Actions

DB Group is taking actions to further strengthen the high level of protection for whistleblowers and adapt it to changing conditions. Whistleblower protection was further developed in 2025 through the following measures in particular:

• Expansion of whistleblower communication: DB Group’s website has been enhanced and provides whistleblowers with comprehensive information on the topic of “whistleblowing at DB,” including information on available reporting channels, the process after submitting a report, the confidentiality of the identity of whistleblowers and whistleblower management, including reporting offices. In addition, a central overview page has been set up on the DB intranet with a consolidated presentation of all reporting offices and relevant contact options for employees.
• Implementation of reporting office concept: With a view to the German and European implementation laws for the EU directive for improved whistleblower protection, further adjustments were made to processes and communication in the existing reporting system. This was also done in connection with the establishment of additional reporting offices.
• Update of the electronic whistleblower system: In 2025, we carried out a comprehensive update of our electronic whistleblower system and thus adapted the system landscape even more effectively to the legal requirements, especially the HinSchG, as well as to internal Group processes and general organizational conditions. Among other things, the reported subjects and the authorization concept were modified to reflect the current structure of the Group’s internal reporting offices. The entry page was also updated.
• Data protection audit: In 2025, a comprehensive data protection audit was carried out for our electronic whistleblower system to identify potential weaknesses in the processing of personal data. The audit was completed without any objections.

Action plans 2026

The aforementioned actions will continue as described. In 2026, one focus will be on measures relating to the tender for the future provision of the whistleblower system based on the results of market research.