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.
Submit a report now

O2 Telefónica has implemented a whistle-blower procedure which enables individuals, companies and other organisations such as non-governmental organisations to report human rights and environmental-related risks or violations as well as breaches of applicable law, internal guidelines, the Business Principles or the Supply Chain Sustainability Policy or concerns regarding a potential or actual infringement of these regulations.

The purpose of the whistleblowing procedure is to ensure that all reports submitted are examined and processed transparently and fairly. To ensure that all persons affected by the actions of O2 Telefónica and its suppliers have effective access to this whistleblowing procedure, the website can be read aloud in German and English via the speaker icon in the path bar above. The Rules of Procedure are available in five languages.

Rules of Procedure

Complaints procedure / whistleblowing procedure
1. Foreword
2. Who can make a report?
3. What topics does the whistleblower procedure cover?
4. To whom can I submit my report?
5. Can reports also be submitted anonymously?
6. What information should a report contain?
7. Who is responsible for processing the reports received?
8. How are reporting persons protected?
9. What happens after a report is submitted and how quickly are reports processed?
10. When will I receive information about the outcome of the procedure?
11. How long will the information be kept?
12. Can a report also be submitted to external reporting offices?
13. Review of the effectiveness of the whistleblowing procedure
14. Accessibility of these Rules of Procedure

ANNEX I

Categories of the whistleblowing procedure
Category: Labour disputes
TopicBackground informationResponsibility for processingRelevant reporting channels
Bullying"Bullying" is the systematic hostility, harassment and discrimination of workers amongst each other or by superiors. It includes any continuing behaviour that violates the dignity of the person concerned and creates a "hostile environment" characterised by intimidation, hostility, humiliation, degradation or insults.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Sexual harassmentAny behaviour of an unwanted sexual nature that belittles, insults or humiliates a person. The behaviour disrupts cooperation and creates an intimidating, hostile or offensive work environment. Although it is usually a pattern of behaviour, it can also be a single incident.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Discrimination and unequal treatment in employmentunequal treatment or arbitrary distinction, for example on the grounds of sex, religion, nationality, ethnic origin, sexual orientation, political opinion, disability, age, language, social origin, unless justified by the requirements of the employment. Discrimination can also be an isolated event affecting one person or a group of persons in a similar situation.Human Rights and Environment CommitteeOmbudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Inappropriate behaviour and other conflicts in the workplaceOne-off or recurring behaviour of abuse of power by superiors towards their subordinates as well as by employees among themselves.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Category: Working conditions and occupational health and safety
TopicBackground informationResponsibility for processingRelevant reporting channels
Occupational health and safety incl. working timeOne-time or recurring disregard of applicable occupational health and safety regulations if this results in the risk of accidents at work and/or work-related health hazards (e.g. due to lack of safety standards, lack of protective measures; insufficient training and instruction). This also includes violations of the Working Hours Act, etc.Human Rights and Environment CommitteeOmbudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Adequate wagesErrors in the remuneration process as well as withholding of appropriate wages (payment of salaries, overtime, bonus, etc.) not related to fraud. The appropriate wage is at least the minimum wage established under the applicable law.Human Rights and Environment CommitteeOmbudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Child labourUnlawful employment of children under the age at which compulsory education ends according to the law of the place of employment, whereby the age of employment may not be less than 15 years, as well as unlawful disregard of the prohibition of the worst forms of child labour (e.g. slavery, prostitution, pornography, drug trafficking) for children under 18 years.Human Rights and Environment CommitteeOmbudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Forced labour and slaveryThe use of labour akin to slave-like practices, such as slavery, human trafficking, debt bondage, servitude and sex work.Human Rights and Environment CommitteeOmbudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Freedom of associationSituation in which employees are prohibited from joining a coalition and/or joining or forming a trade union, or are unjustly discriminated against on the basis of their membership of a coalition and/or trade union.Human Rights and Environment CommitteeOmbudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Abuse of power by private and public security forcesHiring or using private or public security guards to protect the company's project if, due to a lack of instruction and/or control by the company, they do not respect the requirement of humane treatment and/or the freedom of association. Human Rights and Environment CommitteeOmbudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Category: Protection of the environment and habitats
TopicBackground informationResponsibility for processingRelevant reporting channels
Environmental protection (to protect health and life)Causing harmful environmental changes such as soil pollution, water pollution, air pollution, noise emissions or excessive water consumption. Human Rights and Environment CommitteeOmbudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Other environmental protection topics (to protect the environment and health)Use of mercury in products and production and treatment of mercury waste contrary to the provisions of the Minamata Convention Use and production of persistent organic pollutants (POPs) and treatment of waste containing persistent organic pollutants contrary to the provisions of the POPs Convention Import and export of hazardous waste contrary to the provisions of the Basel ConventionHuman Rights and Environment CommitteeOmbudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Habitat protectionSituation of unlawful eviction and unlawful deprivation of land, forests and waters in the acquisition, construction or other use of land, forests and waters, the use of which secures the livelihood of a person.Human Rights and Environment CommitteeOmbudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Category: Information security / Data protection
TopicBackground informationResponsibility for processingRelevant reporting channels
Information security/ Data protectionUse of information of the company, customers, employees, shareholders or external partners for their own benefit or for the benefit of third parties. Violation of processes that guarantee the confidentiality, integrity and availability of sensitive company information.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Conflicts of interestA conflict of interest exists in situations where a personal or private advantage or interest influences professional decisions of an employee and this personal advantage or interest conflicts with the interests of the Telefónica Deutschland Group.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Bribery of public officialsPromising, offering, paying, giving or authorising gifts, hospitality or any other type of inducement to a public official for the purpose of improperly influencing or obtaining an unlawful advantage.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Category: Actions that damage integrity or that are economically criminal
TopicBackground informationResponsibility for processingRelevant reporting channels
Bribery in commercial transactionsPromising, offering, paying, giving or authorising gifts, invitations or other types of inducements to a business partner for the purpose of improperly influencing or obtaining an unlawful advantage.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Corruptibility in business dealingsAcceptance of gifts, invitations or other types of inducements by employees who perform a breach of duty in return.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Theft / embezzlementUnlawful appropriation of property belonging to third parties (e.g. the company, other employees, business partners).ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Fraud / InfidelityProcuring an unlawful pecuniary advantage by deceiving a third party or damaging the company's assets by breaching a fiduciary duty as well as causing financial damage >50k EUR.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Internal control system for financial reportingAccounting irregularities (accounting fraud) related to internal control over financial information.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Non-compliance with contractual obligations towards customersNon-compliance with obligations entered into with clients with regard to contractually agreed services, billing, quality of products and services, etc., as well as suspicion of theft of client data and/or company-sensitive information.ComplianceOmbudsperson: www.telefonica.de/ombudsperson-en Compliance PO Box:
Category: Other
TopicBackground informationResponsibility for processingRelevant reporting channels
OtherAny other indication that cannot be attributed to any of the aforementioned characteristics.N/A; Responsible department
Read page