Deutsche Bank Governance and operations Non-Financial Report 2022 Product responsibility Each business division must have measures in place to identify and manage conflicts appropriately, including a Conflicts of Interest Register, which lists conflicts of interest that have arisen or may arise within the division. The maintenance of this register falls within the remit of an oversight body consisting of senior representatives of the division’s management who receive input from Compliance. Beyond the business divisions, the bank has numerous control functions that directly or indirectly manage conflicts of interest. For example, the Business Selection and Conflicts Office is responsible primarily for managing transaction-related conflicts and reports to the Management Board at least once a year. In addition, the bank’s Employee Compliance program is designed to check whether employees’ personal transactions are conducted in line with regulatory requirements and are not harmful to clients or the market. Further, the bank’s Compliance Control Room team support the management of conflicts by recording the flow of inside information and insiders. 95
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