Policies (S2-1)
As a Group with diverse and, in some cases, international supply and service relationships, we consider the protection of the health and safety of workers in the value chain to be a material human rights issue for us. To implement the requirements of the Act on Corporate Due Diligence Obligations in Supply Chains (Lieferkettensorgfaltspflichtengesetz; LkSG), DB Group has established comprehensive structures, guidelines and processes. These are designed to ensure that human rights and environmental due diligence obligations are implemented in the company’s own business operations and along the supply chain.
The Management Board has appointed a Group LkSG Officer to monitor the implementation of the statutory due diligence obligations. The Group LkSG Officer is involved in the continuous development of the LkSG risk management system and carries out risk-based control measures to examine compliance with human rights and environmental obligations. The Group companies subject to the LkSG have also each appointed an LkSG Officer to monitor the implementation of the legal obligations. In addition, an LkSG Coordinator has been appointed at each of the Group companies subject to the LkSG in order to manage the implementation of human rights and environmental due diligence obligations at an operational level.
DB Group’s policy statement on protecting and respecting human rights and the Group guideline on risk minimization apply throughout the Group. Both refer to the due diligence obligations under the LkSG and thus cover the entire scope of application of the law. The term “supply chain” covers all of a company’s products and services as well as all necessary production and service provision stages in Germany and abroad. In principle, the full scope of application of the LkSG therefore applies, including activities in the company’s own business operations, with direct suppliers and, in some cases, with indirect suppliers.
Our policy statement on protecting and respecting human rights also covers the issues of child labor, forced labor (e.g. as a result of human trafficking) and slavery. These topics are also covered by the LkSG. The DB Code of Conduct for Business Partners also refers to these risk areas. Accordingly, all business partners of DB Group must strictly reject child labor, comply with the relevant ILO regulations and place the welfare of children at the heart of their actions. Furthermore, they must not use or tolerate any form of slave labor, forced or compulsory labor, debt bondage, servitude, human trafficking or involuntary labor.
The Management Board has adopted the policies described below (Group guideline on risk minimization, DB Code of Conduct for Business Partners and policy statement in accordance with the LkSG). The Management Board is responsible for monitoring and revising the Group guideline on risk minimization, the policy statement and the Code of Conduct.
Policy statement on human rights
In DB Group’s policy statement on protecting and respecting human rights, we commit ourselves to sustainable and responsible corporate governance. The statement is updated annually and on an ad hoc basis (if the risk situation of DB Group changes). It sets out how the human rights and environmental due diligence obligations are implemented and regularly reviewed in accordance with the requirements of the LkSG. This includes the prohibition on endangering the health and safety of workers in the supply chain, which is enshrined in the LkSG, and the requirement to ensure decent working conditions. In the latest policy statement dated December 2025, the risk of “disregard for occupational health and safety and work-related health hazards” in the area of suppliers is once again prioritized.
The policy statement also includes a commitment to compliance with internationally recognized human and environmental rights standards. These include the International Bill of Human Rights with the United Nations Universal Declaration of Human Rights (UDHR), the United Nations International Covenant on Civil and Political Rights (ICCPR) and the United Nations International Covenant on Economic, Social and Cultural Rights (ICESCR), the UN Guiding Principles on Business and Human Rights (UNGP) and the core labor standards of the International Labour Organization (ILO). In addition, DB Group is committed to the Ten Principles of the UN Global Compact (UNGC) and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. There were no reports of violations of the aforementioned guiding principles in 2025.
If DB Group identifies human rights or environmental risks or violations, appropriate preventive or remedial measures are taken immediately. Existing preventive or remedial measures are regularly reviewed and further developed. The most important remedial measures include the risk-based development of specific action plans together with suppliers and the affected area in the event of identified risks or violations. There is also a comprehensive catalog of preventive and corrective measures, which also covers the topics of health protection and occupational health and safety. DB Group reserves the right to impose appropriate sanctions or, as a last resort, to terminate contracts or business relationships, particularly in the event of serious violations.
The policy statement is available on DB Group’s website, among other places.
Group guideline on risk minimization
With the Group guideline on risk minimization, DB Group defines Group-wide minimum standards for identifying and minimizing risks and establishing clear responsibilities. Among other things, it includes the implementation of the due diligence obligations in accordance with the LkSG. To fulfill these due diligence obligations, DB Group operates an appropriate and effective LkSG risk management system. The aim is to identify, prevent or minimize risks to human rights or the environment both in our own business operations and along the supply chain at an early stage. This also includes protecting the health and safety of workers in the supply chain and ensuring decent working conditions. Environmental risks are also recorded as part of LkSG risk management if there is a possibility of them affecting people’s health or livelihood. Remedial measures are implemented for human rights violations or environmental damage that have already occurred.
The Group guideline on risk minimization is available in the Group regulations database. The LkSG coordinators at Group and subsidiary level are responsible for the strategic management of implementation. The relevant specialist departments, especially procurement, are responsible for the operational implementation of the due diligence processes with the support of other specialist departments.
DB Code of Conduct for Business Partners
DB Group is committed to sustainable action in the DB Code of Conduct for Business Partners. It sets out the expectations we have of our business partners and thus fulfills a key requirement of the LkSG. The Code reflects the human rights and environmental rights standards set out in the policy statement and obliges business partners to implement them in their own supply chains. Business partners are expected to cooperate with DB Group and provide the necessary information to show that they comply with the principles mentioned and promote them in their own supply chain. The DB Code of Conduct for Business Partners refers to internationally recognized standards, namely the UDHR, the ICCPR, the ICESCR and the core labor standards of the ILO. Business partners are all companies not belonging to DB Group from which DB Group procures goods and services. Examples include suppliers, consultants, representatives and other providers of goods and services. Business partners are responsible for implementing and complying with the internationally recognized standards listed in the Code of Conduct in all of their business operations around the world and in their supply chain.
The DB Code of Conduct for Business Partners stipulates that health and safety is a top priority and must be one of the core values of all business partners. They are expected to create a safe and healthy working environment that guarantees access to sufficient drinking water, clean sanitary facilities and safety-related training measures. In addition, they must ensure the safety of their employees in accordance with national standards as a minimum and continuously improve their occupational health and safety performance.
Business partners with more than 250 employees are encouraged to introduce an occupational health and safety management system based on the principles of ISO 45001 or a comparable standard. In addition, all potential sources of danger in the working environment should be minimized or eliminated as far as possible. The relevant departments of DB Group are involved in every update of the Code of Conduct.
DB Group can carry out measures itself or through contracted auditing companies to verify compliance with these principles. Questionnaires, on-site audits in justified cases, the evaluation of available information and other suitable control measures are used for this purpose.
The DB Code of Conduct for Business Partners is published on DB Group’s website.
Framework guidelines on the use of external companies
In order to reduce risks for external company employees and safely manage interfaces between multiple external companies, DB Group has binding occupational health and safety policies with clearly defined responsibilities and processes.
The central foundations are the framework guideline on occupational health and safety when using external companies and temporary workers and the framework guideline on coordination of hazards when working with multiple companies. These framework guidelines define the responsibility, organization and processes for ensuring legally compliant, safe and healthy occupational health and safety for all external company employees who work on behalf of DB Group or on DB Group sites. The aim of the guidelines is to minimize risks through systematic planning, coordination and control. The binding minimum requirements include carrying out risk assessments, implementing protective measures, providing mandatory instructions and documenting all relevant processes. One particular focus is on the identification and management of interface risks in the activities of several companies. The up-to-dateness and effectiveness of the guidelines is reviewed annually by the specialist authors in consultation with the Group companies as part of the Group-wide occupational health and safety working group. The regulations apply to all Group companies in Germany. They serve as a guide for foreign Group companies, taking into account the respective national legislation.