Engage. Challenge. Escalate. Holding companies to account on workplace culture

Siemens: Constructive engagement and transparency

• Sector: Technology
• Location: Germany

Siemens shows us how constructive engagement can improve investor understanding of workforce-related risks.

Ahead of the company's annual general meeting (AGM), we engaged on workforce culture metrics, whistleblowing transparency and the relationship between health and safety outcomes and executive remuneration. We also sought clarification regarding an increase in reported fatalities and a decline in its inclusion-level score.

The company provided detailed explanations that helped place the reported figures in context. Siemens explained that the increase in fatalities largely reflected changes linked to new reporting requirements and historic occupational disease cases, rather than a deterioration in current safety performance. Injury-related fatalities have remained low and stable in recent years. The company also clarified that its inclusion score remained close to target and did not indicate a significant decline in workplace culture.

While we continue to encourage greater transparency around whistleblowing disclosures and stronger links between workforce outcomes and remuneration oversight, the engagement provided sufficient reassurance.

Action: As a result, we voted for the relevant AGM resolutions while maintaining dialogue on areas where further progress could be made.

SAP: Progress, but important disclosure gaps remain

• Sector: Application software
• Location: Germany

Our engagement with SAP highlighted a different challenge. The company has made positive progress in recent years by increasing disclosure around policy violations investigation volumes and reporting channels, which we welcomed.

However, SAP confirmed that it does not currently plan to disclose substantiated policy violations, aggregated investigation outcomes or indicators relating to employee confidence in speaking up. The company also indicated that it does not intend to publish responses to survey questions relating to reporting concerns or retaliation.

While reporting volumes are useful, they do not demonstrate whether misconduct is being addressed consistently or whether employees trust the process. We believe additional disclosure would provide important insight into the effectiveness of SAP's culture and compliance framework.

Action: We therefore maintained our abstain vote on the ratification of management and supervisory board actions while continuing engagement ahead of future reporting cycles.

DHL: Disclosure versus accountability

• Sector: Logistics
• Location: Germany

Our engagement with DHL centred on similar themes. The company highlighted its compliance with European Sustainability Reporting Standards and its existing disclosures on employee feedback, whistleblowing mechanisms and workplace incidents.

We welcomed the company's willingness to engage and the disclosures it already provides. However, several of our key requests remain outstanding. DHL does not currently disclose investigation outcomes, substantiation rates or quantitative indicators relating to employee confidence in reporting concerns. Nor has it indicated plans to improve the comparability of misconduct reporting across jurisdictions.

This illustrates a wider challenge for investors. Compliance with reporting requirements is important, but it does not always provide sufficient insight into how culture-related risks are being managed in practice.

Action: We therefore maintained our abstain vote on the ratification of management and supervisory board actions while continuing dialogue with the company.

BYD: Escalation where engagement falls short

• Sector: Automobiles
• Location: China

Over several years, we sought engagement with the company regarding whistleblower protections, reporting channels and broader workplace culture disclosures. Despite repeated attempts, we did not receive a response.

The lack of engagement became increasingly concerning as workforce-related controversies emerged, including allegations relating to labour practices at overseas construction sites. In our view, these developments increased the importance of robust disclosure around whistleblowing arrangements, workforce oversight and governance processes.

Without meaningful engagement or improved transparency, investors have limited ability to assess how workforce risks are identified and addressed. We therefore escalated our voting approach.

Action: In 2025, we voted against the annual report and accounts. After further progress failed to materialise, we escalated again in 2026 by voting against both the directors' report and annual report items.