Policies (S1-1)

To manage material impacts and risks in connection with its own workforce, DB Group uses an integrated set of Group-wide policies that also open up opportunities for fair, sustainable and competitive employment conditions.

As part of the implementation of its policies, DB Group undertakes to comply with recognized international standards (documented in the policy statement on protecting and respecting human rights):

• Universal Declaration of Human Rights (UDHR) and the International Covenants on Civil and Political Rights (ICCPR) and on Economic, Social and Cultural Rights (ICESCR)
• UN Guiding Principles on Business and Human Rights (UNGP)
• Core labor standards of the International Labour Organization (ILO)
• OECD Guidelines for Multinational Enterprises
• Ten Principles of the UN Global Compact (UNGC)

The Group guideline on organization regulates fundamental responsibilities for the implementation of policies throughout DB Group. The aim is to clearly assign responsibilities. The intra-Group auditors and the Compliance function perform auditing and monitoring tasks to ensure compliance with the policies.

The following Group principles and guidelines generally apply to DB Group as a whole. Accordingly, almost all DB Group employees are included.

The mentioned Group employer/works council agreements (Konzernbetriebsvereinbarung; KBV) are agreements between the employer and the Group works council and generally relate to employees of all Group companies in Germany, excluding executives. The Management Board is primarily responsible for implementing the policies. The Group works council was involved in drawing up the policies. Policies are accessible to all employees online via the Group regulations database and the “myDB” HR portal.

• Group principles on ethics: The Group principles on ethics (DB Code of Conduct) define standards for acting with integrity and are an integral part of all employment contracts. The aim is to ensure ethically sound business activities, to establish equal treatment and anti-discrimination, particularly with regard to remuneration, to ensure adequate remuneration in accordance with statutory and collective bargaining requirements and to promote flexibility, individualization and participation.
• Policy statement: With our policy statement, we commit to protecting and respecting human rights and to sustainable and responsible corporate governance. The statement sets out how the human rights due diligence obligations are implemented in accordance with the requirements of the Act on Corporate Due Diligence Obligations in Supply Chains (Lieferkettensorgfaltspflichtengesetz; LkSG). It contains the commitment to internationally recognized human rights standards (e.g. UN Guiding Principles on Business and Human Rights, ILO core labor standards) and explains the procedures for implementing the statutory due diligence obligations, for example through risk analyses. In addition, the policy statement identifies the human rights issues that have priority and sets out the expectations that DB Group has of its own employees.
• Group guideline on HR management: This guideline defines Group-wide principles and standards for employee issues. The aim is to ensure uniform employment conditions, including the organization of working hours and remuneration, taking into account collective bargaining and co-determination regulations. In addition, the focus is on sustainable HR development through skills-based competence management and learning ecosystems, among other things.
• Group employer/works council agreement (Konzernbetriebsvereinbarung; KBV) on personnel development: This KBV defines uniform collective standards for personnel development within DB Group. The aim is to ensure consistent development measures for all employee groups within the defined scopes.
• KBV on education: This KBV defines the principles and framework conditions for education in DB Group under collective law. The aim is to create binding standards for training, further training and continuing education. In accordance with the KBV on education, the planning, implementation and results assurance of professional qualification are based on recognized quality standards, in particular DIN EN ISO 9001.
• KBV on work, family and career path: This KBV regulates the principles and framework conditions for reconciling work, family and career path under collective law in conjunction with the collective bargaining agreement designed to address demographic change. The aim is to strengthen the compatibility of employment and private life phases and to ensure long-term employability.
• KBV on equal treatment and protection against discrimination: This KBV obliges DB Group to treat all employees equally regardless of gender, age, origin, religion, disability, sexual orientation or political views and to protect them from discrimination, bullying and sexual harassment. It provides for specific measures, sanctions and offers of support to promote a working atmosphere based on partnership and to consistently punish violations.

DB Group is also a signatory or member of national and international diversity and equality initiatives, including:

• Diversity charter (since 2008)
• “Chef:innensache” initiative (since 2019)
• Women on supervisory boards (FidAR; since 2023)
• Women’s Career Index (FKI; since 2021)

This reaffirms DB Group’s commitment to equality, equal opportunities and a working environment that is free from discrimination.

Human rights policy for own employees

We are committed to respecting human rights and ensuring responsible corporate governance in our dealings with our employees. This is based on the DB Code of Conduct, the policy statement on protecting and respecting human rights, the Group policy on risk minimization and the Group policy on HR management.

This human rights due diligence and governance ap-proach explicitly extends to employee rights and involves a commitment to upholding equal treatment, non-discrimination and appropriate employment conditions. All policies are consistent with international standards, including the UDHR, ICCPR, ICESCR, UNGP, the ILO core labor standards, the OECD Guidelines for Multinational Enterprises and the Ten Principles of the UNGC.

Strategies to promote equal opportunities and combat discrimination

DB Group pursues a clear strategy to combat discrimination and promote equal opportunities. Central regulations are enshrined in Group-wide employer/works council agreements, including the KBV on equal treatment and protection against discrimination in DB Group, the KBV on the inclusion and professional advancement of disabled employees within DB Group (KBV on inclusion) and the framework KBV on work, family and career path. In addition, Group-wide policies on the General Act on Equal Treatment (Allgemeines Gleichbehandlungsgesetz; AGG) and company integration management apply.

The commitment to diversity is an element of the Strong Rail strategy and is anchored in the HR strategy as a dedicated focal point.

DB Group is committed to an uncompromising approach to discrimination. The prohibition explicitly covers all characteristics defined in national and European law, including national, ethnic or social origin, skin color, health status, disability, sexual orientation, gender, age, political opinion, religion or belief and trade union membership. This prohibition on discrimination also applies to determining remuneration.

Various procedures and contact points are available within DB Group to implement the policies against discrimination. For example, employees can submit reports anonymously via the electronic whistleblower system. In addition, an ombudsman office, a pool of mediators and our equal treatment clearing house offer advice and out-of-court conflict resolution. Prevention and awareness are supported by a wide range of training courses, including training on the AGG, diversity and inclusion and the legal basis for inclusion. With over 30 free, virtual diversity seminars and needs-based face-to-face or module offerings depending on the business unit and area of work, DB Group systematically anchors anti-discrimination in training. In addition, guides on respectful communication, anti-discrimination toolboxes and communication formats such as the Group-wide Diversity Week are used.