Implementation of the German Act on Corporate Due Diligence Obligations in Supply Chains
We have established an appropriate risk management system in order to comply with our human rights and environmental due diligence obligations under the Act on Corporate Due Diligence Obligations in Supply Chains (Lieferkettensorgfaltspflichtengesetz; LkSG). This risk management is integrated into the relevant business processes and is continuously refined in order to optimize its integration. As of June 30, 2025, a total of 23 Group companies (as of December 31, 2024: 25 Group companies) fell within the scope of the LkSG due to their number of employees. The decrease is due to the sale of DB Schenker and the merger of DB Kommunikationstechnik GmbH into DB InfraGO AG.
We have defined clear responsibilities to ensure effective compliance with the LkSG. The central element of our LkSG risk management system is the regular and ad hoc performance of risk analyses. The abstract risk analysis to identify country-specific and sector-specific risks in our own operations and at direct suppliers was completed in March 2025. Based on the results of this analysis, the risk dispositions for violations of human and environmental rights are defined more precisely by subjecting parts of the company’s own operations and a selection of suppliers to a specific risk analysis. Risk-based surveys are used for this purpose. The specific risk analysis is set to be completed in the third quarter of 2025. To take suitable preventive and remedial measures, we develop risk-based action plans on a case-by-case basis using an overarching catalog of measures. Our established whistleblower system can be used to submit reports on human rights and environmental risks and violations of obligations, regardless of whether or not these occur in the supply chain or in our own area of operations.
DB AG reports from a Group-wide perspective to the Federal Office for Economic Affairs and Export Control (Bundesamt für Wirtschaft und Ausfuhrkontrolle; BAFA) on the fulfillment of the human rights and environmental due diligence obligations in accordance with the LkSG. The report for 2024 was submitted to BAFA in April 2025 and is published on our website.