Deutsche Bank Governance and operations Non-Financial Report 2022 Anti-financial crime Deutsche Bank’s most critical asset against financial crime risks are its employees. Deutsche Bank promotes a risk culture that encourages employees to speak-up and a thorough awareness for financial crime risks. Deutsche Bank has carefully nurtured a culture of compliance and integrity in the bank, including the fight against financial crime. Tone from the top is extremely important and senior management is highly committed to drive cultural change through behavioral changes and reinforcing the change. Culture initiatives are driven both on group and divisional level across Deutsche Bank and a culture review framework is in place to identify areas that may be exhibiting poor culture to act through targeted culture reviews. Special focus is put on speak-up, which is subject of wide-ranging training efforts and communication campaigns. Regular (at least annual) training for all employees is conducted covering all financial crime risks and testing their policy knowledge. There is a mandatory curriculum accompanied by other additional facultative training offerings. The training modules highlight the importance of identifying financial crime risks and raising concerns or suspicions including the use of the anonymous whistle-blower hotline. Modules articulate personal, professional, financial, regulatory, and societal consequences of failing to manage financial crime risks. A completion rate of 99,96% has been achieved for the learners required to complete the mandatory anti-financial crime training by year end 2022. Learners who have not completed the training within the final due date are reported to the Compliance red flag team for investigation and may receive a red flag, if eligible. Management Board members receive ongoing periodic online training about financial crime topics as well as in-person tailored training and briefings on topics such as the risks of cryptocurrency. (*) which Deutsche Bank discloses ESG related reports and events under its Investor Relations website ESG – Deutsche Bank includes both certifications and documentations and discloses on AML, Know Your Customer (KYC) and the U.S. Patriot Act KYC/AML/Patriot Act – Deutsche Bank (*). 88
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