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.

Whistleblowing and complaints procedure

DLR has set up a freely accessible whistleblower system that employees and third parties can use at any time to report human rights or environmental risks and violations of human rights or environmental duties caused by DLR, DLR's direct and indirect suppliers or other DLR cooperation and business partners. Complaints can be addressed in particular to sorgfaltspflichten[at]dlr.de. The effectiveness of the complaints procedure is reviewed annually by DLR.

A detailed description of the complaints procedure can be found here.

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.