Ethics & Integrity

Pursuing transparent communication and robust ethical practices to instill trust.

Click through to learn about our 2025 impact in action. For detailed ethics data, please see our 2025 data table.

Our Approach

At AT&T, we strive to go beyond compliance by cultivating a culture that integrates ethical principles into all that we do. We empower employees 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 150 years, 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 and expect our employees to reflect these principles in the decisions and actions they take on behalf of AT&T.

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

Our Guiding Policies

The AT&T Code of Business Conduct (the “Code”) defines the ethical behaviors all AT&T employees are expected to follow, and we require employees to review it annually. We update the Code regularly to help ensure ongoing relevance and effectiveness. As of 2025, the Code also includes guidelines on the responsible use of artificial intelligence (AI).

Our Board of Directors is required to follow our Code of Ethics. It includes the importance of avoiding conflicts of interest and our expectations for ensuring timely, accurate Securities and Exchange Commission filings and related financial statements.

As outlined in our Anti-Bribery Anti-Corruption (ABAC) Policy, AT&T strictly prohibits giving, offering, authorizing or taking bribes as well as engaging in fraud or corruption under any circumstance, which applies to all employees. We have additional policies that govern specific risk and operational areas.

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

Streamlining our Policies

Our annual policy review and implementation program, which has been scaled enterprise-wide, ensures more effective, efficient policy governance. This program enhances our policy management and enables us to evaluate our existing policies, determining where we can consolidate and streamline them to make them clearer and more effective. Our policy search tool also makes it easier for employees to find the information they need.

Managing Risks

To establish an effective, consistent risk management approach, we maintain an Enterprise Risk Management (ERM) governance program led by the CCO and supported by an executive-level ERM Committee composed of officer-level leaders, including our Chief Operating Officer, who set strategy, address top risks and oversee the program.

The ERM Committee is supported by a management team of senior leaders who identify and oversee risk issues, and by risk response teams assigned to each top risk to develop and implement mitigation plans. Business unit stakeholders participate throughout this structure to ensure comprehensive risk identification and management.

Anti-Corruption Due Diligence

In addition to annual risk assessments, which include anti-bribery and anti-corruption (ABAC) considerations, we continuously monitor for bribery and corruption risks to assess the effectiveness of existing controls.

We maintain rigorous processes for reporting, investigating and disclosing outcomes related to bribery and corruption, including confidential internal reporting mechanisms, thorough investigation protocols and appropriate disclosure of material outcomes through voluntary disclosures and regulatory filings.

Using the Diligent software platform, we conduct various ABAC transactional reviews as part of our risk-based approach to certain payment activities. The AT&T internal audit organization, led by our Senior Vice President of Audit Services, also performs annual audits of ABAC controls.

As a major U.S.-based multinational company, AT&T is subject to strict anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and relevant international standards. AT&T’s ABAC program closely follows the U.S. Department of Justice’s FCPA Resource Guide, which is designed to align with United Nations Convention against Corruption standards, particularly in areas such as bribery of foreign officials and accounting requirements.

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

Third-Party Risk Management

We also have a robust approach to our third-party risk management, collaborating with key organizations under a unified third-party framework. Our goal is to ensure 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.

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

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 for employees, including senior management. 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.

Ethics Resources

To support ongoing learning, we offer Ethics Central, a set of resources and in-person and web-based trainings on topics such as:

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

Reporting Concerns

We are committed to supporting a speak-up culture where employees feel comfortable discussing ethics issues. We maintain several channels for them to share their feedback, opinions and concerns.

Employees with questions or concerns related to the Code or any other ethics or compliance issue, can discuss them with their supervisor or Human Resources (HR) or go through our online Ask Compliance portal. Our Speak Up Portal is a consolidated reporting platform for employees, vendors and others to report ethical concerns and is comprised of a telephone hotline and online reporting mechanisms for confidential (and anonymous, if desired) reports of suspected or actual policy violations. A feature of the platform allows individuals to receive updates on their report throughout the investigation process. Information on these resources is available via our intranet, the Code, compliance-related trainings and our Ethics Central Hub.

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

As outlined in the Code, AT&T does not tolerate retaliation. 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:

Audit Committee of the Board of Directors: Oversees compliance with legal and regulatory requirements as well as administration and enforcement of our codes, policies and Compliance program, as deemed appropriate.
Chief Compliance Officer: Has overall responsibility for the CCO 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. Also reports annually to the full Board on Enterprise Risk Management.
Ethics Advisory Council: Meets quarterly to discuss ethics topics and ways to enhance the company’s ethical culture. Established in 2025, this council is composed of leaders from major business units, including business, consumer, sales, product and marketing. Through the council, the CCO is able to elevate the ethics message across business units and address function-specific opportunities.
CCO and Integrity & Compliance Teams: Provide guidance and help to ensure business units comply with internal compliance requirements and applicable laws and regulations, with particular attention to areas such as ABAC, antitrust and competition, third-party oversight, data protection, sales practices, records and information management and privacy.
ERM Committee: Facilitates an enterprise-wide approach to identifying and managing key risks to help AT&T achieve its strategic objectives, improve strategic and tactical planning, safeguard assets and optimize opportunities for sustainable growth. More information on the ERM Committee is outlined in the “Managing Risks” section above.
Ethics Champions: Dedicated business unit representatives that help to drive ethics and integrity across the company through education and advocacy.

Stakeholder Engagement

We collaborate and share best practices with external stakeholders, including industry peers. We participate in the Organisation for Economic Co-operation and Development program. Through this, representatives of our CCO engage with other chief compliance officers, government representatives and civil society leaders on emerging and systemic corruption issues.

Impact in Action

Our 2025 Impact in Action

Throughout 2025, 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 formally launching an Ethics Advisory Council, which plays a vital role in enhancing our understanding of AT&T’s ethical culture and addressing any challenges we encounter. This network of leaders acts as trusted advisors, and their perspectives help us integrate ethics into all aspects of our operations. The Ethics Advisory Council meets quarterly to provide input on elevating ethics messaging, addressing business-unit-specific challenges and increasing enterprise-wide engagement.

In 2025, we also streamlined all policies connected to the Code of Business Conduct to make them clearer and easier to understand.

Reinforcing Our Commitment to Ethics

In the past year, we introduced a series of ethics-focused initiatives to foster a more ethical corporate culture by raising awareness of ethics and integrity across the organization:

Ethics in Every Choice: We introduced a new internal tagline to our Compliance Program, Ethics in Every Choice, to underscore the intentionality we expect in every decision our employees make.
Speak Up Portal: We launched the Speak Up Portal, a consolidated reporting platform that unifies multiple reporting channels into one enterprise-wide system for employees, vendors and others to report ethical concerns.
Ethical Awareness Campaign: We launched a monthly ethical awareness campaign for employees, highlighting a specific ethics topic each month (e.g., ethical technology use, civility, intentional listening and the new Speak Up line), with targeted communications sent to HR business partners, chiefs of staff and senior leaders to incorporate into their BU communications to reinforce ongoing ethics awareness and drive engagement.
Ethics Central: We launched Ethics Central, a unified platform that consolidates ethics training and resources across the company. Through the platform, employees can also provide business-unit-specific feedback and request targeted ethics trainings, surveys and focus groups for their business units.

Driving Shared Understanding

In response to employee feedback, we introduced changes to streamline, personalize and prioritize ethics and compliance learning and engagement:

Code of Business Conduct Updates: We updated the Code for greater clarity and accessibility, adding links to new resources, an enhanced section of frequently asked questions—with a new focus on AI—and links to relevant policies. We also updated the design for greater readability. To collect employee insights and measure awareness and effectiveness of our initiatives, we also added three optional survey questions on leadership’s communications about ethics and integrity, the employee’s awareness of how to report ethical concerns and the company’s commitment to ethical practices.
Risk-Based Training Prioritization: We aligned trainings with AT&T's highest-impact ethical and compliance risk priorities. We also introduced third-party risk training for vendor managers aligned with these risks. Additionally, we designed a course on effective third-party vendor relationship management. Whether an employee is directly or indirectly involved in working with third parties, managing vendor relationships is a core business skill that is essential for ensuring we serve our customers without introducing legal or regulatory risks.
Enhanced Live Training: We introduced live ethics training sessions for employees with five or more years of tenure, enabling faster, more efficient delivery compared with online alternatives, which are intended for a wider range of employees.
Performance Management: We added ethics messaging to supervisor and employee guides for mid year and annual performance reviews, prompting managers and employees to discuss how work was performed in an ethical manner. We also added information about our Equal Employment Opportunity (EEO) policy to new-hire materials and integrated ethical compliance statements into our EEO policy.
Test-Forward Approach: We implemented a test-forward approach to consolidate training content within individual training courses and allow eligible employees (with five or more years of tenure) to test out of sections by demonstrating knowledge and awareness. This also helps us identify topics that require greater awareness.

Third-Party Risk Management

In 2025, we made significant progress with our Third-Party Risk Management Program (TPRM) through the following actions:

Established a third-party risk management board to drive continuous improvement
Developed a third-party risk management framework for more consistent processes
Increased the percentage of organizations that use centralized global supply chain for contracting
Created a more comprehensive, enterprise-wide TPRM inventory dashboard
Increased data risk elements that are collected across thousands of contracts and suppliers
Continuously improved systems to capture key third-party data vendor management training
Established the first ever TPRM Awareness Week
Shared “Tone at the Top” templates for leaders to distribute to their teams.