When we speak of workers in the value chain, or “workers”, we are referring to all workers who are under contract with our suppliers and are subject to the instructions of those suppliers or who perform outsourced services at our sites, such as tradespersons or external forwarding agents. Our own employees, temporary external workers or self-employed persons (contractors) are not taken into account, as they are already covered by the reporting on our own workforce.
We are fully aware of our responsibility toward workers in the upstream value chain due to our operations and our global reach. We have therefore put in place strict ethical, social and environmental principles to guide us in our business activities. Those principles are set out in our Supplier Code of Conduct. The Supplier Code of Conduct is, in principle, a binding component of our relationships with our suppliers and obliges them to adhere to our standards and to implement them in their own supply chains. If breaches are identified, remedial actions are discussed with the supplier and plans for corrective actions are agreed upon. In this way we want to protect workers in the upstream value chain and to enable them to enjoy the same standard of working conditions that our own employees expect. We do not have direct relationships with these workers or with the contractual partners of our suppliers, management of relationships with suppliers.
Material impacts, risks and opportunities identified (ESRS 2 SBM–3)
The materiality analysis did not identify any material risks or opportunities arising from workers in our upstream value chain. However, it did identify both potential and actual impacts, which are set out in the table below. Neither our strategy nor our business model needed adjusting as a result, since they already take account of the impacts identified, materiality analysis process.
MATERIAL IMPACTS IDENTIFIED
ESRS aspect
Impact on the business model1
Impact on the value chain
Working conditions
Adequate
wages
Lack of adequate wages could lead to financial insecurity and poorer living conditions. The quality of life and well-being of these workers is then negatively impacted.
Identified in the following procurement categories: promotional items, uniforms and protective clothing, output-based services2, buildings: renovations and new constructions, road transport.
Negative impact (potential)
Yes
Health
and safety
High standards for occupational health and safety can lead to spillover effects and raise standards in the markets.
Identified in the following procurement categories: promotional items, uniforms and protective clothing, output-based services2, buildings: renovations and new constructions, road transport.
Positive impact
(actual)
Yes
A lack of sufficient occupational health and safety standards can lead to work-related injuries or fatal accidents.
Identified in the following procurement categories: promotional items, uniforms and protective clothing, buildings: renovations and new constructions, road transport.
Negative impact
(actual)
Yes
Equal treatment and equal opportunities
Violence and harassment in
the workplace
No or inadequate actions against harassment in the workplace could result in more incidents.
Identified in the following procurement categories: promotional items, uniforms and protective clothing, output-based services2.
Negative impact (potential)
Yes
Other
work-related rights
Exclusion of
child labor
No or inadequate measures to prevent child labor could result in child exploitation and related negative consequences.
Identified in the following procurement categories: promotional items, uniforms and protective clothing.
Negative impact (potential)
Yes
Exclusion of
forced labor
If suppliers are paid based on results/performance, this can lead to a higher incidence of exploitation of the workers employed.
Identified in the procurement categories: buildings: renovations and new constructions, output-based services2
Negative impact (potential)
Yes
1 The ESRS call for the following distinction: actual impacts occurred at least once during the fiscal year, whereas potential impacts did not.2 Personnel-intensive services where the personnel are managed by the supplier and the supplier is remunerated according to output/service.
The evaluation is based on the Verisk Maplecroft risk score assigned to the procurement categories, among other factors. We also use this risk score to evaluate the potential geographical risks of child or forced labor. No material risks that could affect workers in the value chain were identified.
Policies related to value chain workers (ESRS S2–1)
The workforce of our suppliers, especially in road transport, has a significant impact on our reputation and on the success of our strategic goal of being the best provider and a pioneer in ethical business.
DHL Group does not have any direct relationships with workers in the value chain, but requires DHL Group suppliers to adhere to all applicable laws and standards as laid out in our Supplier Code of Conduct and to implement those laws and standards in their own supply chains. Our Supplier Code of Conduct is based on the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights, the UN Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises as well as the 1998 International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, in accordance with national laws and practice. In this way, we also want to counter the identified negative impacts – potential and actual – which we address in our Supplier Code of Conduct under the topics covered by “human rights and fair labor practices” (child labor and forced labor, compensation and working hours, freedom of association and collective bargaining, and diversity and inclusion) and “occupational health and safety.” We reserve the right to monitor adherence to the Code of Conduct, for example by way of audits.
The Supplier Code of Conduct and the management of relationships with suppliers are the primary means by which we implement our ethical and social standards in the upstream value chain. During our supplier selection process and continuous risk assessment process, we check that our standards are implemented and adhered to, and we review progress on agreed action plans. This also applies to the impacts of our business identified in relation to working conditions, equal treatment and equal opportunities, child labor, and occupational health and safety. Furthermore, our standards address the issue of forced labor and prohibit human trafficking. We publish information about the expectations we place on our suppliers in the supplier portal on our Group website. The procedures for monitoring adherence to those requirements are described in detail under management of relationships with suppliers. Responsibility for supplier management lies with the Global Business Services Board department, which is headed by the CEO. If a breach of the Supplier Code of Conduct is identified, remedial actions are discussed with the supplier and plans for corrective action are agreed upon.
Engagement of workers in the value chain (ESRS S2–2)
Our Supplier Code of Conduct is also designed to protect the rights of workers in the upstream value chain. Adherence to the Supplier Code of Conduct is monitored during supplier relationship management. In onsite audits, the supplier’s workers are also invited and their perspective is considered. DHL Group does not maintain any direct relationship with these workers.
Remediation of negative impacts and channels for raising concerns (ESRS S2–3)
We address the potential negative impacts identified by setting clear requirements in our Supplier Code of Conduct, including providing fair and appropriate remuneration, avoiding workplace harassment, promoting occupational health and safety as well as excluding child labor. These factors are taken into account in the supplier selection process with respect to each procurement category or according to the potential geographical risk, and compliance is effectively monitored, management of relationships with suppliers.
Workers in the upstream value chain can report concerns or possible breaches of our Supplier Code of Conduct or of the law at any time through our whistleblower system, which is publicly accessible on the Group website. We describe how we handle incoming reports in the section entitled whistleblower system. Our suppliers are required to inform their own workers and the workers in their supply chains about this channel. Incidents reported via the whistleblower system provide an indication of the effectiveness of this measure.
Managing material impacts (ESRS S2–4)
We address the actual material negative impacts identified that could affect workers in the value chain and review the effectiveness of the action taken. In line with our strategic approach to be seen as a role model for responsible corporate governance in our industry and as a credible business partner, we expect our employees to act with integrity and in full compliance with the law, including when dealing with our suppliers. As part of this approach, we also aim to foster stable and sustainable relationships with our suppliers.
Actions taken as part of our management of relationships with suppliers address the potential negative impacts identified and help to prevent material risks from arising. In addition, our actions to respect human rights comply with the requirements of the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG). In this way, we also consider the potential impact on our company as well as on the upstream supply chain. The implementation and effectiveness of these actions are monitored by the LkSG Council, which acts as a human rights officer as defined by the LkSG. There are no other actions in place to address the identified negative impacts on such workers. Incidents reported via the whistleblower system are systematically reviewed. If necessary, the reports are addressed and followed up on by implementing appropriate plans for taking remedial action.
On the authority of the Board of Management, Corporate Internal Audit performs regular or ad hoc independent audits at all DHL Group subsidiaries and at corporate headquarters to evaluate management and monitoring processes (including procurement processes) and compliance with Group policies, thereby contributing to their improvement.
No serious human rights incidents were reported in fiscal year 2025.
Targets for managing material impacts (ESRS S2–5)
We evaluate the effectiveness of our actions using our entity-specific metrics in supplier management: “supplier spend covered by an accepted Supplier Code of Conduct” and “suppliers with high risk potential assessed.” The first metric measures our ability to enforce adherence to our standards in the upstream value chain, while the second measures our ability to contractually enforce such adherence. These metrics cover the information required by the ESRS, even if they go beyond the aspects required here. No other metrics have been set, management of relationships with suppliers.
