Actions (S2-4)
DB Group takes targeted actions to minimize risks to human rights and the environment in the supply chain. Supplier awareness measures are conducted and suppliers are reviewed and continuously integrated into sustainable processes.
A low single-digit number of violations of the prohibition of non-compliance with occupational health and safety obligations necessitating corrective measures were identified at suppliers in 2025. No severe problems or incidents were reported. Action plans were agreed with the suppliers concerned in which specific steps were defined to remedy the violations identified. This approach is always used when risks or actual violations are identified, for example in the area of health and safety. The LkSG coordinators monitor the implementation and effectiveness of measures in the supply chain, including health and safety measures, which the suppliers are responsible for implementing. The LkSG coordinators are available to support the suppliers as specialist points of contact.
The effectiveness of preventive and corrective measures agreed with suppliers is evaluated on the basis of a guideline and an associated template. The specific risk to be reduced by the action, the date by which the target is to be achieved and the evidence to be provided for this are recorded. When reviewing the effectiveness of an action, the results achieved, the changes made and the long-term impacts are evaluated before the overall impact of the action is assessed.
In addition, the effectiveness of LkSG risk management as an overall system is reviewed once a year and on an ad hoc basis. The effectiveness criteria of the UNGP and the requirements of ISO 31000 for risk management are taken into account. The results of the reviews are incorporated into the further development of both the individual measures and the overarching processes.
Risk-based or ad hoc supplier meetings, which serve to raise awareness of priority risk areas and the joint development of improvement measures, are a central component of our measures relating to employees in the value chain. DB Group supports its suppliers with technical advice and suggestions for measures, including in the risk area of health and safety. A guide and a catalog of measures have been developed for structured implementation. An examination of the appropriate and effective actions takes place depending on the type of risk or violation identified. Action plans are derived from the supplier meetings and used for systematic documentation and tracking. This ensures that risks are addressed and the progress made in minimizing risks can be tracked transparently. Supplier meetings are held annually on the basis of risk-based prioritization, which is carried out according to the criteria of probability of occurrence, severity, possibility of influence and contribution to causation. In 2025, a total of 22 supplier meetings were concluded on the basis of the prioritization carried out in 2024.
To monitor compliance with human rights and environmental requirements, DB Group conducts on-site audits of direct suppliers on an ad hoc basis in accordance with the Sedex Members Ethical Trade Audit (SMETA) standard for social audits if there are reasonable grounds for assuming an increased risk. In 2025, five SMETA audits were carried out at direct suppliers in the upstream supply chain. The audits focus in particular on compliance with relevant labor law standards, especially regarding working hours, remuneration and occupational health and safety.
As part of the step-by-step plan for a sustainable supplier landscape introduced in 2023, contractors are gradually placed under obligation to submit sustainability ratings and meet the minimum requirements defined therein. The step-by-step plan covers all tender procedures:
- Since 2023: Mandatory request in all EU tenders (without minimum requirements).
- Since 2024: Mandatory submission after conclusion of contract for tenders in excess of € 100,000 (without minimum requirements).
- Since 2025: Mandatory sustainability rating with defined minimum requirements in EU tenders.
- From 2026: Mandatory sustainability rating with defined minimum requirements for tenders in excess of € 100,000.
The transparency on sustainability performance gained through the sustainability ratings serves to reduce risk and contributes to greater resilience in the supply chain. The assessments also specifically support our LkSG-related risk analysis.
With our own procurement training, we seek to prevent DB Group’s procurement practices from having or contributing to a significant negative impact on workers in the supply chain. It informs the employees involved in the procurement process about how to consider and implement sustainability criteria in the supply chain. One particular training course focuses on the links between our own procurement practices and potential human rights and environmental impacts on DB Group, suppliers and the supply chain. The training can be accessed online across all functions and is aimed with a risk-based approach at buyers in particularly high-risk product groups. All persons required to complete the mandatory training had done so by the end of 2025.
In addition, special training has been developed for the procurement of road transport services, which addresses the relevant human rights risks in this part of the supply chain and highlights possible countermeasures.
In addition to our LkSG-related risk analysis, which we use annually to determine and evaluate the potential and actual risks of our business activities for people and the environment in our own business operations and at our direct suppliers, we are developing our supply chain mapping as an in-depth analysis step. The aim is to make our deeper value chain more transparent and to systematically understand structural dependencies and possible causes for the risk areas identified in the LkSG-related risk analysis, for example the “occupational safety for flagmen on tracks” risk area. This involves systematically determining which parties (e.g. suppliers, subcontractors) are involved in value creation, how material and information flows are organized and where there could be dependencies or key risk areas. For this purpose, the supply chain is visualized with the available data from tier 1 to tier n suppliers and the structural causes of risk areas identified in the LkSG risk analysis are then traced. Supply chain mapping was further developed into a systematic approach in 2025. This will be incorporated into the LkSG processes in 2026.
DB Group is in close contact with industry associations on an ongoing basis and is involved in the Railsponsible industry initiative. Strategically, climate protection in the supply chain and supply chain due diligence are key areas in which DB Group is involved in the industry initiative’s working groups. In 2025, the Supply Chain Due Diligence working group used supply chain mapping to analyze ESG risks for trains and rail infrastructure in greater depth.
The aforementioned actions will continue in 2026 as de-scribed.