Deutsche Bank Governance and operations Non-Financial Report 2022 Culture, integrity and conduct Financial Crime Risk Management has been a focus for the culture, integrity and conduct during 2022, whereby the bank designed, delivered and completed a cross-divisional Financial Crime Risk Management & Culture program, which delivered a global financial crime risk education and culture strategy for use across all divisions, with stakeholders from across all three Lines of Defense brought together to collectively oversee, coordinate, and drive financial crime risk education under a consistent bank-wide strategy. This strategy included – The establishment of a Global Financial Crime Risk Education Working Group, implementation of cross-divisional minimum standards – Annual cross-divisional financial crime risk training needs analysis across six key areas of financial crime risk which supported the creation and implementation of financial crime risk education plans Another key initiative overseen by the Culture, Integrity and Conduct program in 2022 is the supervision and culture read across (in response to an operational incident) to assess potential related enhancements to the supervisory framework, control framework and overall culture. The read-across exercise noted a number of themes which were taken forward for development and implementation and included – Enhanced communications around lessons learned for sensitive investigations (providing guidance on how tailored scenarios and discussion content can be prepared and shared with impacted employees without compromising the confidentiality requirements of the investigation) – A comprehensive, scenario-based training exercise designed and rolled out to all supervisors within the impacted divisions – A Culture Review Framework which seeks to identify areas of the organization that may be exhibiting poor or negative culture, with the aim to making relevant recommendations for enhancement 80