Deutsche Bank Transition toward a sustainable and climate-neutral economy Non-Financial Report 2022 Environmental and social due diligence The enhanced environmental and social due diligence requirements address sectoral issues as well as cross-sectoral issues like biodiversity or social issues. The bank reviews the scope of sectors as well as related due diligence requirements on a best effort basis. It also observes prevailing sector-related environmental and social standards and industry best practices in order to improve understanding of environmental and social issues and, if necessary, adjust its approach. The bank’s assessment also takes into account developments in this area, such as climate protection and the respect of human rights. Main positions and minimum standards of environmental and social due diligence1 Enhanced due diligence/norm 2 Area compliance Environmental and/or social principles applied Cross-sectoral Human rights Yes No engagement in business activities where the bank has substantiated evidence of material 3 adverse human rights impacts without appropriate mitigation, e.g., child and forced labor Deforestation Yes No direct involvement in deforestation of primary tropical forests World Heritage Sites Yes No activity within or in close proximity to World Heritage Sites, unless the respective government and UNESCO agree that such activity will not adversely affect the site’s outstanding universal value Sectoral Industrial agriculture and forestry Yes Soft commodities (soy, beef, timber): expectations regarding membership in certification as well as environmental and social management schemes for growers and primary processers, including public commitment to the “No Deforestation, no peat, no exploitation” standards New development of related lands is only permissible if a High Conservation Value assessment determines that the land is not High Conservation Value Palm oil Yes Minimum requirement of a time-bound implementation plan for Roundtable on Sustainable Palm Oil-certification by 2025 at the latest Metals and mining Yes Enhanced environmental and social due diligence requirements; potential exclusions based on outcome Oil and gas Yes Oil sands: no financing of new projects involving exploration, production and transport/processing Arctic region (as demarcated by the 10° C July Isotherm boundary): no financing of new oil and gas projects Oil and gas extracted by means of hydraulic fracturing: no financing of projects in countries with ‘extremely high’ water stress Coal power and mining Yes No financing of new coal power plants and new thermal coal mining projects or associated infrastructure No financing of thermal coal mining from 2025 onward for clients in scope of the policy Exclusions for financing mountaintop removal mining Hydropower Yes Enhanced environmental and social due diligence requirements; potential exclusions based on outcome Nuclear energy Yes Enhanced environmental and social due diligence requirements; potential exclusions based on outcome and exclusion for certain jurisdictions Tobacco Yes Enhanced due diligence requirements with a focus on e-cigarettes and cannabis; potential exclusions based on outcome Defense/controversial weapons Yes Enhanced due diligence requirements with exclusions including controversial weapons, conflict countries, private military security companies, as well as civilian use automatic and semi- automatic firearms and human-out-of-the-loop weapon systems Adult entertainment Yes Enhanced due diligence requirements; exclusion of any business directly associated with adult entertainment (commercial enterprises related to the sale or purchase of sex-related services, ranging from individual workers in prostitution to the pornographic entertainment industry), associated branded products or services or prostitution Gaming Industry Yes Enhanced due diligence required; exclusion of online gambling Business-to-Consumer operators with exposure to markets where gambling is prohibited 1 The detailed requirements are laid out in Deutsche Bank’s Environmental and Social Policy Framework, except for Tobacco, Defense, Adult entertainment and Gaming which are covered by the relevant Reputational Risk documents 2 In addition to the cross-sector and sector-specific principles described above, Deutsche Bank’s enhanced environmental and social due diligence process includes, but is not limited to, the following reviews: compliance with existing environmental and social laws and regulations; existence of robust governance structures and sufficient capacity for managing ES issues 3 For further details, please also see the “Human Rights” below as well as Deutsche Bank’s Statement on Human Rights (*) Commitments, targets, and measures GRI 3-3, FS3 Deutsche Bank strives to manage all types of risk as effectively and efficiently as possible. This involves properly identifying transactions and/or clients that pose potential environmental and social risks, particularly in sectors with elevated environmental and social risk as internally defined and conducting robust due diligence. The bank also works to continually improve its environmental and social performance, in particular by verifying the effectiveness of its processes and guidelines and, if necessary, amending them, and by providing training to all relevant employees to reinforce their awareness and focus. The Group Sustainability function within the Chief Sustainability Office is responsible for designing standards and policies for environmental and social due diligence and sustainable finance and for overseeing business adherence to these. Headquartered in Frankfurt, Germany, the team expanded its regional presence to UK and Asia-Pacific in 2022. The bank also increased the number of environmental and social specialists in its business units. 54
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