Human rights
Management approach and targets
Protecting and promoting human rights is of the utmost importance to us. We report on how we safeguard human rights with regard to working conditions, anti-discrimination measures, and occupational health and safety within DB Group, particularly in the chapter Employees.
We expect our business partners to uphold human rights. Our requirements in this regard are set out in the DB Code of Conduct for Business Partners. This Code refers to the core labor standards of the International Labor Organization (ILO), such as protection against child and forced labor and against discrimination in employment and occupation. It contains regulations on adequate pay, regulated working hours, and the preference for regular employment. The DB Code of Conduct for Business Partners is part of the contractual obligations of our business partners. We reserve the right to audit our business partners. We attach great importance to cooperative relationships. In the event that the Code is breached, we take appropriate measures, which may range from opportunities for remedial action and improvement to termination of the contract in the event of serious breaches. DB Group’s Principles on Ethics (internal DB Code of Conduct) set appropriate requirements for our own employees and executives. These are legally binding under labor law. We oppose modern slavery in all its forms, be it forced or compulsory labor, servitude, human trafficking or child labor, and we report on this in accordance with the provisions of the UK Modern Slavery Act. DB Schenkerʼs global activities are additionally subject to specifically developed Social Minimum Standards. These standards detail the overriding DB Group Code of Conduct and provide, particularly in the international context, minimum standards for situations in which national and international legislation does not stipulate any appropriate social measures. Compliance with the Social Minimum Standards is regularly audited by intra-Group auditors at selected locations.
If human rights violations are suspected, employees, customers, suppliers and any other parties that may be of concern are provided with various channels to report such violations, including the option to report anonymously. One channel is our electronic whistle-blower system. In addition, reports can be made by post and trusted legal practitioners. DB employees can also contact the ombudsmanʼs office. In 2023, 104 reports were submitted via the whistle-blower system in relation to human rights (mainly cases relating to occupational health and safety and potential discrimination).
Implementation of the Act on Corporate Due Diligence Obligations in Supply Chains
Since January 1, 2023, we have been obliged under the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG) to adequately enforce human rights and environmental due diligence obligations in our supply chains and to establish responsible management of our supply chains. In addition to DB AG, a further 15 Group companies were subject to LkSG in 2023 due to their number of employees. These Group companies are generally responsible for their own LkSG matters. During the set-up phase of LkSG risk management, compliance with due diligence obligations within DB Group is also coordinated through a Group-wide project. A Group LkSG Officer was appointed by the Management Board to monitor compliance with the statutory due diligence obligations at DB AG. From 2024 onwards, DB AG will report annually to the Federal Office of Economics and Export Control (BAFA) on the fulfillment of human rights and environmental due diligence obligations in the previous financial year from a Group-wide perspective. Group companies subject to LkSG submit company-specific reports on their LkSG activities to BAFA.
In 2023, we set up an LkSG risk management system for human rights and environmental due diligence in accordance with the requirements of LkSG. We are gradually integrating this into all relevant business processes. Our LkSG risk management serves to identify, minimize and eliminate human rights and environmental risks and breaches. At the core of LkSG risk management is a systematic and targeted LkSG risk analysis in which we identify and assess the potential and actual risks that our business activities pose to people and the environment. Our annual LkSG risk analysis is a two-stage process, starting with an abstract risk analysis to determine the gross risk. In the event of increased gross risks, a more detailed investigation of subsidiaries and suppliers is carried out in a second step in the form of a detailed risk analysis. This aims to identify the actual net risks of human and environmental rights breaches. If there is specific evidence, such as particular incidents, information or reports that indicate potential risks or breaches of human rights or environmental obligations in the business areas or supply chains of DB Group, we also carry out ad hoc risk analyses.
In our policy statement on protecting and respecting human rights, we report on the prioritized human rights and environmental risks in DB Group identified on the basis of our LkSG risk analysis conducted in 2023. In this statement, we also express our commitment and dedication to respecting human rights and environmental obligations, describe our procedures for implementing the due diligence obligations pursuant to LkSG and set out the expectations placed on us, our suppliers and business partners to ensure compliance with human rights and environmental obligations.
If we identify any relevant LkSG risks, we take appropriate risk-based preventive measures. We take a wide range of measures, including both the further development of existing measures and the implementation of new ones. In 2023, we adapted our Group Principles on Ethics (DB Code of Conduct) and the DB Code of Conduct for Business Partners to the requirements of LkSG. In addition, awareness-raising measures were carried out in procurement, various contractual clauses were modified and an overarching catalog of measures was developed. This lists potential preventive measures, such as the creation of directives, the implementation of management and monitoring systems and the performance of audits and training courses. The catalog serves as a starting point for risk-based development of specific action plans for individual cases, known as Corrective Action Plans. These plans set out specific steps and measures to remedy identified problems, for example by revising existing directives or strengthening control mechanisms. Moreover, training courses on topics relevant to LkSG were developed and their implementation started. If we identify a breach of a human rights or environmental obligation, we take appropriate remedial action without delay. We are also continuously refining our catalog of possible preventive and corrective measures to this end.
Since January 1, 2023, our existing whistle-blower system, which we have agreed with the Group Works Council with regard to the interests of employees, has been expanded in accordance with the requirements of LkSG. We investigate all reports received in the context of LkSG to determine whether the reported issues indicate a human rights or environmental risk or corresponding breaches of duty. If this is the case, the report is forwarded to the responsible body. If the initial suspicion is substantiated, the necessary measures are taken to minimize or eliminate risks or breaches. All reports are treated confidentially and, if so requested, anonymously. Using the complaints procedure enables us to identify previously unidentified LkSG risks or breaches of duty. Thus, in addition to the LkSG risk analysis, the complaints procedure plays a key role in enabling us to continuously improve and develop our LkSG risk management. Similarly, we analyze the results of our LkSG risk analysis in relation to the complaints procedure in order to gain additional insights into potential stakeholder groups and continuously optimize the design of our complaints procedure. We review the effectiveness of our complaints procedure once a year and on an ad hoc basis. Our assessment is based on the effectiveness criteria set out in Guiding Principle of the United Nations Guiding Principles on Business and Human Rights.
