Feature Story: Ethical Business Practices BRINGING OUR CODE TO LIFE “Do It the Right Way. Always.” This is one of our core values and foundational to our Code of Business Conduct. That’s why we work so hard to enable all our employees to understand what the Code means and how it translates to their jobs. Integrity365 (i365) is our innovative professional standards training curriculum that brings our Code to life for all employees. Featuring members of Team Magenta, including executives, the TV show format delivers T-Mobile’s annual required compliance and ethics training through refreshers and practical, interactive examples of what it means to do the right thing every single day across a variety of situations. A typical i365 episode includes video-based stories addressing different Code topics through realistic, at-work situations that help employees identify concerns through multiple choice responses to the ethical conduct questions. This training is especially effective because it allows employees to participate in making the right decisions based on the values and principles of the Code. We also created a Manager Edition specifically for people managers which provides supplemental training to equip them to engage their teams on the core principles of T-Mobile’s Code. People managers can access an i365 dashboard to track and drive their team’s training completion. As part of the onboarding process, we also provide our new hires with a tailored edition of i365 to empower them to start off doing it the right way—always. They are required to complete the training during their first four weeks on the job. All employees are required to complete each episode of i365 or other Code training, and quarterly completion reports for all lines of business are submitted to the N ominating and Corporate Governance Committee. This engaging and thorough approach to training helps embed our commitment to ethical business standards into our culture and stay in compliance with federal and state laws and regulations, as well as our own policies. VIDEO TRAINING ON EVERY ETHICS TOPIC i365 training occurs throughout the year and covers the core topics of our Code of Business Conduct, including the following: ■ We Respect Each Other —Standards of professional conduct for T-Mobile employees when interacting with each other ■ Addressing Harassment & Discrimination — How to recognize discrimination and harassment in the workplace and what to do if you are a victim or an observer ■ Protecting Information the Right Way — Importance of and best practices for protecting T-Mobile assets and information, including customers’ personal data ■ Demonstrate Integrity —How to comply with equities trading regulations, conflicts of interest, and giving and receiving gifts ■ Doing Business Right —Awareness of anti- corruption and antitrust rules, government ethics rules and ethical marketing practices ■ Social Media the Right Way —The dos and don’ts of using social media while employed by T-Mobile ■ Speaking Up at T-Mobile —Why speaking up is important, when to speak up, and how to speak up At the end of each course, employees are asked to give feedback on the training. Our Compliance team regularly tracks this feedback, along with completion and engagement rates, to assess overall satisfaction with the training, relevance to everyday job duties, and impact on behavior. This enables T-Mobile to continuously incorporate feedback and learnings into new iterations of i365. THE ENVIRONMENT THE NUMBERS AND SMALL PRINT OUR COMMUNITIES OUR PEOPLE 2021 CORPORATE RESPONSIBILITY REPORT 16 OUR COMPANY OUR GOVERNANCE IN CONVERSATION WITH DAVID WERBLOW, T-MOBILE’S CHIEF COMPLIANCE OFFICER David talks about keeping ethical business conduct at the forefront for employees and evolving the program to address ongoing feedback. Our compliance and ethics programs aspire first and foremost to empower employees to do it the right way through clear policies and effective training. Even with effective training, we understand that the best way to handle an ethical issue in a particular situation is not always clear so we invite and encourage employees to reach out when they have a question about how they should respond the right way. We have an Integrity Line and work diligently to ensure our employees know it exists, know how to access it, and feel confident that their concerns can be reported anonymously, if that’s their preference. Our Speak Up Policy protects employees who raise good faith concerns from retaliation. We also continuously evaluate our performance to help us ensure our programs are effective. We really dive into the data. We conduct surveys and scrutinize the results to make sure we have an accurate assessment of how we are executing on compliance. Through careful analysis of reported concerns and outcomes, we identify trends in a timely manner and then are thoughtful, strategic, and holistic about next steps. While I’m happy to say we get great and candid feedback from employees, we are never satisfied with the status quo and are always striving for continuous improvement. To tap into another core T-Mobile value: We Won’t Stop!”
T-Mobile Corporate Responsibility Report Page 15 Page 17