Deutsche Telekom said this week that it is working to boost ethical behavior and foster a speak-up culture within the company to minimize compliance risks.

“Establishing what’s called a compliance management system is not enough to prevent, investigate and punish rule breaking,” said Thomas Kremer, a member of the Deutsche Telekom board of management for data privacy, legal affairs and compliance. “An appropriate corporate culture, where employees feel able to speak out against inappropriate behavior, also has a vital role to play.”

For this reason, Deutsche Telekom announced that it is taking steps to strengthen ethical behavior and a speak-up culture in the company. “The first step is to analyze how our corporate culture works on a day-to-day basis and the causes of inappropriate behavior,” said Manuela Mackert, chief compliance officer at Deutsche Telekom.

Mackert explained that, with the help of an expert panel, Deutsche Telekom “will work on how to improve our compliance-oriented corporate culture,” she said. Deutsche Telekom has commissioned the European School of Management and Technology (ESMT) and the Hertie School of Governance to examine its corporate culture in detail in a scientific study.

“We want to find out how much significance is attached in the company to ethical and rule-abiding behavior and, in that context, the roles played by hierarchy and orientation in achieving certain goals,” says Profesorr Jörg Rocholl from ESMT Berlin.

And Prof. Helmut Anheier from the Hertie School of Governance adds: “Possible drivers of unethical behavior may include ambiguous responsibilities or a misconstrued sense of loyalty. This requires closer inspection.”

The study will be monitored by an independent expert panel due to hold its first meeting on Sept. 1, 2016. The expert panel includes Mackert, who will co-chair the panel with Prof. Stephan Grüninger, Hochschule Konstanz University of Applied Sciences.

Other members include:

Monika Brandl, chairwoman of the Central Works Council at Deutsche Telekom;

Muel Kaptein, Professor of Business Ethics and Integrity Management, Erasmus University Rotterdam;

Birgit Klesper, head of group transformational change and corporate responsibility, Deutsche Telekom;

Prof. Klaus Leisinger, chairman of the Global Values Alliance Foundation;

Noor Naqschbandi, corruption prevention, UN Global Compact, Germany Network;

Sylvia Schenk, Transparency International, Germany Chapter;

Prof. Rita Süßmuth, former president of the Bundestag and German federal minister; and

Matteo Tonello, managing director, The Conference Board.

The results of the study and its recommendations for action should be ready by mid-2017. “The goal is to produce a white paper with findings on creating a culture that minimizes the risk of law and rule breaking so that it can then also be used by other companies,” the company stated.