Deutsche Bank Governance and operations Non-Financial Report 2022 Culture, integrity and conduct The Committee creates a central plan annually for promoting ethical culture at the bank, including company-wide communications plans and Human Resources programs. In addition, the bank’s divisions and infrastructure functions develop and implement their own culture plans and are responsible for promoting ethical culture in each of their respective units. These plans incorporate mandatory initiatives defined by the Committee as well as the divisions’ and infrastructure functions’ own initiatives to address their key individual requirements. The Committee oversees the Culture, Integrity and Conduct program as well as the divisions’ and functions’ efforts to promote ethical culture. The divisions and functions set their own milestones and timelines and report them to the Committee annually. In addition, they provide the Committee with quarterly updates on the implementation of their plans and must submit evidence of progress to ensure that the plans are on track with the timeline of the Culture, Integrity and Conduct program. On a quarterly basis, the Committee reviews and evaluates 26 key culture-related metrics across the bank, such as employee complaints, analysis of employees’ adherence to certain risk-related policies and procedures, results of investigations (Human Resources, Group Audit and Anti-financial Crime). In addition, it assesses information gleaned from surveys and input from business leaders in order to identify key culture and conduct focus areas. The Committee also produces an annual Global Report which evaluates what the Committee has accomplished and how it can effectively work to further improve ethical culture in the following year (the Culture, Integrity and Conduct book of work). The divisions produce their own Culture, Integrity and Conduct Divisional Reports which are tailored to their specific profiles and are drawn on for the Global Report. The annual People Survey asks employees for feedback to gauge how they experience working for the bank and measure progress on key aspects of its culture, including key indicators such as commitment and enablement. In 2022 the survey included eleven questions to provide insights into how employees experience ethics, conduct and the Speak-Up Culture at the bank and seven questions about raising concerns. Results showed that people continue to experience an environment that lives up to the bank's standards with the vast majority feeling able to express themselves. The results demonstrated that compared to the previous years, more people feel able to raise concerns and know how to do so. More information on the People Survey can be found in the section on “Employee Feedback Culture”. Key topics and initiatives in 2022 GRI 2-26, 404-2 Deutsche Bank’s long-term aim is to foster a sustainable performance culture in which all employees and managers feel empowered and can realize their potential. In 2022, the Culture, Integrity and Conduct program continued to focus on Purpose, Trust and Accountability. With a focus on trust, the bank built upon the Speak-Up activities and expanded their reach and scope beyond raising concerns to empowerment and purpose. This revised Speak-Up message supports the bank’s focus on accountability by enhancing the supervision culture, and as such supports the continued evolution of the Culture, Integrity and Conduct agenda. Commencing in 2022 all new managers are now automatically enrolled onto the two-and-a-half-hour virtual classroom course on Speak-Up. The Culture, Integrity and Conduct program has undertaken a number of initiatives during 2022 to achieve its aim, and continues to conduct ongoing company-wide and divisional specific communications initiatives on the focus areas (trust, accountability and purpose), which are integral to the bank’s efforts to cultivate an environment where employees feel safe, included, productive and comfortable getting involved and proposing innovations. In 2022 over 500 messages relating to culture, integrity and conduct related topics were launched, with topics including: – Fostering the bank’s Speak-Up Culture, particularly regarding potential misconduct such as the use of unauthorized communication channels – Regular engagement by management with their staff about topics related to culture, integrity and conduct Further, the Culture, Integrity and Conduct program provides the bank’s divisions and functions with toolkits to help bring these topics to life, e.g., the Leadership Kompass Manager Guide, Unconscious Bias toolkit and Everyday Inclusion trainings. Human Resources continues to enhance the Consequence Management framework for large-scale, long-running and complex investigations. In order to support the bank’s view that consistent and transparent outcomes will enhance employee compliance as well as corporate culture and work environment, in which work has been undertaken to consolidate the Managing Performance & Developing Careers policy with the Compensation & Benefits Policy and Framework along with Consequence Management to provide a single stop source for employees and managers to refer to; the document is planned to be published in the second quarter of 2023 as part of a Performance Consequences and Reward Policy. 79