Engagement with own workforce and workers’ representatives, channels for expressing concerns or needs and approaches to remedy

Processes for engaging with own workforce and workers’ representatives about impacts (S1-2)

DB Group systematically involves its employees in decision-making processes. Key forms include the continuous involvement of interest groups (works councils, general works councils, Group works council, European works council), collective bargaining with the Railway and Transport Workers Union (Eisenbahn- und Verkehrsgewerkschaft; EVG) and the German Train Drivers’ Union (Gewerkschaft Deutscher Lokomotivführer; GDL), as well as participation in company working groups and commissions. In addition, we use Group-wide employee surveys and the culture barometer to regularly assess the perception of working conditions and the implementation of the strategy. There are also participative formats such as employee workshops, idea platforms and dialog with employee networks such as Women at Deutsche Bahn, railbow, DB Cultures and BIPoC (Black, Indigenous, and People of Color) on Track.

Involvement is continuous and depends on the respective subject areas. Co-determination obligations under the Works Constitution Act (Betriebsverfassungsgesetz; BetrVG) and the European Works Council Act (EWC Act) are fulfilled on an ongoing basis. The employee survey and the culture barometer are carried out on an alternating basis every two years, meaning that employees are involved and surveyed annually. Strategic processes such as the building blocks are designed to last several years and are developed further in regular cycles together with employees.

Overall responsibility for employee involvement lies with the Management Board member for Human Resources and Legal Affairs.

DB Group has concluded extensive agreements with employee representatives at national and European level. These include provisions on employment conditions, working time regulations, remuneration, training and diversity. This is based, among other things, on the policy statement on protecting and respecting human rights and on international frameworks (UNGP, UNGC, OECD Guidelines).

The effectiveness of the measures is assessed through regular evaluations and the use of clearing houses and joint commissions.

We pay particular attention to the views of employees who belong to marginalized groups or who may be particularly vulnerable to disadvantage. Group-wide employee networks such as Women at Deutsche Bahn, railbow (LGBTIQ+), DB Cultures and BIPoC on Track exist to integrate these perspectives in a structured manner. They act as a sounding board, are in regular contact with Diversity Management and are supported by mentors from the Management Board. The networks gain visibility during the annual Diversity Week, among other events. In addition, the central Diversity Management department coordinates a Diversity Working group in which decentralized diversity managers from the business units exchange ideas several times a year.

Processes to remediate negative impacts and channels for own workforce to raise concerns (S1-3)

DB Group has procedures in place to take appropriate remedial action when it has caused or contributed to a material negative impact on individuals in its own workforce. In such cases, immediate measures are taken to end or mitigate the violation. The procedure includes the risk-based development of action plans, the establishment and ongoing development of a catalog of measures for preventive and corrective action, risk-based training and audits. Effectiveness tests are also carried out to assess the extent to which the actions taken are suitable for eliminating negative impacts in the long term. The implementation and the effectiveness of these actions are monitored by a Group LkSG Officer.

In addition to the statutory options for employee representation, employees have various communication channels at their disposal for reporting concerns or possible violations. This includes a Group-wide electronic whistleblower system, submitting reports by post and consulting trusted lawyers. There are also internal contact points for conflict resolution and personal support, such as the ombudsman office, threat management and the MUT hotline. The channels are open to all employee groups and also allow for anonymous reporting. The electronic whistleblower system is the formal complaints mechanism. It has been expanded since January 1, 2023 in accordance with the requirements of the LkSG and is designed in consultation with the Group works council. Incoming reports are checked and forwarded to the relevant departments if there is an initial suspicion. If risks or violations of obligations are confirmed, suitable measures are taken immediately to minimize or terminate them. Processing is carried out exclusively by trained, independent employees who are obliged to maintain confidentiality. Personal data is treated confidentially. The complaints procedure is implemented throughout the Group, regulated in its own rules of procedure and anchored within the organization through internal guidelines.

The availability of the channels is ensured through broad communication. Information on the complaints procedure is communicated, for example, via the intranet, on notice boards, at internal events (e.g. the Diversity Week) and as part of training courses. Internal contact points also make targeted reference to the complaints procedure in the case of relevant concerns. Employees and external persons can submit information anonymously either electronically or by post. Notifications can also be submitted via works councils or trade unions. The electronic information system is available in 12 languages. It is designed to be accessible and easy to use and can be accessed via all Internet-enabled devices. Publicly accessible rules of procedure, which are also available in plain language, ensure that information on accessibility, responsibility and the process is presented clearly and comprehensibly.

All incoming reports are systematically recorded, checked and documented. The effectiveness of the complaints procedure is reviewed once a year and on an ad hoc basis. The analysis of the effectiveness of the complaints procedure applied is systematic and based on random samples of anonymized cases and a methodology in accordance with the effectiveness criteria of the UN Guiding Principles (Guiding Principle 31). Effectiveness monitoring is overseen by the Group LkSG Officer.

Incoming complaints show that the procedure is known of and actively used by employees. The rules of procedure expressly protect whistleblowers against discrimination or punishment. This protection complies with the requirements of the Whistleblower Protection Act. If desired, a detailed discussion of the facts can be conducted with the person submitting the report.