Compliance

Compliance with laws and regulations is a fundamental principle of our business conduct.

Every day brings new challenges and important decisions to make. Ensuring compliance with applicable laws, regulations, and internal rules is not only expected but is also a key prerequisite for sustainable business success.

As part of risk management within the DB Group, compliance activities focus primarily on preventing corruption and economic crime.

The DB Code of Conduct serves as the binding framework for our day-to-day business activities and guides our actions across the organization.

We expect integrity and compliance with applicable rules not only from our employees and managers but also from our business partners. A separate Code of Conduct applies to business partners. With regard to benefits and gratuities, including invitations and gifts, significantly stricter standards apply to our employees and managers, as they are considered public officials under German criminal law.

To meet its compliance obligations and fulfill the requirements of the German Whistleblower Protection Act (HinSchG), DB InfraGO AG uses the reporting channels provided by Deutsche Bahn AG. These channels enable individuals to report specific suspicions of serious violations of laws, regulations, or Deutsche Bahn policies.

The Deutsche Bahn AG whistleblowing system offers several channels for reporting potential compliance violations:

• DB Group's electronic whistleblowing system (BKMS)
• Email: compliance.hinweismanagement@deutschebahn.com
• Telephone: +49 30 297 62710 – Available Monday through Friday from 10:00 a.m. to 3:00 p.m.
• Deutsche Bahn AG – Compliance Reporting Management, Potsdamer Platz 2, 10785 Berlin, Germany
• External trusted attorneys (for cases involving fraud, breach of trust, or corruption)

To ensure prompt and comprehensive processing of reports, please provide as much specific information as possible. If possible, the following five questions should be considered: Who? What? When? How? Where?

In addition to the internal reporting channels, the following external reporting offices are available:

• Federal Office of Justice (Bundesamt für Justiz)
• Whistleblower Office of the Federal Financial Supervisory Authority (BaFin)
• Whistleblower Office of the Federal Cartel Office (Bundeskartellamt)

Additional information can be found on the respective organizations' websites.

Information regarding data protection is available on the Deutsche Bahn AG website under Data Protection Information.

Dr. Pascal Guinomet

Compliance Officer Infrastruktur
Deutsche Bahn AG

Adam-Riese-Str. 11 – 13
Frankfurt am Main 60327

pascal.guinomet@deutschebahn.com
+49 69 265-31327

• Compliance at Deutsche Bahn AG
• DB Code of Conduct
• Whistleblowing
• Information for our business partners

As DB InfraGO AG, we take responsibility for our work in Germany as well as in all other countries where we operate. Therefore, we also expect our suppliers to treat people and the environment with respect as a basis for a reliable partnership.

With the introduction of the Supply Chain Due Diligence Act (LkSG), the legislator has created the framework for responsible and sustainable value creation along the entire supply chain. We at DB InfraGO AG comply with the requirements of the LkSG.

To ensure that the LkSG is being complied with in our own business area and in the supply chain, we have established a complaint procedure. Complaints and reports on human rights and environmental risks, as well as violations of human rights-related or environmental obligations, can be reported there.

The complaint procedure can be accessed via deutschebahn.com/lksg. Further information can also be found in our procedural guidelines.

LkSG - Supply Chain Due Diligence Act

Friedhelm Simon

Leiter Beschaffung/Vertragsmanagement
DB InfraGO AG GB Fahrweg

Adam-Riese-Str. 11 – 13
Frankfurt am Main 60327

Friedhelm.Simon@deutschebahn.com

+49 69 26547490

+49 160 97471387