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Responding department: Group Sustainability

Does your company have a publicly available commitment to respect human rights?

Deutsche Börse Group refers to “human rights” in its Code of Ethics and Code of Conduct for Suppliers.

Code of Ethics 

Code of Conduct for Suppliers 


How are human rights governed in your company?

Recently the Group Sustainability Board (GSB) was established.

Supported by the Executive Board, each board division is represented by three employees. All decisions taken by the GSB are forwarded to the Executive Board. The GSB deals with all issues related to sustainability alongside Deutsche Börse Groups business – ecological, social and governmental.

The chair and the member are supposed to rotate on an annual basis. The vice chairman is the Head of Group Sustainability and does not rotate. Also, her team takes the responsibility for the overall sustainability performance and development. 

How are human rights managed within your company?

Companies are responsible – not just for their business, but also for their social environment. Deutsche Börse Group takes this responsibility very seriously and puts it into practice in its company-wide sustainability management. We see this commitment as an ongoing obligation to our employees, customers and investors, society and the environment to ensure that our company remains competitive in the long term taking all our relevant stakeholder groups into account.

Deutsche Börse Group is aware of its social and ecological responsibility and is committed to the principles of sustainability. Therefore, its suppliers and service providers are also expected to observe these principles. To ensure this, our suppliers have been given a code of conduct for suppliers comprising ecological, social and sustainability criteria.

The majority of our suppliers have signed this code of conduct, while others comply with voluntary commitments which include the criteria stipulated in our code of conduct or even surpass them. Our general terms and conditions also call for sustainable practices. Our procurement procedure includes checking that suppliers have suitable certification.

Asking our suppliers and service providers to sign our code of conduct is just one part of our efforts to select business partners who take their responsibility seriously. Within and across the different business areas of the company we continuously assess and evaluate our suppliers. The criteria for this ongoing evaluation include economic, social and ethical sustainability.

Deutsche Börse offers a 2-day introductory event for new hires in Germany, Luxembourg and Prague. It is open for colleagues from all other locations as well. One major point during these 2 days is the topic corporate responsibility including the topics of human rights policies. In 2015, we offered 6 events where 194 new colleagues attended in total.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Deutsche Börse Group continuously interacts with a large number of different stakeholder groups, whose significance for the company we evaluated in an internal survey of the Group’s divisions. Depending on their points of view, i.e. whether they consider Deutsche Börse as a capital market organiser or whether they regard it as a listed company, stakeholders and their interests can vary.

While shareholders, employees and business partners are primarily interested in the company itself, i.e. in solid corporate governance and strong operations results in the long term, customers – as issuers, trading, clearing and post-trade participants – focus on a comprehensive, efficient and high-quality product and service offering. For supervisory authorities, politics and society in general, the most significant role of Deutsche Börse Group is its contribution to the stability and efficiency of the financial markets, and therefore its key role in a functioning national economy.

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Health (including workplace health & safety, prevention of pollution)
  • Workplace diversity / non-discrimination
  • Women
  • Migrant workers 

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

As an organiser of international financial markets, Deutsche Börse Group sees it as its natural obligation to provide the basic conditions to initiate, support – and reward – responsible trading. Knowledge is one of the core prerequisites for responsible trading, and this knowledge depends on comprehensive, transparent information which is accessible to all market players. We therefore promote initiatives enhancing transparency, which is the basis for integral investment strategies.

Its role as a publicly listed company increases Deutsche Börse’s focus on transparency as a key aspect of effective capital markets communication. What we ask of ourselves: to not simply comply with reporting obligations uncritically but to help shape the reporting of tomorrow. Firmly convinced that transparency increases trust and thereby creates safety, we support initiatives on sustainable reporting such as the Global Reporting Initiative (GRI) ([link]), the German Sustainability Code (GSC) ([link]), and the International Integrated Reporting Council (IIRC) ([link]).

We want to lead by example and offer our stakeholders information which is relevant for them. In its corporate report for 2015, Deutsche Börse Group continues to adhere to the concept of embedding social responsibility and sustainability in all business areas.

Corporate report

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

From a cultural perspective, DBAG fosters a feedback-friendly culture, which encourages employees to address grievances openly.
Demonstrating the high priority of this topic, an email address was created to give employees the possibility to address grievances directly to the CEO.

To receive and handle grievances is an integral part of the duties for top and middle management at DBAG.
As an institutionalized worker representation, grievances can be also addressed to the works council, who assesses the justification of the grievance and aligns on remedies with employer.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

Sustainable Stock Exchange (SSE)

The Sustainable Stock Exchanges (SSE) initiative is a peer-to-peer learning platform for exploring how exchanges, in collaboration with investors, regulators, and companies, can enhance corporate transparency – and ultimately performance – on ESG (environmental, social and corporate governance) issues and encourage sustainable investment.

UN Global Compact

The UN Global Compact is an initiative for companies that are committed to aligning their operations and strategies with ten universally accepted principles in the areas of human rights, labour, environment and anti-corruption. It is the broadest and most important network for corporate social responsibility issues.

World Economic Forum

The World Economic Forum is an independent international organization committed to improving the state of the world by engaging business, political, academic and other leaders of society to shape global, regional and industry agendas. Members regularly come together at the organisation’s conferences.

The German Sustainability Code

The German Council for Sustainable Development adopts the German Sustainability Code and recommends that the political and business communities make extensive use of this voluntary instrument. Deutsche Börse Group has published an annual declaration of conformity with the German Sustainability Code since 2011.

International Labour Organisation

This UN agency is the international organisation responsible for drawing up and overseeing international labour standards; it brings together representatives of governments, employees and employers to jointly shape policies and programmes. By signing up for this, Deutsche Börse Group has agreed to observe these standards.

Diversity Charter

As a signatory to the Diversity Charter, the company is committed to acknowledging, respecting and promoting the diversity of its workforce, customers and business associates – irrespective of their age, gender, disability, race, religion, nationality, ethnic background, sexual orientation, or identity.

United Nations Global Compact

The UN Global Compact is an international agreement between companies and the United Nations. By participating, Deutsche Börse Group has agreed to meet minimum social and ecological standards along its entire value chain.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

Deutsche Börse Group endorses the UN’s Universal Declaration of Human Rights. As a member of the UN Global Compact, Deutsche Börse Group is highly committed to implementing the UN Global Compact’s ten principles in the areas of human rights, labour, the environment and anti-corruption throughout the Group when designing our business processes and strategies. In 2015, Deutsche Börse Group developed a range of initiatives in conjunction with the Global Compact’s ten principles.

In 2015, suppliers which account for 96.6 per cent (2014: 94.7 per cent) of the worldwide amount of purchases of Deutsche Börse Group have signed our Code of Conduct. The Code is based on the UN Global Compact principles and includes ecological, social and sustainability criteria.
Deutsche Börse (Purchasing) continuously improves the ratio of expenses covered by Code of Conduct (CoC) agreements. To do so, we analyse suppliers steered by Purchasing on a recurring basis and partition them utilizing an ABC analysis (into three blocks 70 per cent, 20 per cent, 10 per cent related to spend volume). It is our target to achieve at least a 90 per cent coverage of total expenses with CoC agreements (meaning that all “A” and “B” suppliers have to sign). In addition, bigger “C” suppliers are asked to sign, of course.

Furthermore it is mandatory for all suppliers that are on-boarded newly by Purchasing to sign the CoC.

As stated in the Code of Ethics, Deutsche Börse Group advocates openness and fairness in the workplace and promotes a culture of open dialogue, trust and mutual acceptance. Employee involvement is an important guiding principle for the corporate responsibility engagement. In Frankfurt and Luxemburg employees are presented in different boards and committees. Deutsche Börse Group has collective bargaining agreements in place that allow, for example, for payment above industry average, flexibility with respect to working time.

Deutsche Börse Group does not tolerate discrimination of any kind. The principles of equal opportunity and non-discrimination regardless of nationality, ethnical background, religion, age, gender, sexual orientation and identity, or disability of any kind are complied with.

The Group sets high standards regarding the professional qualifications and personal suitability of our new colleagues. Training and continuing professional development are a top priority at Deutsche Börse. Staffs constantly expand and refresh their knowledge of the financial markets and can also undertake regular training for their communication and organisational skills. Deutsche Börse offers a wide range of internal and external training opportunities to support its staff and their supervisors in mastering their own personal challenges. For example, the Employee Development Planning training course for managers teaches managers how to define appropriate measures to support their staff. Further training opportunities are at the planning stage.