DLR policy statement on its human rights strategy pursuant to § 6 of the German Supply Chain Due Diligence Act (LkSG)

The German Aerospace Center (DLR) is the Federal Republic of Germany's national research centre for aeronautics and space. Its extensive research and technical development work in the fields of aeronautics, space, transport, energy, digitalisation and security is integrated into national and international cooperative ventures. On behalf of the Federal Government, DLR is also responsible for planning and implementing German space activities and for representing Germany in international bodies, in particular ESA. In addition, DLR is the umbrella organisation for the largest project management agency in Germany. DLR carries out these tasks with a high degree of responsibility in line with its role as a research institution geared towards scientific excellence. In addition, DLR acts as a competent management institution for strengthening Germany as a location for knowledge and innovation.

DLR is equally aware of its role in society and its responsibility towards its customers, business partners, members and employees, and is committed to sustainability. Against this backdrop, DLR contributes to addressing societal issues and to minimising environmental impact, conserving resources and promoting environmental protection as well as the well-being of the community. This is not only done to ensure DLR's long-term success, but also because DLR is a vital and valuable building block in international, national, regional and local communities.

DLR is committed to the United Nations Global Compact and in particular to the basic principles set out therein on human rights, labour standards and environmental protection. In order to fulfil this commitment, DLR bases its actions on the United Nations Guiding Principles on Business and Human Rights and the National Action Plan for Business and Human Rights of 2016 (National Action Plan; cf. the Federal Government's draft bill of 3 March 2021).

DLR is committed to responsible, sustainable business practices and supports the implementation of internationally recognised principles on human rights and fair working conditions, both within the company and with business partners. It expects its business partners and suppliers to respect and comply with human and labour rights in their business activities.

Responsibilities

The DLR Executive Board is responsible for monitoring compliance with and implementation of human rights-related due diligence obligations. Risk management is monitored by the DLR Human Rights Officer. Risk analyses and the implementation of preventive and remedial measures are carried out by the relevant DLR departments, for example DLR Purchasing, in close cooperation with the DLR Human Rights Officer.

Information and complaints procedures

DLR has set up a freely accessible whistleblowing system through which employees and third parties can report human rights or environmental risks and violations of human rights or environmental obligations committed by DLR, DLR's direct and indirect suppliers or other cooperation and business partners of DLR at any time.

Information should be sent to: Sorgfaltspflichten[at]DLR.de. Incoming messages are forwarded directly to the DLR Human Rights Officer and their representative, the Human Rights Expert. The recipients are impartial, independent and bound to secrecy with regard to the verification of the reported information. The messages are always treated confidentially and, if desired, anonymously; protection against discrimination or punishment on the basis of a complaint is guaranteed.

Receipt of the message is confirmed immediately and automatically. The DLR Human Rights Officer or their representative contacts the whistleblower within seven working days and discusses the information provided. Complaints about serious violations of human rights and environmental obligations are prioritised and the DLR Executive Board is informed accordingly, while maintaining the confidentiality or anonymity requested by the whistleblower. The whistleblower will be informed transparently and comprehensibly about the course of the procedure and the progress made. The communication of appropriate measures will take place within 90 days. If possible, the measures to be taken will be worked out in consultation with the whistleblower. The evaluation of the measures should also be carried out together with the person giving the information. For this purpose, and assuming the person's consent, contact will be made with them again after the measures have been implemented and the person making the report will be asked about their satisfaction with the process and the results.

If a report is to be made anonymously, the functional mail address Compliance-anonym[at]DLR.de can be used for this purpose. The DLR Human Rights Officer and their representative for compliance matters have access to the functional mail account; the aforementioned assurances (confidentiality, etc.) also apply here. It should be noted, however, that the discussion with the whistleblower described above is not possible in the case of an anonymous whistleblower.

Technical information on the anonymous whistleblower system: First, the whistleblower's mail is sent to the first e-mail relay for the DLR.de domain. This is a server with the name mailhost.dlr.de. On this mail host, the sender's address can still be seen in plain text. From here, e-mails to Compliance-anonym[at]DLR.de then branch to the server on which NoSpamProxy is installed. There, the sender address is anonymised and forwarded to the host with the name smtprelay.dlr.de. This means that the sender address is encrypted for all subsequent systems from this point on.

The owners of the functional mailbox for anonymous reports of compliance/LkSG violations reply to the e-mail of the whistleblower and only see the encrypted e-mail address. DLR's mail server is configured to always send such emails to NoSpamProxy. There, the encrypted address is converted back into the correct address. NoSpamProxy is set so that the e-mail with the plain text recipient is delivered directly to the recipient's e-mail server. No other email server from DLR or its IT service provider is involved.

Message tracking on the NoSpamProxy server is deactivated. This means that even an administrator with access to NoSpamProxy cannot find out who the whistleblower is.

In addition to the functional mail address, all DLR employees and third parties can contact the DLR Human Rights Officer or the Human Rights Expert directly and at any time with questions and information, either by telephone or by mail. The contact details can be found on this page.

The effectiveness of the complaints procedure is reviewed annually by DLR. Among other things, the results of the risk analysis will be included in the review, with the aim of improving accessibility to the procedure – especially for potentially affected persons.

Risk analysis

In order to review the impact of DLR's actions on human rights, an abstract risk analysis relating to human rights and ecologically relevant aspects was carried out for the first time in 2022 for DLR's own business division and DLR's business partners relevant within the meaning of the LkSG. The aim of this risk analysis was to identify possible human rights-related risk topics in a structured manner and to prioritise where potentially high risks are identified.

Building on the abstract risk analysis, DLR carries out IT-supported concrete risk analyses of prioritised suppliers and business partners on an annual basis and as required in accordance with the LkSG.

Measures

If DLR determines that a violation of a human rights-related or environmental obligation has already occurred or is imminent in its own business area or at business partners, suppliers or customers, it immediately takes appropriate remedial measures to prevent or end this violation or to minimise the extent of the violation. DLR has appointed a so-called Due Diligence Task Force – as an advisory and decision-making body on necessary remedial measures within the meaning of the LkSG – which meets in the event of serious violations of due diligence obligations within the meaning of the LkSG that have occurred or are imminent in order to examine and decide on appropriate remedial measures.

Based on the results of the risk analyses, DLR derives specific measures to reduce and avert the identified potential risks, aligns its considerations and processes accordingly to include these risks, and sensitises both employees and suppliers to these risks and the associated remedial measures in a targeted manner as required.

Concrete measures include, for example, contractual assurances from suppliers that DLR requirements will be adhered to and addressed along the supply chain, or sending questionnaires to suppliers for whom an increased risk was identified in the course of the risk analysis. Further concrete measures are based on the requirements of the LkSG and are defined in a tiered model, whereby the lowest level of measures involves holding discussions on measures to be implemented and the highest level of measures involves terminating cooperation with suppliers.

Documentation and reporting obligations

Starting in 2023, DLR will report annually publicly and to the Federal Office for Economic Affairs and Export Control (BAFA) on its supply chain due diligence activities, including disclosure of the results of the supply chain risk assessment and a description of the measures taken to mitigate the identified risks and an assessment of their effectiveness.