Ethics & Integrity

Pursuing transparent communication and robust ethical practices to instill trust.

Click through to learn about our 2024 impact in action. For detailed ethics data, please see our corporate responsibility KPI webpage. 

The ability to build and maintain trust improves businesses’ bottom line. In fact, 84% of consumers consider a company’s ethics and values before making a purchase. Additionally, 46% of employees say working for an ethical business is more important to them than a higher salary. To achieve responsible, long-term success, businesses must embed ethical considerations at every stage of their operations and value chain.

At AT&T, we strive to go beyond mere compliance; we cultivate a values-based culture that integrates ethical principles into all that we do. Our goal is to empower every employee to embrace and uphold our standards, driven by the conviction that doing the right thing benefits all.

Ethics and integrity are foundational to who we are, and for more than 140 years, these principles have guided our interactions with our customers, our shareholders, our communities and each other. As we deliver our purpose to connect people to greater possibility with expertise, simplicity and inspiration, we maintain an unwavering commitment to ethics and integrity. We are committed to doing the right thing every day.

The Chief Compliance Office (CCO)

Our approach is directed by our CCO, which is, in part, modeled on the Federal Sentencing Guidelines for Organizations. We continuously improve CCO programs and policies in accordance with U.S. Department of Justice’s Evaluation of Corporate Compliance Programs and other best practices.

Managing Risks

The CCO conducts annual risk assessments, focusing on areas that could present significant reputational, operational and/or financial risk.

To establish an effective, consistent risk management approach, we maintain an Enterprise Risk Management (ERM) governance program. Launched by the CCO, along with business unit stakeholders, the ERM program aims to identify and address key risks across AT&T.

Learn more about our risk management approach in our Annual Report and Proxy Statement.

Our Guiding Policies

The AT&T Code of Business Conduct (the “Code”) defines the honest, ethical behaviors all employees are expected to follow, and we require employees to review it annually. We update the Code regularly to ensure ongoing relevance and effectiveness, with a particular focus on our commitments to ethics and integrity and to doing the right thing for our business, shareholders, customers and others, as well as to making a difference in our community. Additionally, our Board of Directors follows our Code of Ethics. The Code of Ethics emphasizes the importance of avoiding conflicts of interest and our expectations for ensuring timely, accurate Securities and Exchange Commission filings and related financial statements.

In addition to the Code, we have policies that govern specific operational areas. Some of these policies apply enterprise-wide, while others are tailored to particular business units or segments. One key policy relates to anti-bribery and anti-corruption (ABAC). AT&T strictly prohibits giving, offering, authorizing or taking bribes, as well as engaging in fraud or corruption under any circumstance. Our Anti-Bribery Anti-Corruption (ABAC) Policy applies to all employees, and risk-appropriate training is conducted annually.

All employees must act in accordance with these guiding policies. Violations may result in disciplinary action including, but not limited to, written warning, adverse pay treatment, suspension or termination of employment.

For more on company policies, see our Policies & Commitments page.

Raising Employee Awareness

Promoting ethical conduct is a shared responsibility, and we deliver trainings and communications to help ensure employees understand what is expected of them. New hires receive initial Code training, with annual ethics and compliance training for existing employees. Our Chief Compliance Officer and senior leadership also regularly communicate with employees on ethics and integrity, driving our tone from the top.

As part of broader training requirements, we deliver targeted ABAC training. We regularly train employees who interact with public officials to help them understand permissible conduct. Employees exposed to ABAC risk must complete ABAC basics training, and those who perform certain functions must complete role-based ABAC training.

Targeted Ethics Resources

To support ongoing learning, we offer Ethics@Work, a set of resources and in-person and web-based trainings on topics like:

• ABAC
• Data protection
• Social media
• Conflicts of interest
• Reporting suspected violations
• Privacy

Employees can access the program’s toolkit via the Code and our Ethics@Work Hub.

Understanding Employee Perceptions

We are committed to supporting a speak-up culture where employees feel confident discussing ethics issues. As such, we maintain several strategies for receiving feedback, opinions and concerns.

Employees with questions or concerns related to the Code or any other ethics or compliance issue, can go to their supervisor, another manager, Human Resources, the CCO, Global Security and Investigations, or Legal. We also maintain a telephone hotline and online reporting mechanisms for confidential (and anonymous, if desired) reports of suspected or actual policy violations, while our “Ask Compliance” portal creates a direct route between employees and the Compliance team for policy-related questions and guidance. Information on these resources is available via our intranet, the Code, compliance-related trainings and our Ethics@Work Hub.

The CCO also periodically surveys employee perceptions of ethics, honesty and integrity. Results — which inform cross-company ethics programs — are anonymous and aggregated to protect identities, ensuring people feel comfortable completing the survey.

Everyone should feel safe and confident reporting unethical behavior or a violation of company policy or law, and we maintain a strict non-retaliation policy.¹ Wherever we receive allegations of retaliation, we investigate them and take appropriate action.

Ethics & Integrity Governance

Compliance is the responsibility of every AT&T department and employee, with overall oversight from various internal bodies:

• Board of Directors’ Audit Committee: Oversees compliance with legal and regulatory requirements, as well as administration and enforcement of the Codes and the Compliance Program.
• Chief Compliance Officer: Has overall CCO responsibility and partners with business stakeholders, sharing tools and information to mitigate risk and manage compliance. Reports at least annually to the Audit Committee on compliance and ethics-related trends, risks and action plans, holding independent discussions with committee members as needed.
• CCO/Integrity & Compliance Teams: Ensures adherence to internal compliance requirements and all relevant laws and regulations, focusing on areas like ABAC, antitrust and competition, third-party oversight, data protection, sales practices, records and information management, and privacy.
• ERM Executive Team: Oversees our ERM progress, including setting the mission and vision, defining risks, identifying key business objectives, consulting on key risk programs and promoting risk culture. It is led by the Chief Compliance Officer and comprises various senior officers and business leaders.

Stakeholder Engagement

We are continually looking to strengthen our commitment, including in collaboration with external stakeholders. The Chief Compliance Officer participates in The Conference Board of the Global Business Conduct Council, a forum where senior compliance leaders can share information and best practices.

Various CCO members participate in the Organisation for Economic Co-operation and Development (OECD) Anti-Corruption Leader program. Through this, they engage with other chief compliance officers, government representatives and civil society leaders on emerging and systemic corruption issues. CCO members also have other ethics and compliance memberships and participate in several best practices sharing forums and conferences.

Throughout 2024, we had no material losses related to litigation or non-appealable regulatory decisions involving anticompetitive behavior.

We took targeted steps in the year to advance our ethics and integrity approach. This included initiating work to establish an Ethics Advisory Council, which will convene representatives from various business units in 2025 to inform our ethics approach. The council will play a crucial role in deepening our understanding of AT&T’s culture of ethics, identifying challenges and solutions, and acting as trusted advisers to guide us in continuously raising our standards.

Reinforcing Our Commitment to Ethics

In the past year, we introduced a series of ethics-focused initiatives aimed at fostering a more ethical corporate culture and attracting talent committed to ethical values:

• Integrating an ethical statement into our Equal Employment Opportunity (EEO) Statement: To appeal to prospective employees who prioritize working for ethical companies, an ethical statement was added to the EEO statement. This underscores our commitment to maintaining high ethical standards and creating a fair, inclusive workplace.
• Incorporating ethical culture questions into employee surveys: Recognizing the importance of employee feedback in shaping corporate culture, we created ethical culture questions to be used in the next enterprise-wide employee survey. We also embedded these questions on our Code of Business Conduct site for employees to optionally respond to. These questions are designed to gauge employees’ perceptions of AT&T’s ethical climate, identify areas for improvement and ensure ethical considerations are integral to company operations.
• Expanded our Ethics@Work in-person training: Training now encompasses all levels of management, as detailed in the section below.

These initiatives collectively contribute to a stronger ethical framework, reinforcing our commitment to ethical practices and improving our culture.

Driving Shared Understanding

We have continued to deliver annual trainings, with 99.9% of employees completing the annual Code training in 2024.² To better inform how we deliver compliance-required training courses, we gathered insights from our business units throughout the year. Through a series of knowledge-based Q&As, we explored which business units could benefit from more in-depth information on specific ethics issues and where we could enhance our existing trainings to better meet those needs. Additionally, our training team traveled to various AT&T locations, engaging with employees in person to deliver more effective, fit-for-purpose trainings.

Strengthening Our Risk Approach

We launched our ERM Committee and Framework in 2024, establishing a simplified, coordinated, enterprise-wide approach to identifying and managing key risks to help AT&T:

• Promote company-wide compliance with laws, regulations and internal policies.
• Improve strategic and tactical planning to enhance decision-making.
• Safeguard assets.
• Optimize opportunities for sustainable growth.

We assessed and identified various risks, and we are working with business units and providing guidance to address them, with support from leadership. Each risk is overseen by a functional team that determines assessment and mitigation efforts, reporting back to the ERM Management Team and Executive Team. Risks are routinely reviewed and updated to ensure they are relevant, current and aligned with risk management objectives and priorities.

Third-Party Risk Management (TPRM)

Recognizing the need for key organizations to collaborate under a unified third-party risk management framework, we launched an expanded TPRM program in 2023 and have been on a journey of improvement ever since. In 2024, we made significant progress with the program, which is focused on safeguarding our organization by identifying, evaluating and mitigating risks associated with third-party relationships. The goal is to ensure all third-party engagements align with AT&T’s compliance standards, ethical principles and operational excellence.

By implementing robust risk assessment processes and continuous monitoring, we aim to protect our data, maintain regulatory compliance and uphold our commitment to integrity and security. The result will be a resilient and trustworthy ecosystem in which both AT&T and third parties can thrive, ensuring our collaborations contribute positively to our strategic goals and customer satisfaction.

Streamlining Our Policies

During 2023, we launched an annual policy review and implementation program to ensure more authentic, efficient policy governance. In 2024, we launched an initiative to scale this program enterprise-wide. We enhanced focus on, and effectiveness of, policy management, assessing our existing policies and determining where we can consolidate and streamline them. We also enhanced our policy search tool to make it easier for employees to find the information they need.