Deutsche Bank Governance and operations Non-Financial Report 2022 Public policy and regulation In addition, Deutsche Bank has a global policy in place to ensure that its communications with supervisory authorities are consistent. Regarding engagements in political dialogue, all employees must adhere to the bank’s global Anti-Bribery and Corruption Policy. This policy lays out rules for the offering and acceptance of gifts by Deutsche Bank employees, employees’ participation in events organized by third parties, and the associated record keeping. Financial transparency GRI 415-1 (*), which requires it to comply with the register’s code of conduct The bank is a signatory to the EU Transparency Register and to disclose an estimation of expenditures for advocacy toward EU institutions. In 2022, the bank had three employees (full time equivalent) focused on political engagement in the EU. Annual estimated costs related to activities covered by the Register were € 1,750,000 to € 1,999,999. These costs consisted of, among other things, expenses for the bank‘s Brussels offices, including staff there as well as staff outside of Brussels and a percentage of membership fees in associations active at the EU level. In addition, Deutsche Bank is a signatory to the Federal German Lobbying Register, which requires to comply with a code of conduct and to disclose, among others, an estimation of expenditures for advocacy toward the Federal German Government and German Parliament. Annual estimated costs, based on the provision of law and related to activities covered by the Register, were € 3,570,001 to € 3,580,000. In addition, Deutsche Bank is also reported in the respective Lobbying Registers in the States of Bavaria and Baden-Württemberg. Those registers improve the transparency of Deutsche Bank’s political engagement in Germany. Group policy does not permit donations to political parties GRI 2-23, FS1 Pursuant to the bank’s Group Policy on Donations, Memberships & Sponsorships, the Group does not permit direct or indirect donations to political parties. The bank’s Anti-Bribery and Corruption function must pre-approve donations to organizations affiliated with political parties or activities relating to governments and/or political parties. Employees who are U.S. Citizens or green card holders living in the United States may make voluntary donations to the Deutsche Bank Americas’ Political Action Committee (PAC). The PAC is regulated by the U.S. Federal Election Commission; the PAC makes monthly public filings to the Federal Election Commission as required by law. Corporate contributions to federal elections are prohibited. U.S. law therefore prohibits contributions by the bank to the PAC, although the bank may pay the PAC’s administrative costs. Memberships in trade associations GRI 2-28, 415-1 Deutsche Bank is a member of a number of trade associations globally. Deutsche Bank engages with trade associations and brings in inhouse experts into their relevant working groups, supports their work on consultation processes and filters back feedback on their positions where Deutsche Bank considers this relevant or can leverage inhouse expertise. The Chief Executive Officer Christian Sewing is president of the Associations of German Banks (Bundesverband deutscher Banken, BdB) and designated president of the European Banking Federation (EBF – starting March 2023), he has highlighted the relevance of the banking sector to shape the transformation to a digital and sustainable economy. 82