Deutsche Bank Transition toward a sustainable and climate-neutral economy Non-Financial Report 2022 Environmental and social due diligence The Reputational Risk Framework stipulates that certain matters, including those with a potential negative ES impact and those matters linked to the defense or gaming industry, must be reviewed by subject matter experts. These matters are discussed in more detail in the sections below. Environmental and Social Policy Framework GRI 2-23/24/25/27, 3-3, FS1, FS3 Deutsche Bank’s environmental and social due diligence provisions are an integral part of the bank’s Reputational Risk Framework. The environmental and social due diligence provisions consist of cross-sectoral and sector-specific requirements outlined in respective guidelines and they jointly form the Deutsche Bank Environmental and Social Policy Framework. A summary of this Framework (*) is publicly available and was approved by the Group Reputational Risk Committee. The Framework applies to lending and trade finance activities of Corporate Bank and lending and capital market activities of Investment Bank as well as to Private Bank’s commercial lending activities. It does not apply to DWS as DWS operates as a separate legal entity that sets its own sustainability strategy. The Environmental and Social Policy Framework defines rules and responsibilities for risk identification, assessment, and decision-making, and specifies the requirements for environmental and social due diligence. Deutsche Bank applies a risk- based approach and focusses its attention on sectors that it has defined as having an inherently elevated potential for negative environmental and social impacts, see below. The bank familiarizes its employees with the criteria for the mandatory referral of transactions and clients to the bank’s Group Sustainability function. Employees have access to detailed sector-specific guidelines for all sectors requiring mandatory referral to Group Sustainability. Environmental and social issues deemed to pose at least a moderate reputational risk are subject to the reputational risk assessment process as well. Deutsche Bank’s approach to environmental and social due diligence is guided by the following international standards and principles that include: – UN Global Compact – OECD Guidelines for Multinational Enterprises and associated Responsible Business Conduct standards for the financial sector – UN Guiding Principles on Business and Human Rights – International Finance Corporation Performance Standards – Equator Principles Deutsche Bank participates in a variety of initiatives and working groups to enhance its knowledge of existing and emerging issues and to inform its approach to environmental and social due diligence. In 2022, through its membership in the University of Cambridge Initiative for Sustainability Leadership’s Banking Environment Initiative (*), the bank continued to participate in the initiative’s activities around nature- and climate-related issues. For instance, in 2022, Deutsche Bank contributed to a capacity building workshop on assessing nature-related financial risks by presenting use cases related to the EU’s Farm to Fork Strategy and fertilizer companies. In addition, in 2022, Deutsche Bank partnered with German-based Mannheim Business School on a project focusing on biodiversity. A group of MBA students analyzed current biodiversity-related challenges and opportunities. They formulated recommendations for the further incorporation of biodiversity considerations into the bank’s environmental and social due diligence requirements. Deutsche Bank’s Environmental and Social Policy Framework has defined the following sectors and activities as having an inherently elevated potential for negative environmental and social impacts: – Metals and mining including thermal coal mining – Oil and gas – Utilities including thermal coal, hydro and nuclear power – Industrial agriculture and forestry – Chemicals – Industrials and infrastructure projects in certain countries – Other activities either with a high carbon intensity and/or potential for human rights infringements Other industries and sector-specific topics, such as the defense, gaming, and adult entertainment industry, which are inherently considered to carry an enhanced level of social and governance risk, and potentially environmental risk, are covered by the Reputational Risk Framework. Due to geopolitical developments in 2022, there was an increased focus on the defense sector while topical issues such as the digital asset and crypto currency sector as well as tobacco and cannabis were also discussed. Details on the Reputational Risk Framework are presented in the “Governance” section above, and specific due diligence requirements of the mentioned sectors are summarized in the table entitled “Main positions and minimum standards of the environmental and social due diligence” below. 53