The FSTC 2023 started with the welcome words of Ali Kazimi from Hansuke. After a brief review of the current political situation in the world, Ali Kazimi explained the challenges and issues which the financial industry is facing today and announced the conference sessions which will focus on those topics. Again, similar to last year, the conference was built as a series of panel discussions rather than teaching-style lectures. This provided an excellent platform for a very broad spectrum of experience exchange and allowed for the analysis of topics from different angles and perspectives. The audience participated very actively in all sessions by asking many very sophisticated questions from practice and discussed possible solutions together with the panelists. This significantly increased the practical value of every single panel discussion.

The first panel discussion dealt with today’s challenges and issues related to EU WHT reclaims. A panel of leading international experts, Steffen Gnutzmann from WTS Global as the moderator, Alexandre Maitrot de la Motte from the University of Paris, Jeroen Van Der Wal from Taxology and Rebecca Wilmott from JP Morgan discussed the legal and practical aspects of reclaiming discriminatory EU withholding taxes suffered on portfolio investments. EU Member States had introduced strict documentation and substantiation requirements for the eligible claims to be accepted. It was again very clear that despite the EU initiative for standardisation and simplification of the withholding tax reclaim procedures in the EU, better known under the acronym FASTER, there are still many unanswered questions out there. The most frequently mentioned concerns were still related to harmonisation of the procedures within the EU – with a clearly demonstrated concern to end up with 27 different documents and 27 different definitions which would have to be submitted to 27 tax authorities within the EU.

In the next panel, Jessalyn Dean led through the session as a moderator and Awa Diouf from the Institute of Development Studies, Danish Mehboob from Bloomberg Tax and Paul Aplin, former President of the ICAEW discussed the taxation of digital financial services and its impact on the taxation of traditional financial services. One of the most intense discussions developed around the question of whether there should be a difference between the taxation of digital and traditional financial services. After the very intensive discussions the panelists came to the final conclusion that it is inevitable that tax policy and administrative decisions must balance competing interests including fairness, inclusion and international development.

The Half-Time Summary: EU 1 – 0 UK sounds rather like an announcement for a football match than for a tax discussion. The Brexit discussion at the FSTC 2023 conference led by Tim Sarson from KPMG and joined by Patrick Reidy from Capital Group, Tapiwa Mashingaidze from Alcentra and Dr. Kunka Petkova from the German Federal Ministry of Finance was really a very interesting one and again raised the questions of whether the Brexit was the right decision for the UK and how it has influenced the development of the UK’s economy and especially the financial industry since then. We have heard some critical words on the Brexit strategy and economic development of the UK in general, but the panelists’ opinion regarding the financial industry has remained unchanged – the opinion that since Brexit London’s position as a financial centre has been marginally eroded in only some of the business lines (i.e. as the banking hub for the euro area), but in its role as an international financial centre, London has retained its top position.

After the lunch, which provided a very pleasant opportunity for networking, we continued with no less interesting topics compared to the morning sessions. Helen Whiteman from the Chartered Institute of Taxation moderated the panel with Inga Nitsche from iCapital, Dr. Kunka Petkova from the German Federal Ministry of Finance and Michel Braun from WTS Germany as the panelists. The first panel discussion in the afternoon had a very provocative title: “ChatGPT Eats Tax Professionals for Breakfast”. This topic drew huge attention of the audience and led to some very emotional discussions about the role of tax professionals today and their perspectives in the future. The question of whether the practice of tax is art or a science was raised. Since many claimed that only creative jobs would survive the onslaught of AI, the panel discussed how to survive as a tax professional in the world of automation, boosted productivity and AI. After a very lively discussion in the panel, complemented with a very strong involvement of the audience, the panel came to the conclusion that “ChatGPT has an insatiable appetite, but it’s not quite ready to eat us yet”.

One of the further hot topics on the agenda was the tax integrity across the financial services industry. Ali Kazimi moderated the panel with Sara Jespersen from the Copenhagen Business School and Sandra Martinho Fernandes from EBRD. The panelists discussed tax integrity as the final frontier of the tax profession and agreed that adopting human-centred tax integrity should be seen as essential in all firms. They should adopt it and develop approaches to reduce risks of misconduct and to foster genuine engagement, robust governance and a positive corporate reputation.

The last two sessions of the conference dealt with the taxation of private equity industry where the jurisdictional competition plays a very big role and the impact of current regulations and initiatives on the tax departments. Both sessions caused a strong involvement of the audience, which again proofed the very high relevance of all topics discussed at this conference.

CONCLUSION

The 5th edition of the FS Tax Conference also proved to be a highly desirable and robust platform for tax professionals, academics, tax authorities, journalists and leading industry practitioners for the exchange of information and opinions on current topics in the field of taxation from different angles and perspectives. It provided some in-depth insights into the practice of taxation, its daily challenges and issues and gave some orientation for the future.

SDS as a renowned technology and software solutions provider in the area of international tax and regulatory reporting for FATCA, CRS, QI, OECD TRACE and WHT with long-standing experience serving global financial institutions was delighted to sponsor this excellent industry event for the fifth consecutive year.

Observation by:

Hrvoje Kajzer

Feel free to contact me anytime for further information, an expert chat or any discussion about the topics mentioned above.

The proposed EU FASTER initiative tackles the issue of a practical tax disadvantage for non-domestic investors within the EU.

This disadvantage, also known as Giovannini Barrier 11, has been a problem for the free flow of capital within the EU for a long time and no practical solution has been found so far. In order to eliminate the high cost and administrative burden regarding the proper taxation of cross-border payments both in the source and the target country, the EU now proposes a mix of at least two withholding processes.

For undisputed cases, a fast-track procedure (either quick refund or relief at source) has to be implemented by the EU countries that grant tax relief for cross-border income. The system shall be easily accessible to investors. In particular, an electronic tax certificate shall help with the identification of the beneficiary’s tax status, and the fast-track procedures shall be handled primarily by the financial intermediary within the payment chain. Both measures shall facilitate a faster relief than with the current procedures.

For disputed cases, namely for transactions within two days prior to the so-called ex-date of dividend payment and for transactions that are linked to open financial arrangements, no such fast-track procedure shall apply. Instead, the traditional long-form approach has to be used.

The two rules and the proposed handling of unsettled transactions raise a number of questions that have been addressed by the financial industry. From a specialist’s point of view, some of the proposed rules do not appear to make things easier. In some cases, we may even see a rollback of some simplifications that the industry has already adopted.

However, since most of the disputed rules are designed to target tax abuse, it is unclear to what extent the tax authorities in the EU are willing to listen to the concerns of the industry.

To learn more about what the EU has proposed and what the potential pitfalls for implementation are, download the second part of our whitepaper series on EU FASTER.

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22 years ago, the Giovannini report on Cross-Border Clearing and Settlement Arrangements in the European Union was published, and one of the barriers that the working group had identified was the tax withholding process for cross-border financial investments within the European Union. The practical application of a correct withholding tax rate for both the source and the target country – according to their double taxation agreement – is problematic. The crux is that the issuer of a security is obliged to withhold tax on income payments on a maximum level in the source country (some exceptions apply) and that the country of the beneficiary will perform another withholding at a local tax rate. To facilitate the correction of this overwithholding, the beneficiary needs to get the two tax authorities to agree on his/her tax status and the taxation of the payment according to a double taxation agreement (DTA). The beneficiary also needs to either apply the correct tax rates at the time of the payment or to correct the withholding afterwards.

Despite several attempts, the fundamentals of the barrier have remained intact. Now, with the recent proposal by the Commission (https://taxation-customs.ec.europa.eu/taxation-1/corporate-taxation/faster-initiative_en), the EU financial markets will experience an initiative to solve the issue on a regulatory level.

The initiative builds on a combination of three different concepts for tax relief.

The most conservative approach is the long-form reclaim after the payment and the overwithholding have been performed, where it is up to the beneficiary to supply the necessary documentation about his/her tax status and tax residence and to provide the tax authorities in the source country with appropriate documents. While this task can be handed over to a tax advisory or intermediary, the cost and the time for a refund can be significant and may force investors to waive their right to a proper taxation.

Quick refund is in principle the same, but the documentation is provided up front, and the relief can be granted much faster, at least in undisputed cases. In addition, the relief procedure may be outsourced by a tax authority to a withholding agent, which makes quick refund a process that runs within the financial industry and their well-honed systems, communication channels and procedures.

Relief at source is a fundamentally different process, where the issuer in the source country or an intermediary has upfront knowledge about the tax rates that have to be applied on the income payments and only withholds at a rate in accordance with the DTA. The intermediary who makes a payment to the beneficiary in the receiving country applies the reduced local tax rate. Relief at source is without a doubt the most elegant and efficient of the three models, but it is seen as being more prone to tax fraud than the other two.

To learn more about the three models, their pros and cons, and how they work in detail, take your time to download the first part of our series of whitepapers on EU FASTER.

The opening remarks of Ali Kazimi of Hansuke, chairman of the conference, gave us an outlook on what we could expect during the conference day in a very charming and funny way.

The concept of the entire conference was to provide many panels, discussion forums, and interactive sessions which included the audience rather than lecture-style presentations. In the first session – a panel discussion about how to deal with increased tax authority scrutiny, moderated by Mark Huyan of State Street – panelists Corinna Hedtke of Standard Chartered Bank, Pilar Espejo of BNY Mellon, Jeroen Van Der Wal, CEO of Taxology, and Robert Welzel, Partner at WTS Global, emphasised that dealing with increased tax authority scrutiny is a very big topic nowadays. In the UAE, for example, there is a strong enforcement of FATCA and CRS adoption. A new law defines “non-compliant FI” and “non-compliant person”. Banks are forced by law to collect missing data of their customers within 30 days of onboarding as a part of the customer due diligence (CDD) process. Otherwise, huge fines are planned – USD 5,000 per customer, which is a large amount for a retail bank with many customers. Non-compliance by the bank is treated as a violation of the law. During the discussion, we learned that not only the beneficial owner but the entire surrounding economic set-up including family members is considered. There is a high granularity of data required by authorities, and financial intermediaries are being held liable to collect correct data. Additionally, global custodians have the liability for the correctness of all data along the chain. The panel concluded that there is an exponential increase in the number of enquiries by tax authorities and that tax authorities have significantly more resources per customer for processing these enquiries than banks do.

The second very important and extensively discussed topic was the latest trend towards total tax transparency due to the Crypto-Asset Reporting Framework (CARF) coming into force. Hywel Griffith, Technical Advisor (CARF) at HMRC, and Corinna Hedtke, Director and Regional Lead Client Tax Information EMEA at Standard Chartered Bank, discussed questions around CARF and CARF interaction with CRS 2.0 with Abdullah Bhana, Senior Policy Advisor at HM Treasury. With CARF, the number of reports and amount of information that has to be collected is increasing dramatically. The information is very comprehensive and is kept for an indefinite period of time, which leads to a huge amount of data being accumulated over the years. In addition, everything is changing very rapidly in this area – new products and even new asset classes are appearing on the market fast while other existing products are disappearing from the market at a similarly high speed. This leads us to the question: Where is the limit? The panel concluded that there are still many uncertainties, e.g. CARF vs. stocks & bonds on blockchain – what is the difference? How can spillovers be prevented? There are still many unanswered questions, which does not make it easier for financial institutions to deal with this topic.

Subsequently, Steffen Gnutzmann, Partner at WTS Global, and Gohar Khan, Partner at KPMG and responsible for the Asset Management & Operational Taxes team, examined recent developments in the area of EU WHT reclaims and showed that there were completely different approaches to this subject in different countries across Europe. As a result of these different approaches, the European Commission launched a public consultation on the EU WHT framework in late 2021. Among other things, the issues included costly and inefficient procedures, lack of clarity regarding documentation requirements, lack of digitalisation as well as reliance on a paper filing system.

Following initial feedback and a questionnaire stage, the consultation has moved to a third stage with the Commission being expected to publish the draft legislation, the FASTER proposal, on 28 June. The aim of the EU initiative is to streamline what are considered to be burdensome withholding tax relief procedures for cross-border investments in the securities market. The next steps are the European Commission’s draft legislation on 28 June 2023 followed by the consultation on the draft legislation.

There was a large panel of high-profile experts discussing how to prepare for amendments to the Common Reporting Standard (CRS). Jenny Turner, Executive Director Group Tax at UBS, Paul Worlock, Anti-Tax Evasion/Operational Tax Director at NatWest, David Smith, CRS Lead at HMRC, Martin Killer, Financial Services Tax Partner and Head of Operational Tax at Grant Thornton and Chloe Tuffin, Director at Deloitte, entered the discussion dealing with the question about the influence of CARF on CRS and vice versa, since – alongside the publication of the CARF in 2022 – the OECD also published amendments to the Common Reporting Standard (CRS) which will be implemented by participating jurisdictions. Some of the highlights of this publication include electronic money accounts, which were included in the scope of CRS, the treatment of the e-money providers as depository institutions, the introduction of Central Bank Digital Currencies (CBDC), the definition of crypto-assets as financial assets, the inclusion of additional data points in CRS reporting as well as additional CRS due diligence requirements.

The effective implementation of the Central Electronic System of Payment Information (CESOP) was discussed in the panel with Gary Campbell, Tax Partner, Tax & Legal at Deloitte, Olivia Boyle, Associate Director, Tax & Legal at Deloitte, and Tom Howgate, Director at Deloitte.

The fact is that from 2024 onwards, all EU payment service providers (PSPs) will be required to record and report transactional data for cross-border payments. The main concern in the discussion was how to deal with the increased number of transactions within the scope of CESOP and how to ensure that the systems are prepared and can withstand the strain of extra data reporting requirements. The timeline for the implementation is very tight – this reporting regime will come into force in January 2024. Thus, the question is what firms should do now to increase efficiency while managing external stakeholders and their interests as well as balancing reporting compliance with data protection requirements. This reporting regime could be seen as “FATCA and CRS on steroids”, since it requires quarterly line-by-line reporting of all transactional data for all cross-border payments. The European Commission has prepared penalties for not filing, filing incorrectly, or overfiling. Expected differences between Member States, similar to CRS in terms of files (size, format, XML scheme) and reporting procedures, submitting transactional data to 20+ tax authorities as well and monitoring the changes per country were seen as huge challenges in this regard.

In the last conference session, chaired by Susanne Rauscher-Nwokedi, Senior Business Analyst at SDS, and attended by Mathias Frostholm Kristensen, Head of Unit at Skattestyrelsen (the Danish tax agency), and Tom Howgate, Director at Deloitte, the question of how tax administrations are improving tax processes for businesses and customers was raised. In a short overview, Mathias described the quick refund process, which is being used at the Danish tax agency. The EU initiative for standardisation and simplification of the withholding tax reclaim procedures in the EU, better known under the acronym FASTER, was the main subject of discussion. Tom Howgate emphasised three building blocks of the initiative:

• Documentation – standardised digital TRC (Tax Residence Certificate)
• Report – standardised XML sent to the corresponding tax authority
• Reporting process – relief at source (TRACE) or quick refund

Changes in the TRACE regime are expected, which may include the reporting of acquisition costs and the introduction of intra-year reports. Apart from that, the question of the actual beneficial owner will still remain a difficult one to answer.

CONCLUSION

• Again, this conference proved to be a platform where the current hot topics in the tax industry are discussed. The conference attracted industry professionals, tax experts, and tax authority representatives from across Europe.
• All topics discussed are more than relevant for the entire financial industry and will keep us all very busy in the next months and years.
• As a technology and software solutions provider in the area of international tax and regulatory reporting for FATCA, CRS, QI, OECD TRACE, and WHT, SDS was delighted to sponsor this excellent industry event and to actively contribute to all expert discussions.

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This event was aimed at investment firms and the fund industry and provided deeper insights into and prompted discussions about fund structures and the future UK funds regime, trying to predict future tax developments and digging deeper into the practical benefits and potential disadvantages of new investment vehicle classifications.

International regulatory and substance requirement developments were explored. OECD Pillar Two requirements and exemptions for firms in larger consolidated group structures constituted the main discussion topics. Authorities’ greater focus on shell companies was also debated and it was concluded that there are still many uncertainties regarding the expected approaches of different authorities to this topic. There was a lively discussion about the difference between the taxes of the UK and those of Luxembourg, especially in terms of complexity. With regard to that aspect, the debate showed clearly that Luxembourg, with its straightforward and very simple tax rules, was favoured by most participants.

Managing changes to tax risk and governance was a big issue at this conference, as it is at many other tax conferences, too. How to anticipate regime changes and implement a forward-looking process was identified as one of the biggest challenges of the industry these days. Embedding proposed frameworks into current processes and monitoring tax risk profiles while aligning them with those of the whole company – paired with the question how to shape the tax team and skill set to cope with stricter compliance obligations – was seen as an extremely challenging and time-consuming task in all organisations.

An international outlook on withholding tax developments was discussed in one of the most interactive panel discussions with participation of Susanne Rauscher-Nwokedi from SDS. The analysis of a future harmonisation of the EU withholding tax regime – followed by an exploration of European Commission proposals and potential challenges of implementation – raised a discussion about the need for such a harmonised regime. The main question was how to capitalise on EU withholding tax reclaims. A broader debate was sparked on TRACE and its implementation successes and problems. It is obviously still necessary to convince the various actors on the market that a harmonised EU withholding tax regime is for the benefit of all stakeholders – individual investors, the financial industry as well as tax authorities.

The industry is seriously concerned about how to cope with an increased number of audits and authority scrutiny since authority investigations are becoming more frequent and more detailed. Thus, finding solutions to compliance issues and control failures by raising risk awareness of capital gains and transaction taxes has become of paramount importance for the industry.

There is a consensus in the industry that for emerging challenges related to tax data and documentation, technological support is inevitable and invaluable. Coping with increased scrutiny and the question how the automation of tax processes and the increasing reliance on technology can be beneficial are the predominant issues the industry is dealing with. Establishing internal consistency and transparency of data in order to cope with additional reporting and compliance requirements is the prerequisite to ensure internal data verification and consistency.

During the last conference session, which was organised as a “fireside chat”, panellists looked ahead to regulatory developments that financial institutions should be aware of and discussed amendments and the expansion of tax information exchange regimes, including the Common Reporting Standard (CRS), solutions to potential challenges of the Crypto-Asset Reporting Framework (CARF) and developments in Blockchain. At the end, the panellists expressed their wish for the establishment of the UK to become an attractive prospect for investment funds following Brexit.

CONCLUSION

This conference gathered high-profile industry experts from the fund industry and gave a broad overview of the current and expected developments and challenges the fund industry is already facing and will have to deal with in the future. Currently, the industry is facing a lot of uncertainty and its perspectives are strongly dependent on finding a way to cope with a higher number of audits and more authority scrutiny. One of the ways is the increased use of technology for collecting and validating data and preparing it for reporting in an automated way by means of standardised applications and intelligent data processing including the utilisation of artificial intelligence (AI). All attendees agree that this is anything but a simple task and will tie up many resources that will be missing for operative work.

Observation by:
Hrvoje Kajzer

Feel free to contact me at any time for further information, an expert chat or a discussion about any of the above-mentioned topics.

The event was aimed at financial services professionals keen to engage in and learn more about the most important developments in the tax industry. The conference provided a fantastic opportunity to take part in debates and discussions with the most qualified and knowledgeable professionals.

The conference consisted of a series of four webinars held Monday through Thursday and a networking event on Thursday evening, culminating in the in-person conference on Friday.

Four webinars during the week covered some of the topics currently most discussed:

• The Great Tax Resignation picked up on the topic of attracting and retaining specialist tax staff by designing new career paths to make the workplace more inclusive, personally satisfying, and adaptive in order to meet the challenges brought about by digitisation, globalisation, and sustainability.
• In Tax, Tech, what’s going on? panelists discussed the challenges for the industry caused by the exponential growth of digital asset investment as well as new challenges for global tax authorities.
• In the webinar Digitising WHT Reclaims, the panel including Susanne Rauscher-Nwokedi from SDS covered topics related to digitising the withholding tax reclaims with a look at the EU’s withholding tax relief system and a review of the implementation of the OECD TRACE regime in Finland.
• The webinar O Tax, Where Art Thou? provided an overview of tax as a topic at the top of the agenda worldwide, driving decisions on policy, trade, strategy, and sustainability, with tax leaders facing new challenges such as rapidly changing compliance obligations and the necessity of contributing to the ESG agenda.

On the morning of the conference day, we observed a bit of a rush hour feeling at the registration desk, where a crowd of attendees, speakers, and panelists came to pick up their name badges.

The opening words were spoken by Ali Kazimi of Hansuke, who welcomed all attendees and especially the main sponsors WTS Global and SDS.

The aim of the conference – with most sessions being held as panel discussions rather than classic lectures – was to encourage the audience to ask questions, comment on what was said in the panels, and actively engage in the discussions, which was successfully implemented during the entire conference day.

The sessions of the conference were very much influenced by current events and affairs, thus again covering the cum-ex affair, which was named the single biggest destroyer of trust between financial institutions and tax authorities. In this case, everything failed – from internal controls and compliance within financial institutions and external auditors (Big Four) to regulators and tax authorities. As a matter of fact, this had and still has a huge influence on policies and the scrutiny of all tax authorities and regulators.

Since the loss of trust is seen as a direct consequence of the cum-ex affair, several sessions tackled the question of restoring trust in the system with topics around audit failures and audit reforms, ESG challenges, the break-up of the Big Four, wealth tax, etc.

Two exciting topics with enormous audience participation were global tax management and the question of how much tax transparency really exists. When talking about tax transparency, you cannot avoid discussing international reporting regimes implemented in the last decade, such as FATCA, AEOI, Common Reporting Standard (CRS), MDR, DAC 6, etc., and all other regulatory and reporting obligations which financial institutions have today. However, it turned out that the crucial question is not whether you have your regulatory reporting process in place and formally fulfill your reporting obligations, but how to deal with those obligations and how to enforce them.

CONCLUSION

• This conference was a gathering of industry specialists, experts, tax authorities, and academics. It provided a comprehensive overview of the current hot topics in the tax industry and the challenges it is facing.
• All the topics discussed in the four webinars, the presentations, and the panel discussions on the conference day are more than challenging for the entire financial industry as well as for the technology providers. However, they are more relevant than ever.
• As a leading provider of software solutions in the area of international tax and regulatory reporting for FATCA, CRS, QI, and OECD TRACE, SDS was delighted to support and sponsor such an excellent industry event.

Observation by:

Hrvoje Kajzer 

Feel free to contact me anytime for further information, an expert chat, or any discussion about the topics mentioned above.

The conference marked the beginning of the return to onsite events and gathered the “hard core” of more than 35 experts in taxation, reporting and digitalisation of tax. The participants were happy to meet old friends, to join in on different conversations and to actively participate in numerous interesting sessions and panel discussions. It was very important for us from SDS to finally meet people in person again, to exchange information with the community about the latest developments and requirements in the operational tax arena and to join expert talks.

On the agenda was a mix of standard tax topics, new tax developments and topics related to the digitalisation of tax and crypto reporting. After listening to the opening words of Peter Grant from KPMG, we enjoyed a very interesting speech by Mark Huyan from JP Morgan. He presented and explained CARF (Crypto-Asset Reporting Framework) and the current status on OECD public consultation in this matter. The talk included a critical review of the challenges in regard to reporting in the crypto world, which is anonymous by design.

The conference proceeded with an overview of the digitalisation of tax, followed by a discussion about current expectations around meeting audit requirements, especially in regard to meeting the new requirements concerning CRS (Common Reporting Standard). Environmental taxes and ESG tax developments across Europe were also part of a short discussion.

The second half of the day was dedicated to OECD TRACE. Katja Pussila from Vero Skatt (Finnish Tax Administration) presented astonishing, positive results from the first year of the TRACE regime in Finland. In summary, individual investors already benefitted exceptionally well from TRACE in the first year alone. This proves that there is no reason not to adopt TRACE throughout the EU. This talk formed a solid basis for the next vivid panel discussion, which featured the SDS tax expert Susanne Rauscher-Nwokedi. She explained how the OECD TRACE initiative could be integrated at EU level and which measures would be needed for such a wide-scale adoption of TRACE.

Conclusion:
From the point of view of SDS, it was a very successful event which enabled us to meet our colleagues from the operational tax community in person and to discuss current and future developments in the tax arena.

Observation by:
Hrvoje Kajzer

Feel free to contact me for further information, an expert chat or any discussion about above-mentioned topics.

Some highlights from the conference:
SDS booth

Panel discussion about the future of OECD TRACE at EU level with SDS panellist Susanne Rauscher-Nwokedi.

Katja Pussila of Vero Skatt (Finnish Tax Administration) presenting the outcome of the first TRACE reporting in Finland this year.

What makes a company successful? A good product on its own will not tip the scales toward success, nor is it the only element in a customer’s decision to buy. A company’s reputation can also influence this decision. Business success requires something extra. Board members, managing directors, executives, and employees are expected to behave in a manner that complies with the legal obligations thus creating essentials such as trust, credibility, reliability, and good reputation.

That something extra also comprises integrity and each employee’s personal responsibility for his or her own actions. In less abstract terms, all these qualities together constitute the company’s value-based culture of compliance. This is a factor that also influences the success of SDS. Business success does not stand above legal obligations nor is it unrelated to morality or integrity. The way SDS achieves business success is at least as important as the very success itself, and the Code of Conduct provides the framework of orientation for this. It combines two essential aspects. All employees are expected to comply with legal obligations and to behave with integrity. For Deutsche Telekom, the Code of Conduct is the combination between internal demands and the promise to outside at the same time. It also ensures that SDS remains a transparent and traceable enterprise for everybody.

The Code of Conduct applies to all SDS-board members, managing directors, executives, and employees of the Deutsche Telekom AG worldwide.