Deutsche Bank Transition toward a sustainable and climate-neutral economy Non-Financial Report 2022 Human rights Alongside the Human Rights Forum, the above-named functions established working groups to address function specific human rights issues, e.g., the Anti-Financial Crime human rights working group which is dedicated to combatting modern slavery and human trafficking in the clients’ business and on which further details are available below in the “Clients” section of this chapter. Meeting the requirements of the German Supply Chain Due Diligence Act, Deutsche Bank further enhanced and strengthened its procurement related human rights management processes. Further details can be found in the “Supply chain” section of this chapter. Deutsche Bank has processes and channels in place to evaluate the effectiveness of its management approach to human rights. The bank draws on insights from the integrity hotline to assess whether the management approach with regard to employees is effective or in need of further refinement. The bank evaluates effectiveness with regard to clients using a range of sources including transaction reviews for clients, in-house research, media reports, dialog with individual clients, and exchange on general trends and developments with peers. The approach to vendors is similar, consisting of information from the vendor screening process supplemented by in-house research, media reports, and discussions with peers. Further details on the bank’s stakeholder engagement may be found in the chapter “Stakeholder engagement and thought leadership”. Deutsche Bank’s human rights governance benefits from the exchange of ideas and experiences afforded by its membership in the Thun Group of Banks, which Deutsche Bank joined in 2012. In 2022, the bank continued to participate in the Thun Group’s meetings and activities relating to human rights in banking and, in particular, the United Nations Guiding Principles on Business and Human Rights. Key topics in 2022 Clients GRI 2-23/24/25/29, 3-3, 404-2, FS1, FS3, FS4, FS5 Human rights due diligence is integral to Deutsche Bank’s Environmental and Social Policy Framework. In order to identify, prevent and mitigate adverse human rights impacts, the bank has integrated human rights considerations in the environmental and social due diligence process, e.g., land rights and cultural heritage, labor and child rights, health and safety of workers and communities, and the rights of indigenous people. The chapter entitled “Environmental and social due diligence”, including the table “Main positions and minimum standards of environmental and social due diligence” therein, contains more information on the related process and the principles Deutsche Bank applies. While human rights due diligence is a cross-sectoral issue, some sectors and activities have an inherently higher risk of negatively impacting human rights. Thus, the Environmental and Social Policy Framework includes specific human rights- related expectations and requirements that apply to the sectors in scope of the Framework. Special attention will be paid to cases involving resettlement; cases where the bank identifies potential negative impacts on indigenous peoples; and cases where clients use security forces for site protection. If Deutsche Bank has concerns about a client with regards to human rights, it consults with relevant stakeholders. This might include direct engagement with the client as well as with civil society representatives that are familiar with the situation. Where appropriate, the bank obtains the advice of independent experts. Based on all available information and its assessment of the risks that have been identified, the bank decides on the further course of action, which may include termination of a business relationship. (*), which the bank officially adopted in 2020, further underscores its human The implementation of the Equator Principles rights risk assessments for eligible projects and its commitment to human rights preservation for transactions outside the scope of the Equator Principles. In 2022, the bank continued to conduct comprehensive trainings to ensure that relevant business areas have an in-depth understanding of the Equator Principles as well as the requirements for assessing the impacts on potential rights holders in the various projects that it finances. The bank-wide framework for the prevention of Financial Crime contributes to preventing, deterring and detecting client activities that might be linked to potential human rights violations. Being a global financial institution that provides a broad range of products and services exposes Deutsche Bank to diverse financial crime risks, including modern slavery and human trafficking. The Principles for the Management of Financial Crime Risks outline the responsibilities and accountabilities of the Anti-Financial Crime Function and of all employees at Deutsche Bank Group and describe the essential organizational requirements and relevant processes for the management of financial crime risks across the 1st and 2nd Line of Defense (‘LoD’). Global Anti-Financial Crime policies define minimum standards for managing financial crime risks, including those with implications for human rights. These bank-wide polices are supplemented by country-specific policies and procedures that reflect national laws and regulations. 58