Description of the process to identify and assess material impacts, risks and opportunities, and material information to be reported (IRO-1)
To determine our material topics in our own business activities and along our value chain in 2025, we used the results of the double materiality assessment from 2024 as a basis and made selective adjustments and improvements. In 2025, no overall revaluation of the IROs (Impacts, Risks, Opportunities) was carried out, but we took a more systematic look at our value chain, took into account initial findings from the application of the ESRS and made evaluation adjustments in individual cases. In addition, the IROs of the discontinued operation DB Schenker, which was sold in 2025, were eliminated from the results.
Procedure for double materiality assessment
When carrying out a double materiality assessment for the first time in 2024 with reference to the ESRS requirements, we first drew up a list of potentially material topics consisting of the sustainability matters contained in ESRS 1 (Application Requirement [AR] 16) of ESRS Set 1 and company-specific topics. In the second step, based on the 2023 Integrated Report and other thematic sources (e.g. DB Code of Conduct for Business Partners or Employee Survey 2022), we defined and assigned actual and potential positive and negative impacts that DB Group has on sustainability topics, as well as the resulting opportunities and risks. Before these IROs entered the assessment phase, they were validated by internal experts for accuracy, relevance and completeness. In the third step, the internal subject matter experts performed materiality assessments for the IROs, taking into account stakeholder interests.
The results of the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz; LkSG ) risk analysis were used to assess the majority of IROs in the upstream value chain. As a result, this step of the materiality analysis mainly considered Tier 1. The detailed valuation methodology was based on the requirements of the ESRS and DB Group’s existing opportunity and risk management system. We have assessed the severity and likelihood of occurrence for impacts and the financial effect and likelihood of occurrence for financial risks and opportunities.
When evaluating the IROs, estimates had to be made with regard to the time horizon (year of entry and short-, medium- and long-term). The significance of the impact was determined on the basis of the components likelihood of occurrence, extent, scope and irreversibility (only in the case of negative impacts). As a rule, the current impact of DB Group was assessed, that is taking into account measures already taken. The financial effect was estimated when assessing the opportunities and risks. A score per IRO was calculated from these assessments, together with the values stored for the different likelihoods of occurrence and taking into account whether an IRO has a connection to human rights.
If the result is equal to or greater than the threshold value, we consider the impacts equally. The impacts are not prioritized based on their assessment results.
The entire value chain was considered when identifying potential and actual IROs. To this end, we have outlined the value chains of expected material impacts of DB Group in 2025, including the flow of goods, players and dependencies, and assigned industry risks to the corresponding sectors. Internal experts then validated the conclusions.
The perspectives of our key stakeholders and other affected parties (e.g. in the context of noise protection) were included indirectly via internal experts as part of the materiality assessment. The experts are in contact with the relevant stakeholder groups as part of various dialog formats and have taken their interests into account on their behalf.