Deutsche Bank Governance and operations Non-Financial Report 2022 Public policy and regulation Memberships in important trade associations in 2022 A selection Region Association of German Banks (Bundesverband deutscher Banken - BdB), including regional associations EU Association for Financial Markets in Europe (AFME) EU International Swaps and Derivatives Association, Inc (ISDA) EU German Derivative Association (Deutscher Derivate Verband - DDV) EU Association of German Pfandbrief Banks (Verband deutscher Pfandbriefbanken - VdP) EU UK Finance UK Institute of International Bankers (IIB) USA Council on Foreign Relations, Inc (CFR) USA Trade Association for the Emerging Markets (EMTA) USA American Bankers Association (ABA) USA National Automated Clearing House Association (NACH) USA Structured Finance Industry Group USA National Council of Real Estate USA Securities Industry and Financial Markets Association (SIFMA) USA Investment Company Institute (ICI) USA U.S. Chamber of Commerce (USCC) USA Institute of International Finance (IIF) USA National Association of Financial Market Institutional Investor China (NAFMII) APAC Asia Securities Industry & Financial Markets Association (ASIFMA) APAC International Bankers Association (IBA) APAC Japan Securities Dealers Association (JSDA) APAC Key topics in 2022 In 2022, Deutsche Bank convened and participated in seminars, public panels and held conversations with policymakers on the digitalization of banking and society, the EU Banking Union and the Capital Markets Union’s progress, the implementation of the final Basel III rules, the review of the EU macroprudential framework, the MiFID review, clearing, and the European Commission’s sustainable finance agenda. On each of these issues the bank also submitted written input, for instance, in public consultations. On the implementation of the final Basel III rules, in the EU, the implementation is through amendments to the EU prudential framework (Capital Requirements Regulation and Directive: CRR/CRD). The European Commission issued proposals in October 2021, which are currently debated by Member States (Council) and European Parliament. The proposals change the way banks calculate their Risk-Weighted Assets and restrict the use of internal models for all types of risk. They also cover other topics, such as suitability assessment for certain bank managers. The bank is convening and participating in meetings with policymakers related to this file. The final Basel III rules will also be implemented in other jurisdictions, with the UK launched this process in November 2022 and U.S. is expected to follow soon. In 2022, legislation related to sustainable finance also played a role in the bank’s engagement with political stakeholders and contributions to trade associations regarding these topics. The further development of the EU Taxonomy was an important aspect. In this context, the Commission’s proposal for a voluntary European Green Bond Standard which aligns projects financed to the rules of the EU Taxonomy is currently under negotiations in Brussels. The Corporate Sustainability Reporting Directive (CSRD) was finalized in 2022 and will apply for Deutsche Bank for the full year reporting 2024. Another important development was the publication of the draft proposal for a Corporate Sustainability Due Diligence Directive (CSDDD) in February. The CSDDD among other aspects establishes due diligence obligations for corporates to avoid and mitigate human rights and environmental risks in companies’ value chains. In Germany corporates prepared for the implementation of the German Supply Chain Due Diligence Act which became applicable on 1 January 2023. In June 2022, the new term of the German Sustainable Finance Advisory Committee started. It supports the German federal government in developing Germany into a leading location for sustainable finance in line with the guiding principle of financial stability and sustainability. The Chief Financial Officer Investment Bank, Corporate Bank & ESG has been nominated again as a member of the Committee. Deutsche Bank sent a delegation to attend the 2022 UN climate conference. The bank’s sustainability experts engaged on sustainability issues at COP27, which was held in Sharm El Sheikh, Egypt. U.S. regulators continued to focus on climate-related initiatives and policies within their existing remits in 2022. Notable developments include, in March 2022, the Securities and Exchange Commission released their anticipated proposal on climate disclosures for public companies which would require certain climate-related information (including scope 1, 2 and 3 emissions) to be included within a company’s annual filings. This also may affect Deutsche Bank’s Group reporting, as the bank’s share is listed at the New York Stock Exchange. Depending on the circumstances, these reporting requirements may not be aligned to corporate reporting requirements stemming from EU regulation. 83
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