Deutsche Bank Appendix Non-Financial Report 2022 Principles for Responsible Banking misconduct, inappropriate behavior, serious conduct risk, and related concerns or suspicions. The bank believes it is vital that everyone understands the financial implications of ESG issues and is aware of the steps governments and regulators are taking to address these problems and how they will impact business and clients. Training is essential to raise the bank’s employees’ awareness and enable them to better identify environmental and social risks and opportunities and consequently assess and refer transactions to Group Sustainability. In 2022, Deutsche Bank continued its related employee training program. In 2022 front-office staff continued to receive live video-training to enable them to understand the Sustainable Finance Framework and to identify opportunities for clients to transition to more sustainable and climate friendlier business models. Following the target to offer training on the bank’s taxonomy to 100% of the relevant front-office staff in the Investment Bank, Corporate Bank and Private Bank by the end of 2022, a Sustainable Finance training has been integrated into the bank’s internal training platform “Connect2Learn”. The sessions also address environmentally and socially related exclusions and expectations and specify the requirements for ES due diligence. Training on and implementation of the Equator Principles continued in 2022, the second year of the bank’s implementation. In 2022, the bank also continued to provide awareness sessions and training to control functions and business teams to reinforce their awareness of reputational risks such as defense and gaming. Non-financial criteria form part of our top-level executives’ compensation. The variable compensation components are linked to several ESG targets, including the volumes of sustainable financing and ESG investments, reducing the power consumption in our own buildings, and a ESG rating index. 5.3 Policies and due diligence processes Does your bank have policies in place that address environmental and social risks within your portfolio?13 Please describe. Please describe what due diligence processes your bank has installed to identify and manage environmental and social risks associated with your portfolio. This can include aspects such as identification of significant/salient risks, environmental and social risks mitigation and definition of action plans, monitoring and reporting on risks and any existing grievance mechanism, as well as the governance structures you have in place to oversee these risks. Response Links and references Deutsche Bank’s environmental and social due diligence provisions are an integral part of Non-Financial Report 2022: the bank’s Reputational Risk Framework. The environmental and social due diligence Environmental and social due provisions consist of cross-sectoral and sector-specific requirements outlined in respective diligence/Environmental and guidelines and they jointly form the Deutsche Bank Environmental and Social Policy Social Policy Framework Framework. A summary of this Framework is publicly available. It applies to lending and trade finance activities of Corporate Bank and lending and capital market activities of Non-Financial Report 2022: Investment Bank as well as to Private Bank’s commercial lending activities. It defines rules Human rights and responsibilities for risk identification, assessment, and decision-making, describes how y companies with a controversial to conduct deal independent risk screening and to identif ES profile, and specifies the requirements for ES due diligence. Deutsche Bank focusses its attention on sectors that it has defined as sensitive and familiarizes its employees with the criteria for the mandatory referral of risks to the bank’s Group Sustainability function. Employees have access to detailed sector-specific guidelines for all sectors requiring mandatory referral to Group Sustainability. ES issues deemed to pose at least a moderate reputational risk are subject to the reputational risk assessment process as well. In order to identify, prevent and mitigate adverse human rights impacts, the bank has integrated human rights considerations in its environmental and social due diligence process, e.g., land rights and cultural heritage, labor and child rights, health and safety of workers and communities, and the rights of indigenous people. 13 Applicable examples of types of policies are: exclusion policies for certain sectors/activities; zero-deforestation policies; zero-tolerance policies; gender-related policies; social due diligence policies; stakeholder engagement policies; whistle-blower policies etc., or any applicable national guidelines related to social risks. 169
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