Investor Relations


Code of Conduct

KPN wants to adhere to all applicable laws and regulations, including anti-corruption laws. In addition, social and ethical norms and values play an important role in our daily decision making. We do everything possible to maintain our customers’ trust and confidence.

Our way of working

The KPN Code of Conduct describes how we work in an open, transparent, honest and socially responsible way to ensure the success of the organization and everyone within it. The KPN Code of Conduct is divided into four separate codes that describes and stimulates how to act with customers, shareholders, business associates, competitors, each other and society in the broadest sense. Some codes further implement statutory regulations, such as competition laws and cartels. Other codes detail how we safely and fairly deal with communication, information and company assets.

Internal reporting procedure

KPN encourages its employees to immediately report any suspicion of non-compliance with the Code of Conduct through one of the internal reporting channels. Potential incidents can be reported by calling the Helpdesk Security, Compliance and Integrity. Employees can also always contact KPN appointed ombudsmen and, of course, talk to their manager.

Following a report, a KPN Security and/or KPN Risk &Compliance expert investigates the potential violation. The outcome of the investigation may lead to a disciplinary action, as laid down in the KPN Collective Labor Agreement (“CAO”). The severity of the disciplinary action is determined by the nature and circumstances of the incident, and may include termination of employment. If necessary, KPN takes additional action to prevent a similar incident in the future.

Anonymous reporting

Violation of the Code of Conduct can be reported by using the SpeakUp Line, an anonymous reporting procedure which can be contacted by telephone or secure website. KPN SpeakUp Line is managed externally by an independent organization. Finally, employees can report incidents anonymously by letter to the chairman of the Supervisory Board.

Risk & Compliance Officer

Since 2005, KPN employs a Risk &Compliance Officer to support the organization. The Risk &Compliance Officer has responsibility for the compliance and integrity program, focused on telecommunications and competition law, and for the Code of Conduct. The Risk &Compliance Officer leads the Risk &Compliance department within KPN and reports to the General Counsel, the Board of Management, the Audit Committee of the Supervisory Board and the ACM.

Political gifts

KPN does not make any political donations. We never solicit any form of gift, invitation, loan, financial advantage or any payment in cash or in kind, including donations to third parties and charitable causes. This rule is absolute; there is no room for discretion. Similarly, we never offer or accept personal gifts, including discounts, from business contacts.


Code of Conduct
Subcode 1 - How we interact
Subcode 2 - How we interact with third parties
Subcode 3 - How we deal with information, communication and company resources
Subcode 4 - How we interact with society
Reporting Procedure ‘Speak Up’