Deutsche Bank Governance and operations Non-Financial Report 2022 Anti-financial crime Anti-financial crime – Preventing, deterring, detecting and reporting financial crime – Maintaining a regular dialogue with supervisory control functions – Continuing to increase investments in financial crime controls Vision and mission GRI 2-12/23/24, 3-3 Financial crime has a detrimental impact on society and can have severe consequences for individuals. Organized crime engages in fraud, bribery, corruption, money laundering, terrorist financing as well as human, drug and arms trafficking. The outcome harms individuals, institutions, and the integrity of the financial system. Criminals use complex schemes including targeted placement and layering across different borders in their attempt to integrate the proceeds of their crimes back into the global financial system. Deutsche Bank is targeted directly by criminal organizations who want to exploit the bank’s global financial products and services to support their illegal activities. Effective anti-financial crime controls are critical components of Deutsche Bank’s strategy to prevent, detect, and report these illegal activities. This includes in-depth knowledge about Deutsche Bank’s customers, their source of funds, and their source of wealth. If criminals find a way around these control measures, individuals or institutions can be harmed and Deutsche Bank can suffer reputational damage as well as severe financial penalties. Fighting financial crime is an integral part of the bank’s business activities and continuous improvements to the Group’s capabilities in fighting financial crime are a critical priority. The Management Board, and all employees, are required to adhere to the highest standards of conduct to fight financial crime. Every employee is responsible for the management of financial crime risk. This includes: (i) The prevention of financial crime by observing obligations, policies and procedures. All financial crime risk policies are available in a dedicated policy portal, reviewed annually and changes are communicated to all employees. Familiarity is reinforced through mandatory training and failure to comply can lead to disciplinary action. (ii) The detection of unusual or suspicious behavior or patterns including the use of transaction monitoring systems which generate alerts that are reviewed by dedicated and trained teams of employees and (iii) The reporting of customers, third parties and/or transactions that appear unusual. Governance GRI 2-9/12/13/24, 3-3 The ultimate decision and authority regarding financial crime risks lies with the Group Anti-Money Laundering Officer, who is, at the same time, the Head of Deutsche Bank’s Anti-Financial Crime function (AFC) and reports to the Chief Administration Officer. The Group Anti-Money Laundering Officer is a delegated authority from the Management Board authorized to establish a financial crime risk management framework and take any measures necessary to manage financial crime risks appropriately and in consideration of applicable legal requirements. AFC acts as an independent function, setting policies and standards for the management and mitigation of financial crime risks at Deutsche Bank. Deutsche Bank’s business divisions are responsible and accountable for the implementation and operationalization of these policies and standards. The Management Board ensures that AFC can execute its tasks independently and effectively. The Supervisory Board of Deutsche Bank is informed about the status of financial crime risk management on a regular basis by the Management Board and the Group Anti-Money Laundering Officer according to German law. For example, the Group Anti-Money Laundering Officer and the responsible Management Board member provided quarterly updates to the Supervisory Board’s Audit Committee. The Supervisory Board and Management Board execute strong engagement and tone from the top with focus on compliance and financial crime risk matters in key committees. The Supervisory Board is well staffed and equipped to oversee the bank’s efforts in this regard. Since 2020, the Supervisory Board has set-up a dedicated Financial Crime Risk Working Group to conduct additional monitoring and to provide holistic advice to the Management Board for the purpose of remedying shortcomings in the Anti-Money Laundering function. In 2022, the Regulatory Oversight Committee has been established, which is mandated to provide central oversight across regulatory engagement and remediation across the bank. 85