Engagement with workers in the value chain, channels to raise concerns or needs and approaches to remedy
Processes for engaging with value chain workers about impacts (S2-2)
DB Group endeavors to incorporate the needs and concerns of workers along the value chain when designing human rights due diligence measures.
A concept for the inclusion of rights holders in accordance with the LkSG was developed in 2025. A key component of the concept is the inclusion of their interests in the due diligence processes depending on the risk, for example when reviewing risk causes and developing possible measures. The concept is to be piloted in 2026.
The current focus of our stakeholder engagement is on direct suppliers, whom we specifically involve in human rights due diligence issues. Suppliers are selected for supplier meetings in accordance with a risk-based review process or on an ad hoc basis in line with the requirements of the LkSG. Expectations, measures to minimize risks, the definition of measures and the assessment of their effectiveness are jointly discussed at these meetings. Further information on supplier meetings can be found under Actions (S2-4).
DB Group ensures that the interests of workers in the value chain are taken into account both in the complaints procedure and in the development and implementation of remedial measures.
Whistleblowers have the opportunity to submit reports and present their perspectives via our complaints procedureµ . Their views are taken into account when developing remedial measures to end, minimize or prevent violations. Direct, ad hoc involvement takes place in the context of discussions with direct suppliers in connection with complaints. If external stakeholders, such as non-governmental organizations (NGOs), approach DB Group, it can involve them in the process on a case-by-case basis.
In addition, DB Group uses external exchange formats and initiatives such as econsense, the UN Global Compact and Railsponsible to incorporate best practices and stakeholder expectations into its own actions. A professional exchange on human rights due diligence and supply chain responsibility, for example with the Federal Government’s Business and Human Rights Helpdesk, also takes place at events.
As part of the implementation of DB Group’s due diligence obligations in accordance with the LkSG, operational responsibility for incorporating the views of value chain workers lies with the Group companies. The Group Sustainability and Environment function performs a governance role and manages implementation in collaboration with the Group Compliance, HR Strategy, Legal and Procurement functions. Findings from the dialog with suppliers, business partners and external specialist bodies, networks and civil society organizations are selectively incorporated into the further development of the processes and measures for fulfilling the statutory due diligence obligations under the LkSG. In order to continuously expand their expertise, the responsible employees are trained in LkSG-relevant topics.
Processes to remediate negative impacts and channels for value chain workers to raise concerns (S2-3)
DB Group has set up a complaints procedure through which employees in the value chain as well as all employees, customers, suppliers and other potentially affected parties can submit reports on human rights and environmental risks and potential violations of obligations, both in the supply chain and in the company’s own business operations. Various reporting channels are available for this purpose, including the electronic whistleblower system and the submission of reports by post.
The electronic whistleblower system is available on Internet-enabled devices, can be used anonymously and is available in 12 languages. It is also accessible, for example for blind and visually impaired people. The rules of procedure protect whistleblowers against reprisals. If desired, a detailed discussion of the facts can be conducted with the person submitting the report.
Regardless of how DB Group receives information, it is processed immediately and according to a standardized procedure. The DB Code of Conduct for Business Partners stipulates that business partners must inform their employees and the persons working for them that violations of the Code can be reported and how to do so. They can use DB Group’s whistleblower system or equivalent internal or external complaint channels (e.g. trusted lawyers or industry-specific complaint mechanisms) for this purpose.
All reports are processed by selected and specially trained employees who are impartial, independent and bound to secrecy. As part of the complaints procedure, the employees handling the complaint document the measures planned or taken in a standardized form. The actions are defined together with the responsible employees of the Group companies concerned and are based on the recommendations of a Group-wide catalog of measures developed to address risks to human rights and the environment and violations within the meaning of the LkSG. Complaints received from the supply chain show that the complaints procedure is known of, used and trusted by workers in the value chain.
The effectiveness of the complaints procedure is systematically reviewed once a year and on an ad hoc basis. The assessment is based on the effectiveness criteria of the UNGP (Guiding Principle 31). In addition, the Group LkSG Officer continuously monitors the complaints procedure to ensure that it is implemented properly.
Further information on the protection of whistleblowers against discrimination and punishment can be found in the “Business conduct (G1)” chapter under Protection of whistleblowers.