our employees and managementstaff to show mutual respect, acknowledgement andappreciation in their dealings with each other. Whenimplementing the Code of Conduct, each business unitof Deutsche Telekom must observe both its specificnational legal obligation and, on the basis of these, theindividual culture of the country in which it operatesrespectively.Yet it would not be sufficient to consider the Code ofConduct simply as a general guideline. It must rather befilled with life and most actively promoted by role models. It is primarily the Executives of Deutsche Telekomwho must assume this function of role modeling, notonly by showing integrity, behaving in a legally compliant manner and exuding credibility. They must also ensure that their employees know the content of the Codeof Conduct and comprehend what behavior is required.The Code of Conduct and the values it embodies are notlimited to employees permanently working for DeutscheTelekom. This explains why Deutsche Telekom expectsits suppliers and consultants to comply with the rulesof behavior manifested in this Code of Conduct and toendeavor them to ensure that they are also obliged toabide to its regulation by contact.Birgit BohleBoard Member for Human Resourcesand Legal Affairs, Labour DirectorDr. Claudia JunkerHead of Law & Integrity,Senior Managing Director,Acting Chief Compliance OfficerFor all the reasons outlined above, Deutsche Telekomhas determined the content of its Code of Conduct asfollows:2

Code of Conduct 01CorporategovernanceDeutsche Telekom complies with all legalregulations governing the management and themonitoring of the company and respects andmaintains the internationally recognized standardsof good and responsible corporate governance.Elmir Rasavac3

Code of Conduct2.1 Active corruptionIn order to preserve the trust of its customers, business partners, shareholders and of the public, DeutscheTelekom firmly rejects any and all forms of corrupt behavior and avoids even the mere suggestion of such behavior. Specifically, this means that Deutsche Telekomemployees may not offer, promise or grant benefits toany public officials in their local country or abroad, norto any decision makers operating in the private sector intheir local country or abroad, in order to achieve preferential treatment or a favorable decision for DeutscheTelekom. Deutsche Telekom employees must bear thisin mind when dealing with gifts or invitations to businessmeals and events.2.2 Passive corruptionDeutsche Telekom employees may not allow themselves to be promised or offered benefits and shall notaccept any benefits if this creates, or could create, theimpression with the parties bestowing the benefits thatthey can thus influence the employees’ business decisions. Further, Deutsche Telekom employees must neverrequest any benefits for themselves or third parties.2.3 Public service contractsThe public service market is an important market forDeutsche Telekom. Deutsche Telekom’s employees adhere to the rules prohibiting undue influence in public sector tenders and ensuring fair competition.2.4 Trade controlsDeutsche Telekom has international business relations.It is thus actively involved in the global trade in goodsand services, and is a supporter of free trade. Within thiscontext, Deutsche Telekom complies with the applicable trade regulations regarding import/export controlsand embargoes. 02BusinessrelationshipsTrust and fairness in all businessdecisions are the indispensibleelements of Deutsche Telekomdealing with its business partners.The private interests or personalgain of employees do not have anyinfluence on business decisions.2.5 ProcurementDeutsche Telekom Procurement and authorized parties are responsible for procuring goods and servicesin a professional manner and at optimal conditions forthe benefit of Deutsche Telekom. Procurement acts incompliance with the applicable laws of the countriesin which Deutsche Telekom operates. As bypassingProcurement can lead to disadvantages for DeutscheTelekom, Procurement has been given responsibility forall of the purchasing activities.Katrin Müller4

Code of Conduct2.6 SuppliersDeutsche Telekom maintains business relations with itssuppliers that are based on trust and fairness. In turn,Deutsche Telekom expects its suppliers to treat it withthe same respect and integrity it shows them. Suppliersare frequently also customers. Deutsche Telekom refrains from taking unfair advantage of such situationsand strictly separates any related purchasing and salesactivities. Any reciprocal arrangements must be approved accordingly by responsible procurement department.2.7 CompetitionDeutsche Telekom and its employees commit themselves to fair competition in all business relationships.They ensure that no agreements are concluded withcompetitors, customers or suppliers which restrictcompetition on prices or by division of product or geographic markets. This applies, in particular, to tenders.Business decisions are made independently and withoutthe exchange of sensitive information with competitors.Deutsche Telekom neither disseminates incorrect information on products or services of competitors, norseeks to gain a competitive advantage in any other unfair or abusive manner.2.8 Transparent financial reportingDeutsche Telekom’s financial reporting is carried out incompliance with local and international financial reporting regulations and gives a true and fair view of its assets, liabilities and results of its operations and financialposition.Michelle Fuchs5

Code of Conduct2.9 DonationsAs a responsible member of society, Deutsche Telekomtakes social responsibility in all those countries it operates. Deutsche Telekom acts as a supporter and sponsorof education, science, culture, activities relating to social responsibility, sports and environment protectionon a large scale, all on the basis of the specific local lawsand its internal policies and regulations with regard toits financial possibilities. This support is being shaped bypartnerships, cash and non cash donations, and services.Deutsche Telekom makes no donations in order to obtain any commercial advantage. Donations to individuals or private accounts as well as individuals or organizations that could potentially damage either the DeutscheTelekom’s interests or image will not be granted.2.10 Political contributionsDeutsche Telekom does not donate any money to political parties or elected officials, and does not grant themany non cash benefits beyond what is legally permissible.2.11 Money-launderingDeutsche Telekom takes all necessary measures to prevent money-laundering activities within its sphere ofinfluence.2.12 SponsoringSponsoring is one of Deutsche Telekom’s corporatecommunications instruments. Sponsoring activitiesare focused on the platforms of sports (mainly soccer),music and activities relating to social responsibility. Allsponsoring activities must conform to the respectivelegal system in each country and the internal sponsoringpolicy. All sponsoring activities are handled transparently, and involve appropriate and verifiable communications and marketing services on the part of the sponsoring partners/organizers.6

Code of Conduct3.1 Secondary employmentSecondary employment must not conflict with the interests of Deutsche Telekom; that applies in particular tosecondary employment with competitors.3.2 Equity participationsEquity participations by Deutsche Telekom employees incompetitors or business partners of Deutsche Telekomthat grant the investor influence over the business arenot in the interests of Deutsche Telekom. 03Avoidingother conflictsof interestDeutsche Telekom expects that the personal interestsof its Board of Management members, managingdirectors, executives and employees will not interfereor conflict with its interests.Vanessa Machura7

Code of Conduct 04Private useof companypropertyThe private use of company property is permissibleonly where provided for by individual contract,collective agreement or company regulations, orwhere such use is accepted company practice.Gabriela Dodevska8

Code of Conduct5.1 Data securityData security is of paramount concern to DeutscheTelekom. It is a decisive factor of its success and publicimage. That is why Deutsche Telekom uses all the appropriate and reasonable technical and organizationalmeans at its disposal to protect company data and thedata of its customers, business partners, shareholdersand employees against unauthorized access, unauthorized or improper use, loss and premature destruction.It does so within the respective legal framework and national laws as well as in compliance with its own internalpolicies and regulations. 05Handlinginformation5.2 Data privacyDeutsche Telekom is aware that the personal data itscustomers, business partners, shareholders and employees entrust to it is highly sensitive, and protects thatdata by handling it in a careful and responsible manner.Therefore Deutsche Telekom takes a variety of technicaland organizational measures to ensure the confidentiality of personal data in these efforts. Every individual isresponsible within the scope of his/her duties for ensuring a high level of data privacy at Deutsche Telekom. TheDeutsche Telekom’s employees adhere strictly to thedata privacy regulations and, in particular, respect andobserve the comprehensive rights of those whose datathey collect, process and use.5.3 General duty of confidentialityIn addition to the technical and organizational measures of data privacy, each Deutsche Telekom employeeis obliged to protect the company’s business interests.For this reason, any information leaving the companyor any information related to Deutsche Telekom issuesmust be communicated to authorized recipients only,no matter if they are employees of Deutsche Telekom orthird parties. Similarly, Deutsche Telekom considers theconfidentiality of information and safeguards businessdocuments against unauthorized access.5.4 Inside informationIn order to ensure market integrity and enhance publicconfidence in the financial markets, Deutsche Telekom’semployees adhere to the rules prohibiting the use of inside information, in particular the rules on confidentiality, the prohibition on making recommendations to orinducing others and the prohibition of insider dealings.Cathya Gonzalez Valencia9

Code of Conduct 06Compliancewith rulesof behaviorDeutsche Telekom expects its Board of Managementmembers, managing directors, executives and employees to behave in line with the Code of Conduct.Any breaches of these rules, legal obligations, or of internal policies and regulations may have serious consequences not only for the individuals committing them,but also for Deutsche Telekom. Therefore, deliberatemisconduct will not be tolerated.Without any exception, Deutsche Telekom will severelysanction any such misconduct or violation against legalprovisions. In doing so Deutsche Telekom will take noaccount of the employee’s rank or position within thecompany.Deutsche Telekom creates a climate and atmospherefree of any fear of negative consequences to encourageemployees to communicate violations and misconduct,if necessary.Dorota Buczynski10

Annex:questionsand notesCode of ConductLevent DoganThe direct superiors are the first port of call for any questions regarding the application of the Code of Conductin employees’ everyday work. In addition, the “Ask me!”advice portal has been set up to help resolve uncertainties as far as compliance relevant behavior is concerned.Serious misconduct must be announced for preventionpurposes and for appropriate sanctions. For this reasonthe “Tell me!” whistleblower portal has been established.“Ask me!” portalCompliance-relevant questions regarding the Code ofConduct and internal policies can be addressed to the“Ask me!” advice portal.Contact information for “Ask me!”Will be found for employees on the intranet of DeutscheTelekom.“Tell me!” whistleblower portalInformation concerning possible violations of legalobligations or internal policies and regulations can bereported through the Tell me! whistleblower portal.Nobody making a report to the portal will suffer anydisadvantages, provided they themselves acted in accordance with the applicable legal obligations. Thesereports should be done to the best of knowledge andbelief. Anyone, however, who is carelessly or knowinglymaking false or unfounded accusations or allegations,must bear the full consequences. As a matter of principle, Deutsche Telekom encourages its employees tospeak directly with their superiors. Thus, problems canoften be resolved exhaustively. Should that path beruled out, reports of misconduct can be made by regularpost, telephone or via e mail. It is also possible to file areport in “Tell me!” anonymously. The anonymous wayhowever should only be used in exceptional cases if youfear serious negative consequences for you personally,e.g., under labor law or consequences of a social nature.Any information provided will be treated as strictly confidential and will be checked for plausibility by specifically trained persons who are obligated to confidentiality.Contact information for “Tell me!”Deutsche Telekom AGFriedrich-Ebert-Allee 140, 53113 Bonn, GermanyPhone: 8000 38 24 835E-Mail: [email protected]: tleblowerportal11

Code of ConductAnnex:furtherinformationYou can find further information on the Code of liance/code-of-conductAdditional useful information can be found below:Deutsche Telekom’s strategy, which describes thecompany’s utsche Telekom Guiding Principles, which provide guidance for putting the company’s strategyinto yprofile/corporate-valuesDeutsche Telekom’s Group policies, e.g., the GroupPolicy on Accepting and Granting Benefits, theSponsoring Policy and the Global Procurement PolicyandRegulations that are important to employmentrelationships, e.g., works agreements and collectiveagreements will be found for employees on the intranet of Deutsche Telekom.The German Corporate Governance Code, which wasformulated by a government commission, constitutesDeutsche Telekom’s benchmark for good and responsible corporate governance. Code of Human Rights & Social Principles, underwhich Deutsche Telekom commits, among otherthings, to respect and promote human rights (including the ILO’s core labor standards). DeutscheTelekom’s compliance with the Code of HumanRights & Social Principles is surveyed once a year atall Group companies worldwide as part of the SocialPerformance ReportandThe Group Policy on Employee Relations, which elaborates the relationship between Deutsche Telekomcompanies and their printDeutsche Telekom AGGroup Compliance ManagementFriedrich-Ebert-Allee 14053113 BonnAll people shown are employees of GroupDeutsche Telekom.As of July 202112

Deutsche Telekom Group (Deutsche Telekom). Business success does not stand above legal obligations nor is it unrelated to morality or integrity. The way Deutsche Telekom achieves business success is at least as impor-tant as the very success itself, and the Code of Conduct provides the framework of orientation for this. It com-