Deutsche Bank Transition toward a sustainable and climate-neutral economy Non-Financial Report 2022 Climate risk The minutes of the meetings of the delegated sub-committees are shared with the members of the GRC Group Risk Committee when they become available. The minutes of the Group Risk Committee are shared with the Management Board when final. An ESG Risk Forum, comprised of experts across all key risk types and other control functions, oversees the integration of climate risk into the bank’s existing risk frameworks for managing financial and non-financial risks. ESG topics are also regularly discussed in business unit risk councils and other committees and fora. Information around the committees in the organization chart that are not covered in this section can be found in the governance section of the chapter “Sustainability Strategy”. Deutsche Bank has incorporated environmental, social and governance risks into the group’s risk taxonomy and adopted a Climate and Environmental Risk Policy at group level outlining roles, responsibilities as well as qualitative risk appetite principles and quantitative risk-appetite metrics. Training and risk awareness sessions on climate risk were held throughout the year. The sessions were available to Risk Management staff and senior leadership teams around the globe, on topics such as the bank’s net zero targets, sustainable Finance, ESG fundamentals and regulatory landscapes, ESG and the role of compliance, and others. Compliance is a part of the overall Governance around Sustainability and ESG risks described above and is represented in the Risk, Governance & Controls workstream (under the Sustainability Strategy Steering Committee) and in the ESG Risk Forum. Compliance has also set up a global ESG working group with representation from all relevant areas of the function and other 2nd Line of Defense functions such as NFRM and Legal. The working group provides a platform to exchange knowledge and discuss topical aspects of ESG. It carries out activities such as changes to policies, design and delivery of ESG-specific trainings, changes to the compliance annual risk assessment, reporting to the Compliance Executive Committee and to the management board as part of the annual compliance report to the management board. The working group also assesses further need for change in the mandate and set-up of the Compliance function to meet statutory requirements and regulatory expectations on an ongoing basis and advises the Compliance Executive Committee on those. In 2022 the Compliance ESG working group conducted a review of the entire Compliance-owned policy portfolio, with amendments being implemented ad-hoc or as part of the annual policy review. The Compliance Risk Type Policy was supplemented with several additional risk scenarios addressing ESG risks. A two-module training on ESG and the related tasks for compliance officers was delivered to a global audience. ESG risks formed an integral part of the Compliance annual risk assessment in 2022 and compliance officers participated in the risk and control assessments with a focus on ESG. Regarding the 3rd Line of Defense, Deutsche Bank’s Internal Audit function (Group Audit) provides independent and objective assurance to the Management Board of Deutsche Bank AG and its group companies on the adequacy of the design, operating effectiveness and efficiency of the bank’s risk management system which includes climate and environmental risks. Group Audit also acts as an independent, proactive and forward-looking challenger and adviser to Senior Management of the Group. 39
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