Deutsche Bank Transition toward a sustainable and climate-neutral economy Non-Financial Report 2022 Human rights Meeting the requirements of the German Supply Chain Due Diligence Act, Deutsche Bank further enhanced and strengthened its procurement related human rights management processes. Based on a respective risk analysis, the bank adopted a risk management system targeted at minimizing human rights adverse impacts across its supply chain. In addition to the above requirements with regards to the submission of an external ESG rating, the bank enhanced preventive measures, including vendor due diligence, contract clauses according to vendors’ risk profile and standardized processes for remedial action in case of actual human rights incidents in the bank’s supply chain. The process for remedial actions is triggered by a variety of observations: incidents being flagged in Deutsche Bank’s risk review cycles, reported incidents through internal and external complaints channels, incidents being identified in adverse media monitoring and allegations directly reported to Deutsche Bank, e.g., by NGOs or media. In such cases, the incidents will be further investigated and appropriate measures to remedy the adverse effects will be agreed with the vendor and monitored over time. The brand DWS is not covered by the management approach related to the German Supply Chain Due Diligence Act described in this section. Employees GRI 3-3, FS4 Deutsche Bank aims to be an ‘employer of choice’ for existing and future employees. The bank strives to create a workplace that is both diverse and supportive and which is always welcoming of different views. The bank encourages high standards of conduct and work performance and is committed to providing a working environment free from harassment, discrimination and retaliation. Given the activities it undertakes and the geographies in which it operates, Deutsche Bank’s own operations have only limited exposure to adverse impacts from human rights violations. The bank aims to continue to monitor the safeguarding of human rights using a risk-based approach and focusing on those geographies where human rights issues are most likely to occur and where the bank has a material presence. Deutsche Bank is guided by the International Labour Organization Declaration on Fundamental Principles and Rights at Work as well as applicable labor laws in the different jurisdictions in which it operates. This includes sovereign state legislation on collective agreements, bargaining and freedom of association. In countries where internationally recognized standards may not be fully implemented, the bank aims to honor the principles of internationally recognized human rights. The bank expects all employees to understand their responsibilities and to act in accordance with its policies, procedures, and initiatives regarding human rights. The bank reinforces this awareness through bank-wide training. For example, 86.8% of employees completed trainings on compliance and ethics that also include aspects of human rights in 2022 (2021 excluding Postbank: 93.3%). The bank investigated all employee grievances reported to the integrity hotline in 2022. If violations were identified, they were reported to the appropriate functions, and the necessary steps were taken. 60
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