Deutsche Bank Transition toward a sustainable and climate-neutral economy Non-Financial Report 2022 Human rights The Anti-Financial Crime human rights working group, which is part of the above-described bank-wide Human Rights Forum, was established in 2021 to develop and pursue concrete measures and initiatives within the Anti-Financial Crime function to fight modern slavery and human trafficking. As a practical example of the progress made in 2022, modern slavery and human trafficking related key risk drivers were incorporated within Deutsche Bank’s Non-Financial Risk Taxonomy. This is going to further support the enhancement of Deutsche Bank’s control framework. Independent of the working group the Anti-Financial Crime department pro-actively contributed to initiatives within several Public Private Partnerships. Deutsche Bank is currently leading the workstream “Financial Flows of Human Trafficking” within the German Public Privat Partnership Anti-Financial Crime Alliance (AFCA) and is part of a taskforce covering among other topics human trafficking in the Europol Financial Intelligence Public Private Partnership (EFIPPP). In October 2022 the bank hosted an event organized by the Finance Against Slavery and Trafficking (FAST) initiative. To reinforce employees’ awareness of activities linked to potential human rights violations the bank conducts periodic trainings. One specific example is a 45-minute mandatory online course on anti-money laundering (AML) and the prevention of terrorist and proliferation financing - topics that have potential connections to human rights violation. Every Deutsche Bank employee worldwide must complete the module once every year. Around 99% of staff (including in-scope contingent workers) did so in 2022. Mandatory Risk Awareness training is also deployed to all staff every other year. This online training now includes a specific case on modern slavery in the private banking business and includes a question for learners on typical risk indicators. This updated course was launched in the fourth quarter of 2022 to English speaking staff and is going to be rolled out as translated versions in non-English speaking locations at the beginning of the second quarter 2023. Supply chain GRI 2-6/25, 3-3 The products and services that Deutsche Bank buys, who it buys from, and how it consumes has a significant influence on its sustainability footprint. For this reason, sourcing and procurement activities play a key role in the bank’s ambitions to respect and improve human rights. While the divisions are accountable for the suppliers they use, the Global Procurement function leads on the vast majority of sourcing and procurement decisions. In support of this, globally consistent processes and procedures are in place to govern the sourcing and procurement of goods and services, onboarding of suppliers and the ongoing management of supplier performance. Suppliers are required to meet a range of requirements including financial health, anti-fraud and corruption, and compliance checks to engage with Deutsche Bank. Supplier Code of Conduct The intention of the Supplier Code of Conduct (“Code”) is that suppliers understand the core values and standards of behavior that Deutsche Bank expects its suppliers to conform to when providing goods and services. The Code is acknowledged by the supplier responding to a request for proposal and on starting an engagement with Deutsche Bank, suppliers are expected to provide a copy of this Code to its personnel who will be involved in the supply of the goods and services. The Code contains sections on Compliance with Law, Human Rights, Diversity and Inclusion, Sustainability, and Corporate (*). Social Responsibility. The Code is available on Deutsche Bank’s public supplier portal Screening of the bank’s vendors for adequate social and environmental standards The bank undertakes the assessment of prospective vendors’ environmental and social standards starting with a questionnaire analyzing the significance of potential social or environmental impacts related to a vendor’s service delivery. Conditional on the results of this analysis, the vendor risk management process may further scrutinize the potential for sustainability risks. For vendors, with which Deutsche Bank spend more than € 500,000 annually vendor balanced scorecards were launched. These scorecards evaluate vendors across a holistic set of key performance indicators. This evaluation includes a sustainability performance indicator which is either the rating score provided by EcoVadis or the vendor can use an equivalent reputable sustainability rating agency. From July 2022, the prerequisite for every new or prolonged contract worth more than € 500,000 a year is that the vendor has an external sustainability rating from EcoVadis or other rating agencies (*). To that end, the bank maintains a registration website (*) where vendors can obtain relevant information and start their assessments with the sustainability rating agency, EcoVadis. 59