Unfortunately, this question is not so easy to answer, because managing directors and executives are not generally considered to be employees. At the same time, Section 12 of the German Occupational Safety and Health Act only requires employees to be instructed. At first glance, it would therefore appear that managing directors and executives do not need to be instructed.
However, if they work for a company on the basis of an employment or service contract, they are legally covered by the accident insurance as employees. Since DGUV Regulation 1—in contrast to the German Occupational Safety and Health Act—requires instructions for all insured persons, managing directors and executives are included here. As long as managing directors are covered by statutory accident insurance, they must also be instructed, regardless of whether they are considered employees under the German Occupational Safety and Health Act.
The situation may be different if managing directors are not covered by statutory accident insurance, for example because they own shares in the company and regularly work independently in the company due to their significant influence on the company's decisions. In such a case, only voluntary insurance can be considered under certain circumstances.
But beware! If the option of voluntary insurance is taken up, the obligation of providing instructions applies again and also extends to managing directors.