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 in the Employees chapter in particular.

We expect our business partners to respect 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 wages, regulated working hours, regular employment in terms of compliance with national and international laws and industry standards for employment relationships, as well as occupational health and safety. The DB Code of Conduct for Business Partners is part of the contractual obligations of our business partners. We reserve the right to audit them. We also attach great importance to cooperative relationships. In the event of violations of the Code, we take appropriate measures, which may range from the opportunity to remedy and improve the situation to the termination of a contract – as a last resort – in the event of serious violations. The Group’s Principles on Ethics (internal DB Code of Conduct) sets out corresponding requirements for our own employees and executives. These are legally binding under labor law. We oppose modern slavery in all its forms, whether 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.

In the event of indications of human rights violations, employees, customers, suppliers and other potentially affected parties have various channels available for reporting, including anonymously. One channel is our electronic whistle-blower system. Reports can also be made by post. In 2024, a total of 161 reports were received via the whistle-blower system, 94 thereof related to human rights (thereof 41 with potential discrimination). We became aware of one confirmed case of discrimination via our whistleblower system in 2024 (previous year: three cases (figure adjusted)). In addition, DB employees have access to trusted legal practitioners or the ombudsman’s office, for example.

Implementation of the German 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 (Lieferkettensorgfaltspflichtengesetz; LkSG) to adequately enforce human rights and environmental due diligence obligations in our supply chains and to establish responsible management of our supply chains. As a topic area of the LkSG, this also includes those due diligence obligations that relate to occupational safety if this results in the risk of accidents at work or work-related health hazards. Following the lowering of the statutory threshold for the scope of application of the LkSG as of January 1, 2024, a total of 25 DB companies are obligated to comply with the LkSG due to their number of employees. This includes the parent company, DB AG. We have defined clear responsibilities for implementing the LkSG. The Management Board has appointed a Group LkSG officer to monitor the implementation of the statutory due diligence obligations at DB AG. Within DB AG, the operational implementation of human rights and environmental due diligence obligations is ensured and managed by a Group LkSG coordinator. To implement the requirements of the LkSG, we have set up an LkSG risk management system so that we can take specific measures to fulfill our due diligence obligations. It aims to identify, minimize and eliminate human rights and environmental risks and violations. Dealing with human rights and environmental risks we see as a process that we want to embed ever more deeply in our operational structures and continually improve.

The central element of our LkSG risk management is the targeted and systematic implementation of a risk analysis. Our annual LkSG risk analysis has a two-stage structure and begins with an abstract risk analysis of all LkSG risk areas, in which we determine and assess the potential and actual risks of our business activities for people and the environment. We use the risk data of a specialist external provider to continually identify country-specific and sector-specific risks in our own business and at direct suppliers. The assessment of the country and sector risks is based on a large number of indicators as well as publicly available reports and media sources. The results of the abstract risk analysis are then validated, allowing us to make an initial assessment of the existing risk profiles in our own area of business and at our direct suppliers. If our abstract risk analysis reveals increased risks in particular, we then subject the affected DB companies and our direct suppliers to a more detailed investigation. This so-called specific risk analysis aims to identify the actual risk dispositions for violations of human and environmental rights. Once the specific risk analysis is complete, the risk findings on the probability of occurrence of a violation are prioritized based on the appropriateness criteria of the severity of the risks, the existing potential influenceability and the contribution to causation. We initiate appropriate risk-based preventive measures on this basis.

We conduct risk analyses on an ad hoc basis, including in the event of specific indications, such as particular incidents, tip-offs or reports that indicate potential risks or violations of human rights or environmental obligations in the business areas or supply chains of DB Group. More than 53,000 suppliers were included in the 2024 abstract risk analysis, with more than 350 suppliers being subsequently subjected to a specific risk analysis. Twenty-nine suppliers were then selected for talks in which they were made aware of the relevant LkSG risk areas. In addition, discussions were held in which additional prevention measures were agreed. We report on the prioritized human rights and environmental risks at DB Group as identified on the basis of our 2024 LkSG risk analysis in our policy statement on protecting and respecting 
human rights.

If we identify relevant LkSG risks, we immediately take appropriate preventive measures. In the event that a violation of a human rights or environmental obligation is identified, appropriate remedial action is taken without delay. The revised Group Principles on Ethics (DB Code of Conduct) and the DB Code of Conduct for Business Partners have been in force since the beginning of 2024 after we adapted them in line with the requirements of the LkSG. In addition, awareness-raising measures were carried out in procurement and various contractual clauses for business partners were refined. An overarching catalog of measures lists potential preventive measures, such as the creation of directives and the implementation of social audits as well as risk-based training and raising awareness. We are continually developing our catalog of potential preventive and remedial measures. In 2024, no business relationships were terminated due to a serious violation of rights or environmental obligations. When developing and implementing due diligence measures, we strive to appropriately involve those potentially affected by our business activities and their diverse interests in order to ensure effectiveness. The effectiveness analysis follows a criteria-oriented approach in which the status quo is compared with established standards. This is based on ISO 31000 for risk management and the UN Guiding Principles on Business and Human Rights.

In the policy statement on protecting and respecting human rights, we also express our commitment and dedication to respecting human rights and environmental obligations, describe our procedures for implementing the due diligence obligations under the LkSG and set out our expectations for ourselves and our suppliers and business partners to ensure compliance with human rights and environmental obligations. It was first published on our website in 2023 and updated in 2024. The prioritization of human rights and environmental risks, in particular, was adjusted based on the results of the 2024 LkSG risk analysis.

Another core component of fulfilling our due diligence obligations is the provision of an effective complaints procedure that meets the requirements of the LkSG. This can be used to submit reports on human rights and environmental risks and violations of obligations, regardless of whether or not these occur in the supply chain or in our own area of business. We review the reports we receive to determine whether or not the reported facts indicate a human rights or environmental risk or a corresponding violation of obligations. 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 violations. All reports are treated confidentially and, if so requested, anonymously. They are processed by selected and specially trained employees who are impartial, independent and bound to secrecy. Use of the complaints procedure is aimed at enabling us to identify previously undetected LkSG risks or violations of obligations. Thus, in addition to the LkSG risk analysis, the complaints procedure plays a key role in enabling us to continually improve and further develop our LkSG risk management.

We review the effectiveness of our complaints procedure once a year and on an ad hoc basis. To this end, a systematic analysis of the complaints procedure is conducted in which samples of different, anonymized, cases are reviewed in detail and evaluated with regard to their effectiveness. Our assessment is based on the effectiveness criteria set out in Guiding Principle 31 of the United Nations Guiding Principles on Business and Human Rights.

DB AG reports from a Group-wide perspective to the Federal Office of Economics and Export Control (Bundesamt für Wirtschaft und Ausfuhrkontrolle; BAFA) on the fulfillment of the human rights and environmental due diligence obligations in accordance with the LkSG. The 2023 report was submitted in 2024 and is published on our website, where it is accessible for a period of at least seven years. The other 24 LkSG-obligated Group companies are generally responsible for handling LkSG matters in their own right. Among other things, they submit a company-specific report on their activities to BAFA in accordance with the LkSG and publish their own policy statement, which presents the individual risk situation of the respective Group company. To implement the LkSG uniformly as a matter of principle, Group management performs a governance function in dealings with the obligated Group companies.