Whistleblowing procedure

Procedure for complaints and notices

Responsible, ethical and lawful conduct is a top priority for O₂ Telefónica in its own business activities and in its relationships with its business partners, customers and other stakeholders.

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Telefónica Deutschland has established a whistleblowing procedure that allows individuals, companies, and other organisations, such as non-governmental organisations, to report human rights and environment-related risks or violations, as well as violations of applicable law or internal guidelines and business principles. An overview of human rights and environmental issues can be found at the bottom of this page. No general customer complaints will be processed via the complaints channels of the whistleblowing procedure. The purpose of the whistleblowing procedure is to ensure that all reports submitted are examined in a confidential, transparent and fair manner. Reports can also be submitted anonymously and are handled in accordance with the data protection regulations. Discrimination or punishment against informants will not be tolerated by Telefónica Deutschland.

Reporting Channels

Graphic: What happens to my report. Telefónica Deutschland's whistleblower procedure for human rights and environmental issues is based on the requirements of the Supply Chain Due Diligence Act (LkSG) and the Whistleblower Protection Act (HinschG). Detailed information about the process can be found in the rules of procedure. 1. You submit a report. 2. Within 7 days, you will receive confirmation of receipt. 3. If necessary, you will be contacted to discuss any questions and details regarding your report. 4. The report will be processed and, if necessary, measures will be taken. 5. After 3 months, you will receive a notification regarding your report and, if applicable, any measures that have been implemented or are planned.

The steps of the whistleblower procedure

Rules of Procedure

Complaints procedure / whistleblowing procedure

Download rules of procedure

englisch | PDF | 649 kb

Download rules of procedure

german | PDF | 907 kb

1. What is the whistleblower procedure?

2. How are informants protected?

3. Who can make a report?

4. What topics does the whistleblower procedure cover?

5. How can reports be submitted?

6. Can reports also be submitted anonymously?

7. What information should a report contain?

8. Who is responsible for processing the reports received?

9. What happens after a report is submitted and how quickly are reports processed?

a. Confirmation of receipt of your report The informant will receive a confirmation of receipt within seven days after submitting the report, if the reporting channel permits. This excludes customer complaints that are not related to human rights or the environment within the meaning of the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG) or compliance within the meaning of § 2 of the German Whistleblower Protection Act (HinSchG) and other laws. b. Examination of human rights and environment-related reports If the report was not submitted anonymously, the informant will be contacted within 14 days of receipt of the report to inquire about further information regarding the report and expectations for possible measures. The further examination of the report is carried out by the Corporate Responsibility & Sustainability department and the Human Rights Committee, maintaining confidentiality (see Chapter 2 and Chapter 6 for more information on confidentiality and anonymity). Depending on the specific case, other relevant contact persons will also be involved. The informant will be regularly informed about the status of the procedure. After the examination is completed, an assessment is made as to whether the report concerns a human rights or environmental violation or risk. If this is the case, further relevant internal and external stakeholders (e.g. departments or suppliers) will be involved if necessary to take appropriate preventive or remedial measures. For a report that falls within the scope of the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG), the informant generally receives information about the outcome of the procedure within three months of the confirmation of receipt. However, for extensive and/or complex reports, processing may take longer. If the report is unfounded, Telefónica Deutschland will discontinue the procedure and inform the informant of this decision. A report is unfounded if no risk or violation of human rights or environment-related obligations has been identified, or the report has no connection to Telefónica Deutschland or its business partners. The whistleblower procedure remains available to the informant at all times, even after a procedure has been concluded. c. Examination of compliance-related reports If the report was not sent anonymously, the informant can be contacted to discuss the facts of the report in more detail. Further coordination of the investigation is carried out by the Compliance Department by maintaining confidentiality. For a report that falls within the scope of the German Whistleblower Protection Act (HinSchG), the informant, will receive information on planned or already taken follow-up measures and relevant reasoning within three months of receiving confirmation of receipt if the chosen reporting channel permits it.

10. Can a report also be submitted to external reporting offices?

11. Privacy information for Whistleblowers

Graphic: Human rights and environmental obligations: Explanatory text below the graphic in text form

Text version of the graphic

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