Deutsche Bank Transition toward a sustainable and climate-neutral economy Non-Financial Report 2022 Human rights Human rights – Enhancing the bank’s governance process on human rights – Updating the Statement on Human Rights – Preparing implementation of the German Supply Chain Due Diligence Act GRI 2-23/24/25/29, 3-3, FS3 While it remains the governments’ legal obligation to protect against human rights abuses by persons, including businesses, through appropriate policies, legislation, and adjudication, Deutsche Bank acknowledges its corporate responsibility pursuant to the “Protect, Respect and Remedy” framework of the UN Guiding Principles on Business and Human Rights. Deutsche Bank’s commitment to respecting human rights is anchored in the bank’s Code of Conduct (*), which was approved by the Management Board. The bank is guided by international standards and guidelines, such as: – UN Guiding Principles on Business and Human Rights (*) – International Labor Organization Declaration on Fundamental Principles and Rights at Work (*) including the International Labor Organization Core Labor Standards (*) – UN Global Compact (*) – OECD Guidelines for Multinational Enterprises (*) The core principle of the bank’s approach is to not engage in business activities where Deutsche Bank has substantiated evidence of material adverse human rights impacts and it is determined through Deutsche Bank’s internal processes that such adverse human rights impacts cannot be avoided or appropriately mitigated. Deutsche Bank’s Statement on Human Rights (*) describes its commitment and management approach in greater detail. The bank worked on a review of the Statement, which was published in March 2023, also to reflect the increased public and regulatory focus on the topic, including in context of the German Supply Chain Due Diligence Act, effective from January 2023. The bank’s approach encompasses all dimensions of its business, from client transactions and interactions with vendors and service providers to the treatment of its employees. Deutsche Bank assesses its sectoral and geographical risk exposure to human rights violations regularly and undertakes due diligence to identify and assess the nature of the actual and potential adverse human rights impacts with which it may be directly or indirectly linked. Deutsche Bank also annually publishes a Modern Slavery and Human Trafficking Statement (*). The following subchapters address the bank’s human rights governance structure and the governance and mitigation measures, it has undertaken for the different stakeholder groups, particularly for clients, suppliers, and employees. Governance GRI 2-12/13/16/25/26, 3-3 In 2022, building on the former Human Rights Working Group, the Human Rights Forum was established to ensure oversight of Deutsche Bank’s human rights management. This Forum consists of senior representatives of the following functions and business divisions: Procurement, Anti-Financial Crime, Chief Sustainability Office, Human Resources, Legal, Non-Financial Risk Management, Governance as well as Corporate Bank, Investment Bank, and Private Bank. DWS is involved ad hoc as appropriate. The Human Rights Forum is co-chaired by the Chief Sustainability Officer and the Head of Group Sustainability and reports to the Sustainability Committee. Via the Human Rights Forum, which meets bimonthly, the members monitor trends, collect and share learnings from within Deutsche Bank, liaise with external experts and initiate strategic projects relevant for human rights management. In 2022, the Human Rights Forum served as an interface for both strategic and operational actions related to Human Rights. As a specific activity within the Forum, the members evaluated the implications of the draft EU Corporate Sustainability Due Diligence Directive. In addition, the Forum supported the implementation of the German Supply Chain Due Diligence Act, which came into force in January 2023. The members of the Human Rights Forum also engaged in preparing the (*) for aforementioned Modern Slavery and Human Trafficking Statement (*) as well as the updated Human Rights Statement publication. The updated human rights governance was presented to the Supervisory Board; and the revised Statement on Human Rights and the Modern Slavery and Human Trafficking Statement have been signed off by the Management Board. 57
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