Deutsche Bank Governance and operations Non-Financial Report 2022 Culture, integrity and conduct Culture, integrity and conduct – Over 500 key central communications promoting a sustainable performance culture – Delivery of a cross-divisional financial crime risk management and culture program GRI 2-16/23/26, 3-3 The commitment to integrity guides everything the bank and its employees do. The bank expects its employees to conduct themselves ethically at all times, to adhere to its policies and procedures and to comply with all applicable laws and regulations. Anything less would prevent the bank from thriving, deepening stakeholders’ trust and safeguarding its reputation. The bank’s core values — integrity, sustainable performance, client centricity, innovation, discipline and partnership — are articulated in a Code of Conduct (*). Its purpose is to guide employees’ interactions with each other as well as the bank’s dealings with its clients, competitors, shareholders, business partners, government and regulatory authorities and society as a whole. The Code is also designed to foster an open, diverse and inclusive environment in which Deutsche Bank’s employees understand what the bank expects of them. It also serves as the foundation for company policies, provides guidance on legal and regulatory compliance and helps Deutsche Bank achieve its corporate purpose. In addition, the Raising Concerns (including Whistleblowing) Policy actively encourages employees to report, without fear of retaliation, any potential misconduct, inappropriate behavior, serious conduct risk and related concerns or suspicions. Employees may do so using the Whistleblowing Integrity Hotline operated by the Whistleblowing Central Function, anonymously if they prefer. The Whistleblowing Central Function is a dedicated team within the bank’s Anti-Financial Crime Function tasked with – Operation of the secure escalation channels – The end-to-end coordination of escalations, thus ensuring appropriate follow-up of reports alleging possible violations of laws, rules, regulations, or policies and procedures to which, violations may result in disciplinary action The Whistleblowing Central Function has personnel in Frankfurt and London. Quarterly reporting on trends and themes is provided to senior management as well as the Supervisory Board’s Audit Committee. In 2022, the Whistleblowing Central Function updated its processes in line with the EU Whistleblowing Directive and aims at continuing to do so in line with country implementation laws as required. These changes widen the protections against retaliation and enhance communication with individuals who raise possible violations. Deutsche Bank recognizes that managing risks effectively is integral to its governance and corporate culture. The bank is committed to constantly challenging itself to improve, learning lessons from past events and applying them to improve in the future. Pursuant to its risk management principles and risk governance outlined in the 2022 Deutsche Bank Annual Report – Management Report – Risk Report, the bank has three Lines of Defense for managing risks, which is integral to the bank’s risk culture, a sub-component of culture, with roles and responsibilities of the three Lines of Defense being outlined in Deutsche Bank’s risk management framework. Culture, Integrity and Conduct program Purpose and governance GRI 2-9/12/13/23/24, 3-3 The bank’s Culture, Integrity and Conduct (CIC) program has been in place since early 2018. Its purpose is to reinforce the bank’s aforementioned values and further enhance integrity and ethical conduct across the organization. It is overseen by the Culture, Integrity and Conduct Committee, a committee established by the whole management board. The program is a part of the Committee’s mandate, with the Committee being co-chaired by the Chief Administrative Officer and the Management Board member responsible for Investment Bank and Corporate Bank. It consists of representatives of each business division and key infrastructure functions, who are appointed by the Management Board member responsible for the respective division or function. 78