How we work The KPN code of conduct

Simply close by


About this code of conduct


The three core values of KPN


The KPN code of conduct in practice


The company code of conduct and the subcodes


Compliance with the KPN code of conduct


‘The core values reflect how we want to be rather than how we are.’

How we workThe KPN code of conduct We offer our customers simple products and

shareholders, business partners, and regulatory

services along with personal attention. And we

authorities. Living up to our core values requires

want our customers to trust our products and

personal responsibility from each one of us. And

services. This is why ‘simplicity,’ ‘personal

we talk to each other about this where

approach,’ and ‘trust’ are our core values. The

necessary. After reading about our code of

basis of these core values starts with us - always

conduct, you will have a better understanding of

and everywhere. The company code of conduct

the meaning of our three core values and how

explains the way in which we apply and live up

you can apply them in practice. I wish you every

to these three core values within our


organization. Everything we do influences the relationship with our customers. If we live up to

Yours faithfully,

our core values, our customers will be satisfied. The same is true for our relationships with

Eelco Blok

The KPN code of conduct 

About this code of conduct What is a code of conduct?

recognized by the world around us.

Just as a country has a legal code and a family conduct. The code of conduct is a collection of

How does this code of conduct work?

agreements, points of view, and guidelines that

This code of conduct applies to all KPN

apply within the company, to regulate contact

employees. The code of conduct is there to

with others both in and outside the company.

ensure that everyone knows what is and is not

has its own house rules; a company has a code of

possible, what is and is not done, and what is

Why have a code of conduct?

and is not permitted. We call each other to

The world of KPN has much in common with

account on this, at all levels within our

many parts of society. Not just employees but

organization. And we should realize that those

also customers, suppliers, shareholders,

who do not adhere to the code of conduct, risk

governments, and all other parties who are

the imposition of sanctions.

involved in any way with our business activities

The rules and sanctions arising from the code of

are also part of the world of KPN and of society.

conduct are further described per subcode. The

It is important that within KPN we all operate by

code of conduct and the subcodes can be found

the same standards. The code of conduct

on the TEAM KPN homepage under ’code of

describes the standards that we operate by in our


daily business within KPN. The code of conduct ensures that those standards are easily

 How we work

The three core values of KPN KPN cannot function without technology, but we

will make it easy for the customer to understand.

do want our customers to enjoy this technology.

In order to achieve this in practice, we treat each

We want our customers to feel that their world is

other as we would treat our customers.

always close by thanks to our products and

We search for solutions to each other’s problems.

services. And to achieve this, it is essential that

We know that we can rely on each other and we

the ultimate aim of everything we do is to serve

work accordingly. This also means that we treat

our customers. After all, without our customers

each other personally, we do not consider each

we would not be here. Customer focus is not a

other as just a representative of a position, but as

gimmick, it has to be embedded in our genes and

colleagues. When working together we always

in our culture; only then can we live up to the

endeavor to provide insight and simplicity. Our

expectations of our customers - or even better,

processes are clear and we can see each

we exceed them.

neighboring link in the process chain. This improves our level of service by leaps and

Our solutions have to fulfill the wishes of our


customers. This creates trust. In doing so we do not see our customers as numbers, but must

To live up to our standards we have defined three

instead always treat them personally. And

core values that guide all aspects of

because we know that our customers do not

KPN’s business, these are:

want to get frustrated by the limitations of bits and bytes, or by the complexity of telecoms

• Simplicity

technology, we strive for simplicity. However

• Personal approach

complicated the technology may be, at KPN we

• Trust


••Personal approach


We want to help people communicate more and more easily. Technology is our means, but we make sure that the customer never thinks that it is too technical or too complicated. We are constantly looking for innovative products and services that are exceedingly easy to use. Our processes are simple and we make clear jargon-free statements that everyone can understand. By doing this, everyone can take advantage of our innovative opportunities.

We want to be available and approachable for our customers. For this reason we are honest, open, and explicit. We listen well and we readily investigate our customers’ and colleagues’ requirements and questions. If someone has a problem, then we feel that it is our responsibility to find a solution and to take the initiative. And if something goes wrong, we do not hide behind rules or procedures but instead we solve the problem together. This energetic and pleasant way of working means that we offer what the customer wants.

We want to meet expectations. This is apparent from the quality of our products and services. The customer can rely on this, just as he can rely on our honorable way of doing business. In our dealings with each other we are also just as reliable and focused on the customer. We fulfill our promises and we are not afraid to call each other to account where necessary. This is the only way that we can work together in an atmosphere of mutual trust on innovative, user-friendly products and services that allow us to exceed the customer’s expectations.

The KPN code of conduct 

The KPN code of conduct in practice The code of conduct guides the way we at KPN deal with the world around us. This can mean different things to different groups of people, but it is all driven by the same basic principles: simplicity, personal approach, and trust.

What does the KPN code of conduct mean for customers? and understandable for customers - even in

This means that customers can expect KPN to deliver on the following aspects and in other areas too

technically complex situations.

•• That customers’ requirements are always the

•• Simplicity. KPN wants to appear clear, explicit,

•• Personal approach. KPN is committed to providing professional, fast services, with a

guiding factor when working together. •• That the quality KPN provides in its products

personal touch, to reacting to the customer’s

and services (from connection to invoicing)

requirements, to applying the best

meets these requirements and that the pricing

communications technology and to helping customers to familiarize themselves with the solution. •• Trust. KPN earns the trust of its customers by

is appropriate to the quality provided. •• That any problems arising in services provided will be rectified quickly and effectively. •• That normal business principles apply to the

offering high-quality, reliable services at a

relationship between KPN and its customer:

reasonable price that respect the customer’s

from courteous helpfulness to timely

requirements concerning confidentiality and

reminders and from regular maintenance to

privacy. We want to make our customers feel sure that they have made the right choice. .

specific offers. •• That KPN takes the lead in transforming technical innovations into practical solutions.

‘Offering customers an immediate solution. Something they can use right away. That’s what customer focus means to me.’

 How we work

What does the KPN code of conduct mean for employees? •• Simplicity. We believe in direct lines and individual involvement. We realize that different situations call for different behavior - and we adjust to the situation as necessary. We do not hesitate to call each other to account if necessary, in plain language. We also ensure

This means that KPN employees can expect the following from each other and from KPN: •• That in exchange for fulfilling duties diligently, high-quality employment conditions and social policy are provided. •• That other people’s property is treated with care (including the equipment that KPN issues).

that our processes are transparent, so that we

•• That cooperation is considered as an important

understand each other’s business activities and

factor in promoting and increasing customer

so that we work together in the best possible way.

satisfaction. •• That working conditions are provided in which

•• Personal approach. We listen to each other,

individual health and safety are key issues.

take our own responsibilities, take a flexible

•• That any form of racist language, sexist or

approach, and bear in mind each other’s

violent behavior, sexual harassment,

weaker points. We talk to each other, not

discrimination against minority groups or any

about each other. Within KPN we allow others

form of harassment will not be tolerated.

to show their entrepreneurial spirit and appreciate guiding leadership. We do not see employees as anonymous cogs in a machine but as people who deploy their talents for a

•• That a suitable confidential advisor is available with whom work-related problems can be discussed openly and without risk. •• That we call each other to account for behavior

common employer. We see our employees as

that deviates from the code and that if

people who have the right to be treated

necessary, disciplinary action will be taken.

respectfully by colleagues, management and by the organization as a whole. We see our employees as valuable ambassadors of the organization. •• Trust. Within KPN we show that we trust one another, and in turn we are trusted too. We respect each other’s expertise and opinions, at all levels. The KPN code of conduct 

‘Simplicity? To me, that means explaining things without superfluous information. Including product descriptions.’

What does the KPN code of conduct mean for shareholders?

This means that shareholders can expect the following from KPN:

•• Simplicity. We talk but we listen too, which

•• That they will receive, in a timely way, all

means that we at KPN can guarantee a timely,

relevant information they need to exercise

effective and open exchange of ideas, whereby

their authority.

every subject gets the attention it deserves. In

•• That the directors are aware of the

this way, the process is made clear and

indispensable role that shareholders fulfill as

understandable to everyone.

capital providers and of the necessity to view

•• Personal approach. Communication to shareholders is pro-active in nature and takes the form of an open dialogue. •• Trust. Based on a clear-cut vision of the world of telecommunications, KPN makes clear strategic choices and ensures excellent management of the business operations and

shareholders as important partners, both individually and collectively. •• That one of the core tasks of the directors is serving the interests of shareholders and other stakeholders in the organization (customers and society) in a balanced and consistent way. •• That both the letter and the spirit of the law

organization, where the focus lies on achieving

and of other socially accepted guidelines are

a sustainable return on investment. This

complied with. Far-reaching corporate

healthy and sustainable entrepreneurial spirit

governance principles such as the so-called

means that we earn and repay shareholders’

‘Dutch Tabaksblat Code of Corporate

trust. Transparency in policy and transparency

Governance’ will be enforced.

in reporting, including financial reporting are important pillars in this respect.

 How we work

What does the KPN code of conduct mean for business partners? •• Simplicity. KPN acknowledges and recognizes that each relationship is different and requires

This means that suppliers and other business partners can expect the following from KPN: •• That KPN is committed to maintaining stable

an individual approach that does not just

relationships, for the mutual benefit of both

revolve around the KPN position. This

parties and with partnership being the guiding

approach must be clear to all involved and be set down in clear agreements. This applies to

consideration. •• That the choice of business partners is based

suppliers as well as other types of business

on honest and open consideration of the

partners (for example distribution partners and

goods and/or services offered and the related

consultants). •• Personal approach. KPN is committed to open,

price. •• That KPN will enforce the subcode

honest and long-term sustainable relationships

‘Promotional Gifts’ both in letter and in spirit if

in which business and personal interests are

any attempt is made to influence KPN

respected. This is why KPN enters into clear,

decision-makers personally with non-business

specific agreements, based on the

items (outings, luxury gifts, significant favors,

requirements of our customers. KPN expects

private benefits etc.).

business partners to uphold the same personal standards with respect to quality and service. •• Trust. Mutual trust forms the foundation for joint success, based on these shared principles and focused on mutual growth. .

•• That KPN employees will only use non-business means with the greatest restraint in their dealings with business partners. •• That KPN employees will treat business partners as equal professionals.

‘ A personal approach? I see it as making the effort to see things from the other person’s point of view.’ The KPN code of conduct 

What does the KPN code of conduct mean for society?

This means that society can expect the following from KPN:

•• Simplicity. KPN wants everyone to be able to

•• That it goes without saying that consideration

enjoy technological developments and new

for the environment is part of all business

opportunities for telecommunications that are a


direct result of these developments. This is why our products excel in their ease of use, the aim being to achieve easier communications for everyone. •• Personal approach. KPN’s ethical, business, and social policy is determined by a philosophy of life focused on people. This is also apparent

•• That KPN’s infrastructure meets high standards with respect to safety and sustainable quality. •• That within the limits set by the law, KPN will do everything in its power to prevent harmful, improper or irresponsible use of its infrastructure. •• That KPN considers involvement in society

from the high standards set by KPN with respect

important and that KPN wishes to make an

to environmental conservation and safety. Our

appropriate contribution to the problems facing

personal service and our focus on ease of use

society. The major areas of focus here are

means that no one is excluded from the many

education and young people and health care

opportunities that telecommunications offers.

and the elderly.

•• Trust. In respect of the services provided by KPN, society can count on integrity, social involvement and consideration of sustainability

•• That KPN will take the needs of disadvantaged people into account. •• That KPN maintains a dialogue with social

issues. Society will be able to count on KPN in

groups. That KPN is aware of the unwanted side

the event of an emergency, social unrest or

effects of telecommunications (spam/viruses,

other situation in which KPN’s knowledge and

internet security for children, privacy) and does

expertise can play a relevant role.

all in its power to prevent or reduce these effects.

 How we work

‘Trust? To me, that means living up to your promises. In other words, doing what you say you’ll do.’

What does the KPN code of conduct mean for the competition?

This means that competitors can expect the following from KPN:

•• Simplicity. KPN endeavors to accommodate

•• That KPN takes a tough but honest attitude in

competitors in a way appropriate to their size and position in the market. KPN avoids the use of objectionable methods and maintains an open and clear attitude in the market and with respect to individual market players. •• Personal approach. Diversified competition is in the customers’ interest and is accordingly

the struggle for the customers’ favor. •• That KPN plays by the rules of good business and respectable entrepreneurship. •• That the competitive struggle takes place where it belongs, in the marketplace with everything open and above board. •• That KPN determines its behavior in the market

encouraged by KPN. KPN wants to learn from

independently and does not breach the

what others do. Even though competitors are

regulations concerning competition (including

business opponents, KPN also considers them

the telecommunications and monopolies

as colleagues. For this reason, KPN does not


portray its competitors as stereotypical enemies but instead upholds personal standards in the contest with competing organizations and individuals. •• Trust. Competitors can trust KPN to differentiate between business activities that are subject to full competition and those where KPN still has a certain dominant position. We are confident of our own ability to react to competition in an honest, open, and sincere manner.

The KPN code of conduct 

The company code of conduct and the subcodes The KPN code of conduct is a dynamic concept,

be clearly indicated on TEAM KPN and

which means that it is never ‘finished’. The latest The code of conduct is explained

version of the code of conduct can be found on

in further detail in subcodes for specific processes

the TEAM KPN homepage and at

and areas.

When the code of conduct or a part

The relationship between the different subcodes

of the code is changed, this will

is illustrated in the diagram below:

Business information

Additional activities

Business transactions and promotional gifts

Inside information

Code of conduct

Code of Ethics for the financial function

Cartel law

Commu­­­ni­ cations and Equipment

Competition Privacy

Custumer information

• for all KPN employees


• for specific job groups

Custumer information

Besides the subcodes mentioned here, there are

code of conduct or legal regulations.

also three related guidelines and instructions:

•• KPN fraud policy: guidelines for KPN employees

•• Whistleblower procedure: regulations under

to understand what fraud is, where (suspected)

which KPN employees can report (suspected)

fraud can be reported and what action will be

breaches of the law and/or the KPN code of

taken when fraud is reported.

conduct directly (and anonymously) to the Audit Committee. •• Protocol for integrity investigations: guidelines for investigating a possible breach of the KPN

 How we work

The latest versions of the subcodes, guidelines and instructions can be found on the TEAM KPN homepage, under ‘code of conduct’.

Compliance with the KPN code of conduct Our ‘house rules’ are defined in the company

employees can always contact the KPN Helpdesk

code of conduct. Working at KPN means that all

Security, Compliance & Integrity (0800-4040442).

employees, at all levels within our organization,

They can also make direct contact with the

are personally responsible for the way in which

confidential advisor within their own business

our code of conduct is interpreted in their

unit if they feel intimidated or sexually harassed

behavior and area of work. Managers will ensure

in any way. A list of confidential advisors can be

that their staff are familiar with the code.

found on TEAM KPN in the ABC index (search for:

Managers are also expected to create an

’vertrouwens­personen’ - confidential advisors).

atmosphere where the code and its compliance can be openly discussed. Those who do not

Some elements contained in this code of conduct

comply with the company code of conduct and

are explained as explicit rules and regulations in

the subcodes, risks disciplinary action being

separate subcodes. The business unit

taken under employment law which may result in

management teams and the subcode compliance


officers report on the implementation and compliance of the subcode. Based on these

Within KPN employees may be faced with

reports the Board of Directors holds regular

problems, incidents, or questions concerning

discussions with the management teams.

compliance with the code of conduct. If it is not

Furthermore, each year KPN will issue an external

possible to resolve these matters within their own

report concerning the degree to which the code

department or with those directly involved, then

of conduct is embedded in the organization.

‘ Even in my technical environment, everything I do is geared to meet the wishes of the customer.’

The KPN code of conduct 

‘Whenever I explain to my niece what I do for a living, I keep in mind that she’s not familiar with all the internal processes and product names. I just tell her what we make possible at KPN and what the user gets out of it and can do with it. And that’s the same thing I do when I talk to customers.’

 How we work


November 2012