CDR reports analyzed: The first CDR reports have been published 

This summer, on July 05, 2022, the members of the CDR Initiative published their Corporate Digital Responsibility (CDR) reports for the first time. The member companies – BARMER, Deutsche Telekom, ING, Otto Group, Telefónica, Weleda and Zalando – come from different industries and want to report annually on their CDR measures from now on.  

To date, there are no applicable standards or reporting requirements for CDR in Germany. It is therefore up to the companies directly to evaluate their digital activities. For example, when processes become so automated that employees have less and less interaction with real people or applications are rejected because of statistical inaccuracies.  

The CDR initiative of the German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) therefore aims to be a learning and exchange platform for committed companies to promote corporate responsibility in the digital transformation on a voluntary basis.  

In a joint CDR code, the member companies of the CDR initiative have committed themselves to becoming active and applying concrete CDR measures. The published reports therefore serve to present these very measures.  

Analysis of the reports 

The individual measures are presented based on five fields of action – (1) handling data, (2) education, (3) climate and resource protection, (4) inclusion and (5) employee involvement.  

The reports are structured in the same way: For each field of action, there are goals formulated by the initiative, which are then to be met by the measures described. The status of the measure is also indicated – either implemented or in planning. 

Each report starts with a short introduction followed by an “initial example”. The bank ING, for example, reports on its “Smart Movers Program”, an IT retraining program for employees, or online retailer Zalando shows how machine learning can be used to reduce the number of returns. Finally, the companies provide information on how CDR is anchored in the company. 

Insight into the CDR reports 

Below, we highlight how companies describe their CDR approach and provide insights about their CDR measures: 


According to BARMER, CDR is a topic for the top management. At BARMER, the issue is driven by the Vice Chairman of the Board of Management, the Chief Digital Officer and the digital coordinator of the in-house innovation department (BARMER.i). 

Exemplary CDR measures 

  • Values Check – BARMER adopted its own digital ethical values. In the future, these will be used as baseline in the development of digital projects. In a “values check” the project goals are compared with the digital ethical values. – Field of action: Handling data; Goal: Ensure responsible handling of data in the company. 
  • DigiCoaches – In order to involve employees in thier diverse topics of digital transformation, BARMER empowers “DigiCoaches”. In their teams, the DigiCoaches serve as contact persons and motivate for new developments in the digital ecosystem of BARMER. – Field of action: Education; Goal: Educate about ethical issues of digitization. 


CDR @ Deutsche Telekom 

At Deutsche Telekom, the two Board of Management departments Group Corporate Responsibility and Law & Integrity are responsible for the further development of their CDR. They are supported in this by an internal CDR community that extends beyond certain business units. 

Exemplary CDR measures 

  • Awareness formats – Deutsche Telekom runs several campaigns to draw attention to CDR issues. For example, they publish the youth magazine “Reif”, a magazine for news from the world of technology and IT, or carried out the initiative “#DABEI – Gegen Hass im Netz”. – Field of action: Education; Goal: To educate people about opportunities and risks and enable them to act independently. 
  • Digital Ethics Assessment – Deutsche Telekom's central quality security program, in short PSA (Privacy and Security Assessment), has been expanded to include a Digital Ethics Assessment. This is intended to ensure that their guidelines for artificial intelligence are taken into account in the development of products and services. – Field of action: Handling data; Goal: Actively counteract distortions of data analyses ("bias"). 

CDR Report Deutsche Telekom 


Corporate Digital Responsibility at ING is part of corporate responsibility and is thematically assigned to the Center of Expertise (CoE) Strategy and Business Development, which is linked to the CEO. Besides this, operational units with a connection to the development of digital processes assume responsibility in the consideration of CDR aspects. In addition, ING's Consumer Protection Officer performs a coordinating function vis-à-vis internal and external stakeholders regarding CDR. 

Exemplary CDR measures 

  • Local Data Ethics Councils – ING has established Local Data Ethics Councils that employees can contact if they have ethical questions related to the use of data. The purpose of the councils is to ensure a structured discussion of ethical issues, promote ethical behavior, and ensure that ING consistently addresses ethical issues around data use. – Field of action: Education; Goal: Educate about ethical issues of digitization. 
  • Digital ethics e-learning – ING trains its employees with the help of online learnings. E-learning units such as “Data Ethics” or “Dealing with Dilemmas” sensitize employees to ethical issues (e.g., the emergence of bias) in the use of data. – Field of action: Handling data; Goal: Actively counteract distortions of data analyses ("bias"). 

CDR Report ING 

CDR @ Otto Group 

Within Otto Group, each entity shapes its objectives in terms of CDR – to which is referred to internally as “Digital Responsibility” – individually adapted to its respective business models. The objectives of the Group entities are discussed and approved by a central body, the Corporate Responsibility Board, with a focus on the level of ambition and effectiveness. In addition, there is a contact person in each Group entity who networks with the relevant specialist departments and drives forward the setting and achievement of targets. There is also a central contact person in the Otto Group Holding whose main task is the Group-wide coordination and further development of the topic. 

Exemplary CDR measures 

  • Ethical AI Community – In 2021, the Otto Group founded the Group-wide “Ethical AI Community”. Within this community, employees from the area of data and AI can network and exchange ideas. Among other things, the community deals with the risks and measures to avoid bias. In addition, AI governance approaches are developed within the community. – Field of action: Education; Goal: Educate about ethical issues of digitization. 
  • Systems for anonymizing data The – Otto Group entities use advanced systems for the purpose of pseudonymization as well as anonymization of data (1) Encryption of personal data by “independent third parties” so-called “trusted third parties”, (2) Outsourcing of data processing to a data trustee, (3) Conversion of data into “synthetic data” prior to performing analyses. – Field of action: Handling data; Goal: Promote responsible technology design when handling data. 

CDR Report Otto Group 

CDR @ Telefónica 

The position of Chief Officer Legal & Corporate Affairs is central to the development of the topic of Corporate Digital Responsibility in the Management Board division of Telefónica. 

Exemplary CDR measures 

  • igital training initiative „Digital Basics“ – With the company-wide digital training initiative “Digital Basics”, Telefónica provides its employees with important basic skills in digitalization, which also includes dealing with ethical risks. – Field of action: Handling data; Goal: Actively counteract distortions of data analyses ("bias"). 
  • Ethische Prinzipien zur Nutzung künstlicher Intelligenz – Telefónica orientiert sich bei der Verwendung von KI an ethischen Prinzipien. Zentral dabei ist für sie, dass der Mensch immer oberste ethische Instanz bleibt und der KI Grenzen gesetzt werden. – Field of action: Handling data; Goal: Actively counteract distortions of data analyses ("bias"). 

CDR Report Telefónica 

CDR @ Weleda 

Corporate Digital Responsibility at Weleda is closely linked to organizational development and digital transformation. The central advisory body for CDR at Weleda is the CDR Council, which is appointed and monitored by the Executive Board. The CDR Council makes binding recommendations for action and deals with all digital-ethical issues. 

Exemplary CDR measures 

  • CDR Check – Projects at Weleda are subject to a portfolio process. A “CDR check” is used within this process. This consists of two steps. In the first step, seven questions are asked of the project. If one of the questions is answered with yes, the project is considered CDR relevant. CDR-relevant projects are discussed with those responsible for the project. It is checked whether digital-ethical dilemmas exist and whether special measures need to be coordinated. – Field of action: Education; Goal: Educate about ethical issues of digitization. 
  • Projects for digital participation – Weleda specifically promotes basic digital skills for participation. For example, with the #TecSnacks format. In short video sequences, employees are taught the basics of how to participate in the digital world of work. – Field of action: Inclusion; Goal: Promote solutions to support participation. 

CDR Report Weleda 

CDR @ Zalando 

At Zalando, several teams take care of the further development of their CDR. While the Sustainability Director is in charge of sustainability measures, the Governance Head of Privacy is responsible for measures dealing with the responsible handling of data. 

Exemplary CDR measures 

  • Digital product pass – Zalando launched the first "redeZIGN for circularity" collection from its in-house label ZIGN in 2020. Each collection item contains a digital product passport in the form of a QR code in the label. This leads to a product page where people can find out more about the origin of the item and obtain further information on its reuse after purchase - for example, the materials used or details of the production site. – Field of action: Climate and resource protection; Goal: Strengthening digital solutions to protect our environment. 
  • Introducing the hybrid work model – Zalando is currently in a learning year regarding the design of their hybrid work model. Currently, teams are free to decide how to design on-site presence for each member. Additionally, employee surveys are being conducted. These are evaluated jointly with the employee representative body. – Field of action: Employee involvement; Goal: Involve employees in shaping and decision-making in the digital transformation. 

CDR Report Zalando 

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