Non-financial Report 2019

Non-Financial Report

2019

Deutsche Bank

Contents

3 Letter from the Chairman

of the Management Board

5 Introduction

6 About Deutsche Bank

7 About this report

8 Stakeholder engagement

9 Sustainability ratings and indices

10 Combined separate

non-nancial report

11 Legal basis

14 Culture and integrity

17 Client-related matters

18 Product responsibility

20 Client satisfaction

23 Sustainable nance

31 Organizational matters

32 Anti-nancial crime

37 Data protection

38 Information security

41 Public policy and regulation

44 Employee-related matters

45 Employment and employability

52 Key employee gures

53 Digital transformation

54 Digitization and innovation

57 GRI supplement

58 Approach to sustainability

61 Reputational risk

65 Human rights

67 Climate risk

71 Access and inclusion

72 Tax

73 In-house ecology

78 Corporate social responsibility

84 Art, culture and sports

85 Appendix

86 Reports of the independent auditor

90 GRI and UN GlobalCompact

103 Abbreviations

106 Imprint / publications

Letter from the

Chairman of the

Management Board

Dear Readers,

Sustainability is finally being given the status it deserves in economic life. We experience it in our day-to-day contact with our

clients and we sense it in our dialog with our investors: a bank such as ours is expected to be commercially successful, but

that alone is not enough. Our stakeholders – along with the general public – are focusing increasing attention on non-financial

objectives – and rightly so. Good governance as well as fulfilling our responsibility for the environment and to society as a

whole are essential for a global bank’s success. We see no contradiction between sustainability and profitable returns. Lasting

commercial success is only possible if we do business responsibly. Only then will we secure the necessary acceptance from

the societies in which we operate. That is why we have been committed to the Ten Principles of the United Nations Global

Compact for many years now. In September we signed up to the UN Principles for Responsible Banking as well.

This Non-Financial Report is a key element of our review of our performance in 2019. It delivers additional, valuable, and

above all, comparable information for the dialog and conversations about societal issues, covering an even broader range of

topics than in previous years. As transparent communication about non-financial matters is rapidly gaining importance, we

welcome that corporate reporting requirements are becoming more exacting as a whole.

The year 2019 was marked by our decision to implement the most fundamental transformation of our bank for 20 years. We

are focusing rigorously on our strengths, we have restructured our business units and set ambitious financial targets for the

period until 2022.

We have made a very good start to this transformation, as we detail in our Annual Report, but our transformation does not just

revolve around revenue, cost, and earnings targets. It is also about a fundamentally new way of working. We have therefore

set ourselves four non-financial objectives: we want our clients to always be at the center of what we do; we want to develop

a new form of leadership and become more entrepreneurial; we want to make better use of new technologies, and we aim to

operate more sustainably right across our business. I am convinced that making resolute progress in these areas is the only

way for us to also achieve long-term financial success.

If we want to work differently than we have previously then we must focus on our employees. Only if we offer attractive and

interesting prospects will we be able to continue winning the battle to recruit and retain the most talented people. Although

reducing our workforce is a regrettable but unavoidable part of our transformation, we are conducting this process responsibly.

At the same time, we are investing in our people worldwide, including in their training and continued professional development.

We are translating our support for diversity into action. We are committed to placing more women in leadership positions.

Although the share of women in senior positions has been increasing each year since 2010 and there are lots of support

programs, we are not satisfied with our progress in this area.

With our commitment to lesbian, gay, bisexual, transgender, queer, and intersex (LGBTQI) equality and inclusion, we believe

we are strong advocates for greater openness. Our Human Resources Report provides more detail on diversity at Deutsche

Bank.

We are also continuing to invest in strengthening our control environment, and above all in the area of anti-financial crime. We

have already made considerable progress and will continue resolutely on this path. In 2019, we spent some € 600 million on

protecting Deutsche Bank from non-financial risk, three times more than in 2013. We are beginning to see the benefits of

successfully combining our Anti-Financial Crime, Compliance and Risk functions under a single leadership team which we

announced in July – for example, through better workforce automation and more standardized risk frameworks.

We are also making progress with our digitalization initiatives. To ensure that we implement technology and digital solutions

far more extensively throughout the bank, we have created a Technology, Data and Innovation function that is represented

on the Management Board. With our new technology strategy, we are fundamentally changing the way we develop

technological solutions: we are bringing together businesses and technology experts in agile teams. We no longer rely as

much on external contractors, but are boosting internal hires to ensure that we have in-house expertise. We continue to

simplify our processes and make them more flexible by modernizing our IT infrastructure and preferring cloud solutions, where

these are feasible and make sense. In doing this, we will not make any compromises on data or IT security.

Our efforts over recent years have started paying off: we are regaining trust among our most important external stakeholders,

namely our clients, the regulatory authorities, investors and the media.

The results of this year's in-house People Survey also showed an improvement in internal sentiment. Our employees feel

more committed and rate their working environment more positively, while three out of four support our new strategy.

Another topic that is absolutely central to building trust in our bank is sustainability. We always want to consider the

environmental and social impact of our actions. This is not exclusively about environmental protection and the global climate,

although they are of course included. Our sustainability strategy is shaping our processes more and more markedly – be it

risk management, our own refinancing processes, or just providing the right incentives for our business divisions.

What does sustainability mean for Deutsche Bank in practice?

Sustainability has four dimensions that we are promoting through our Sustainability Council that I chair: we are reducing the

environmental footprint of our own business activities; we are broadening our business policies so that sustainability matters

are given better attention; and we seek to be a thought leader on political and societal matters. And above all we are assisting

our clients in making their own transformation to more sustainable business models – be they companies or investors. This

sustainable finance business is precisely where our focus is currently trained.

We see Deutsche Bank as being strategically well positioned. Our loan book of roughly € 430 billion is a key component in

this respect. Over the next few years we will increase the proportion we set aside for sustainable financing and use this to

structure green bonds and other investment products. In 2019, we were involved in ESG (Environmental, Social, and

Governance) bond issuance and placement for clients that amounted to over € 22 billion, two-and-a-half times as much as in

2018. And this year we plan to issue our first Deutsche Bank green bond and announce specific sustainability targets.

Across all of these activities we are determined to provide very specific and clear details. We are convinced that having a

rigorously prepared and feasible sustainability strategy will enable us to make the most effective contribution to the necessary

transformation of our bank and the economy.

We have traditionally delivered a strong positive impact with our corporate citizenship activities. We are proud to report that in

2019 some 1.6 million people were able to benefit from our initiatives. And last year nearly 19,000 colleagues worldwide

participated in our social projects, acting as mentors for young people or as advisors to social enterprises. In the year that

marks our 150th anniversary we are asking employees to spend at least 150 minutes of their working time – ideally longer –

volunteering for a specific social initiative.

We have made a good start to this anniversary year, and we have a clear sense of where we are going. Our mission is to be

a bank that our clients and investors can trust, a bank to rely on. And we want to be a bank where our employees are proud

and enthusiastic to work.

Best

regards,

Christian Sewing

Chief Executive Officer

Introduction

6 About Deutsche Bank

7 About this report

8 Stakeholder engagement

9 Sustainability ratings and indices

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

About Deutsche Bank

Founded in 1870, Deutsche Bank is Germany’s leading bank, with a strong position in Europe and a significant presence in

the Americas and Asia Pacific. For 150 years, Deutsche Bank has been connecting worlds to help people and businesses get

to where they want to be.

Our purpose

What inspired the founders of this bank still drives us now: we are here to enable economic growth and societal progress by

generating positive impact for our clients, our people, our investors, and our communities.

Our values

We expect all of our employees to apply our corporate values: integrity, sustainable performance, client centricity, innovation,

discipline, and partnership. Our Code of Conduct articulates what our bank stands for and what we want our overall culture to

be. We want to foster an environment that is open and diverse, where staff opinions and “speaking up” are valued and our

employees’ and the bank’s success is built on respect, collaboration, and teamwork.

Our business

Deutsche Bank provides commercial and investment banking, retail banking, transaction banking, and asset and wealth

management products and services to corporations, governments, institutional investors, small and medium-sized businesses,

and private individuals.

Our strategy

In July 2019, Deutsche Bank announced a fundamental transformation and a profound restructuring of its businesses. The

bank now consists of four strong, client-centered businesses. Alongside our Investment Bank, Private Bank (including Wealth

Management), and Asset Management, we established a fourth division, the Corporate Bank, which comprises the former

Transaction Bank and German commercial banking business. As part of the restructuring process, we are withdrawing from

businesses in areas where we do not have a leading position and are allocating capital to businesses that show higher

earnings and growth. To this end, we have reorganized assets from non-strategic businesses into a separate unit, called the

Capital Release Unit. We will only refer to this unit if there is a direct link to the respective topic in this report.

The changes do not only affect our business model; we will also strive to change the way our employees work. Our declared

goal is to transform Deutsche Bank into an organization that is inspired by our clients and continuously designed by our

employees. We are therefore focusing on four levers that will help us to achieve our ambitions: client centricity,

entrepreneurship, technology-led, and sustainability.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

About this report

GRI 102-49/52

This Non-Financial Report 2019, covering developments from January 1, 2019 to December 31, 2019, communicates

Deutsche Bank’s group-wide management approaches for a determined set of non-financial topics, major activities, and

progress made in 2019, as well as describes our governance, policies, and structures.

The reporting content complies with § 315c (1) of the German Commercial Code (Handelsgesetzbuch, HGB) in conjunction

with § 289c (2) HGB and is aligned to the Global Reporting Initiative (GRI). In this respect, this report has been compiled in

accordance with the GRI Sustainability Reporting Standards: Core option. It also serves as our Communication on Progress

for the UN Global Compact (see GRI index and UN Global Compact). All information contained in this report is subject to

independent assurance (see “Reports of the independent auditor”). References to information outside the Deutsche Bank

Group Management Report do not form part of the Non-Financial Report and the independent assurance.

While we merged the legal entities Deutsche Postbank AG (Postbank) and Deutsche Bank Privat- und Geschäftskunden AG

into DB Privat- und Firmenkundenbank AG in the previous reporting year, the integration process has not yet been fully

completed. As a result, some Postbank-related content is still presented separately in this report, while other information is no

longer explicitly disclosed for Postbank. Irrespective of the merger of the legal entity, Postbank continues to be present in the

market as a key brand of our Private Bank.

Deutsche Bank AG’s approach to non-financial topics is in line with the group-wide principles. As the parent company,

Deutsche Bank AG’s approach to sustainability includes our affiliated entities.

This Non-Financial Report 2019 is also available in German. The report is disclosed annually. The next report will be published

in March 2021.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Stakeholder engagement

GRI 102-12/21/40/42/43/44, G4 DMA

We value an ongoing dialog with our stakeholders, helping us to understand the expectations and concerns of various groups,

and to recognize the positive and potentially negative impact of our business activities. We have clearly defined responsibilities

for each stakeholder group, and use various formats, including bilateral conversations with individuals or groups, as well as

exchanges in the context of meetings, events, forums or working groups. We also regularly release publications on a range

of topics and communicate via digital platforms.

The table below lists a cross-section of exemplary stakeholder engagements by Deutsche Bank:

Stakeholder group

Channels/ formats

Examples in 2019

Clients

-person meetings and calls

Interviews and surveys

Conferences and events

Publications

Online communications and social

media

Hotlines

• Surveying clients in Germany via online banking and

self

-service devices, conducting client interviews with

the aim of improving the service quality and client

experience (see "Client satisfaction");

• Conducting more than 200 advisor and

client events

in order to increase ESG awareness, hosting several

ESG

-related events, including the ESG Engagement

Conference with a focus on green bonds in New York

or the Next Generation Innovation Summit on ESG

investments in San Francisco (see "Sustai

nable

finance"); and

• Publishing articles in client magazines as well as

structured investment and market assessments (Chief

Investment Officer View, CIO View) on ESG topics

(see "Sustainable finance").

Investors

In person meetings and calls

Conferences

and events

Annual General Meeting

Online communications

Publications

• Organizing the Annual General Meeting, attended by

around 3,900 shareholders;

• Providing information about the Annual General

Meeting on an dedicated website;

• Regularly excha

nging with shareholders on the

bank’s strategy and financial results as well as further

topics;

• Conducting an Investors’ Day for analysts and

investors;

• Publishing presentations, financial reports, and

results on the Investor Relations website; and

• T

ransmission of investor events on the Investor

Relations website.

Employees

Employee surveys

Employee meetings

Networks

-mails and newsletters

Publications

Online communications and social media

Hotlines

• Conducting the annual employee survey, the

quarterly surveys on feedback culture, and life

-cycle

surveys on joining the bank, settling in, changing jobs

or leaving the bank;

• Regularly communicating on employee

-related, non-

financial and sustainability/ESG

-related topics on the

internal website; a

• Hosting global hackathons, e.g. “Banking on

Sustainability”, engaging more than 1,100 participants

worldwide.

Society

Meetings

Conferences and events

Memberships and partnerships

Participation in consultations

Publications

Online communications and

social media

Hotlines

• Participation in the Value Balancing Alliance (VBA)

as a founding member, working collaboratively on the

development of a standardized Impact Measurement

and Valuation (IMV) model (see “ESG approach“);

• Membership of the Sustainab

le Finance Advisory

Council, inaugurated by the German federal

government to support the development of a national

and sustainable finance strategy; and

• Giving colleagues several weeks off to implement or

advance development projects in emerging markets as

part of our Corporate Community Partnership (CCP)

program, since 2018. In 2019, a panel discussion in

Frankfurt am Main marked the end of our three

-year

collaboration with the Gesellschaft für Internationale

Zusammenarbeit (GIZ), whose aim was to build

and professionalize the banking sector in Myanmar.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Sustainability ratings and indices

In recent years, we have observed a growing demand from stakeholders for ESG information. This trend reflects the growing

importance of ESG/sustainability ratings. At Deutsche Bank we consider sustainability ratings, on the one hand, as a valuable

instrument for internal benchmarking and, on the other hand, as a common basis to adjust our ESG approach. The market for

ESG ratings is not a regulated market with a high number of market participants. Therefore, the bank’s focus is on agencies

identified as relevant with regard to their importance for the bank’s investors and customers, significance for the bank’s

sustainability performance, and methodology transparency.

In 2019, Deutsche Bank responded, inter alia, to CDP Climate Change, ISS-oekom Corporate Rating, RobecoSAM Corporate

Sustainability Assessment, Sustainalytics, Vigeo Eiris, FTSE Russel, and MSCI ESG Research. Selected

results are outlined

in the table below:

Selected sustainability ratings

Dec 31, 2019

Dec 31, 2018

Dec 31, 2017

CDP Climate Score (on a scale from A to D-)

n/a

ISS-oekom (on a scale from A+ to D−)

C/Prime

MSCI ESG Research (on a scale from AAA to CCC)

BBB

RobecoSAM (on a scale from 0 to 100)

Sustainalytics (on a scale from 0 to 100)

Industry classification according to Global Industry Classification Standard (GICS).

No scoring in 2017 due to re-evaluation of our climate risks and opportunities in light of TCFD recommendations.

Sector average: D+; maximum in sector: C+.

Intangible Value Assessment (IVA) Rating.

Sector average: 35; maximum in sector: 83.

Deutsche Bank ranking in sector: 140 out of 353.

Based on sustainability ratings, Deutsche Bank continues to be listed in the FTSE4Good Index (World, Eurozone) and MSCI

Sustainability Index. Our final score, particularly in RobecoSAM’s assessment that defines the composition of the Dow Jones

Sustainability Indices (DJSI), was largely impacted by controversies stemming from litigations and conduct-related issues.

Consequently, Deutsche Bank stocks, have no longer been listed in the DJSI since September 2019. We have been interacting

with the rating agency to better understand how to balance these adverse effects in order to pursue our objective to be listed

in the major sustainability indices.

Combined separate

non-nancial report

11 Legal basis

14 Culture and integrity

17 Client-related matters

31 Organizational matters

44 Employee-related matters

53 Digital transformation

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Legal basis

GRI 102-49/50/54

The following combined separate non-financial report includes non-financial information in accordance with the requirements

of §§ 315b and 315c in connection with §§ 289b to 289e of the German Commercial Code (Handelsgesetzbuch, HGB) and

formally belongs to the Management Report of Deutsche Bank. As a framework, the GRI Sustainability Reporting Standards

were used.

Materiality and risk assessment process

GRI 102-15/21/29/31/44/46, 103-1

To ensure we focus management attention and non-financial reporting on those topics that are relevant in an ever-changing

global environment, we continued our materiality assessment of non-financial topics. We adopted a two-dimensional approach

that considered the impact of Deutsche Bank’s business activities on the respective topics, and the impacts of these topics on

Deutsche Bank. This also included that expectations of stakeholders and topics addressed by peers were taken into account.

We executed an evidence-based approach to uncover the material topics. We set clear thresholds for topics to be considered

and always view them in a Deutsche Bank context. Just as in previous years, some of the non-financial topics identified are

more mature and well regulated, while others are rather emerging topics still requiring further evaluation. The assessment is

conducted from the group perspective and equally applies to Deutsche Bank AG, the parent company.

Throughout the year, we conducted desk research to identify potentially material non-financial topics. We checked for changes

in global societal trends, the global sustainability agenda, and regulatory adjustments, as well as key environmental, social,

and governance topics (risks and opportunities) impacting Deutsche Bank.

In 2019, we surveyed the opinions of 272 internal senior management representatives regarding the relevance of non-financial

topics for Deutsche Bank. Furthermore, we held a group discussion with ten internal subject matter experts. The results of

both stakeholder engagements were merged with the results of our desk research.

To ensure we report in accordance with § 315c (2) in conjunction with § 289c (3) of the German Commercial Code

(Handelsgesetzbuch, HGB) we complemented our assessment of the impact of Deutsche Bank’s activities on a non-financial

topic and of the importance of a non-financial topic to stakeholders by an analysis of whether a non-financial topic is relevant

to understand Deutsche Bank’s development, performance, or position. The results of all three assessment steps were

combined in a materiality matrix which was the basis for our validating meeting with the Non-Financial Report Steering Group.

In accordance with § 315c (1) in conjunction with § 289c (3) no. 3 and 4 HGB, Deutsche Bank also evaluates all potential

significant risks that are very likely to have or will have a severely negative impact on material non-financial topics with respect

to its own business activities and business relations, as well as its products and services. No such risks were identified.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Legal basis

Materiality results for 2019

GRI 102-44/47/48, 103-1

Compared to the previous year, sustainable finance and climate risk gained in importance. We also included the topics of

access and inclusion as well as digital transformation in our materiality matrix. Digital activities which were part of other

chapters of the Non-Financial Report in previous years are presented in a separate chapter in this Non-Financial Report 2019

to provide for the increasing importance of this topic.

Moreover, we merged the topics of diversity, attracting talents and employee development into the topic cluster Employment

and employability. This is to ensure that all material details linked to our human resources work are covered. The business

integrity topic cluster has been renamed Culture and integrity.

The materiality matrix reflects the requirement in § 315b (2) in conjunction with § 289c (3) HGB to assess (a) the relevance of

a non-financial topic to understand Deutsche Bank’s development, performance, or position, which also includes the relevance

of a non-financial topic to stakeholders (x-axis) and (b) the relevance of Deutsche Bank’s business activities on the non-

financial topic (y-axis).

The topics in the top right quadrant of the matrix are the ones that in accordance with § 315c (2) HGB, are both necessary to

understand Deutsche Bank’s development, performance, or position and the impact of Deutsche Bank’s activities on the topic.

These topics are part of this section “Combined separate non-financial report” and are formally part of the Deutsche Bank

Group Management Report.

Further information on non-financial topics not in the top right quadrant of the matrix is disclosed in the section “Additional

information according to GRI”.

As human-rights-related matters and in-house ecology do not fulfill the materiality criteria of § 315c (2) in conjunction with

§ 289c (3) HGB, we continue to disclose relevant information, such as our management approach, and results relating to

these matters in the section “Additional information according to GRI”.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Legal basis

Report limits and further information

This report is a supplement to the Annual Report of Deutsche Bank. A description of the business model of Deutsche Bank in

accordance with § 315c (1) in conjunction with § 289c (1) HGB is part of this Non-Financial Report and can be found in the

Deutsche Bank Group Management Report. In addition to the information in this report, information on our key economic data

is disclosed in our Annual Report. For the parent company, please refer to the

Deutsche Bank AG Annual Financial Statements

and Management Report.

Deutsche Bank’s system for data generation and aggregation of greenhouse gas (GHG) emissions is based on the

GHG Protocol and ISO 14064.

In addition to our annual reporting, we strive for transparency throughout the year by providing additional information to

sustainability rating organizations (see “Sustainability ratings and indices” in this report) and by publishing information on our

corporate responsibility website

Material topic index

Reported topics

Chapter

Access and inclusion

Anti-financial crime

Climate risks

Culture and integrity

Data protection

Digital transformation

Digitization and innovation

Employment and employability

ES Due diligence

Reputational risk

Human rights

Information security

In-house ecology

Product responsibility

Public policy and regulation

Social responsibility

Corporate social responsibility

Sustainable finance

Tax

Material in accordance with HGB.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Culture and integrity

GRI 103-1

Integrity is the basis of everything we do. Without it, we cannot thrive as a business. Deutsche Bank expects its employees to

operate to the highest standards of integrity and conduct. Without this, we can neither build trust and protect our reputation,

nor serve our clients and stakeholders.

Code of Conduct

GRI 102-16/17, 404-2

The Code of Conduct

(the Code) articulates the bank’s key values and the standards of conduct to which employees should

adhere. The Code seeks to foster an open and diverse environment in which employees understand what the bank expects

of them. This includes, among other things, acting ethically, responsibilities as a manager, risk awareness, protection of

confidential information, identification and management of conflicts of interest, financial crime prevention and detection, fair

and free markets, treating clients fairly. Also included is an expectation that employees have a responsibility to speak up and

challenge poor practices and behaviors, especially where actions or failures to act are inconsistent with the Code. Employees

are actively encouraged to escalate, without fear of retaliation, any potential misconduct, inappropriate behavior, or any serious

potential conduct risk to their supervisors, Compliance, Legal, or Human Resources, in line with the Code and other bank

policies and procedures (including the Whistleblowing Policy). Additionally, employees can also report concerns or suspicions,

including anonymously, using the Integrity Hotline. In 2019, the bank introduced a new permanent Report a Concern button

on the bank’s intranet. The information provided here helps employees to identify the right channel to report a concern and

gives them the relevant contact details.

As the Code articulates the bank’s key values and standards of conduct, internal and external employees were required to

complete an e-learning course specifically focused on the Code and the bank’s values. That training was launched in late

2018 and continued in 2019. By the end of 2019, more than 68,000 employees had enrolled in the training, with a completion

rate of 99.9 %. Employees in scope for Compliance Attestation must attest, among other things, to their understanding of the

Code on an annual basis. The Compliance Attestation completion rate was 100.0 % of internal employees and 90.4 % of

external employees.

Failure to adhere to the Code and the bank’s policies and procedures can result in referrals to Human Resources as a part of

the bank’s disciplinary processes.

Culture, Integrity, and Conduct program

GRI 102-16/18/20/26, 103-2/3, 412-2, G4 DMA

Objectives and governance

Deutsche Bank also drives culture and ethical conduct through its Culture, Integrity, and Conduct (CIC) program. The objective

of the program is to reinforce the bank’s values, as articulated in the Code of Conduct, and desired outcomes, and to deliver

enhanced conduct and integrity across all geographies, businesses, and infrastructure functions within Deutsche Bank.

The Management Board and CEO have overall responsibility for achieving the desired cultural outcomes. Each Management

Board member is accountable for culture in their respective business division or infrastructure function. The culture-related

initiatives to support the CIC objectives are developed and implemented in the individual business division and infrastructure

function culture plans.

The CIC Committee oversees the implementation and management of the CIC program. The Committee establishes group-

wide CIC initiatives and drives the CIC topics and messages that are to be embedded in business division and infrastructure

function culture plans.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Culture and integrity

This formal Management Board committee is chaired by the Chief Risk Officer and the Senior Group Director responsible for

Legal and Regulatory Affairs. This committee comprises representatives from each business division, infrastructure function,

and region who are nominated by the respective Management Board member. Group-wide coordination of conduct and

integrity-related initiatives is supported by the CIC Operating Forum (CIC OpFo), which reports to the CIC Committee.

The CIC Committee reports to the Integrity Committee of the Supervisory Board at the Integrity Committee’s request. The

chairs of the CIC OpFo updated members of the Group Management Committee (GMC) on the CIC agenda and progress of

various CIC initiatives in the fourth quarter of 2019 and will continue to do so periodically. The GMC is designed to more

closely link the Management Board to the divisions and comprises Management Board members as well as leaders of the

business divisions.

2019 CIC focus values and mandatory initiatives

GRI 102-44

In 2019, the CIC Committee focused on three of the bank’s six values, with a special emphasis on the value integrity:

– Integrity: Focus on enhancing positive conduct and reducing misconduct, ethical decision-making, and a ”speak-up” culture;

– Discipline: Focus on individual accountability and fiscal responsibility; and

– Client Centricity: Focus on treating clients fairly as a top priority for client-facing employees, and the creation of products

that provide value to clients.

In the context of the specific emphasis on integrity in the year under review, the CIC Committee identified three group-wide

mandatory initiatives that were incorporated into the 2019 CIC Book of Work as well as in the annual business division and

infrastructure function culture plans:

– Speak Up: Encouraging employees to speak up if they see something that feels wrong;

– Listen- Up: Educating managers on how to listen to concerns and respond when people raise issues to them, and to create

an environment conducive to speaking up; and

– Gray areas in ethical decision-making: Fostering a culture where structured conversations can be held on potential gray

areas in ethical decision-making as part of creating a Speak Up and Listen Up environment.

The group-wide focus values and mandatory initiatives are incorporated into:

– CIC Book of Work: A set of centrally led initiatives focused on group-wide frameworks and processes (e.g. reviewing HR

employee life cycle processes), training, and campaigns (e.g. Be on the Right Side Speak Up Campaign); and

– Annual business division and infrastructure function culture plans: Annual culture plans of each business division and

infrastructure function tailored to their specific needs and incorporating the global topics and messaging to better embed

the CIC objectives.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Culture and integrity

Key CIC initiatives in 2019

GRI 102-16

The key initiatives implemented in 2019 included:

– An integrated Conduct and Speak Up awareness campaign and training program was launched in July 2018 and continued

through 2019. The integrated campaign promoted a culture where employees could feel comfortable to express their

concerns, including those that might be conduct-related, with no fear of reprisal or retaliation. A robust Speak Up culture –

focusing on being on the “right side” – is intended to increase employee awareness and responsibility. Such a culture

should also increase the likelihood that problems will be identified at an early stage before they can become more serious.

The campaign also focused on educating managers on how to encourage speaking up, and how to listen to and respond

when people raise issues to them. April 2019 saw the launch of the Speak Up Navigator to guide employees through

Speak-Up and Listen Up training resources. The results of the People Survey showed a clear link between the impact of

managers and employees giving and receiving feedback, mutual appreciation and attendance rates for team meetings on

commitment to the bank, enablement and confidence to speak up. Appreciation is particularly critical in helping people

voice their concerns and take the right actions in line with the bank’s values, beliefs and principles. Five questions focused

on the Speak Up culture were included in our 2019 People Survey. The results for each of these questions showed an

improvement on the previous year’s results. For further details about the 2019 People Survey, please refer to the 2019

Human Resources Report;

– The Whistleblowing Policy, which was revised in 2019, sets forth the framework for employees to report concerns or

suspicions regarding possible violations of laws, rules or regulations, or possible violations of internal policies or

procedures, including the bank’s Code of Conduct. Any reports received are reviewed to establish their nature, content,

and priority. If necessary, an internal investigation of the incident will be initiated. This may result in a number of outcomes,

for example disciplinary actions against employees or changes to the relevant processes. One of the channels employees

can use to report such concerns or suspicions is the bank’s Integrity Hotline which can also be used on an anonymous

basis. An important feature of the Whistleblowing Policy is that retaliation of any kind is prohibited against employees who

make a report internally or externally to any regulatory, investigatory or other agency or authority, or to self-regulatory

agencies;

– While we are fully aware that culture is difficult to measure, we report a number of metrics from various group-wide sources

to evaluate progress against our culture objectives in the Culture and Conduct Metrics Dashboards. The Dashboards are

produced at a group, divisional, and regional level and reported quarterly to the CIC Committee. The metrics are aligned

to the bank’s values and include, for example, data on investigation processes, disciplinary and consequence management

processes, gender diversity, the number of employee hours attributed to corporate social responsibility, and client

satisfaction, as well as escalations through whistleblowing channels. The metrics also incorporate results from the bank’s

annual People Survey, which can provide a more in-depth view of employees’ engagement with the bank’s values. Some

of the culture metrics are included in the Management Board balanced scorecard. In 2019, as part of our continued efforts

to enhance the Culture and Conduct Metrics Dashboards, we undertook a review of the existing suite of culture and conduct

metrics. This included looking across the industry to identify best practices and any gaps in our metrics compared to other

firms. Based on the industry review, our Culture and Conduct Metrics Dashboards report metrics in line with common

industry practice;

– The Market Conduct and Integrity Classroom training program launched in 2018 was completed in 2019. More than 4,000

primarily front office employees were trained in small class-room settings; employees not able to attend in person received

an online version of the classroom training. Since its launch, the training reached a completion rate of 99.6 % by the end

of 2019. The training consisted of two video scenarios designed to explore good conduct and inappropriate behaviors in

connection with securities and investment-banking-related businesses. The scenarios were intended to create some gray

areas, in which the learners could explore and discuss the facts about appropriate and inappropriate behaviors. They also

gave them the chance to learn how to make decisions, exercise judgment, reach out for help in resolving gray areas, and

escalate where necessary. A total of 99 % of the attendees strongly agreed or agreed that the course objectives had been

met; and

– Targeted communications to business divisions and infrastructure functions on culture and conduct topics were delivered

across the bank. This included embedding key messages in senior management communications, articles, and video

interviews on the dbnetwork homepage, as well as in town hall meetings.

While the emphasis of many of the initiatives was on integrity, there were a number of business division and infrastructure

function culture plans initiatives focused on the values client centricity and discipline, including:

– Redesigning the client on-boarding process to increase speed, improve the client user experience and promote behavioral

change across the bank;

– Creating client value metrics on client satisfaction; and

– Improving the speed of decision-making through clearer accountability.

Client-related matters

18 Product responsibility

20 Client satisfaction

23 Sustainable nance

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Product responsibility

GRI 102-16/42, FS4

Product responsibility at Deutsche Bank is defined by the principles of our Code of Conduct, which lay down the guidelines to

ensure that all our business divisions – Corporate Bank (CB), Investment Bank (IB), Private Bank (PB), and

Asset Management (AM) – behave responsibly and with integrity towards clients. As these business divisions are responsible

for implementing the Code of Conduct, they are accountable for treating clients fairly at every stage – from the development

to the sale of our products and services. Specific control functions support the business divisions in living out their

responsibility. Processes and controls set up as a result of legislation and regulations, for example MiFID II, help us to

recognize relevant topics in good time and define action areas, including market screenings of products to identify those that

best fit our specific client needs. The bank’s internal guidelines address these topics and regulate important aspects of them.

For further details on product governance please refer to our Annual Report 2019 - Risk and capital overview - Risk

governance as well as Operational risk management - Operational risk type frameworks.

In view of the differing profiles of our client groups, our business divisions enjoy varying degrees of freedom in implementing

these guidelines. Their interpretation is determined, for example, by a specific client group’s touch points with the bank, the

need for client protection, or how much a client group knows about financial transactions. In order to ensure we are acting

with integrity in a client-centric manner, we regularly train all employees involved in client relationships. The topics we pay

particular attention to include a responsible attitude towards new products and dealing with new product-related requirements,

advising clients responsibly, helping clients to avoid becoming heavily indebted, and knowing how to deal with conflicts of

interest.

Product design and approval

GRI 102-11/15, 103-1/2/3, 417-1, G4 DMA

A group-wide New Product Approval (NPA) and Systematic Product Review (SPR) process defines the design and approval

of new products and services. Regional or divisional NPA councils also express their opinions on new products and material

developments affecting existing products, such as new risk factors or businesses. We also systematically review our products

throughout their life cycles to ensure they remain fit for purpose and consistent with the needs, characteristics, and objectives

of the respective client groups. Additionally, any features causing concern, such as a potential reputational impact on the bank

from environmental or social issues, are referred to the relevant management approval committees, such as our Regional

Reputational Risk Committees or, ultimately, the Group Reputational Risk Committee.

Our investment activities are based on a process designed to ensure decisions are taken in our clients’ best interests. To

provide products and advice that match our clients’ specific needs in a given market environment, our analysis of market

conditions is conducted separately from sales planning. For current and prospective clients, this process provides

transparency on the bank’s views on specific investment topics, asset classes, and market events. In our AM and PB, for

example, this investment process leads to the formulation of structured investment and market assessments by the Chief

Investment Officer (CIO Views), which draw on the expertise of senior employees and are used to inform both our portfolio

managers and our client advisors. In order to take into account the different cultural, and regional backgrounds of our clients

in client portfolios, we adapt our CIO Views to regional conditions.

Product and advisory principles

GRI 102-16

Minimum standards for our product lines commit us to offering ethically justifiable and transparent products and services based

on processes and principles designed to ensure compliance with legal and regulatory requirements. For example, our

guidelines on product oversight governance require frequent monitoring as to whether specific products have only been sold

to the appropriate client group. Moreover, we strive to offer clients responsible and foresighted advice that fulfills their needs

and reveals the respective benefits and risks. To ensure the suitability and appropriateness of our products, we assess a

variety of parameters, including the complexity of a product, a client’s knowledge of and experience with a product, and a

client’s regulatory classification and investment objectives. Then we select the product that matches the desired client demand.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Product responsibility

Our basic principles require us not to sell any product or service if it becomes obvious that a client does not need the product,

cannot afford it in the mid-term, and has not understood it, or that a product does not meet the client’s risk profile. Furthermore,

our products must be designed in such a way that their potential returns exceed the cost of investing in the product.

The principles we apply also state that our products should be beneficial to the individual but not have detrimental side effects

on society at large. This rules out products or investments that, for example, involve the manufacturing or sale of nuclear

weapons, cluster munitions, and landmines, promote or use child labor, violate human rights, or in any way support drug

trafficking or money laundering.

In our Investment Advisory business, we advise on and offer both Deutsche Bank and third-party products, which enables us

to only provide products that best fit specific client needs. Our Product Guidelines for Investment and Insurance Products also

define products that are not to be advised to clients, such as investments in contracts for difference (CFDs). Furthermore, we

do not launch new products based on momentum strategies in soft commodities.

Prevention of excessive indebtedness

GRI 102-11

In granting loans, particularly to private clients, we strive to protect them from over-indebtedness. Therefore, each loan

application must be accompanied by an obligatory analysis of the client’s personal situation. A loan engagement will only be

set up if sufficient financial leeway is left after the deduction of interest and repayment amounts. The stated aim is to protect

clients against over-indebtedness and, in particular, loss of property. We fully reflected these requirements in our loan

processes and regularly train our sales employees in this respect.

For non-performing loans the bank deploys a series of measures to mitigate hardship. In cases of late or nonpayment, we

contact our clients at an early stage. In the event of a financial emergency due to unemployment, illness, or insolvency, for

example, or in other justified exceptional cases, our PB Germany Deutsche Bank brand business has a separate hardship

process and employs individualized strategies to provide the necessary financial solutions, for example moratorium of

payments or reduced repayment rates.

Communications and marketing

GRI 103-1/2/3, 417-1, G4 DMA

We are dedicated to marketing our products and services responsibly and to providing information our clients can trust. All

information contained in marketing material as well as product information, must be transparent, clear, fair, accurate, and not

misleading. All our client communications – irrespective of format, medium, or audience – must meet the minimum standards

and requirements set out in our internal policies, such as our Business Communications Policy. While advertising our products

and services, we do not guarantee a particular outcome or result.

Conflicts of interest

GRI 102-25

Conflicts of interest are inherent in all business activities and can arise in conjunction with employee trading, outside business

interests, transactions performed by deal teams, or family and close personal relationships. Failure to recognize and

appropriately manage conflicts of interest can result in inappropriate or adverse consequences for clients, the bank, and

employees. Our employees are required to notify their supervisor and/or Compliance if they identify such a conflict. Every

business division has implemented a conflict-of-interest framework to identify actual and potential conflicts, mitigate them, or

manage them fairly and appropriately for all involved parties. Senior managers are required to sponsor systems and controls

to document, track, manage, and mitigate any conflicts of interest and regularly review their effectiveness. The bank’s Business

Selection and Conflicts Office is an independent control function responsible for group-wide oversight of management activities

relating to conflicts of interest and reports at least once a year to the Management Board.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Client satisfaction

GRI 102-42/44

As loyal and satisfied clients are vital for our ongoing success, we work to improve our products and services and to ensure

compliance with the legal requirements for such advice. We apply business-division-specific approaches to assess client

satisfaction, including client satisfaction surveys, test purchases, mystery shopping

, and third-party assessments. We

integrate client feedback into quality assurance and optimization measures. The results are communicated internally to

relevant internal stakeholders, for example senior management. Based on the respective feedback, steps for improvement

are formulated and, where appropriate, incorporated.

In our Investment Bank (IB) we employ broker reviews as an approach to ensure client satisfaction. This dialog puts us in a

position to take educated decisions on proposed changes by key stakeholders. In 2019, our Corporate Bank (CB) and IB

teams jointly engaged in our Voice of the Client process, which covers our global corporate client activities across coverage

and sales/implementation, as well as service activities. We used the feedback from key decision makers and service recipients

to create client-specific action plans and initiate product developments. In 2019, 81 % of our clients stated they were mainly

or fully satisfied with how we dealt with their feedback.

Client surveys, interviews, and test purchases are key tools for measuring client satisfaction and loyalty in our Private Bank

(PB) Germany and Private & Commercial Business International. Overall, the level of satisfaction in 2019 changed little from

2018. However, our clients’ feedback revealed, for example, some room for improvement in our advisory processes. Our sales

employees get in touch with dissatisfied clients to discuss the reason for their dissatisfaction.

In 2019, we received responses on the degree of satisfaction with PB Germany, Deutsche Bank brand business, from around

170,000 clients in Germany via self-service devices and online banking. We use mystery shopping to check that our advisory

processes meet our clients’ needs. In 2019, an independent market research institute conducted interviews with around

8,000 clients. This gave us feedback on their satisfaction with our advice. Additionally, a total of 1,993 test purchases took

place in Germany. In our Private & Commercial Business International, 328 test purchases were conducted in 2019. The

results have been integrated into our branches’ sales management processes.

Client satisfaction index Private Bank (excl. Wealth Management, WM)

(unless stated otherwise)

Dec 31, 2019

Dec 31, 2018

Dec 31, 2017

Client satisfaction Private Bank Germany (excl. WM), Deutsche Bank brand

Index Private Bank Germany (excl. WM), Deutsche Bank brand

69.4

68.2

70.2

With our services

70.3

69.3

71.5

With our advice

70.5

69.2

71.4

With actively offered products and services

65.0

63.7

65.6

Willingness to recommend Deutsche Bank

71.5

70.6

72.3

Number of clients taking part in the survey

171,053

192,207

237,095

Client satisfaction Private & Commercial Business International

Index Private & Commercial Business International

78.4

79.5

77.4

Willingness to recommend Deutsche Bank

84.9

76.5

75.5

Number of clients taking part in the survey

19,200

20,510

24,272

Comparative values for prior years 2017 and 2018 have been restated to reflect the transition of commercial clients from our PB to our CB division in Germany.

The figures for Private & Commercial Business International include numbers for Spain and Italy and are based on country-specific survey methods with different scales. The

results have been converted to a uniform scale of 0-100 %.

Mystery Shopping index Private Bank (excl. WM)

(unless stated otherwise)

Dec 31, 2019

Dec 31, 2018

Dec 31, 2017

Private Bank Germany (excl. WM), Deutsche Bank brand

Mystery Shopping Index

82.6

81.1

78.5

Private & Commercial Business International

Mystery Shopping Index

84.7

79.8

74.5

Private Bank Germany (excl. WM), Postbank brand

Mystery Shopping Index

67.2

67.0

68.8

Comparative values for prior years 2017 and 2018 have been restated to reflect the transition of commercial clients from our PB to our CB division in Germany.

In 2019, Private & Commercial Business International conducted test purchases in Spain, while Belgium, India, and Italy did not participate in the mystery shopping program.

Therefore, the Mystery Shopping Index for 2019 consists only of results from Spain. The index value for 2018 contains test purchases from Poland, Portugal, and Spain. The

figures for Private & Commercial Business International are based on country-specific survey methods with different scales. The results have been converted to a uniform

scale of 0 – 100 %.

Mystery shopping is only used in our Private Bank.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Client satisfaction

Postbank, which remains present in the market as a key brand, measures not only the degree of satisfaction with its services

as a whole but also the willingness to recommend its services as well as other detailed aspects of the client-bank relationship

(including client satisfaction with central service processes and client contact points). In 2019, overall client satisfaction was

lower than the previous year. The various reasons included the closure of branches, pricing measures, availability problems,

and some changes in the online banking application, for example a modified security process. In 2019, Postbank conducted

2,048 test purchases. Its Mystery Shopping index rating was essentially flat in comparison to 2018 despite the impact of strikes

and the conversion of the online banking access to the two-factor authentication process.

Various measures were initiated to improve the client experience and quality of advice, such as the ongoing development of

sales software. Additionally, Postbank uses the self-developed online tool Competence Quiz to improve the quality of sales

and advice. The tool offers sales employees the possibility to test and expand in a playful manner their client-related knowledge

about products, processes, and regulations based on relevant and up-to-date customer use cases. In 2019, Postbank

employees used the online Competence Quiz more than 100,000 times.

In 2019, Wealth Management (WM) in Germany continued using its Net Promoter Scores (NPS) and Client Satisfaction Survey

for the majority of eligible clients

. In 2019, the NPS in Germany was 75 %. In 2019, we started working on a Voice of the

Client survey in collaboration with Scorpio Partnership. This client survey is scheduled to be piloted in the Americas region in

Q1/2020 before a broader rollout takes place later in the year. Ongoing measures to enhance client satisfaction include

process improvements, such as the optimization of client onboarding within Global Markets and the digitization of the client

onboarding process.

Since 2008, an external service provider has been commissioned to conduct client satisfaction surveys with the aim of

improving service quality and the client experience in our AM. The annual client satisfaction survey among AM clients focuses

on perceived service quality, professionalism, and service process transparency. Clients and advisors can rate their

satisfaction on topics, such as staff friendliness, response rate, professional competence, comprehensibility, solution

orientation, and sales-specific questions. The degree of advisor satisfaction with, for example, recommended solutions,

professional competence, and friendliness was again evaluated, and we regard the fact that advisors stated they were “likely

to recommend our telephone services to colleagues” as proof of customer loyalty. For AM’s U.S. insurance and institutional

business, an annual client satisfaction survey is conducted with a focus on investment performance and other areas of

improvement, such as relationship management, innovation, and overall satisfaction. The intention here is to embed client

feedback into AM’s senior management sessions and U.S. Fund Board meetings. Regular surveys covering knowledge,

sincerity, problem-solving, and overall client satisfaction are also conducted on a monthly basis by a third-party vendor who

services the direct retail client base in the U.S.

Eligible clients are those who meet each of the following criteria: the client is German speaking; the client has an email address registered with Wealth Management and; the

client has positively acknowledged an opt-in email.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Client satisfaction

Complaint management

GRI 102-15/17/31/44, 418-1

We have a defined set of core values for dealing with complaints fairly, impartially, and without undue delay. How we address

complaints is governed by the Group Policy on Minimum Requirements for Handling and Recording of Complaints, which

applies to all our businesses and complies with the EU Guidelines on Complaints Processing for Securities Trading (ESMA)

and Banking (EBA) and their interpretation by the Federal Financial Supervisory Authority (Bundesanstalt für

Finanzdienstleistungsaufsicht, BaFin). Our business divisions are responsible for developing and implementing procedures

incorporating the objectives and minimum requirements set out in the Group Policy. We strive to anticipate and avoid potential

complaints before they arise or solve them, whenever possible, during the initial client contact. To achieve this, a robust and

consistent client complaint handling and reporting process helps to facilitate the improvement of client satisfaction by

identifying and remedying poor client outcomes. This enables us to learn from mistakes and thus reduce their incidence and

any related costs, as well as to enhance risk transparency and improve management information. Clients who are dissatisfied

with a product, service, or decision can contact the bank in any local branch, by e-mail, online, by calling our client service

center, or through authorized third parties. We immediately acknowledge receipt of complaints and work to resolve them

quickly and transparently by regularly training our complaint managers. Client complaints are reported to the bank’s senior

management and Compliance function and are subject to periodic review. Complaint metrics also feed into our Non-Financial

Risk Report oversight reporting. We screen new complaints for recurring noticeable problems. Management information

provides an oversight of the type of complaints (clustered by group-wide non-financial risk-type taxonomy), materiality,

severity, and time to closure.

In 2019, we continued our efforts to comply with a consistent complaint-handling framework. As we realign our businesses

into the newly established CB and IB, our focus continues to be on integrating the complaint-handling processes. These

processes are regularly enhanced, while staff training ensures consistent capturing and reporting of complaints, as well as

improved oversight and governance. As a result, the number of complaints handled by IB was over 40 % lower in 2019 than

in 2018. The focus here was on transaction processing.

In our PB, the number of client complaints rose sharply in 2019. Despite a decline in the Private & Commercial Business

International, triggered by the discontinuation of the private client business in Portugal and Poland, the overall number

increased due to complaints related to PB Germany, Postbank brand business. This was particularly due to the deactivation

of the mobile TAN procedure in the course of the Payment Services Directive 2 (PSD2) implementation. In our PB, we

participate in all applicable dispute resolution schemes run by national ombudsmen, which offer a free, fair and easily

accessible service to consumers who prefer to resolve a dispute not directly with the bank.

For complaints from WM clients, our complaint indicator revealed that there were fewer complaints in 2019 than in 2018. A

Global Product Governance Forum (GPGF) reviews quarterly the output of product life cycle analysis and management

processes, including product-related client complaints, and in particular global trends.

In 2019, AM observed an increase in complaints. This is almost exclusively due to a delay in the distribution of tax filings and

declaration of profits in Germany and Luxembourg respectively. We have taken an important governance measure by initiating

a globally responsible complaint management function, assumed within the Divisional Control Office of AM. This function

coordinates complaints across regions and business areas. In this capacity, this function also reports to regulatory bodies.

Furthermore, complaint filing, logging, and reporting have been centralized in a new system known as Salesforce. The relevant

employees were trained for both measures in 2019.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Sustainable finance

GRI 102-15/43

In 2019, the public debate about the urgent need to transition to a sustainable and low-carbon economy and the discussion

about the role the financial sector plays in this – above all, the call for sustainable finance – gained a new level of importance

worldwide. Climate protection was also a major topic of discussion with politicians and supervisory authorities. When

Deutsche Bank signed the Paris Pledge for Action in 2015, we demonstrated our commitment to contribute to the goals of the

Paris Agreement. This commitment continues unabated.

As a global financial intermediary, we have a role to play in facilitating the transition of economies towards sustainable and

low-carbon growth. In this context, we understand sustainable finance to be business activities that support this transition by

directing financial flows towards more sustainable and climate-friendly solutions. We use our market expertise, products, and

solutions to drive our customers' transformation towards this direction. Our increased focus in this field was reflected in the

results of our 2019 materiality assessment (see “Legal basis“). Sustainable finance also includes questioning our involvement

in certain business areas, such as the financing of new coal-fired power plants.

The transition to a more sustainable and low-carbon economy and the physical effects of climate change will also lead to risks.

Our approach to managing climate risk and a summary of the steps we are taking to enhance our framework in alignment with

the Task Force on Climate-related Financial Disclosures (TCFD) recommendations are outlined in the GRI supplement of this

report (see “Climate risk“). It contains a summary of how Deutsche Bank manages exposures to carbon-intensive industries,

risks from commodity price volatility, and physical risks to infrastructure, employees, and key processes.

We offer a range of sustainable finance solutions geared towards our clients’ specific needs. In doing so, we can play to our

strength as a universal bank. For our commercial and corporate clients, we create individual lending offerings to advance their

own business transformation to low carbon models. Our Investment Bank (IB) assists companies and governments in gaining

access to sustainable financing on the capital markets. In our Asset Management (AM), we are focusing on mainstreaming

ESG by integrating ESG aspects into our investment strategies, as well as the respective product portfolio and services. We

are continuously growing the number of sustainable investment products available for institutional and private investors. Some

of our offerings seek to directly or indirectly contribute to the Sustainable Development Goals (SDGs) of the United Nations

Global Agenda 2030.

Governance

GRI 102-12/16/18, 103-2/3

Our group-wide Sustainability Council is mandated by the Management Board to drive the integration of sustainability

throughout the bank (see “Approach to sustainability“). In 2019, the focus was on developing the bank’s approach to

sustainable finance. The discussions focused on, among other things, the establishment of a consistent group-wide definition

of sustainable finance for our lending and capital market activities. To support these discussions, the bank joined the pilot

project led by the United Nations Environment Programme Finance Initiative (UNEP FI) and the European Banking Federation

(EBF) to draw up guidance on the voluntary application of the EU taxonomy to core banking products. Furthermore, we focused

on assessing the bank’s opportunities across various business lines and initiated steps to set targets for sustainable finance,

which we expect to adopt in 2020.

We address sustainable finance opportunities through divisional ESG governance structures to ensure that we generate

appropriate answers to client demands, and to continually expand our ESG product portfolio and services. International

standards, such as the UN Global Compact and the OECD Guidelines for Multinational Corporations, are examples of the

guiding principles for our business. In 2019, Deutsche Bank committed itself to the newly established Principles for

Responsible Banking. Furthermore, we are governed by several internal policies, such as our publicly available Environmental

and Social Policy Framework, and the Responsible Investment (RI) Statement, ESG Integration Policy for Active Investment

Management, and ESG Engagement Policy that are specific to our AM. We regularly review our policies and procedures.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Sustainable finance

Training and awareness

GRI 102-21/43, 103-1, 404-2, G4 DMA

To develop and complement our in-house competences, we collaborate with industry experts and external service providers.

We also invest in ESG research, engage with our stakeholders, and participate in a variety of initiatives to foster sustainable

finance. In our Private Bank Germany, we conducted more than 200 advisor and client events in the year under review in

order to increase ESG awareness. To further develop our capabilities in Wealth Management (WM), we built up a network of

ESG Ambassadors in each region to serve as first points of contact on ESG-related financial matters. The European

Federation of Financial Analysts Societies (EFFAS) was also engaged to roll out a Web-based Certified Environmental Social

Governance Analyst (CESGA) training course for all our 4,000 WM employees worldwide. In-person training sessions were

conducted in Europe and the U.S. In AM, we continued our regular training for investment professionals across AM in Active,

Passive, and Alternatives on the assessment of ESG risks and opportunities in order to support ESG integration across the

entire investment platform. In 2019, we continued the engagement of AM investment professionals towards environmental

and social issues in Active and ran mandatory internal training sessions for Active investment experts. This included offering

the optional EFFAS ESG Certification Program. In 2019, a total of 36 current and permanent employees across AM registered

for the exam and have become certified ESG analysts. At the end of 2019, AM counted a total of 123 CESGA-certified

employees.

Deutsche Bank also recognizes its responsibility as a convener for multi-stakeholder engagements towards sustainable

financing. As such, our Corporate Bank (CB) and Investment Bank (IB) hosted various events on the key topic of green bonds

and sustainable finance in 2019, for example an ESG Engagement Conference in Frankfurt am Main co-hosted by the Green

and Sustainable Finance Cluster Germany and the International Capital Market Association (ICMA), the Next Generation

Innovation Summit held in San Francisco in November, and an ESG engagement conference in New York focusing on green

bonds. We also co-initiated the Conscious Capitalism European Conference in Berlin. To increase education and client

discussions in WM, the September 2019 issue of our German client magazine WERTE was dedicated to sustainability topics.

Moreover, our outreach included key client events, such as dedicated ESG-themed sessions at Wealth with Responsibility in

Germany, as well as smaller-scale ESG-focused client events in Milan and Napa Valley in October. We are also working to

improve our clients’ understanding of ESG-based investment approaches and ESG-related market developments. In 2019,

we continued publishing CIO Insights on ESG topics, including “The E in ESG”, which took an in-depth look at the

environmental aspect of ESG, and “The S in ESG”, which highlighted the importance of social sustainability.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Sustainable finance

Lending and advisory

GRI 102-16, 201-2, 404-2, G4 DMA, FS8

ESG and green bonds

In our IB division, a dedicated debt capital market product team helps our clients around the world to achieve their sustainability

strategies and to make environmental and social contributions while meeting their financing needs. We advise clients

holistically on broader sustainable finance aspects as well as on how to successfully issue ESG bonds, including all the

strategic and operational preparation required. In 2019, we partnered with a number of global clients in supporting them with

their ESG bond transactions and helped them to raise more than € 22 billion funding in various instruments, such as green,

social, sustainability, and sustainability-linked bonds. Besides advancing the ESG bond market, these transactions were of

high strategic importance to Deutsche Bank’s issuers. For example, we helped the Italian utility company Enel to introduce a

new format known as sustainability-linked bond, which was the first-ever public bond format to attach contractual

consequences to the fulfilling of certain pre-defined sustainability key performance indicators. We also provided support to

Assicurazioni Generali in issuing the first green-subordinated benchmark transaction by a financial institution in Europe, to

Standard Chartered in issuing their inaugural sustainability bond, and to the Republic of Indonesia in issuing their second

green sukuk bond. These exemplary transactions illustrate how Deutsche Bank drives the development of sustainable finance,

and how we facilitate the flow of capital into sustainable projects in alignment with the SDGs set by the United Nations.

Renewable energy

Our IB became involved in financing renewable energy projects in the mid-2000s when projects reached industrial scale. In

2019, we arranged full or partial project finance totaling around € 2.5 billion for renewable energy projects generating over

2,200 megawatts.

Corporate loans

The European corporate loan market saw green or ESG incentives become a regular component of refinancing transactions

in 2019, although the total volume remained relatively small. Sustainability-linked loans are being issued by companies

irrespective of their size, industry, or sustainability score and highlight an issuer’s commitment to its sustainability targets. This

trend is being supported by the Sustainability Linked Loan Principles issued by the Loan Markets Association in March 2019.

In 2019, Deutsche Bank acted as coordinator for eight sustainability-linked loans. Five of these closed in December 2019,

including the German companies Continental, LANXESS, and Zeppelin, the U.K. company NEPI Rockcastle, as well as the

U.S. company Crown, where Deutsche Bank led the first leveraged sustainability-linked loan agreement in the U.S. market.

Overall, Deutsche Bank has participated in over 20 sustainability-linked loans with a total deal volume of more than € 50 billion

in 2019.

Infrastructure development

In 2019, our CB arranged or participated in more than € 3.4 billion of financing for infrastructure projects with strong

developmental credentials and a positive contribution to the development of local communities in sectors like education,

agriculture, and power, as the following examples show:

– Mandated lead arranger and sole rates hedge arranger for the NTD 82 billion (€ 2.3 billion equivalent), 640 megawatt

Yunlin offshore wind farm project financing developed by a consortium led by Wpd AG: This project was the largest offshore

wind project in Asia Pacific at deal closure and has provided a viable financing template for large-scale offshore wind

projects to facilitate the gradual phase-out of nuclear energy and coal-fired power generation in Taiwan;

– € 96 million of financing for the Province of Cordoba, Argentina, to support part of Governor Schiaretti’s social program:

The financing addresses two different plans: first, the construction of a primary care hospital in the southwest of the province

to enable access to public health for its most needy inhabitants; and second, the construction of 34 schools as part of the

Advanced Program for Education in Information and Communications Technology;

– US$ 150 million of financing in two Sinosure 95 %-covered 13-year buyer’s credit facilities for the Ministry of Finance of the

Republic of Angola to support two national tax collection infrastructure improvement projects: the Integrated Computer

Systems for Tax Project (SIGT) and the Customs Management Project (SIIAT). This project will help to strengthen domestic

and import taxation compliance and to improve tax collection in Angola, which suffers from an inefficient and unreliable IT

infrastructure; and

– Financing the upgrade and modernization of 34 vocational training institutes across Ghana, worth € 123.5 million in all:

One of the key projects in the 2019 budget is to address the unemployment and skill gap in Ghana. By targeting region-

specific requirements, the project will support the government’s objective of creating a sustainable vocational education

system

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Sustainable finance

Subsidized loans (KfW)

In 2019, we again collaborated closely with KfW, Germany’s nationwide development bank, to support private and corporate

clients across all business divisions through government-subsidized loans or procurement of guarantees with an overall

volume of € 1.6 billion (2018: € 1.6 billion). Of this amount, more than 41 % was provided for various corporate investments

in energy efficiency, environmental protection, or renewable energies, as well as in private clients’ projects to build, purchase,

renovate, or modernize residential properties (2018: 38 %). Additional subsidized financing volume was enabled in

collaboration with regional promotional banks belonging to Germany’s federal states, as well as with the European Investment

Bank and the European Investment Fund.

A broad range of financing solutions with subsidized components is offered to corporate clients. In addition to general corporate

financing, more specific financing opportunities, such as energy transition measures or innovations, are also eligible. In all,

we arranged 550 KfW loans for our corporate clients with a volume of more than € 400 million in 2019 (2018: 800 loans totaling

€ 700 million). Of this, € 180 million was for energy transition measures (2018: € 240 million).

Through our mortgage facilities, we support our private clients in the acquisition of residential real estate and contribute to

wealth creation. Through our cooperation with KfW, more than 18,000 clients obtained state-subsidized mortgages totaling

€ 1.2 billion in 2019. This sum included about € 490 million for financing agreements of low-energy houses or for construction

and modernization projects that meet higher energy standards than those required by Germany’s Energy Saving Ordinance

(2018: € 360 million).

Investment products

GRI 102-16, 201-2, 417-1, G4 DMA, FS8

Private Bank

Retail business

In line with our product principles, we apply exclusion criteria to our entire product offering, for example by ruling out investment

products with agricultural speculation. As exemplified by the collaboration of our Private Bank Germany with third-party product

providers for mutual funds, we expect product providers to demonstrate their commitment to responsible investing by being a

signatory to the UN Principles for Responsible Investments (PRI). When selecting dedicated ESG investment products for our

retail clients, we take additional ESG criteria into account, which we develop over time.

In 2019, we also began offering an equity fund that invests in companies that contribute to the objectives set out in the SDGs.

After the launch of the equity fund, we generated gross inflows of approximately €

248 million (equivalent to around 22 % of

total gross flows into equity theme funds). Additionally, we started offering a green bond fund whose target is to invest into

bonds to support environment-related projects. For Private & Commercial Business International, four new thematic ESG

funds were actively recommended to clients in Belgium, which took the total number of recommended ESG funds to nine. In

Italy, we launched an ESG model portfolio to enhance the focus on sustainable investment solutions within the advanced

advisory service and two discretionary lines within the standard DPM solutions’ offering. Furthermore, ESG fund solutions

were offered to clients, such as DWS ESG Multi Asset Defensive Fund and Nordea Sustainable Global Stars. In early 2020,

Postbank will offer two sustainable VZI portfolios and there will be five ESG funds available for this purpose.

Wealth Management

In 2019, WM launched an accelerated ESG strategy to expand its ESG investment services, as a new generation of wealthy

clients is increasingly focusing on adding purpose to investment performance. The strategy, approved by our WM Executive

Committee (ExCo), focuses on three key pillars: incorporating ESG ratings into WM portfolio construction and reporting

systems, extending our ESG product offering, and creating ESG awareness. Our ESG investments are handled within the

established WM investment processes, with governance primarily implemented through existing structures within our

discretionary portfolio management services. To walk the talk in our commitment to expand our ESG product offering and

increase investment, WM has formally entered into an agreement with MSCI to access enhanced ESG ratings in support of

Wealth Discretionary (WD) and Wealth Advisory solutions. This will empower WM to better advise clients on ESG investments

and allow portfolio managers and the funds team to select appropriate ESG securities and products. To address the growing

importance of ESG to WM clients and deliver on our ESG strategy, we formed a dedicated ESG team that works in an agile

way and is supported and overseen by our wider WM ExCo. The ESG team is staffed cross-functionally to combine a range

of skills and knowledge in order to accelerate the implementation of the ESG strategy across the three aforementioned pillars.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Sustainable finance

As of year-end 2019, WD managed assets under ESG mandates of nearly € 500 million, utilizing a variety of methodologies

to support our global client base. Utilizing MSCI ESG ratings data, our WD offering is based on a best-in-class approach, with

certain sectoral exclusions implemented to ensure consistency with our clients’ values. Our WD ESG offering generally

requires that a minimum MSCI ESG rating of 6 (on a scale of 10) be applied to instruments utilized in the construction of WD

mandates. In 2019, we expanded our WD ESG offering to serve our clients in the Americas and emerging markets, and we

will continue to increase the availability of offerings into 2020 for our European clients.

Our ESG product offering in Wealth Advisory covers funds as well as private and capital markets. When considering funds to

approve for addition to our dedicated product platform, our Global Funds Group (GFG) concentrates on three areas in selecting

and on-boarding suitable ESG funds for WM clients via their due diligence process: products identified as investing with an

ESG approach, impact investment products, and products that invest according to specific themes correlating to ESG

challenges. We prefer managers and boutiques that are PRI signatories, support ESG integration and shareholder

engagement, and clearly incorporate ESG principles into their investment philosophy, idea generation, and investment

process. Since 2019, we have been utilizing MSCI ESG ratings as a key reference to complement our qualitative assessment.

Our offering includes asset managers like Candriam (an early ESG adopter), DWS (a dedicated best-in-class ESG offering),

and Pictet (a leading thematic provider). Currently, we have 19 ESG funds on our global approved list. Client assets in ESG

funds grew markedly over the year (56 % at year-end 2019).

In capital markets, we now offer recommended lists for both equity and fixed income that include ESG leaders, i.e. companies

with an MSCI ESG Rating of AA or AAA. These lists enable clients to construct narrow or broad portfolios with exposure to

companies displaying strong ESG criteria. ESG & Impact Investing are one of four anchor themes for the Private Markets

platform that answers both the investors’ demand for ESG-friendly investment solutions and the need to offer solutions that

address the climate crisis. We currently have two live funds in the ESG Space: the Princeville Climate Technology fund and

the Closed Loop Leadership Fund. The Princeville Climate Technology fund focuses on growing tech-enabled companies that

have a positive climate impact. The Closed Loop Leadership Fund focuses on companies operating in the circular economy,

i.e. companies that can bridge the last link in the production value chain and generate value out of disused goods.

Asset Management

GRI 102-15/31/44, 305-5, FS11, FS12

In our AM, we continue to pursue ESG integration as part of our duty as a fiduciary partner. We see ESG as a value-enhancing

development for clients, as it enables a more comprehensive analysis for risk‒return expectations. In September 2019, we

announced the creation of a Group Sustainability Office in AM to integrate ESG capabilities across our platform with the aim

of positioning AM as a leader in the industry. Through the DWS Group, we are a signatory to the UN PRI and a Responsible

Investment Statement guides our ESG approach. AM’s progress in ESG integration has been recognized by the annual PRI

ratings, which can be seen on the AM website: PRI Assessment Report

Our ESG Engine continues to enable data-driven ESG analysis based on input from six leading ESG data vendors: ISS-Ethix,

MSCI, ISS-oekom, RepRisk, Sustainalytics, and Trucost. As a proprietary software system, it is the centerpiece of our

commitment to integrating ESG into our investment process and our Active and Passive portfolios. The structured ESG

information is embedded into portfolio management, thus supporting our due diligence process and enabling us to offer clients

bespoke ESG solutions. As the ESG Engine is fully integrated into the global portfolio management system and research

architecture for listed securities, all portfolio managers and research analysts who are responsible for liquid investment

strategies have access to a 360-degree assessment of issuers and investees. Both the availability and coverage of ESG data

enables ESG integration for our portfolios. For certain types of asset classes, we acknowledge challenges

with the data

coverage but are working to increase the coverage. In August 2019, AM announced it was entering into a strategic partnership

with Arabesque S-Ray

. Going forward, we plan to use S-Ray as an additional data vendor for our ESG Engine.

If required, our investment professionals regularly engage with the senior management of our investee companies to discuss

ESG topics, as well as a company’s fundamentals, strategy, and outlook. In 2019, the key engagement topics were corporate

governance issues (e.g. supervisory board independence or remuneration), but also environmental topics, such as

deforestation. For our European-domiciled funds, we have a quality approach to our governance engagements with companies

on our Proxy Voting Focus List. This is based on a thorough analysis of the independence and composition of boards,

executive compensation practices, auditors, overall company structure, and transparency. The analysis is based on available

information on governance quality, including documents on the investees’ websites, governance research, historic voting, and

engagement outcome. In cases where we identify gaps between our expectations on governance and a company’s attitude

towards it, we may decide to directly engage with the company representatives.

Our AM is committed to timely corporate governance topics and therefore reviews its Corporate Governance and Proxy Voting

Policy on an annual or ad-hoc basis. We also challenge whether our understanding of good corporate governance still prevails

As expected, ESG data availability for e.g. United States municipal bonds, high-yield bonds, small-cap issuers, or emerging market issuers is more heterogeneous, resulting in

lower coverage for portfolios pursuing these strategies.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Sustainable finance

in light of global market developments. Since 2019, this policy has put a stronger focus on companies’ adherence to

responsible investment or ESG standards, such as CDP or PRI. Participants of this review include the CIO for Responsible

Investments, the ESG Thematic Research Team, and the Head of Equity Research, as well as the Corporate Governance

Center and Communications. Greater emphasis is now placed on the respective board’s responsibility for ESG. According to

a recently published report by the U.K. campaign group ShareAction, AM also finished among the leading asset managers

globally in voting on shareholder resolutions linked to climate change. In a separate report published by majority action,

“Climate in the Boardroom: How Asset Manager Voting Shaped Corporate Climate Action in 2019”, AM was among the leaders

with over 95 % support of climate-critical shareholder proposals in 2019. These results confirm our AM’s strong record on

corporate engagement relating to ESG matters.

In 2019, we voted at a total of 2,043 meetings in 57 countries, an increase of 64 % on 2018 for our portfolios domiciled in

Europe and Japan. These meetings represented approximately 78 % of our equity assets under management in Europe and

Japan. We aim to gradually increase the number of meetings per year we vote at, while ensuring not to compromise on the

quality of our analysis. The results of our proxy voting and engagement are reported annually on our website. For the mutual

funds domiciled in the U.S., we strive to exercise the voting rights for all equity holdings. In 2019, we voted at a total number

of 9,466 meetings in 66 listing markets.

In classifying our ESG assets under management (AuM) we follow the methodology of the Global Sustainable Investment

Alliance (GSIA). In order to provide additional transparency, we decided to additionally break down our assets into the

categories as shown in the tables ESG and sustainable AuM and ESG in Alternatives.

As of December 31, 2019, we reported € 69.7 billion of ESG AuM, made up of € 51.6 billion of ESG and sustainable AuM in

Active and Passive, € 715 million of sustainable investment funds/impact investments, € 16.5 billion of real-estate investments

in certified green-labeled buildings, and € 862 million of infrastructure assets in renewable assets, within an overall asset

management volume of € 767.4 billion.

As of December 31, 2019, our Active portfolio management teams were responsible for € 40.7 billion of ESG AuM within an

overall Active AuM volume of € 515 billion. Our Passive portfolio management teams were responsible for € 10.9 billion of

ESG AuM within an overall AuM volume of € 155.8 billion. The growth of ESG AuM in Active and Passive reflected the launch

of a series of new ESG-focused ETFs, a series of conversions of retail and institutional funds, and net flows into our dedicated

ESG strategies. In 2019, the Alternatives portfolio management teams expanded the initiatives to integrate ESG into

investment processes across the various asset classes and were responsible for € 18.1 billion of ESG AuM (comprising

sustainable investments funds and individual real estate and infrastructure assets) within an overall Alternatives AuM volume

of € 96.2 billion.

ESG and sustainable AuM

In € m.

Dec 31, 2019

Dec 31, 2018

ESG within Active investments

40,686

28,922

Portfolios based on client-specific exclusions for institutional clients

24,662

N/A

Retail and institutional assets managed according to uniformly defined investment standards or client-specific

derivations

13,090

N/A

Particular sustainability themed ESG products

591

N/A

Third-party initiated mutual funds applying external ESG approach

2,343

2,270

ESG within passive investments

10,869

3,313

Exchange traded funds or products

2,452

N/A

Passively managed mandates for institutional clients

8,417

N/A

Total dedicated sustainable AuM within Active and Passive investments

51,555

34,505

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Sustainable finance

ESG in Alternatives

In €

Dec 31, 2019

Dec 31, 2018

Sustainable investment funds / Impact Investments

Private equity or debt funds focused on sustainable/impact investing, including public–private “blended finance”

funds with environmental or social objectives

715

595

ESG within Real Estate investments

Certified green-labelled buildings (Energy Star, LEED, BREEAM, etc.)

16,527

13,436

ESG within Infrastructure investments

Renewable assets, both in debt and equity investments, including solar, wind and waste-to-energy

862

Total sustainable AuM in sustainable investment funds, real estate and infrastructure within Alternative investments

18,104

14,893

Valuations of € 612 million of equity investments made within two of AM’s major infrastructure funds are per September 30, 2019. Equity investments are revalued each

quarter. Year-end 2019 figures will be made available in the context of Q4/2019 reporting to investors on March 30, 2020 and April 30, 2020 for the two funds. Debt

investment amounts are set and do not change unless debt is repaid.

We were able to successfully distribute dedicated ESG mutual funds founded on SDG contribution or analysis of green bonds

to retail investors through our Private Bank branch network in Germany. In 2019, we enhanced our passively managed product

portfolio by adding two U.S.-domiciled exchange-traded funds (ETFs) to our portfolio and an Xtrackers ESG MSCI Emerging

Markets UCITS ETF tracking, an index of companies meeting defined ESG criteria and low-carbon requirements based on

MSCI’s ESG research. The underlying index is part of the MSCI ESG Leaders Low Carbon ex Tobacco Involvement 5 %

Index series.

Several of our actively managed funds were also converted into dedicated ESG funds by adopting our internal ESG investment

standards (MESGS). The MESGS are built on the various pillars of ESG, apply market-common exclusions on controversial

sectors and violations of the UN Global Compact, and implement best-in-class methodologies, including the assessment of

climate transition risks and opportunities. In the first half of 2020, we plan to roll out our Climate Transition Risk and

Opportunities (CTRR) score to sovereigns and extend our assessment of climate risk with the incorporation of physical climate

risk through an additional data vendor. In 2019, we also tightened our evaluations of norm violations that now take human

rights violations more strictly into account. The new norm methodology now seeks severity reconfirmation across vendors,

includes non-strictly UN Global Compact controversies, aggregates multiple “less severe” controversies to treat them equally

as one severe controversy, and considers multiplicity of controversies. Last but not least, the approach puts more emphasis

on environmental- and human rights topics while comparatively putting less emphasis on governance topics, unless very

severe and reconfirmed controversies in this category are present. As a consequence of the recalibration, the number of F-

rated (i.e. firms with severe and reconfirmed violation of international norms) issuers now stands at 33 instead of 19 prior to

the recalibration. F-rated issuers in that category are not investable for AM mutual funds using our uniform ESG investment

standards.

We have piloted our derived ESG Key Performance Indicators (eKPIs, for example on CO

emissions or information on climate

change indicators of a fund) to give our investors transparency on the ESG contributions of the DWS Invest SDG Global

Equities fund on our website

. A key insight from the pilot is that AM aims at rolling this out to additional dedicated ESG funds

in 2020. We continue to develop our ESG methodology, especially with regard to carbon and climate risk sensitivity,

opportunities from impact investing, and the SDGs, by integrating them into the ESG Engine.

Real-estate investments

To further our commitment to ESG in real-estate investments, we announced the goal of halving carbon emissions by 2030

against the reference year 2017 for our entire portfolio of European office properties held by funds managed by the European

real-estate business. In setting this goal, we are furthering AM’s decade-long support (through our

Global Investor Statement

to Governments on Climate Change) in the topic of climate change and our commitment to the investors’ call on global leaders

to achieve the Paris Agreement climate goals. Cutting carbon emissions across the entire Europe office portfolio is estimated

to result in an annual reduction of 61,000 metric tons of carbon dioxide emissions – the equivalent of taking approximately

24,000 diesel cars off the road and saving around 23 million liters of diesel.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Sustainable finance

Sustainable investment funds

Our Sustainable Investments (SI) team within AM creates solutions for institutional investors, private investors, development

banks, and governments that share common social and environmental investment objectives and seek attractive financial

returns. SI operates investment initiatives ranging from financial inclusion and microfinance to sustainable agriculture,

renewable energy, and clean urban transportation. In 2019, we managed eight sustainable and impact funds with a combined

volume of € 715 million. Our ongoing partnership with a significant corporate client demonstrates the strength of our ESG

franchise. Moreover, AM has been highlighted for its key role in completing its first three acquisitions on behalf of its China

Renewable Energy Fund (CREF). The funds comprise a 75 % equity interest in three operational wind farms in the Hubei and

Hunan provinces for an overall installed generation capacity of 134 megawatt. This contributes to CREF’s plan of achieving

almost half a gigawatt of acquisitions for completion by the end of the year under review.

Sustainable investment funds

Fund

Mission/Information

Africa Agriculture and Trade

Investment Fund (AATIF)

Improve food security and end poverty through sustainable investment along the entire agricultural chain in

Africa

SDGs

1, 2, 8, 9, 13, 14, 15

European Energy Efficiency

Fund (EEEF)

Energy efficiency and renewable energy in the public sector in Europe

SDGs

11, 13

Essential Capital Consortium B.V.

Debt financing to health, energy, and financial service providers in low in-come communities in the developing

world (closed in 2019 and will be repaid)

SDGs

1, 3, 4, 5, 7, 8

Global Microfinance Funds III

Senior and subordinated debt financing for microfinance institutions and banks in the developing world, to

increase access to high-quality financial services

SDGs

1, 2, 3, 4, 5, 8

China Renewable Energy Fund

(CREF)

The fund’s objective is to generate investment returns and offset investors’ carbon emissions in their global

supply chain

SDGs

7, 13

Clean Energy and Environment

Fund (CEEF)

The fund intends to fund the growth of private companies that focus on developing clean energy and clean

technology sectors in China

SDGs

7, 13

Global Commercial Microfinance

Consortium II

Senior and subordinated debt financing for microfinance institutions and banks in the developing world, to

increase access to high quality financial services (closed in 2019 and will be repaid)

SDGs

1, 2, 3, 4, 5, 8

Microcredit Development Fund

Senior and subordinated debt financing for microfinance institutions and banks in the developing world, to

increase access to high-quality financial services

SDGs

1, 2, 3, 4, 5, 8

Organizational matters

32 Anti-nancial crime

37 Data protection

38 Information security

41 Public policy and regulation

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Anti-financial crime

GRI 103-1

Deutsche Bank is a leading European bank with a global footprint that provides a broad suite of products and services across

its Corporate Bank (CB), Investment Bank (IB), Private Bank (PB), Asset Management (AM), and Capital Release Unit. The

bank is exposed to diverse financial crime risks, including money laundering, terrorism financing, and sanctions, as well as

other criminal activities, such as fraud, bribery, and corruption. In line with its legal and regulatory obligations, Deutsche Bank

believes it is vital to combat financial crime in order to ensure the stability of banks and the integrity of the international financial

system. Failure to manage financial crime risks exposes Deutsche Bank and its employees to potential criminal and/or

regulatory liability, civil lawsuits, and a loss of reputation. Although it is not possible to eliminate these financial crime risks

entirely, commensurate controls must be in place to minimize these risks.

Given the strict and challenging regulatory and legal environment in which it operates, Deutsche Bank continually invests in

controls to enhance its management of financial crime risks. The media, authorities, and the general public have shown interest

in the perceived or actual control gaps, while the evolution of global market structures poses new challenges, for example the

emergence of new payment methods or fintechs. Deutsche Bank continues to be subject to various enforcement actions at

its main locations, requiring ongoing focus and disciplined execution. Deutsche Bank is currently subject to increased levels

of regulatory scrutiny and activities over its financial crime risk management. These regulatory activities have led to the

appointment of a number of external monitors, one of them being KPMG as the Federal Financial Supervisory Authority

(Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin) Special Representative to oversee the implementation of the

measures ordered by the BaFin.

If Deutsche Bank is unable to improve its infrastructure and control environment within given

timelines, its business operation, financial condition and reputation could be materially and adversely affected. In response to

these challenges, Deutsche Bank continued to actively improve its control environment during 2019.

Governance

GRI 102-15/17/20/29/31, 103-2/3

Deutsche Bank’s Management Board is ultimately responsible for the management and mitigation of financial crime risks. The

Management Board delegates tasks relating to these obligations to the Anti-Financial Crime (AFC) function. Since the

announcement of the new Management Board structure in July 2019, the Chief Risk Officer (CRO) has been the Management

Board member responsible for the AFC function. AFC is a second-line-of-defense (2LoD) control function, overseeing the

management and mitigation of the financial crime risks assigned as per the bank’s non-financial risk type taxonomy. The

business divisions as first line of defense are responsible for designing and implementing controls to mitigate the financial

crime risks emerging from their respective business activities and processes.

4 For further details on specific regulatory activities incl. the order issued by BaFin, see the Annual Report 2019, Notes to the Consolidated Balance Sheet, Note 27 –

Provisions.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Anti-financial crime

The financial crime risks managed by AFC are defined as and grouped in the risk themes described below:

– Risk of money laundering: If Deutsche Bank knowingly or despite reasonable suspicion employs an inadequate framework

of controls leading to Deutsche Bank products and services being misused to facilitate money laundering, terrorist

financing, and/or tax evasion;

– Risk of violating sanctions or embargoes: If Deutsche Bank knowingly or despite reasonable suspicion engages in a

sanctioned financial activity, including sectorial sanctions or project-based financing, or fails to take adequate measures to

prevent or detect circumvention of existing controls;

– Risk of bribery and corruption: If Deutsche Bank engages in bribery either as a company or via an employee, third party,

vendor, supplier, or intermediary, or provides products and services to clients in the public or private sector who abuse a

position of power for an improper or business advantage, thus directly or indirectly facilitating the misuse of funds or

financing by corrupt individuals or entities;

– Risk of fraud: If, either as a company or via an employee, Deutsche Bank performs any intentional act or omission, including

a misrepresentation that misleads or conceals, or attempts to mislead or conceal, in order to gain a personal or business

advantage, or to avoid a personal or business disadvantage; and

– Risk of failing to prevent “other criminal activities” that might jeopardize the institution’s assets (derived from section 25h,

German Banking Act).

Two of these risks – money laundering, and sanctions and embargoes – are classified as group-wide Top Risks. Failing to

manage any of these risks may have serious consequences for employees and Deutsche Bank. Hence, Deutsche Bank has

set up the AFC function as follows in order to handle specific areas of financial crime risk:

– To prevent money laundering and combat the financing of terrorism, AFC, through various functions, undertakes measures

to comply with rules and regulations regarding identification and verification of clients, including financial crime risk reviews

of clients and transactions; to develop, update, and execute internal policies, procedures, and controls; and to detect and

report suspicious transactions. In this way, valuable information is provided to regulatory and government bodies in line

with existing legal and regulatory requirements to support the fight against financial crime;

– The Sanctions and Embargoes (S&E) function is accountable for performing measures to comply with finance and trade

sanctions and embargoes, especially detecting, evaluating, and, if required, ensuring the observance of sanctions, law-

related publications, and binding requirements in connection with the financial and trade sanctions of the respective

authorities;

– The Anti-Fraud, Bribery, and Corruption (AFBC) function monitors and advises relevant functions, and administers controls

and safeguards to mitigate fraud, bribery, and corruption risks, for example with respect to vendor fraud, joint ventures,

offering and accepting gifts and entertainment, hiring practices, high-risk client relationships, transactions, and new

products;

– AFC Investigations (AFCI) is mandated to centrally and consistently manage and/or coordinate the bank’s response to

fraud and internal misconduct-related investigations allocated to AFCI, and to facilitate decision-making and escalation

processes via the AFC Governance Framework. After becoming fully operational at the end of 2018, AFCI acts to protect

Deutsche Bank’s integrity by ensuring it provides an impartial investigative response to fraud and internal misconduct in a

holistic and effective manner;

– As the Head of AFC is responsible for having an adequate risk management framework in place for all “other criminal

activities” that are not directly managed within the AFC function, a Global Financial Crime Governance Committee was

additionally established to provide governance and oversight of all financial crime risks mentioned above; and

– In addition, AFC works closely with various groups of experts and financial crime networks (e.g. the Joint Money Laundering

Intelligence Taskforce in the U.K. and the Wolfsberg Group of Banks) to assist its fight against financial crime.

From an organizational perspective, Deutsche Bank continuously developed the AFC function towards lean and sustainable

governance structures in 2019. In line with Deutsche Bank’s commitments to further strengthen the AFC function and in

response to regulatory requirements, the AFC function had approximately 1,400 employees (FTE) by the end of December

2019. An additional approximately 200 employees (FTE) were supporting AFC in a Shared Services function for controls

testing and quality assurance, risk management, management information, and training.

The “other criminal activities” are derived by and large from the German Penal Code and include, for example, theft, damage to property, robbery, cybercrimes, and antitrust.

Due to the thematic context and specific subject matter expertise relating to these risks, they remain with other infrastructure functions.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Anti-financial crime

Targets and measures

AFC has built the foundations across all risk types AFC is responsible for. Although Deutsche Bank continues to face severe

pressure across jurisdictions on financial crime matters, it can now focus on strategic investments and establish better

connectivity with the business and other control functions to further increase effectiveness. In order to execute this strategy,

AFC developed a holistic five-year plan for 2019 until 2024. By the end of the five-year planning cycle, Deutsche Bank intends

to have stabilized the environment for all core controls so that all AFC risks are constantly identified and assessed, employees

across the bank understand their role in fighting financial crime, risk appetite is well-defined and fully embedded across

business areas, client information is updated and of good quality, transactions are monitored across all relevant businesses,

locations and products to generate early risk insights, and Deutsche Bank deploys technology to move from detective to

preventative controls, wherever possible. This five-year plan will involve the following:

– Providing active support in designing and implementing better front-to-back Know Your Client (KYC) and monitoring

processes across the business, Operations, and AFC;

– Investing in a more focused manner in technology and modeling to improve the quality of transaction alerts and deliver

superior risk insights;

– Reducing reliance on external expertise, consultancy, and manual intervention in operational processes;

– Improving decision-making within AFC, and better aligning accountability and delivery by combining responsibility for

change and daily risk management; and

– Leveraging the community of Risk, Compliance, and AFC practitioners to improve risk management, change delivery, and

business engagement.

Deutsche Bank’s Risk & Control Assessment (RCA) process comprises a series of bottom‒up assessments of the risks

generated by business divisions and infrastructure functions (1LoDs), the effectiveness of the controls in place to manage

them, and the remediation actions required to bring the risks outside of risk appetite back into risk appetite. This enables both

the 1LoD and 2LoD to have a clear view of the bank’s material operational risks. In 2019, Deutsche Bank launched an

integrated risk and control assessment that combined the risk assessments led by AFC, Compliance, and NFRM in a

coordinated way. The coordinated approach aims to improve visibility across various risk types and to streamline risk

assessment processes, tools, and reporting across the three risk control functions, creating efficiencies and improving

engagement. Alongside the integration of risk assessments, Deutsche Bank further enhanced its central control inventory and

started the development of a new control assurance framework to enhance the transparency of control assurance activities

across various levels of Deutsche Bank.

Policies

The AFC Charter sets out the mandate and responsibilities of AFC across Deutsche Bank. Global AFC policies set the

minimum standards for the management of financial crime risks, which are supplemented by further, country-specific policy

requirements. All AFC policy documents are reviewed at least once a year to ensure that relevant new or revised legislation

and regulations are properly reflected, and to take into account any lessons learned. All Deutsche Bank employees are

required to comply with global and local requirements relating to internal policies.

The progress made in 2019 included materially upgraded KYC, AML, and Sanctions Policies that reflect the latest legal and

regulatory standards. A special focus for AFC in 2019 was to ensure regulatory adherence with the fifth Anti-Money Laundering

Directive (5AMLD) of the European Union

. Major progress has been made in reflecting all the respective requirements and,

generally speaking, in ensuring 5AMLD adherence is on track for Deutsche Bank. AFC successfully coordinated the

implementation and publication of the new KYC Policy and AML Policy in July 2019, as appendices to the existing policies.

Both policies replaced previous versions and became fully effective on January 1, 2020. The Group Sanctions Policy was

revised in May 2019 in order to comply with the group-wide requirements for policies.

5AMLD introduces: (i) Additional due diligence requirements for client relationships and transactions involving high-risk third countries; (ii) creation of beneficial ownership

registers for corporates and trusts as well as central bank account registers; (iii) AML regulations that will now apply to virtual currencies providers, real-estate agents,

auditors, external accountants, tax advisors, and art dealers; and (iv) lifting of the anonymity of electronic money products, such as pre-paid cards, and restricting the use of

these when the country of issuance is outside of the EU and regulation is not EU-equivalent.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Anti-financial crime

Training and awareness

GRI 103-1, 404-2

AFC Training & Awareness forms part of the AFC risk and governance frameworks to govern, mitigate, and report on financial

crime risks. Here, training is a key control measure in raising employee awareness to identify AFC-related risks and understand

how and when to escalate.

To ensure employees have the necessary technical knowledge and skills, and to keep pace with a constantly changing

regulatory environment, Deutsche Bank delivered a mandatory AFC curriculum developed via a robust year-on-year Annual

Training Needs Analysis process. This process engages key stakeholders across the second line of defense (2LoD) to identify

where training can help to mitigate AFC risks and identify training requirements arising from regulation, policy, and legislation.

Course development is managed via Training Advisory Groups comprised of internal subject matter experts. To support a

continuous cycle of improvement, training evaluations are conducted to improve course quality and assess the impact on

employees’ awareness. The 2019 AFC mandatory curriculum included updated courses on anti-money laundering, anti-fraud,

bribery and corruption, and sanctions. The course completion rate is very high, with minimal overdue ratios for late or non-

completion of mandatory training. Participation is monitored and delayed completion is escalated to an employee’s line

manager. This can result in red flags for employees or their managers, which are taken into account in annual promotion and

compensation decisions.

Through Deutsche Bank’s partnership with the Association of Certified Anti-Money Laundering Specialists (ACAMS), AFC

employees themselves have access to a wide range of learning resources and tools dedicated to AFC professionals.

Risk monitoring processes

GRI 102-15/31

Know Your Client

Know Your Client (KYC) is an ongoing process throughout the life cycle of a client relationship. As such, Deutsche Bank not

only needs to know the client (including their ownership structure, ultimate beneficial owners, and source of funds where

applicable), but also the anticipated nature of the client relationship. AFC and the business divisions continued to pro-actively

address KYC matters in 2019, especially by further improving the control environment via the various projects undertaken.

The New Client Adoption process governs the onboarding of potential clients with the intention that no funds or assets may

be accepted or transacted, nor any legal commitment entered into (e.g. operation of an account, sale of a product, or rendering

of a service), until this process has been completed, barring very limited circumstances (e.g. certain corporate finance

mandates and block transactions). As part of its regular client due diligence, Deutsche Bank screens its client relationships

against internal and external criteria, for instance relating to politically exposed persons, terrorism, or sanctions. As a

consequence, a client relationship may be declined or subject to monitoring or conditions imposed on accounts, transactions,

or product usage. In addition, payments are screened prior to being made (see below).

The High Risk Clients Review was completed as required in ten months, while simultaneously making improvements in core

aspects of the KYC process. In the Investment Bank (IB), Corporate Bank (CB) and Wealth Management (WM) divisions,

significant efforts were invested in KYC file quality improvement, with the IB and CB activities conducted under the BaFin

order covering KYC. However, further improvements in quality are still required. Significant progress has been made in

delivering the future IB and CB KYC client file management application. A new Client Financial Crime Risk Council, composed

of AFC, other 2LoD and business representatives, was set up to identify, monitor, and manage adherence to global risk

appetite at the client level, including periodic reporting on material client financial crime risks with the goal of de-risking the

bank’s portfolio by exiting clients of concern. This also contributed to the work undertaken to address the BaFin order regarding

correspondent banking.

A consistent Client Risk Rating Methodology (CRRM), which makes use of quantitative measures to calculate the individual

risk of every client, was rolled out to IB, CB, Capital Release Unit, and AM. Deployments for other businesses are currently

ongoing. Furthermore, AFC reviewed the CRRM in line with 5AMLD and incorporating correspondent banking-specific risks,

which will be rolled out in 2020. AFC also continues to work towards an enhanced methodology design that reflects the

specifics of the retail business.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Anti-financial crime

Anti-money laundering and prevention of terrorism financing

Despite AFC being able to enhance its control environment during 2019, media attention on Deutsche Bank, which mostly

related to legacy AML issues, remained high. Major improvements have been made to key technology controls such as Name

List Screening (NLS) and Transaction Monitoring (TM). NLS has been rolled out globally to ensure all clients are screened on

a daily basis against the applicable regulatory lists. A new TM system has been implemented in the U.S. and Germany focusing

on correspondent banking, which provides coverage of 95 % of the corresponding banking volumes globally. This tool will be

further rolled out as necessary to cover additional risks. Further, Deutsche Bank is continuously enhancing its TM capabilities

across all business lines and regions which includes the development of money laundering detection scenarios and rollout of

new systems.

By utilizing the AFC control environment, Deutsche Bank provided information that led to a successful raid on one of Europe’s

largest dark net money laundering infrastructures.

AFC also partnered with IB, CB, and the Capital Release Unit to enhance their account activity review process. This control

requires client coverage leads to assess whether transaction activity was consistent with the expected nature of the client’s

business and the purpose for which it maintains a business relationship with Deutsche Bank.

Sanctions and embargoes

The inherent risk regarding the complexity of sanctions regimes increased in 2019 due, for example, to sanctions against

Russia, Venezuela, and (temporarily) Turkey. In order to manage the intrinsic risk, Deutsche Bank has implemented several

measures, one example being the Russian Oligarchs Framework using a risk-based approach for clients who are or have a

nexus to Russian oligarchs. All relevant relationships have to be presented to the Regional Reputational Risk Committee for

a decision to maintain or exit.

Deutsche Bank implemented daily screening across its customer base and monitors all transactions against different

sanctions’ lists. This enables Deutsche Bank to stop transactions, end customer relationships, and avoid forbidden customer

relationships.

Anti-fraud, bribery, and corruption

GRI 103-2/3, GRI 205-1

The Anti-Bribery and Corruption (ABC) Policy, which was revised in 2019, sets out Deutsche Bank’s arrangements in

connection with the identification, escalation, and management of bribery and corruption risk, and the behavior expected by

all employees and with respect to associated persons and other third parties. In turn, the Anti-Fraud Policy sets out the bank’s

minimum standards in line with the identification, escalation, and management of internal and external fraud in compliance

with applicable obligations and within the risk appetite scope detailed in Deutsche Bank’s Financial Crime Risk Appetite

Statement.

Over the past two years, AFBC has made progress in improving controls and monitoring. For example, a tool was implemented

to manage the life cycle of business development consultants (BDCs), standardized request and monitoring processes were

implemented to manage gifts and entertainment (G&E) for 95 % of the total G&E volume, and monitoring was delivered for

BDCs and joint ventures. From a fraud perspective in 2019, the Fraud Monitoring Capability delivered improvements

particularly for online banking. Further enhancements apply to the areas of Risk Appetite Statement, Management Information

Strategy and Reporting, and enhancements through the Global Conduct and Internal Fraud Risk Management Framework

Policy.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Data protection

GRI 103-1, 102-15, 418-1, G4 DMA

Data protection has become a significant issue in societal awareness. As almost all Deutsche Bank’s business involves

processing personal data, protecting such data is a matter of special concern to the bank because of its commitment to legal

requirements, such as the EU General Data Protection Regulation (GDPR), as well as increasing expectations from clients,

employees, partners, and regulators.

Governance

GRI 102-16/20, 103-2/3

Deutsche Bank’s Group Data Privacy (GDP) department is a specialized and independent function controlling the collection,

processing, and use of personal data, and is complemented by a Data Protection Unit at Postbank. The team reports directly

to the Management Board and is supported by local Data Protection Officers in the countries where the bank conducts

business. The Management Board member responsible for Legal receives quarterly reports, inter alia, about new legal

developments and potential audit issues or incidents. Furthermore, it is ensured that regular exchanges on data protection

topics within our centralized and decentralized organization take place. In response to the increased controls required to

ensure compliance with the EU’s GDPR provisions, the bank is expanding its GDP department to ensure enough personnel

to monitor, test, and assess Deutsche Bank’s data privacy and protection processes.

Our data protection organization is set out in our GDP policies and procedures, which comprise data protection principles and

requirements, such as confidentiality, the need-to-know principle, or access rights requests. Since 2019, we have developed

a monitoring and testing framework to ensure an ongoing improvement process.

Deutsche Bank also contributes to the development and interpretation of industry-specific and prevailing standards on data

privacy and protection by participating in data protection committees and working groups, such as the Federal Association of

German Banks, IBM Guide Share Europe, and Bitkom. Developments in data protection regulations are regularly analyzed

and control processes revised accordingly. The same applies to technical developments and new digital business models.

A prominent example is the GDPR program, which involves a catalog of measures to meet the GDPR requirements. In 2019,

we also assessed and, where required, implemented measures derived from new data protection legislation, such as the

California Consumer Privacy Act in the U.S. or comparable legislation in Brazil and Japan.

Training and awareness

GRI 404-2

Employee training on the implications of privacy laws for the bank’s day-to-day business is a key factor in ensuring effective

data protection in all operational processes. The most noteworthy training measure is the GDPR e-learning program, which

was successfully rolled out and provided to our employees in 2018. After having reevaluated needs and the content of the

training programs across the bank in 2019, the data protection e-learning program was transferred to a new concept and now

includes requirements not only set out by the GDPR but also by other data protection regulations. With the development of

this new training concept, our previous year’s goal regarding training coverage has changed and we are now aiming to achieve

100 % data protection training coverage globally by 2020 in all countries where we conduct business – and thus even in

countries where GDPR is not applicable.

Current initiatives

In view of the changes currently taking place across the bank – the integration of Postbank and the establishment of the

Corporate Bank – organizational changes involving the processing of personal data have necessitated particular guidance by

our GDP department. In this context, the adoption of new technologies and digitalization have become rather important topics.

Against this backdrop, our GDP department accompanied the development of new digital products and initiatives along with

data-driven models. Our GDP department also provides legal advice across the bank and all its divisions whenever personal

data are being processed.

Furthermore, we are in the process of analyzing potential requirements from upcoming legislative or factual new tendencies

on an ongoing basis. Such trends include the EU ePrivacy regulation, which could have an impact on the design of corporate

websites and, in particular, their tracking mechanisms. Additionally, we are assessing the data protection implications of

political developments, such as the U.K.’s Brexit, or technical undertakings, such as cloud computing.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Information security

No substantial data breaches observed

Various reporting and escalation processes from our business to GDP were implemented to ensure that potential data

breaches could be assessed and handled in a timely manner. This approach, which was also outlined in a global data

protection procedure, entails analyzing potential data breaches in collaboration with other Deutsche Bank departments.

Should a data breach occur, coordinated follow-up actions would consist of communications to data subjects impacted and

information to the relevant data protection authorities. No data breaches of systemic relevance were observed in 2019.

Information security

GRI 102-15

Clients expect access to their bank’s services anytime, anywhere, and through a variety of channels. At the same time,

cyberattacks on businesses are increasing in scale, speed, and sophistication. Preserving the confidentiality, integrity, and

availability of clients’ and partners’ data and the bank’s information assets is essential for upholding the trust placed in

Deutsche Bank by clients, shareholders, employees, and society.

As the external threat landscape continues to evolve, information security remains a top risk for a bank. Deutsche Bank

acknowledges its responsibility to maintain and contribute to a stable and resilient global financial ecosystem and therefore

continues to invest significantly in its ability to mitigate security risks. In 2019, Deutsche Bank again strengthened its cyber

and physical security capabilities to keep pace with such threats.

Deutsche Bank’s group-wide information security strategy determines the bank’s activities, which are geared to protecting the

ability to deliver suitable products and services to clients, and thereby protecting revenue. In light of both internal and external

drivers, such as changes to the threats’ landscape, corporate strategy, technology, and the regulatory landscape,

Deutsche Bank’s strategic direction towards information security is regularly reviewed, confirmed, and underpinned by our

information security governance model. The current areas of focus for strategy development include the delivery of layered

protection mechanisms (defense in depth), enablement of secure cloud adoption, and transition to further strengthening the

threat-driven approach. This will provide a targeted, threat-based methodology to effectively maintain and continually update

the bank’s defenses. These strategic pillars are, supported by efforts to enhance the frictionless user experience through

streamlined processes and controls as well as automation.

In 2019, we continued to further enhance the security offered to our clients. The measures included the rollout of new strong,

two-factor authentication controls for more than 90 % of our online banking services worldwide with continuation of the roll-

out into 2020. Two-factor authentication requires our clients to provide two different forms of verification when accessing the

online banking systems. The solution offered by Deutsche Bank comprises secure mobile application using biometrics and

push notifications to provide our clients with a quick and secure way to access Deutsche Bank’s online services. Besides

greatly reducing the risk of fraudulent access to client accounts, the solution also ensures compliance with the EU’s Payment

Services Directive (PSD2).

Governance

GRI 102-20, 103-2/3

The Chief Security Office (CSO) is responsible for the bank’s security matters and for implementing technology and physical

security protection in accordance with the group’s risk appetite. CSO develops and drives the global implementation and

operationalization of the group-wide information security strategy, protecting the bank’s employees and assets. An IT Security

Committee with delegated authority from the Management Board’s Representative oversees all IT security activities, including

potential escalations. The Management Board receives a quarterly information security risk posture report as a comprehensive

status update on Deutsche Bank’s information security risk via a set of information security core topics presented by the Chief

Security Officer.

International standards and best practices are employed to structure Deutsche Bank’s information security policy landscape

and its implementation. The bank’s Information Security Management System has been certified to ISO 27001 since 2012

and is regularly re-certified. The governance framework and cybersecurity programs are regularly enhanced to ensure that

security policies and standards continue to keep pace with evolving business requirements, emerging cyber threats, and

regulatory guidance. Information security policies support Deutsche Bank in complying with these parameters and form the

basis for actively managing and governing information-security-related implementation processes.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Information security

Following the appointment of Divisional Chief Information Security Officers (Divisional CISOs) in 2018, the information security

management set-up was further strengthened in 2019 through the appointment of Principal Technical Information Security

Officers (P-TISOs). As the senior accountable officers for information security, the Divisional CISOs and P-TISOs are

responsible for ensuring alignment to Deutsche Bank policies and standards and strengthen the relationship between business

divisions, IT, and the Chief Security Office.

The mandate for Deutsche Bank’s CSO is complemented by a dedicated governance and operations unit at former Postbank

AG (with its own ISO 27001-aligned policy framework), now forming part of DB Privat- und Firmenkunden AG. The year 2019

saw further progress made in the integration of IT security activities within DB Privat- und Firmenkunden AG. The information

security framework was harmonized in various areas, in particular with regard to policies, processes and roles. A dedicated

Information Security reporting has been setup to enable a holistic overview on the information security posture across DB

Privat- und Firmenkundenbank AG. The alignment of security awareness measures leveraged synergies for Deutsche Bank

as a whole. Moreover, an analysis of consolidation opportunities for several information security services forms the foundation

for further functional and technical integration activities of these services.

Third-party risk

GRI 103-3

Reliance on vendors as well as all the outsourced products and services that support critical IT operations can increase the

bank’s risk posture. As new and evolving cyberattack vectors target vendors, this is leading to additional requirements for

oversight and continuous monitoring of vendor security, as well as increased regulatory activity in this space. Deutsche Bank

manages third-party risk through its vendor management program. This includes management of Information Security risks at

Deutsche Bank vendors.

In 2019, Deutsche Bank ratified its cloud strategy as part of its IT strategy. To support secure cloud adoption, a dedicated

cloud security function was implemented.

Defense against cyber threats

GRI 404-2

To protect its information and systems, Deutsche Bank takes a multi-layered, defense-in-depth approach to building

information security controls into every layer of technology, including data, devices, and applications. This delivers end-to-end

protection, while also providing multiple opportunities to detect, prevent, respond, and recover from cyber threats. This

approach is a key facet of the group-wide information security strategy to increase the security and stability of the technology

platforms.

In addition to prevention methods and controls, such as threat intelligence, data leakage prevention, vulnerability

management, and continuous employee awareness programs, high priority is also given to detection, backed by a robust

incident response process. Deutsche Bank’s security incident management covers unwanted or unexpected events affecting

the confidentiality, integrity, and availability of information assets, which may have an impact on Deutsche Bank, its clients, or

employees. The related management and escalation processes are designed to enable Deutsche Bank to respond effectively

to cyberattacks or information security threats, to minimize loss, leakage, or disruption, and to enable the use of information

gained through incident handling to continuously improve our processes.

The Cyber Intelligence and Response Centers (CIRCs) in Singapore, Germany, and the U.S. have been set up to provide

global 24/7 coverage across different time zones – a follow-the-sun model – and have thus improved the bank’s ability to

detect threats and respond to incidents worldwide. Through 24/7 monitoring, the CIRCs handle upwards of 2,500 items of new

intelligence every month, including alerts about potential cyberattacks. In 2019, the CIRCs did not detect any successful

cyberattack, such as Distributed Denial of Service (DDoS) attacks, phishing mails, or malware attacks that materially impacted

our systems, information assets, or client information.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Information security

Training and awareness

GRI 404-2

In 2019, we continued to roll out to all Deutsche Bank employees the global multichannel awareness campaign “Time to be

aware – the target is you”. This campaign covers a broad range of information and corporate security topics, including the

2019 Information Security Month featuring a month of activities at several Deutsche Bank locations. The goal of the campaign

is to help employees understand common yet significant security threats and their individual responsibility and contribution in

helping to protect the bank against these threats. The campaign therefore focuses on tips and relevant basic practices to help

employees protect themselves and the bank in their daily working life, both in the office and on the go.

Besides awareness measures, Deutsche Bank employees are regularly educated through mandatory training measures that

are complemented by specific training for individuals in specialist roles. In 2019, the Information Security Officer (ISO) and

Technical Information Security Officer (TISO) role holder training was substantially reworked and rolled out to all active role

holders in September 2019. This training equips these role holders with the skills and knowledge required to perform their

important security roles and is a pre-requisite for nominees to hold this designation.

Client awareness on cyber threats and how the bank protects their data and assets is a continuous area of focus. To this end,

we supply information material, e.g. explanatory videos, and stage events in all regions.

Dialog and collaboration

GRI 102-21

Deutsche Bank works closely with regulators to understand and collaborate on their requirements. At the same time, the bank

regularly engages with national and international security organizations, government authorities, and peer organizations to

share best practices and threat information. One such body is the Financial Services Information Sharing and Analysis Centre

(FS-ISAC), where Deutsche Bank is a member of the board. In Germany, Deutsche Bank was a founding member of Cyber

Security Sharing & Analytics (CSSA). This alliance of major companies across various industries that enables the exchange

of information to better detect and understand threats, and to enhance response actions.

As sharing relevant indicators of compromise (e.g. forensic data that identifies malicious activity in a system or network) and

further intelligence with other companies reduces the risk for all involved parties, Deutsche Bank has a dedicated team to

coordinate this exchange and further develop these relationships. Engaging stakeholders helps to ensure that we apply the

most up-to-date information security approaches and technology.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Public policy and regulation

GRI 102-15

As today’s operating context is confronted by an unprecedented level of policy and regulation, the risk of changing rules and

regulations is inherent in a bank’s daily business. Deutsche Bank uses a systematic approach that prioritizes significant

regulatory risks to the bank and allocates clear accountability for the identification, impact assessment, and implementation

of regulatory changes.

Governance

GRI G4 DMA

Deutsche Bank has a clearly structured framework that governs how it manages regulatory change risk and helps to build the

bank’s profile in regulatory policy debates. This enables Deutsche Bank to constructively engage with regulatory stakeholders.

It also ensures informed strategic decision-making, provides oversight and control over how key initiatives are implemented,

and delivers insights for senior management on upcoming public policy issues. The Regulatory Management Council (RMC)

supports this process by focusing on cross-bank issues in each stage of the regulatory adherence life cycle. To further

contribute to the policymaking process, Deutsche Bank provides political and regulatory stakeholders (e.g. governmental

organizations, policymakers, and supervisory authorities) with information and data that set out our business strategy and

determinants. Our global policy on engagement with supervisory authorities ensures consistent communications with

Deutsche Bank’s supervisory authorities. All employees must adhere to our global Gifts, Entertainment, and Business Events

Policy, which regulates the conduct and recording of any gifts and event participations offered by or accepted by

Deutsche Bank representatives.

Our Global Head of Government & Regulatory Affairs directly reports to the Chief Administrative Officer. A dedicated

Government & Regulatory Affairs team manages Deutsche Bank’s day-to-day relationships with its core authorities, identifies

relevant political and regulatory developments at an early stage, and coordinates group policy positions accordingly. In doing

so, Deutsche Bank aims to ensure compliance with the relevant political and regulatory requirements (inbound) and include

industry-relevant topics in public discussions (outbound). Deutsche Bank’s Government & Public Affairs offices in Berlin,

Brussels, and Washington, D.C., manage the relationships with key policy makers and provide them with information and

data, while setting out the bank’s business strategy and its determinants. We also liaise with our Country Management in

Beijing to cover China.

Employee‒stakeholder interaction

GRI 102-21

Deutsche Bank sets clear rules and procedures for interactions between employees and external political and regulatory

stakeholders. The interaction with core regulators in the U.S., Europe, Hong Kong, and Singapore is governed by the

Supervisory Authorities Engagement Policy, which obliges all interactions to be logged and minuted by the relevant Regulatory

Management team. For interactions with EU institutions, the mandatory policy on Pre-Clearance of All Communications with

EU Institutions to Discuss Policy Issues sets standards for consistent communication at an EU level and centralized clearance

of all contacts with EU officials. In the U.S., Deutsche Bank acts in line with the internal policy on Political Contributions in the

U.S. and U.S. Lobbying Activities.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Public policy and regulation

Financial transparency

Deutsche Bank is a signatory to the EU Transparency Register, which requires the bank to disclose certain financial data and

comply with the underlying code of conduct. In the U.S., Deutsche Bank is registered with the Office of the Clerk of the Senate

and Clerk of the U.S. House of Representatives, and files a quarterly disclosure on all relevant legislative issues with the

Office of the Clerk of the House of Representatives. Furthermore, Deutsche Bank America’s Political Action Committee (PAC)

is regulated by the U.S. Federal Election Commission (FEC) and the bank makes both monthly and annual public filings to

the FEC. All contributions to the PAC are made voluntarily by Deutsche Bank employees and no funding or contributions from

the bank are allowed by law. Furthermore, Deutsche Bank does not permit direct or indirect donations to political parties. Pre-

approval from Anti-Bribery and Corruption is required for donations to political-party-affiliated organizations or involvements

referring to the governmental or political party arena.

Key topics in 2019

GRI 102-12/44

Our Government & Regulatory Affairs team regularly defines a set of key topics that will determine Deutsche Bank’s focus for

the period of one year. In 2019, these topics related, inter alia, to the digitalization of banking and society, the renewal of the

Eurozone, Brexit, the European elections, and the sustainable finance agenda. On each issue, Deutsche Bank convened and

participated in seminars, public panels, and individual conversations with policy makers. As sustainable finance and the digital

agenda were topics of particular interest throughout 2019, a more detailed overview on both topics is provided below.

Sustainable finance

GRI G4 DMA

The political and regulatory agenda in many jurisdictions delivers clear supervisory expectations for banks to manage

sustainability risks with a focus on climate-related risks. One of the main topics that accompanied us through 2019 was

sustainable finance, along with the associated opportunities for and impact on Deutsche Bank. In March 2018, the European

Commission published their action plan on sustainable finance. The focus of this action plan is on the reorientation of capital

flows towards investments, taking environmental, social, and governance considerations into account. This action plan aims

to manage financial risk and, to tackle climate change and related demands in order to foster the transparency of products

and corporate strategies.

Legislation on sustainable finance of relevance to Deutsche Bank is mainly driven at EU level, with the EU action plan on

sustainable finance continuously evolving. In 2019, Deutsche Bank monitored its progress and its effect on the bank’s

operations. Deutsche Bank welcomes the activities of the European Commission as an important milestone to help the EU

deliver on its Paris Agreement climate goals and wider sustainability agenda.

In 2019, we noted several central bank initiatives, which we deem relevant for the future of sustainable finance regulation. The

Network for Greening the Financial System (NGFS), which is made up of 40+ central banks and supervisors, issued a report

to coordinate their work on risk management, stress tests, and scenario analyses, as well as the central banks’ own portfolio

management and assets. The German financial supervisor BaFin published a draft Guidance Notice on Dealing with

Sustainability Risks, which aims to set non-binding standards for German financial firms. The U.K.’s Prudential Regulation

Authority (PRA) published a Supervisory Statement in April 2019, laying down supervisory expectations for supervised firms

to take a strategic, board-driven approach to managing climate risks.

As part of a broad sustainable finance network, Deutsche Bank is in a position to identify, assess, and react to material

developments globally. We take part in a number of sustainable finance working groups in several trade bodies, on a global,

regional/EU, and German national level. We are also a member of the Sustainable Finance Advisory Council, which was

inaugurated by the German Federal Government in June 2019 to support the development of a national sustainable finance

strategy. By engaging with this council, Deutsche Bank discusses developments in sustainable finance with trade

associations, such as the Association for Financial Markets in Europe (AFME), the European Banking Federation (EBF), and

the Association of German Banks (Bundesverband deutscher Banken, BdB), and regularly responds to consultation and

discussion papers. For example, Deutsche Bank responded directly to consultations from the European Banking Authority

(EBA), the European Securities and Markets Authority (ESMA), the Network for Greening the Financial System (NGFS), and

the Technical Expert Group (TEG). The topics covered were sustainable finance on alleged short-termism in financial markets,

on the assessment of “green” (sustainable) and ”brown” (conventional ) financial assets, and a detailed EU sustainability

taxonomy.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Public policy and regulation

Digital agenda

In addition to sustainable finance, a great deal of interest has been directed to digitalization and fintechs. Following the

publication of the European Commission’s Fintech Action Plan in 2018, regulatory bodies and policymakers within the EU and

its member states have started to set the groundwork for responsible technological innovation.

After an initial phase with a strong emphasis on research and monitoring, there have been regulatory and policy proposals on

artificial intelligence (AI), cyber and operational resilience, virtual assets, as well as data and online platforms. In particular,

these proposals include, but are not limited to, the following:

– EU Commission High-Level Expert Group’s Ethics Guidelines for Trustworthy AI, including a comprehensive assessment

list;

– EBA Guidelines on outsourcing (incl. outsourcing to cloud service providers);

– Consultation on proposed amendments to requirements in relation to outsourcing arrangements by the Monetary Authority

of Singapore (MAS);

– EBA draft Guidelines on ICT and security risk management;

– EU Regulation on online intermediaries, aiming to address power imbalances between platform providers and their

business clients; and

– Discussion papers by the German government on electronic securities and initial coin offerings recommendations by the

Expert Groups on competition law, data, and algorithmic systems.

Deutsche Bank participated in the EU piloting process on the AI Ethics Guidelines and Assessment list, its contributions to the

above-mentioned EBA Guidelines, and its engagement in the Fintech Taskforce of the European Central Bank (ECB). This

helped in understanding the relevance those topics have for the bank and in working towards a regulation that does not create

obstacles to innovation. Together with trade associations, such as AFME, the European Banking Federation (EBF), the BdB,

or the European Financial Services Roundtable (EFR), Deutsche Bank actively partakes in the public debate and develops

industry-wide positions, for example with regard to the creation of an effective data economy, which from our perspective

requires a cross-sectoral framework for data access, based on client consent and standard formats and timing.

Employee-related

matters

45 Employment and employability

52 Key employee gures

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Employment and employability

GRI 103-1

In this chapter, we describe the management approaches, targets, and results relating to workforce management and an

inclusive work environment. Information on further employee-related aspects, such as employee engagement, performance

management, and health management, is published in our separate Human Resources Report

People strategy

GRI 103-1/2/3

Deutsche Bank’s success largely depends on the ideas, competence, commitment, and health of its employees. That is why

the bank attaches great importance to offering its employees an attractive working environment so they can help the company

to become more innovative. The bank’s Human Resources (HR) agenda seeks to create an environment where people can

work in partnership and are enabled to deliver sustainable organizational performance.

Workforce trends are driving the people practice roadmap:

– New working practices: Agile working practices accelerate innovation and are leading to greater customer focus, iteration,

and consultation;

– New behavior patterns: To stay attractive Deutsche Bank needs to ensure work flexibility, a sound work‒life balance, and

investment in the working environment;

– Demographic change: In 2025, 72 % of the bank’s workforce will be millennials (those born between about 1980 and 2000).

Career paths have been redefined. Freelance and interim roles are increasingly becoming a preferred form of employment;

and

– Changing skill requirements: Strong up-skilling or reskilling requirements need to keep pace with the trends, driving the

bank’s business model across the divisions.

These workforce trends are reflected by individual Management Board objectives, which have been agreed with the

Supervisory Board. They include:

– Investing in workforce management by implementing restructuring measures, changing the way of working, and

strengthening the talent and development agenda; and

– Further embedding diversity and inclusion in all people processes.

Governance

GRI 102-16/20, 103-2/3

HR has a clear governance structure, with global priorities and standards defined and monitored by the Global HR Executive

Committee. This includes the Global Heads of HR, the business divisions, infrastructure functions, and entities sharing

responsibility for HR management, as well as the HR Heads responsible for processes and products in the regions. The bank’s

Code of Conduct is designed to ensure that Deutsche Bank as a whole conducts itself ethically – with integrity, and in

accordance with outlined policies and procedures as well as the laws and regulations in all operating regions. The Code is a

general guide, underpinning a basic principle that we should do what is right and proper. Deutsche Bank also takes external

frameworks, standards, and principles into account, such as the new guidelines for Human Resource Management –

Guidelines for Internal and External Human Capital Reporting issued by the International Organization for Standardization

(ISO 30414) in December 2018.

Policies are a fundamental part of the bank’s internal control environment. The global HR policies cover a wide range of HR

topics, such as hiring, managing, and developing performance and careers, the assessment of the suitable members of

management bodies and key function holders, international assignments, diversity and inclusion, compensation, offboarding,

termination, and employee-related incident management. Additionally, there are guidelines and policies for performance

management procedures, disciplinary and dismissal procedures, grievance, and anti-harassment and bullying procedures, for

example.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Employment and employability

HR-related topics are presented to the Management Board, Supervisory Board, and senior management on a regular basis.

For example, the Management Board receives monthly updates on FTE development and the progress of restructuring

measures, while the Supervisory Board receives monthly reports on employee turnover.

The monthly HR Controls Dashboard was implemented in late 2018 and serves as a detective control measure to monitor

HR’s operational performance in managing employee life cycle risk. It provides an overview of the results of a total of 51 HR-

owned controls that are listed in the Non-Financial Risk Management Controls Inventory and thereby allows for identification

of potential risks in HR’s control environment. The results are presented to the HR Performance Review Council, which decides

upon necessary follow-up activities or escalations if control results are outside of risk appetite. For example, the HR Controls

Dashboard triggered a process change relating to candidate background screening in Germany, which helped to reduce the

number of missing prior work experiences by an average of 36 % in the first half of 2019 (due to the implementation at the

end of 2019, the year-on-year development cannot be assessed). The HR Controls Dashboard thus helps to strengthen the

control environment of HR.

Workforce management

GRI 103-2/3, 404-2

Restructuring

GRI 102-8/10/41, 103-2/3, 401-2, 404-2

Restructuring is a topic that spans the entire banking sector, not least due to the pace of digitalization. Deutsche Bank is no

exception. On May 29, 2018, the Management Board announced that the number of full-time employees would be reduced to

less than 90,000 by the end of 2019. On July 7, 2019, the Management Board announced moves to improve efficiency and

infrastructure, which included reducing the workforce to approximately 74,000 by 2022.

As of December 31, 2019, Deutsche Bank had reduced its number of employees by approximately 4,100 (-4,5 %) to 87,600.

Reductions across all regions driven by Capital Release Unit

(-1,329; -52.4 %), Private Bank

(-1,149; -3.0 %), Infrastructure

(-1,784; -6.1 %), and Asset Management

(-88; -2.2 %) offsetting by Corporate Bank

(+75; +1.0 %), and Investment Bank

(+135; +1.4 %). In 2019, business-critical external roles, especially in IT, were again insourced.

In executing this strategy, Deutsche Bank remains committed to carrying out staff reductions in a transparent and socially

responsible manner, with the close and constructive cooperation with employee representatives and social partners marked

by mutual trust.

The bank cooperates with employee representatives and their bodies on the basis of the relevant national legal regulations.

Germany’s Works Constitution Act (Betriebsverfassungsgesetz, BetrVG) governs the involvement of works councils by

stipulating their rights and duties and by prescribing the cases and form in which employers are required to involve a works

council. With members elected every four years, these councils represent the employees’ interests through entering into

discussions and negotiations with Deutsche Bank as an employer. The bank’s executive employees have their own

representative body, which is also governed by German law (Sprecherausschussgesetz).

On the basis of the agreement on cross-border information and consultation of Deutsche Bank employees in the EU,

concluded on September 10, 1996, all employees in the EU are represented by the European Works Council. This adds up

to around two thirds of the bank’s total workforce. As German law prohibits us from asking our employees whether they are

members of labor unions, there is no record of how many of the bank’s employees are union members.

Deutsche Bank’s holistic change concept, which is embedded in the bank’s social plan, provides support to employees

affected by restructuring measures by promoting employability and offering individual coaching in change scenarios. A

comprehensive set of measures and systematic assistance is available to employees, managers, members of the works

council, and HR advisors involved in change processes. Furthermore, the concept supports the bank’s strategy to fill open

jobs with suitable internal candidates as well as to utilize a dedicated network of external partners to identify job opportunities

outside the organization. In 2019, approximately 2,000 employees made use of the various offerings (2018: 1,500 employees).

Employees (Front office full-time equivalent)

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Employment and employability

Recruiting and talent development

GRI 401-1, 103-1/2/3

Even in the context of implementing the above-mentioned restructuring measures, recruiting talent continues to be a key

priority for Deutsche Bank. Thus, filling front office roles in growth areas (e.g. Global Transaction Banking, Wealth

Management and Asset Management), replace voluntary staff turnover in operation centers vacancies was again a priority in

2019, as was hiring talent to meet the growing demand in regulatory roles (e.g. Anti-Financial Crime, Audit, and Compliance).

Additionally, talent acquisition focused on insourcing 881 external roles (2018: 1,207), particularly in IT, as well as hiring

1,622 graduates and vocational trainees (2018: 1,517).

The average time required to fill vacant positions was 56 days (2018: 61 days) and the average time required to fill critical

vacant business positions 15 days (2018: 24 days).

Graduates and vocational trainees

Deutsche Bank remains committed to the strategic priority of hiring graduates, as they contribute to the bank’s change agenda

by building a skills’ set that better aligns to the needs of the future workforce and clients, and to diversifying the organization.

In 2019, 955 graduates were hired (2018: 910 graduates). This increase was due to additional investments in the Corporate

Bank (CB) and PB and the bank’s Technology function as part of the efforts to reinforce the bank’s capability and engineering

culture in this space. For the second time, the bank ran two separate orientation and training programs, one regionally in India

for the bank’s local Technology cohort and one in London, as in previous years.

Vocational training and dual studies are an important component of the bank’s junior staff strategy. Particularly in Germany

they offer an additional opportunity to attract young talent to Deutsche Bank. Thanks to a targeted marketing strategy

(#dbKarrierestart

) and the bank’s Insider Initiative, implemented in 2018, more qualified applications were attracted than in

previous years and 667 new vocational trainees hired in 2019 (2018: 607).

Internal career mobility

As the bank works toward its headcount targets, a new process for hiring was implemented to restrict external hiring to

positions that are viewed as critical to the bank’s success and future growth, with a greater emphasis on internal mobility and

identifying tasks that can be discontinued. The selective hiring guidelines have to be seen in the context of the bank’s cost

and people development targets. Managing headcount through natural attrition has the potential to save jobs. The bank also

becomes more efficient as managers are challenged to identify tasks that can be discontinued or where technology can be

utilized more effectively. Finally, the development opportunities for existing talent have to be maximized.

Internal mobility plays a vital role in developing and retaining qualified and talented employees and in keeping their expertise

and experience within the bank. In 2019, Deutsche Bank continued to develop and embed its internal mobility strategy and

uphold its commitment to filling vacant positions with suitable internal candidates. Reflecting the changing skill requirements

(see above), the goal is still to replace a third of all vacant positions with internal candidates.

All vacant positions are first advertised to internal staff for at least two weeks. Prioritizing internal candidates helps employees

affected by restructuring to find new roles at the bank. Cross-divisional mobility is also promoted to enable employees to

expand their skills and experience for rounded careers. Furthermore, internal mobility helps to reduce the bank’s redundancy

and recruitment costs.

In 2019, 37.6 % (2018: 37.2 %) of all job vacancies were filled internally (excluding Postbank). Particularly at the Managing

Director (MD) and Director (D) levels the internal fill rate was above average at 40.2 % (2018: 40.5 %). This was also true at

the experienced Vice President (VP) level, with 47.5 % of vacancies filled internally (2018: 47.8 %). In Germany, the figure

was 67.7 % (2018: 65.4 %) due to redundancies caused by restructuring measures as well as changes resulting from

digitalization and control functions. Filling positions internally through proactive redeployment efforts resulted in savings of

€ 32 million in 2019 (2018: € 39 million). In all, 76.9 % of business-critical positions were filled internally (2018: 61.5 %).

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Employment and employability

Leadership development

For several years, leadership development programs have been successfully run across Deutsche Bank. As part of the

commitment to keep the bank’s leaders “fit for the future of work”, 2019 saw significant changes and improvements in how

leaders who are a key part of the organization’s culture and transformation are developed.

Deutsche Bank’s Leadership Capability Model and its values and beliefs define what is expected from leaders. They also

provide a shared view of the capabilities that are vital to leading employees and ensuring business success in line with the

bank’s strategy and culture. In 2019, this model was updated and refreshed to reflect the changing future of work, the

requirements of a leader in this digital age, and the new strategy. All leadership and talent development programs are aligned

to this model.

October 2019 saw the launch of the new approach to leadership development based on a more flexible, user-focused model.

Panels of leaders across the organization helped to design learning content that comes in a more bite-sized format, replacing

large long-term programs with short learning workshops, including virtual learning alternatives for small locations. These

alternative forms are embedded in learning journeys that include articles, videos, podcasts, and other online resources.

Leadership development needs to be available at the moment of need and HR is working on more ways to deliver this,

including piloting virtual coaching for leaders of complex teams.

A key focus is on new leaders and helping them to grow into a new role (or to acclimatize themselves to the leadership

philosophy if hired externally). To this end, HR created an interactive tool for leaders to help them understand the bank’s

processes, culture, and key regulatory requirements – as well as how to support and develop their teams.

A key part of the content of this new leader guide relates to the bank’s commitment to creating a climate where employees

are encouraged to speak up. In 2019, all employees were provided with a digital guide focusing on behavior that underpins a

speak-up culture. This guide aims to signpost the employees to learning paths of digital resources, including facilitated virtual

classrooms covering topics such as listening and feedback.

The bank’s leaders are now in a position to take care of their own development and select whatever learning content is

appropriate to them. The new approach means that learning content can now be offered to all the bank’s leaders (including

those leading in a project context) rather than just a selected cohort chosen by hierarchical criteria. Furthermore, employees

aspiring to a leadership role can access this learning, too.

Talent acceleration

To help employees develop professionally and personally and advance their careers, Deutsche Bank’s talent acceleration

programs follow a cross-divisional approach. In 2019, Postbank was fully integrated into Deutsche Bank’s acceleration

programs.

The Accomplished Top Leaders Advancement Strategy (ATLAS) is a highly visible acceleration program for senior female

MDs. Since its launch in 2009, there have been five programs and the 2018‒2019 cohort was the largest to date with

21 participants. The program follows a twelve-month structured development journey with bespoke individual development

and is aimed at increasing the number of women in senior positions across the bank. A full 100 % of active alumnae have

moved into more senior roles.

The bank-wide Director Acceleration Program launched in 2017 had 169 participants in 2019, with 42 % of them women (2018:

152 participants with 36 % women). This twelve-month program includes classroom modules and individual coaching

elements.

The VP Acceleration Program completed its fourth year in 2019 and had 490 participants, with 39 % of them women (2018:

494 participants with 41 % women). The VP program is delivered across five regions.

A third of the Director Acceleration Program’s participants are now MDs and 40 % of VP Acceleration Program’s participants

have been promoted to Director. Overall, the retention and mobility rates for both Director and VP Acceleration Programs are

higher than the benchmark population.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Employment and employability

Future-oriented work environment

GRI 103-1, 401-2, 404-2

In July 2019, Deutsche Bank embarked on its journey to transform the bank into an organization that is inspired by clients and

continuously designed by employees. To achieve this aim, it is necessary to change the way we work, not least by taking into

account demanding and even disruptive developments.

The continuous need to make decisions in this environment not only demands knowledge and experience from employees,

but also a high degree of willingness and the ability to adapt to new and hitherto unknown circumstances.

Designing effective and future-oriented HR work therefore means explaining to existing and future employees the sense,

direction, and orientation of Deutsche Bank’s path and strategy in a fast-moving business environment. The speed with which

internal and external changes are recognized and the effectiveness of the response in creating added value for stakeholders

will be critical for success in the future.

When it comes to innovation, employees are the key to success. This is why Deutsche Bank encourages their intellectual

curiosity, focus on lifelong learning, and courage to try things out. The bank promotes a corporate culture that rewards

innovative, agile, and creative work.

Furthermore, the outcome of demographic and cultural change, generation diversity, and increased mobility (to mention just

three factors) will be a change that requires completely new approaches. As an employer, Deutsche Bank can only stay

competitive if it proactively shapes its response to these challenges.

Today, Deutsche Bank is already preparing its employees for these changing requirements – both professionally and mentally.

In addition to contemporary learning opportunities and coaching, this includes a wide range of health-care offerings and

opportunities to combine personal and professional life.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Employment and employability

Inclusive culture and work environment

GRI 103-2/3, 405-1

We are committed to an inclusive culture that respects and embraces the diversity of employees, clients, and communities,

as demonstrated by a continuing focus on:

– Building talented and diverse teams to drive business results;

– Creating a respectful and inclusive environment where people can thrive; and

– Strengthening relationships with clients, partners, regulators, communities, and potential employees.

We aim to attract, develop, and retain the best people from all cultures, countries, races, ethnicities, genders, sexual

orientations, abilities, beliefs, backgrounds, and experiences. To this end and to prepare for opportunities and challenges

arising from changing demographics, digitalization, and the future of work, the bank follows an integrated and multi-

dimensional approach to diversity and inclusion.

Throughout 2019, we continued our journey to embed diversity and inclusion in our people practices. The key focus areas

were as follows:

– Renewing the bank’s commitment to improve gender diversity: Given that the previous voluntary declaration to substantially

raise the proportion of all female managers globally ended at the end of 2018, the Management Board agreed to set

voluntary next-level goals that became one of the Balanced Scorecard KPIs of the Management Board members and of

the management level below (see “Gender diversity”);

– Improving diversity through talent attraction: Embedding diversity into the renewed Employee Value Proposition, targeted

campaigns to attract more women to the bank, and projects to attract and retain people across generations (see “Gender

diversity”);

– Strengthening cross-generational collaboration and dialog: Regional Employee Resource Group-driven Reverse Mentoring

programs and wider platform-based Reverse Mentoring offerings (see “Inclusive work environment”); and

– Advancing LGBTQI (Lesbian, Gay, Bisexual, Transgender, Queer, Intersex) inclusion worldwide: Honoring 50 years of

LGBTQI Pride worldwide and taking the bank’s responsibility to both business and society seriously by, for example,

intensifying collaboration with coalitions and influential platforms advocating a more inclusive and just world (see “Inclusive

work environment”).

Gender diversity

GRI 103-2/3, 405-1

Throughout 2019, Deutsche Bank continued its efforts to advance women in the workplace.

With seven women on the Supervisory Board, the figure stood at 35 % at the end of 2019 (2018: 30 %). This met the statutory

requirement of 30 % for listed and co-determined German companies under the gender quota legislation introduced in 2015.

The Supervisory Board’s latest target for the Management Board was set in 2017 as at least 20 % female members by June

30, 2022. Given a Management Board size of between eight and twelve members, two women are required to achieve this

goal. At the end of 2019, there was no woman on the Management Board. On January 1, 2020 one woman responsible for

the bank’s businesses in the Americas joined the Management Board. Within the Diversity Principles of the Suitability

Guidelines for selecting the members of the Management Board, the Supervisory Board is working towards the 2022 target.

As of year-end 2019, 19.7 % of executive positions at the first management level below the Management Board were held by

women (2018: 20.8 %). At the second level below the Management Board, the figure was 19.5 % (2018: 20.9 %). In

accordance with the legal requirement in Germany, the bank set targets of 20 % (at first management level) and 25 % (at

second management level) for December 31, 2020.

While women’s representation at Deutsche Bank is not where the bank wants it to be, HR continues to monitor and report on

progress made to the Management Board. The variety of measures already in place includes talent development programs,

manager training, best practices on people-related decisions, internal monitoring, and significant support for grassroots,

employee-driven initiatives.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Employment and employability

The Management Board remains committed to increasing the representation of women in leadership positions. In March 2019,

the Management Board decided to restate the voluntary group-wide aspirational goals for the representation of women. Since

transparency facilitates change, the goals for December 2021 have been disaggregated to focus on the top three corporate

titles individually (in headcount terms): MD (21 %), Director (D) (28 %), and VP (35 %, excluding Postbank). This will also

strengthen the internal pipeline for the two levels below the Management Board. Deutsche Bank firmly believes that an

improved gender balance in leadership roles will meaningfully contribute to its future success.

As of year-end 2019, women made up 18.3 % of MDs, 25.1 % of Ds and 31.4 % of VPs. Monitoring against Diversity goals

also include promotions at the beginning of 2020. Including promotions, we have achieved 18.9 % for MDs, 25.9 % for Ds and

32.6 % for VP (excluding Postbank).

Inclusive work environment

GRI 102-12, 103-1

We recognize the importance of effective collaboration across generations in the workforce to benefit from multiple ideas and

every perspective. We know it is important to recognize the different needs of generations, too. This involves providing the

benefits and support for each stage in life and opportunities for employees at every stage of their career. For details of the

age structure please see the table of key employee figures.

As well as our reverse mentoring program, in which younger employees coach older colleagues, that continues to expand

across the globe, our Employee Resources Groups remained active on generation topics throughout the year under review:

– dbGeneration: Its Future of Work series continued in 2019 with an event exploring how we ready ourselves for the changing

face of the job and working environment. Experts on longevity, social justice, and work patterns explored the impact on

different generations and an aging population;

– NextGen groups in the U.S.: In New York, leaders are actively engaged in becoming mentees on their reverse mentoring

program, with high-touch matching activity and follow-up on pairings continuing; and

– dbFamily initiative in the U.K.: Support and information to members continued with generation-spanning events on coping

with long-distance caring, and mental health, well-being, and resilience in young people.

Employees continue to receive support throughout the working life cycle, such as family responsibilities from childcare to elder

care, a range of flexible working options, and employee benefits to suit different career stages.

As one of many activities to support LGBTQI inclusion and support the bank’s LGBTQI colleagues, Deutsche Bank has a long-

standing Allies program. These visible Allies, who themselves do not self-identify with a particular LGBTQI group, play a key

role in fostering a culture of inclusion across the bank. As leaders and advocates of change at all levels of the organization,

they are helping LGBTQI employees to feel safe at work, bring their whole self to work, and subsequently also be more

productive.

During almost 20 years of experience in diversity and inclusion, a number of key external partnerships have been built across

the globe. These partnerships not only help Deutsche Bank to drive its internal agenda. They also enable good practices to

be shared and boost the bank’s positive impact on the societies it operates in. Deutsche Bank is convinced that this helps to

strengthen relationships with clients, partners, and communities.

– In Germany, the bank is a founding member and currently management board member of the Charta der Vielfalt (Charter

of Diversity), an association under the patronage of Chancellor Angela Merkel that actively fosters diversity in the

workplace; and

– Elsewhere, Deutsche Bank is a founding signatory of the U.K. Treasury’s Women in Finance Charter, promoting a more

gender-balanced financial services industry. It is also partnering with Open for Business, a coalition of global companies

that presents and promotes the business and economic case for LGBTQI rights.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Key employee figures

GRI 102-7/8, 103-3, 401-1, 405-1

Key employee data are shown below. For full details as well as our strategic HR priorities and achievements, please refer to

the 2019 Human Resources Report.

2019

2018

Deutsche Bank

Group

Thereof:

Deutsche Bank

Group

Thereof:

Deutsche Bank

Employees (FTE)

1,2

87,597

25,326

91,737

26,728

Recruitment and talent management

Hired global graduates and vocational trainees (headcount)

1,622

437

1,517

416

Hired global graduates

955

404

910

382

Hired vocational trainees

667

607

Average length to fill vacant positions (in days)

3,4

Internal job vacancy fill rate (in %)

37.6

27.1

37.2

32.9

thereof Managing Director and Directors (in %)

40.2

38.7

40.5

38.5

thereof Vice Presidents (in %)

47.5

35.8

47.8

39.0

Critical business positions (in %)

76.9

80.0

61.5

80.0

Savings from redeployment (in € m)

Participation in cross divisional talent acceleration programs (headcount)

ATLAS acceleration program for senior female Managing Directors

Director acceleration program

169

104

152

thereof women (in %)

42.0

45.2

35.5

37.2

Vice President acceleration program

490

245

494

265

thereof women (in %)

39.0

41.6

41.1

Diversity (headcount)

Women on Supervisory Board (in %)

35.0

30.0

Women on Management Board

Women at Management Board level - 1 (in %)

19.7

20.8

Women at Management Board level - 2 (in %)

19.5

20.9

Female staff by corporate title (headcount)

2,6

Managing Directors (in %)

18.3

20.4

18.1

20.1

Directors (in %)

25.1

24.9

24.5

Vice Presidents (in %)

31.4

32.2

31.2

32.1

Assistant Vice Presidents and Associates (in %)

40.6

43.8

40.2

43.0

Non-Officer (in %)

59.6

55.0

59.8

55.9

Total female staff (headcount, in %)

46.3

39.5

46.2

39.5

Age (headcount)

Up to 29 years (in %)

15.1

11.6

15.5

11.5

30 - 39 years (in %)

28.6

28.7

29.3

30.2

40 - 49 years (in %)

27.1

33.1

27.6

33.8

Over 49 years (in %)

29.2

26.6

27.6

24.5

In 2019, Deutsche Bank company health insurance aligned its FTE definition, which decreased the group number as of December 31, 2019 by 81 (prior period not restated).

Status at year-end.

Time to offer from job opening creation to offer date.

Excluding Postbank.

2018 adjusted for Postbank.

Disclosure adjusted from FTE to headcount given the new approach of voluntary group-wide aspirational goals set in March 2019. Postbank included in 2018 and 2019;

declared corporate titles of Postbank (incl. subsidiaries) are only alternative, technically derived, and not contractually defined or agreed.

Numbers may not add up for rounding reasons

Note: International standards for ”Human resource management” (ISO 30414) also suggest disclosing metrics reflecting lost time for injury, the number of occupational

accidents, and the number of people killed during work. These health and safety-related metrics are primarily relevant for manufacturing industry, not material here, and

consequently not disclosed.

Digital transformation

54 Digitization and innovation

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Digitization and innovation

GRI FS14

Emerging technology continues to shift client expectations, and new competitors are exploring traditional banking services.

Structural changes and business-model-impacting digital trends, such as the accelerating pace of artificial intelligence (AI),

are continuing to force banks to rethink and adjust their models. The increasing influence of millennial clients, who demand

more transparent offerings and pricing models, alongside increasingly stringent regulatory norms and competition from

emerging fintechs, have urged a rethink by banking sector incumbents. Banks need to respond to and take advantage of the

disruption the industry is currently experiencing. New technologies are enabling us to offer innovative products and services.

And they are helping us to improve the way we operate by becoming simpler and more efficient.

Governance

GRI 102-20, 103-2/3

The bank’s digitization vision focuses on the transformation of its core businesses through fully digitized, end-to-end banking

processes. We are thus creating a digital ecosystem that enables us to reach new audiences through innovative business

models and to generate revenue growth through platforms that offer the best possible products, including those from third

parties. At the same time, we want to use our database to better understand and serve our clients and their needs.

In 2019, Deutsche Bank’s Management Board agreed on a new technology strategy focused on strengthening engineering

expertise, introducing an agile delivery model, reducing administrative overheads, de-coupling assets within our IT estate for

faster, cheaper deployment, as well as modernizing the bank’s IT infrastructure with long-term investments and benefiting

from cloud computing.

To ensure an integrated IT, data, and security agenda across the bank, we established a separate group-wide Technology,

Data and Innovation function headed by a member of the Management Board.

Research and development

To foster innovation, Deutsche Bank has established professional research and development capabilities that include five

innovation labs worldwide, a data lab in Dublin (Ireland), the Digital Factory in Frankfurt am Main (Germany), and software

development centers of excellence in Moscow and St. Petersburg (Russia), Bucharest (Romania), Pune (India), and Cary

(U.S.). Our labs identify, evaluate, and support the adoption of emerging technologies to enhance, improve, and reimagine

the way clients can be served. The most promising ideas are developed and brought to market maturity via divisional

technology teams or delivery platforms, such as the Digital Factory in Frankfurt am Main.

Partnership

Collaboration with start-ups is an integral part of the development process of many of our new and innovative online and

mobile banking features. We have also been selectively investing in start-ups, for example Modo

(digital payments),

Quantiguous Solutions (open banking), dwins (the creators of Finanzguru), TrustBills (receivables auction platform), and

Zeitgold (accounting for small businesses). In 2019, we also acquired a 5 % stake in the fintech Deposit Solutions.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Digitization and innovation

Open innovation

Banks have traditionally created products and services mainly without involving external parties to achieve a competitive edge

and protect their intellectual property. While this remains true in some areas, the need to become more open is now essential,

as clients demand industry standards. We are one of the first banks to support SWIFT’s Global Payment Innovation, an

industry-wide initiative that connects parties in the payment chain via a cloud solution, allowing clients to obtain real-time

information on the status of their payments. Since 2017, we have contributed to the open source movement in financial

services by releasing parts of our computer code into the public domain. In doing so, we help client applications to work

together and better understand IT environments. In 2019, we introduced an Open Source Software Governance Program,

which implements a formal process for the usage and contribution of open source software, enabling the bank to maximize

innovation opportunities while mitigating risk through robust controls. We are also partnering with the Fintech Open Source

Foundation (FINOS) to drive industry collaboration around common challenges and thus reduce the cost of non-differentiating

capabilities.

In November 2019, we announced the integration of the Chinese instant messaging provider WeChat into the collaboration

platform Symphony, backing a partnership between Symphony and Tencent to connect Symphony’s community of

450,000 global market professionals with the WeChat network. It allows the bank to communicate with clients on WeChat in

real-time while maintaining adherence to compliance and governance policies. Deutsche Bank was a founding investor in

Symphony in 2014, and in July 2019 increased its investment as Symphony expands beyond messaging to become the

industry standard for collaboration. In 2020, the bank will make an open source contribution of new software libraries to enable

developers to quickly construct new bots and applications using the popular Spring Boot framework. This will save many hours

of developmental effort, enabling greater focus on value-adding functionality.

We are involved in a number of projects to explore the potential of block chain technology and build out the required market

infrastructure. In September 2019, we joined the Interbank Information Network (IIN)

, a peer-to-peer platform based on block

chain technology. This network operated by JPMorgan, allows member banks to exchange information on cross-border

payments in real time to minimize friction in the ancillary payments process. More than 300 banks have joined the network,

and more than 50 banks are already using the service.

New ways of working

To become technology-led, we are creating an environment that encourages our employees to actively participate in shaping

the bank’s digital transformation. We organize talks and discussions on the latest technology trends for our employees to hear

from internal and external experts. And we host global hackathons, the last of which was in October 2019 on the topic of

“Banking on Sustainability” and attracted over 1,100 employees from more than 20 locations worldwide.

Our industry-leading Fabric platform

enables our developers to focus on developing business software instead of dealing with

the infrastructure needed to run their applications. It essentially provides an easy way for developers to source computing

power and storage on demand from our cloud infrastructure. This allows our developers to deploy apps in minutes rather than

the months it took in the past. In 2019, Fabric won a

Red Hat Innovation Award in Boston, one of the most respected awards

in the technology industry.

We are also making better use of our data. Experts at our data lab in Dublin are helping our business and infrastructure units

to analyze their data, generate new business, protect assets, offer better services and products, and streamline operations.

For example, this data lab helped our Anti-Financial Crime department to develop a system to recognize and analyze trends,

patterns, and exceptions in the search for criminal behavior.

As part of the effort to optimize the efficiency of our IT estate and accelerate our pace of change, the bank is increasingly

focusing on improving its architecture. This means reducing customization and duplication, while increasing adoption of bank-

wide standards and solutions. In 2019, this resulted in the decommissioning of more than 300 legacy applications, with work

underway to identify more in 2020. Additionally, all applicable change programs were assessed prior to investment to ensure

they moved the bank towards a strategic, more agile, and lower cost IT estate – avoiding reactive deployments, which address

immediate issues but would add complexity that requires costly remediation in the long term.

Deutsche Bank

Combined separate non-financial report

Non-Financial Report 2019

Digitization and innovation

Further developments in 2019

Throughout 2019, we made significant progress in digitalization across all the bank’s business divisions and infrastructure

functions.

As part of its migration to the public cloud, Deutsche Bank became one of the first companies (and the only financial services

firm) to move into the new Microsoft Azure cloud data center in Frankfurt am Main. This significant development will enable

the bank to transfer certain applications to Azure while complying with local regulations, safeguarding data, and improving

efficiency. This will also give us the opportunity to benefit from a range of advanced tools offered by Microsoft, such as AI and

machine learning models.

For our investment banking clients we launched a new mobile app for foreign exchange (FX) trading known as Autobahn FX.

This app gives institutional clients round-the-clock access to trade on currency pairs, wherever they may be. As the latest

addition to the bank’s Autobahn trading platform, which is used by around 7,000 institutional clients worldwide, this app allows

clients to make trades on around 200 pairs of currencies, 24 hours a day, six days a week. We have also gone live with Cobalt,

the FX infrastructure based on shared ledger and high-performance technology and developed to re-engineer post-trade FX

infrastructure and processes.

In our Corporate Bank (CB), we have made significant progress in digitizing our solutions for our clients to enable them to

conduct their current and future business in a streamlined and efficient manner. With the launch of our digital signature offering

as well as the development of our e-Vault solution (a secure digital repository for the exchange of documents), we support our

clients on their journey to become paperless. Furthermore, in order to allow our clients to make better treasury and investment

decisions, we have built out a Push Notification service that delivers real-time streams of cash account updates and running

balances. As part of our overall automation program, we also continue to develop our Intelligent Document Recognition (IDR)

and Optical Character Recognition (OCR) technology to keep improving the speed and quality of our documents handling.

In 2019, Deutsche Bank also announced the integration of CloudMargin into its collateral management platform and thus

became the first Tier 1 bank to use a public cloud-based service for a critical piece of infrastructure.

With Postbank FYRST, we have introduced a new digital bank offering for corporate clients who are looking for a bank account

with all the functions of a normal account, which can be accessed by smartphone, tablet or a desktop computer, and is also

favorably priced and tailored to their needs. In the first three months of operation, FYRST received two awards from the

German business paper Handelsblatt.

Private Bank (PB) is moving to paper-less client communications to the extent local legal requirements permit and clients

agree/or do not disagree. Around six million core clients regularly receive client information on paper; around four million of

them are registered online banking users. As of 2019, half of them have activated their eSafe, but our aim is that all clients

migrate to this solution for online banking along with the Deutsche Bank Mobile app (including Digital Postbox Personal Safe

and Password Safe). To emphasize our ambition to contribute to the conservation of natural resources, we plant a tree for

each recently activated digital mailbox for private clients in co-operation with the German nonprofit association

Trinkwasserwald e.V.

On the technical side, the new dbAPI (Application Programming Interface), which is currently being expanded, provides

external technology and business partners with an efficient interface that exceeds the PSD2 regulation standards. With the

help of this platform, the advantages of a clear and readily available range of services are combined with the necessary

efficiency targets to enable both the integration of beyond-banking services and networking with selected external partners.

The products, which have initially been offered purely digitally, can be activated across Germany for existing and new clients

in branches and our Regional Advisory Centers. The dbAPI was further developed in key areas and additional cooperation

agreements were concluded in order to offer clients more digital value-added services. In the early part of 2020, dbAPI will

release an open source code based around a tutorial and simulation to facilitate the onboarding of new third parties.

In stationary sales, we are pushing ahead with the automation of work processes in branches. Manual tasks, control activities,

and processing steps are being significantly reduced throughout the process chain. The focus here is on forward-looking

concepts, for example designing the digital workplace in branches, optimizing service provision with client contact and

standardized service processes, reducing control and support tasks for sales, and achieving a more efficient design of

interfaces between sales units and service areas through end-to-end processes.

GRI supplement

58 Approach to sustainability

61 Reputational risk

65 Human rights

67 Climate risk

71 Access and inclusion

72 Tax

73 In-house ecology

78 Corporate social responsibility

84 Art, culture and sports

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Approach to sustainability

In the following section of this Non-Financial Report, we address the issues that our stakeholders and we consider

important - even without regulatory provisions (see “Legal basis“). These topics form part of our broader strategic agenda on

sustainability and corporate social responsibility.

Approach to sustainability

GRI G4 DMA/102-27

Our purpose is to enable economic growth and societal progress by generating a positive impact for our clients, employees,

investors, and communities. This purpose serves as a guideline for all our actions. Together with our commitment to

sustainability, this guideline is anchored in our Code of Conduct (the Code).

In 2019, the Code was amended, among further things, to include an articulation of our group-wide sustainability principles:

– We commit to balancing economic success with environmental and social responsibility;

– We address the environmental and social impacts across our business activities;

– We foster business that enables sustainable growth;

– We follow internationally recognized principles and standards;

– We build our sustainability approach on robust governance;

– We encourage transparent communication and open dialog with stakeholders.

The Code sets out the standards of behavior and conduct to which we expect us as a bank and all of our people to adhere

to. Its principles are reflected in our management structures, policies, processes, and control systems.

In July 2019, Deutsche Bank announced its strategic plans to transform and restructure its businesses. In this context,

sustainability was defined as one of the four priorities next to our financial plan (see “About Deutsche Bank“). This development

reflects the increasing importance of sustainability in the public dialog and in discussions with politicians.

In line with our sustainability principles, we are continuously working to strengthen our sustainability efforts in both our own

operations (including our corporate social responsibility activities) and our core business. As our key impact results from our

core business, we continue to strengthen our responsible banking practices and foster sustainable finance by becoming a

strategic partner of choice for our clients to support their transition and the overall transformation towards sustainable growth.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Approach to sustainability

Governance

GRI 102-15/16/18/20/26

Deutsche Bank’s governance structure ensures that the diverse aspects of sustainability are discussed and taken into account

in decisions by the appropriate functions and committees. Established in 2018, our group-wide Sustainability Council is

responsible for advising the Management Board on sustainability topics and helping to drive the integration of sustainability

into day-to-day business practice. The Council is composed of executives from across our business divisions and infrastructure

functions. Underpinning the relevance of sustainability, our Chief Executive Officer (CEO) assumed the role of the Council’s

chairman in 2019. The Council met eleven times in 2019, predominately discussing sustainable business opportunities as well

as measures necessary to position Deutsche Bank in this field and grow its sustainable finance-related products and services.

Group Sustainability (GS), is centrally responsible for developing the bank’s strategic approach to sustainability, proposing

group-wide policies and guidelines, assessing upcoming topics, and engaging with stakeholders with a focus on civil society,

investors, and clients in close cooperation with our business divisions and Investor Relations. Furthermore, GS assumes

responsibility for advising on client transactions from a sustainability perspective and disclosing non-financial information in

close collaboration with the bank’s finance function. Additional sustainability-related governance structures, policies, and

processes have been established in our business divisions to meet their specific requirements.

Deutsche Bank’s Management Board, the Group Management Committee, and other senior management bodies such as the

Group Reputational Risk Committee and the Enterprise Risk Management as well as the Supervisory Board’s Integrity

Committee are regularly informed about current sustainability topics and developments.

Our sustainability approach considers global agreements, such as the United Nations (UN) Sustainable Development Goals

(SDGs) and the Paris Agreement on climate change. We voluntarily participate in international principles, including the Ten

Principles of the UN Global Compact and the UN Guiding Principles on Business and Human Rights. In 2019, Deutsche Bank

added to these commitments by signing the UN Principles for Responsible Banking as a founding signatory. We reinforce our

commitment to contribute to climate protection – for example by officially supporting the European Union (EU) action plan on

sustainable finance. We are also committed to the protection of human rights, as can be seen from our published Human

Rights Statement.

Engagement

GRI 102-12

We engage in pioneering initiatives. As a founding member of the Value Balancing Alliance, Deutsche Bank supports the

development of a standard on how to measure and publish the contribution companies make to society. We also publish ESG-

related research and regularly involve our employees through communication and engagement. We do this through regular

internal communications on sustainable products, initiatives, finance solutions, and best practice approaches, as well as by

offering our employees platforms for exchange and dedication.

In 2019, it was important for us to engage our employees as multipliers for our commitment to sustainability. At a panel

discussion in February 2019, a climate researcher and a philosopher discussed the role of banks and in particular our role in

tackling climate change with employees in Frankfurt am Main (Germany). On our #PositiveImpact hub a #MyGreenImpact

campaign enabled employees worldwide to share their best practices, advice, and tips for reducing our individual and

corporate carbon footprints. In a global “Banking on sustainability” hackathon, more than 1,100 employees worked to create

digital solutions to help Deutsche Bank contribute to a sustainable future. Other employee-driven initiatives included a

#lessplastic campaign, the Save Birkie project to reduce our paper consumption, and roughly 70 individual tree planting

campaigns.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Approach to sustainability

Impact measurement and SDGs

GRI 102-12

Deutsche Bank’s business activities make a positive as well as a potentially negative economic, environmental and societal

impact. In the year under review, we reiterated our efforts to align with global agreements, such as the SDGs, and continued

to explore impact identification and measurement.

UNEP FI Positive Impact Initiative

In collaborations with peers, we are contributing to the SDG impact discussion within the financial community. We are a

member of the working group set up by the UNEP FI Positive Impact Initiative to focus on mainstreaming impact analysis in

the financing of SDGs. The working group made up of representatives from banks, investors, and advisors is developing and

testing the methodology for impact analysis in corporate finance with unspecified use of proceeds. The working group aims to

produce a tool intended as a resource for banks and investors seeking to develop, or redevelop, their own proprietary

methodologies for impact identification, and to identify potential areas of impact target setting.

Value Balancing Alliance

In August 2019, Deutsche Bank became one of the founding members of the Value Balancing Alliance (VBA). Together with

seven other corporations and the support of the four global accounting firms, we have committed ourselves to working

collaboratively on the development of a standardized Impact Measurement and Valuation (IMV) model. It is intended to

increase transparency about the value companies generate for society. The external effects are to be measured and reported

as costs or social value contributions. Experts from the bank are in regular contact with VBA and contribute their experience

to the development of the model. This should also ensure that the results of the VBA are applicable in practice. Additionally,

Deutsche Bank is conducting an internal pilot project to identify its main areas of impact and to test approaches to evaluate

them.

Sustainable Development Goals

Through our business activities in various industries, we contribute to the achievement of the SDGs. All our social responsibility

initiatives directly contribute to certain SDGs (see “Corporate social responsibility”). Our Asset Management includes some

SDGs in ESG and sustainable investment funds. In other areas, we have not yet systematically mapped out the bank's

contribution to SDGs.

Deutsche Bank’s contributions are detailed in this report, with some examples outlined below:

– SDG 7 (Affordable and clean energy) and SDG 13 (Climate action): Financing renewable energy and issuing green bonds

(see “Sustainable finance”);

– SDG 9 (Industry, innovation and infrastructure): Investing in vital infrastructure addresses (see “Sustainable finance”);

– SDG 12 (Responsible consumption and production), SDG 11 (Sustainable cities and communities), SDG 13 (Climate

action): Operating investment initiatives ranging from financial inclusion and microfinance to sustainable agriculture,

renewable energy, and clean urban transportation (see “Sustainable finance”);

– SDG 4 (Quality education) and SDG 5 (Gender equality): The CSR programs Born to Be and Made for Good help to ensure

inclusive, equitable education and to empower women and girls (see “Corporate social responsibility”); and

– SDG 13 (Climate action): Purchasing and retiring high-quality emission reduction certificates to offset unavoidable carbon

emissions covering GHG Scopes 1 and 2 as well as business travel (see “In-house ecology”).

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Reputational risk

GRI 103-1

The diversity of our business model requires us to identify, assess, measure, aggregate, and manage our risks, and to allocate

our capital among our businesses accordingly. Risk and capital are managed via a framework of principles, organizational

structures, and measurement and monitoring processes that are closely aligned with the activities of the business divisions

and business units. Asset Management (AM) specific matters are reviewed by an AM-dedicated reputational risk committee

and escalated to the AM Executive Board where required.

The Reputational Risk Framework (RepRisk Framework), which contains the specific global policies and guidelines, defines

the appropriate level for potential reputational risk issues based on the materiality of the risk identified. Primary reputational

risk is risk originating from active decisions regarding a relationship, transaction, action, or inaction, knowing it may pose

reputational risk. All employees are responsible for the identification of potential reputational risk matters and initial referral

through the Unit Reputational Risk Assessment Process (Unit RRAP). Matters deemed to pose moderate reputational risk are

reviewed through the relevant Unit RRAP. In the event of a matter being deemed to carry a material reputational risk and/or

meeting one of the mandatory referral criteria, it is referred for further review to one of the four Regional Reputational Risk

Committees (RRRCs), which are sub-committees of the Group Reputational Risk Committee (GRRC). The GRRC receives

quarterly updates and reviews specific reputational-risk-related issues. If issues cannot be resolved at the GRRC level, they

will be referred to the Group Risk Committee or the Management Board. A dedicated Reputational Risk Function oversees

and manages the RepRisk Framework, the reporting, and look-back process, as well as provides training.

Deutsche Bank has deemed that certain issues and matters have to be reviewed by subject matter experts. These matters

are discussed in more detail in the following two chapters.

Matters assessed through the Reputational Risk Framework

Dec 31, 2019

Dec 31, 2018

Number of matters reviewed (on which final decisions have been made)

To Unit Reputational Risk Assessment Processes only

119

Thereof with ES issues

Thereof with gaming-related issues

Thereof with defense-related issues

To Regional Reputational Risk Committees

Thereof with ES issues

Thereof with gaming-related issues

Thereof with defense-related issues

To Group Reputational Risk Committee or above

Thereof with ES issues

Thereof with gaming-related issues

Thereof with defense-related issues

Total

122

176

Thereof with environmental and social issues

Thereof with gaming-related issues

Thereof with defense-related issues

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Reputational risk

Environmental and social due diligence

GRI 102-11/12/15/16/18/20/26/29/31, 103-2/3, 412-2, G4 DMA

Our Environmental and Social (ES) Policy Framework formulates the set of rules and guidance for our daily business. A

summary is publicly available. Internally, the ES Policy Framework is an integral part of the Reputational Risk Framework.

As it is applicable globally for our Corporate Bank (CB) and Investment Bank (IB), as well as commercial lending activities in

our Private Bank, the ES Policy Framework defines procedures and responsibilities for risk identification, assessment, and

decision-making. It also covers deal-independent risk-screening and the identification of companies with a controversial ES

profile, and specifies the requirements for ES due diligence. Our due diligence process regarding project finance is based on

the IFC Performance Standards underlying the due diligence under the Equator Principles.

Furthermore, our approach refers to global frameworks, such as:

– UN Guiding Principles on Business and Human Rights;

– International Finance Corporation (IFC) Performance Standards;

– International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work;

– International Labor Organization (ILO) Core Labor Standards.

In line with the requirements of the ES Policy Framework, employees in our business divisions are initially responsible for

identifying ES risks. We have defined sensitive sectors to focus on, as well as criteria for mandatory referral to Group

Sustainability (GS), our sustainability team. Detailed sector-related guidelines are available for all sectors requiring mandatory

involvement of GS. For all transactions where ES issues are deemed to pose at least a moderate reputational risk, the

reputational risk assessment process also applies (see “Reputational risk”).

Sector-related guidelines

We have defined the following sectors based on their inherent elevated potential for negative ES impacts. There were no

changes in our sector focus between 2018 and 2019:

– Metals and mining;

– Oil and gas;

– Energy utilities;

– Industrial agriculture and forestry;

– Chemicals;

– Infrastructure projects in certain countries; and

– Other activities either with a high carbon intensity and/or potential for human rights’ infringements.

We regularly review and update the scope of sectors. In 2019, we worked on an updated Oil and Gas guideline, which is

currently going through the internal approval process.

We also review existing sector-related standards and industry best practices to assist in our decision-making on environmental

and social topics. Our internal assessment is informed by internationally recognized standards. We also monitor global

developments, such as climate change or human rights protection.

Targets and key measures

We always strive to manage all types of risk as effectively and efficiently as possible. To this end, we prioritize the adequate

identification of transactions and/or clients involving potential ES risks, and the robust and effective due diligence of these. In

this context, our overarching goal is to constantly improve our performance, in particular by:

– Verifying the effectiveness of our processes and guidelines and carrying out amendments, if required, to increase review

robustness in sectors with elevated ES risk potential in line with our internal definition; and

– Increasing risk awareness and focus by conducting training sessions for all relevant employees.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Reputational risk

Transactional reviews

In 2019, 310 transactions and clients were reviewed under our ES Policy Framework, approximately 22 % fewer than in 2018.

Despite fewer reviews, our overall review ratio remains roughly the same at 16 % in 2019 (2018: 17 %), mainly because of

fewer deals in the focus sectors. In order to concentrate our attention and focus on transactions with elevated ES risk potential,

we further specified the referral criteria for deals requiring ES due diligence by GS. For example, we expanded our review

scope to include offshore windfarms. Of the 310 assessed transactions and clients in 2019, six were declined directly. Seven

more were discussed in the respective committees in line with our reputational risk process. Of these, one was ultimately

declined and six were approved.

We are continuing to work on developing a more systematic approach to assessing clients’ ES profiles to increase the

efficiency of ES due diligence and allow early-stage client engagement. In 2019, for instance, we created a guideline to help

our teams to identify and evaluate negative client news on environmental and social issues. Also, we updated instructions for

business teams on how to search for relevant soft commodity certifications of our clients.

Furthermore, we particularly focused on client engagement sessions in the mining and utilities sectors. As a member of the

Banking Environment Initiative and an adopting institution of the Soft Commodities Compact, we published a report

outlining

our approach and progress in helping our soft commodity clients to achieve zero net deforestation. As a result of this portfolio

review, we launched an engagement process in 2019 for our critical soft commodity clients, which we will continue and

complete in 2020.

Training and awareness

Employee training enables our businesses to better identify ES risks and consequently assess and refer transactions with an

enhanced risk profile to Group Sustainability. In 2019, we continued our employee training program for our CB and IB with a

particular focus on selected business teams in our Brazil office They received dedicated training covering topics, such as

climate protection, human rights (incl. the UK Modern Slavery Act), and protection of World Heritage Sites and primary forests.

We have continued to enhance the timeliness of transactional referrals by using reminders within our internal deal logging

system.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Reputational risk

Defense industry

Deutsche Bank has established a dedicated due diligence framework for clients and transactions linked to the defense

industry. This framework covers the manufacturing and sales of weapons and military technology, and includes hardware,

related software, their major components, and services for military, security, and police purposes. These matters are reviewed

by a dedicated control function and referred to the bank’s Reputational Risk Framework, where appropriate.

Our aim is to continuously review the type of business carried out in this sector to help ensure we conduct business responsibly

and protect the bank from reputational risk. One outcome of the continuous review of the approach in 2019 was the

formalization of a restrictive approach for transactions with a nexus to conflict countries and primary military protagonist

countries (as defined by the 1949 Geneva Convention), unless the parties are acting under an internationally recognized

mandate. Furthermore, the dedicated control function monitors emerging issues in the defense space, such as arms export

regulations and new technologies (e.g. lethal autonomous weapon systems).

In 2019, the dedicated control function reviewed, from a reputational risk perspective, 1,356 matters linked to the defense

industry. This was a 29 % decline from 1,902 transactions in 2018, a reduction primarily driven by clarifications in the defense

policy. For example, we exclude certain transactions where the end user is using the underlying goods for civil purposes only.

Gaming industry

The gaming industry involves specific legal, social, and reputational risks that warrant specific guidance with respect to

Deutsche Bank’s involvement. Gaming is illegal in certain jurisdictions, with the consequence that even the processing of

payment transactions (e.g. depositing bets and disbursing winnings) may be viewed as a prohibited activity. Even in

jurisdictions where gaming, or some form(s) thereof, may be legal, Deutsche Bank does not want to be connected to

counterparts in this industry who show signs of proximity to problematic areas (e.g. prostitution) or are likely to serve as a

basis for illegal activities (e.g. money laundering and fraud). These matters are reviewed by a dedicated control function and

referred to the Reputational Risk Framework, where appropriate.

In 2019, this dedicated control function reviewed, from a reputational risk perspective, 144 matters linked to the gaming

industry. This is a 1 % increase on 2018.

Emerging risks and recently identified topics

GRI 102-44

In 2019, Deutsche Bank initiated a more formal monitoring of high-level topics receiving attention from non-governmental

organizations (NGO) in order to obtain a broader view of current and emerging reputational risks. This aims to improve the

identification of topics that would require further enhanced due diligence to prevent or minimize reputational risk.

Throughout 2019, a dedicated control function reviewed several sensitive topics. One common theme identified was that

several of these topics were related to the topic of health. All three of the issues discussed below – opioids, cannabis, and

electronic cigarettes – have an impact on the well-being and health of clients and end users. Further analysis revealed that

marketing practices, limited regulation, and other unethical business practices were common concerns.

Opioids

The U.S. opioid crisis in 2019 has already led to over 2,000 lawsuits against opioid manufacturers and distributors. Current

settlements have resulted in the bankruptcy of one major manufacturer. Other companies are now being directly affected by

litigation and the costs of settlements, as they are alleged to have contributed to the opioid crisis through marketing strategies

and encouraging increased prescription of opioids. Deutsche Bank applies enhanced due diligence regarding potential

business activities with connections to this topic.

Cannabis

The legalization of recreational cannabis in Canada and the continued legalization of medical cannabis in other countries have

triggered discussions within the financial industry. A key aspect is the differentiation between medical and recreational usage.

Most concerns in the public debate center on the legalization of recreational cannabis, which involves greater reputational

risks. Deutsche Bank will act cautiously with regard to business activities relating to cannabis, and enhanced due diligence is

performed on any business with entities involved in the production or distribution of recreational cannabis.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Human rights

Electronic cigarettes

Once heavily marketed as an alternative to traditional smoking products, e-cigarettes have been subject to criticism during the

past twelve months. This ranges from accusations of causing increased numbers of under-age smokers through marketing

practices to investigations by the U.S. regulatory authority over health concerns about lung diseases identified in frequent

users of e-cigarettes. A specific example of this criticism is the production, distribution, and sale of fruit or sweet-flavored e-

cigarettes.

The U.S. regulatory authority, the Food and Drug Administration, has now officially warned manufacturers of e-cigarettes for

violating marketing laws and issued warnings about potential lung diseases related to these products. These health concerns

have led some U.S. states, India, and Thailand to introduce restrictions or bans on e-cigarettes. Consequently, Deutsche Bank

has placed additional governance requirements on certain transactions and relationships linked to e-cigarettes.

Human rights

GRI 102-16, 103-1/2/3

“Human dignity is inviolable” ‒ this principle is the foundation for respectful cooperation. That is why respect for human rights

is a guiding principle embedded in Deutsche Bank’s Code of Conduct.

We endorse international standards and guidelines such as the UN Guiding Principles on Business and Human Rights, the

International Bill of Rights, and the Core Labor Standards of the International Labor Organization (ILO).

Our Human Rights Statement reinforces this commitment and outlines the approach we take to address this important issue.

We also publish Deutsche Bank’s U.K. Modern Slavery Statement. Our approach covers all dimensions of the business from

client transactions and interaction with vendors and service providers to how we treat our own employees. Our principle is not

to engage in any activities or business relationships where there is clear evidence of human rights’ violations.

We actively participate in the Thun group, discussing current banking and human rights focus areas. Special attention is paid

to key legal and regulatory issues as well as evolving developments.

Developments in 2019

GRI 102-15/16, 103-1/2/3, 412-2, FS5

In recent years, Deutsche Bank has taken a proactive approach to safeguarding respect for human rights, as demonstrated

by the integration of human rights due diligence into the bank’s own operations, business activities with clients, and

relationships with vendors and suppliers. We focus on identifying the most salient risks for rights holders and developing

targeted action plans. To implement this, Deutsche Bank established a Human Rights Working Group (HRWG) at the end of

2018, which became fully operative in 2019.

On a monthly basis, the HRWG brings together decision-makers from different business and infrastructure units from across

the bank. One of HRWG’s key objectives is to improve our procedures, guidelines, and communication on human rights topics.

HRWG also gives due consideration to the definitions of “cause”, “contribute”, and “directly linked” linked’ in the UN Guiding

Principles on Business and Human Rights in order to understand the potential and actual impacts the bank has on rights

holders.

In 2019, a scoping and analysis exercise helped to define areas of strength and areas where Deutsche Bank could improve

its human rights performance. The discussions within HRWG led to agreed objectives for the working group members, which

were summarized in a human rights action plan. These actions target the most salient human rights impacts on and risks for

rights holders that Deutsche Bank faces and allocate business unit responsibility and deadlines for implementation. An

overview of the agreed action items is provided in the following sections.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Human rights

Clients

There were 18 client-related actions, with responsibility allocated to the Corporate Bank (CB) and Investment Bank (IB), Asset

Management (AM), Anti-Financial Crime, Financial Crime Operations (FCO), and Group Sustainability (GS). These actions

ranged from deepening the scope of respective human rights due diligence processes with clients and embedding explicit

rules on human rights in the investment process to broadening the target audience for our human rights training.

In 2019, we reviewed 310 clients and transactions in line with our Environmental and Social (ES) Policy Framework. Those

reviews resulted in seven refusals. None of them were refused specifically due to severe human rights issues. But in various

cases specific actions were agreed on to avoid or mitigate negative impacts on rights holders.

Furthermore, in the course of our FCO unit’s ongoing work with the Joint Money Laundering Intelligence Taskforce (JMLIT),

23 requests were received for information on funding flows that were potentially linked to potential human rights’ violations in

2019. The FCO unit reviewed all of them and responded to the law enforcement agencies in each and every case.

Supply chain

GRI 102-9, 103-2/3, 414-2

Six priority actions relating to our supply chain were defined in the above-mentioned action plan. They include the development

of a stand-alone Vendor Code of Conduct and the enhancement of the vendor risk management and screening process.

Procurement and Group Sustainability are responsible for implementing these measures.

In 2019, Deutsche Bank implemented a new vendor screening process that now includes more specific human rights controls

for our new vendors or a review of our existing vendors. This process manages ES risks relating to the vendors Deutsche Bank

works with globally. The focus is on vendors that provide services often associated with human rights risks and provided in

countries with an elevated risk of human rights violations. If a vendor meets certain criteria for more detailed ES analysis, the

vendor will have to fulfill specific environmental and social vendor control requirements (VCRs). The vendor will then have to

explain their approach to the different VCRs and provide adequate evidence for their responses. If the vendor does not or

cannot provide sufficient information or evidence, we discuss internally how to deal with this incompliance with our ES

standards and whether measures can be agreed with the vendor to achieve compliance within a reasonable time. If that is not

possible, it can ultimately lead to a termination of the business relationship with the vendor in question.

In initiating the new vendor screening process, we wanted to ensure that existing vendors who trigger a more detailed ES

analysis also meet our ES standards. In reviewing the ES performance of existing vendors, which is expected to be finalized

by mid-2020, we will be supported by an external service provider. Due to the implementation of the new vendor screening

process, we have rescheduled our human rights training for Procurement colleagues, initially scheduled for 2019, to be rolled

out at the beginning of 2020.

Employees

GRI 412-2

The four priority actions relating to our employees were allocated to Human Resources and GS. One of these priority actions

has been to develop a training course for employees. The aim here is create awareness for the importance of respecting

human rights in all the bank’s business activities. The other topics covered are the individual responsibilities of employees and

the policies, procedures, and measures the bank has already implemented and will continue to do so going forward.

Although we have to incorporate location-based cultural nuances into employee policies, we place a high priority on granting

all our employees the same rights worldwide. Here, a more detailed analysis will help us to determine areas of improvement.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Climate risk

GRI 102-15

Climate change is one of the most important issues facing society today, and Deutsche Bank welcomes the fact that it has

moved to the top of the social, regulatory, and political agenda.

As a key component of the group’s wider response to climate change (see Sustainable finance), Deutsche Bank has started

to develop a holistic risk management framework for climate risks. We have set up an internal working group to combine

existing risk management practices – parts of which already consider climate-related risks – with innovative approaches to

ensure that we understand, and are well protected against, potential negative impacts, including:

– Increased default risk and/or valuation losses on exposures to clients and assets that may be impacted by climate-related

physical and/or transition risks, such as climate-related developments in policy and regulations, the emergence of disruptive

technology or business models, shifting market sentiment, and societal preferences;

– Reputational risks from a failure to adapt to climate risks that may also drive litigation claims from parties who are seeking

compensation after suffering loss or damage; and

– Business disruption risks to our offices, employees, and processes in locations that may be affected by physical climate-

related risks, such as extreme weather events and/or disruptive longer-term shifts in climate.

At the same time, multiple stakeholders, including clients, investors, employees, and society at large, expect us to provide

transparent disclosure of our exposures to, and management of, climate risks.

The development of this risk management framework for climate risks can also support the identification of opportunities to

grow our sustainable finance business (see Sustainable finance).

The year 2019 saw intensified regulatory activities relating to climate change. Deutsche Bank contributed to climate-related

legislative initiatives and participated in industry-wide consultations at EU and national levels including via direct engagement

and via contributions to consultation responses/policy papers by banking associations. The beneficiaries included the

European Commission (EC) in certain components of the EU action plan on sustainable finance.

With the publication of the Prudential Regulation Authority’s (PRA) Supervisory Statement (SS3/19) and the Comprehensive

Bulletin on Sustainability by the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzaufsicht, BaFin),

the recommendations by the Task Force on Climate-related Financial Disclosure (TCFD) have become further embedded as

key elements of future regulatory expectations regarding the disclosure of climate-related risks.

TCFD recommendations

GRI 102-12

The G20 Financial Stability Board mandated the TCFD in December 2015 to propose a reporting framework for companies

(including financial institutions) to provide investors, clients, and other stakeholders with consistent, comparable, and useful

information on climate-related risks and opportunities. In June 2017, the TCFD published its recommendations for voluntary

climate-related financial disclosures that should comprise relevant information on the following:

– Governance relating to climate-related risks and opportunities;

– Actual and potential impacts on the companies’ business, strategy, and financial planning;

– Risk management processes to identify, assess, and manage climate-related risks; and

– Metrics and targets used to assess, and manage relevant climate-related risks and opportunities.

The TCFD expects that companies will develop their approaches over time and that climate-related disclosures will evolve

correspondingly. Deutsche Bank is working towards implementation of TCFD recommendations through internal efforts, as

well as external industry initiatives. In 2020, our internal working group will focus on (i) implementation of an internal climate

risk taxonomy, (ii) refinement of scenario analysis ‒ including expansion of sector coverage, (iii) approaches to define climate

risk appetite and better integrate climate risks into decision-making, and (iv) review of roles and responsibilities within our

organization.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Climate risk

UNEP FI working group

GRI 102-12

In 2019, Deutsche Bank joined the second phase of the UNEP FI pilot project – a collaborative effort by 36 international banks,

supported by the UNEP Secretariat and external consultants ‒ to further develop risk management practices and ultimately

move towards implementation of TCDF recommendations. This phase is scheduled to run until mid-2020, with the group of

banks focusing on the following aspects:

– Scenario analysis: Developing a deeper understanding of how risk factor pathways can be derived from reference scenarios

and how these can be used to assess portfolio risks;

– Data and methodology: Reviewing and understanding the availability and application of climate-relevant data; the group of

banks will agree on a set of best practices regarding sectoral and geographic assessments; and

– Reporting and governance: Building a common understanding of regulatory expectations, developing a reporting template,

and agreeing industry best practices regarding climate risk governance.

Deutsche Bank’s participation in this initiative is accompanying the internal working group to further develop risk management

practices and fully align disclosures.

Governance

GRI 102-20/26, 103-2/3, G4 DMA

As highlighted in the chapter “Sustainable finance”, Deutsche Bank’s group-wide Sustainability Council, chaired by the CEO,

is responsible for advising the Management Board on sustainability topics, including climate change, and helping to drive the

integration of sustainability into day-to-day business practice. The group’s risk management function is represented on the

Council.

The Group Risk Committee, co-chaired by the Chief Risk Officer (CRO) and Chief Financial Officer (CFO) has delegated

formal responsibility for the management of climate risks to our Enterprise Risk Committee (ERC). This includes: (i) oversight

of risk management framework developments; and (ii) approval of specific sectoral risk appetite limits and other restrictions to

manage risks to the bank.

While the ERC is responsible for the holistic management of climate risks, the day-to-day management and approval of

climate-related reputational risks, and physical risks to our staff, infrastructure, and processes will continue to be managed via

other committees:

– Transactions with a potential reputational risk from a climate-risk perspective are identified via the Group Reputational

Risk Framework and based on the risk assessment referred to one of four Regional Reputational Risk Committees, which

are sub-committees of the Group Reputational Risk Committee and report to the Group Risk Committee; and

– Risks to Deutsche Bank’s infrastructure, employees, and key processes in locations that may be affected by physical

climate-related risks are monitored and approved by the Non-Financial Risk Committee, a sub-committee of the

Management Board.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Climate risk

Risk management strategy and processes

GRI 102-15/29/31, 201-2, 305-5, G4 DMA

The bank’s overall strategy towards developing a holistic sustainable finance product suite, including those addressing climate

change, are detailed in the chapter “Sustainable finance”. In this section, we describe how we now manage climate risks and

summarize, going forward, the steps we are taking to improve our climate risk management, in alignment with the TCFD

requirements.

Transition risks to carbon-intensive industries

Deutsche Bank’s principal tool for managing sectoral exposures is our industry risk management framework. A key input into

industry risk assessment, risk appetite setting, and frequency of review is our short and long-term internal industry risk ratings.

Incorporated within the ratings is an assessment of an industry’s vulnerability to climate risks.

Industry risk ratings are also included as an input into our internal rating model for the probability of default (PD) of

counterparties with higher industry risks translating to lower counterparty PD ratings and risk appetite.

The bank’s loan exposure to the oil and gas, utilities (electricity and natural gas), as well as steel, metals, and mining industries,

is relatively low as a proportion of our total exposure. The relative shares of each industry have fallen compared to year-end

2016 as we reduced our risk appetite thresholds, partly due to elevated climate-related transition risks. As of year-end 2019:

– Loan exposure to the oil and gas industry: € 8.4 billion or the equivalent of 2 % of Deutsche Bank’s overall loan volume,

plus revocable and irrevocable lending commitments of € 6.9 billion. The majority of the exposure to the oil and gas

industry is to investment-grade-rated diversified majors and national oil and gas companies;

– Loan exposure to the utilities (electric power and gas) sector: A moderate € 4.2 billion or 1 % of Deutsche Bank’s overall

loan volume, plus revocable and irrevocable lending commitments of € 7.9 billion. The majority of the utilities’ portfolio is

with large incumbents in the EU and the U.S. that benefit from diversification across the value chain (including transmission

and distribution businesses) and/or a balanced energy mix; and

– Loan exposure to the steel, metals and mining sector: A moderate € 4.0 billion or 1 % of Deutsche Bank’s overall loan

volume, plus revocable and irrevocable lending commitments of € 4.4 billion. Exposure to coal-mining groups

is negligible

since the bank has tightly managed and reduced its exposures in recent years. These loan exposures have fallen by 31 %

since year-end 2016.

Scenario analysis

Scenario analysis is a key tool to assess the potential impacts of policy and behavioral changes required to support the

transition to a low-carbon economy. Companies undertaking scenario analysis today face challenges in translating the long-

term macroeconomic, demographic, and demand projections underpinning climate scenarios to industry and client-specific

financial impacts. The UNEP FI initiative mentioned above has work streams dedicated to translating these impacts, which

going forward will be a core component of our scenario analysis development.

In 2019, Deutsche Bank piloted transition scenario analysis for the bank’s loan portfolios to the most carbon-intensive

industries: oil and gas, utilities (electric power and natural gas), as well as steel, metals, and mining, with the following

approach taken:

– Scenario selection: We used the International Energy Agency “Sustainable development” scenario as a basis for the

analysis. The scenario is consistent with the Paris Agreement’s objective of holding the increase in global average

temperatures to well below 2°C above pre-industrial levels and contains energy demand projections across key sources

in line with that objective;

– Portfolio impact assessment: We applied downward PD rating migrations to portfolios with the number of downgrades

dependent on (i) clients’ sensitivity to transition risk based on their current business models, such as energy mix; (ii)

estimates of clients’ financial capacity to absorb the required investment to transition to a low-carbon economy (based on

internal PD rating and market capitalization); and (iii) assessment of environmental performance, exposure to transition

risks and transparency by external experts’ surveys (where available);

– An increase in loss given default (LGD) ratios was also assumed across all clients; and

– The results were translated into estimates of how expected loss (EL) would develop over the medium-to-long term for the

selected portfolios.

Client groups with the majority of sales from coal mining.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Climate risk

While we do see meaningful downward rating migrations for our carbon-intensive portfolios under the “Sustainable

development” scenario (before any mitigating actions), the overall impact on the bank’s balance sheet quality would remain

contained, supported by our focus on well-rated and diversified clients.

Risks from commodity price volatility

Innovation and changes in the regulatory environment aimed at a meaningful reduction of carbon-dioxide emissions can also

have a profound impact on commodity prices, especially for crude oil, and volatility in the medium to long term. To ensure that

downside risks are manageable, Deutsche Bank regularly stresses its trading portfolios under a range of severe scenarios,

whereby commodity price shocks are included in the macroeconomic stress scenarios. At year-end 2019, Deutsche Bank’s

exposure to commodity price fluctuations via its trading books was modest in size and well contained.

Physical risks to our assets

Our Enterprise Risk Management (ERM) unit comprises an in-house intelligence team that measures and tracks country and

selected city-specific risks, including natural hazard risks to our assets and operations. These risk assessments inform

strategic location planning and scenario design for testing and exercising crisis management in order to ensure robust

business continuity and crisis management plans. They also inform corporate security plans, notably health and safety, staff

duty of care, and building resilience.

Physical risks to our clients and assets are considered in the assessment of credit and market risk exposures that may be

heavily impacted by acute events, such as insurance companies who underwrite climate-related risks. Where specific

transactions or counterparties are assessed as having substantial exposure to such risks, Credit Risk Management (CRM)

and Market Risk Management (MRM) take this into account in risk decision-making.

ES-led climate risk restrictions

GRI G4 DMA

In addition to our sectoral risk appetite limits the following restrictions are applied under our Environmental and Social (ES)

Policy Framework in order to reduce our support for fossil fuels:

– No financing for new coal-power facilities and a reduction in existing exposures to power companies heavily dependent

on coal;

– No financing of new thermal coal mines. We have met our 2016 commitment to reduce our existing exposure to thermal

coal mines by 20 % by 2020. Residual exposures are extremely small, and we will continue to review our portfolio in this

area;

– ES due diligence required for climate-intensive sectors, such as oil and gas, metals, and mining, as well as utilities (see

“Reputational risk”). This process includes a review and sign-off by the control function Group Sustainability; and

– In 2019, the industry concentration thresholds for the oil and gas, utilities and steel, metals, and mining sectors were

lowered, with inherent long-term climate risks taken into account.

Future developments

We recognize the need to further develop our risk management understanding and approach to climate risk. Which is why

Deutsche Bank’s Enterprise Risk Management function has been mandated by the Group Risk Committee to further develop

our processes and frameworks in alignment with the TCFD requirements. This includes:

– Further development of our approach to transition risk scenario analysis and physical risk analysis, including extension of

scenario analysis to a broader range of sectors;

– Deeper integration of sustainability factors into our client-level risk analysis, including PD ratings/assumptions on the loss

given in default (LGD); and

– Development of climate-specific risk appetite limits/targets and controls;

– Development of our climate risk disclosures.

A number of challenges will need to be overcome in order for us to achieve this. These include the ability to accurately model

climate change impacts and translate them to portfolio risk developments, improved climate risk disclosures at client level,

and the establishment of a climate risk taxonomy. We are working with peers via UNEP FI and other engagements to remediate

these challenges.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Access and inclusion

Accessibility

GRI FS14

In line with the requirements of the EU Accessibility Act, Deutsche Bank has implemented a variety of measures to ensure

unhindered mobility, self-service, and online banking for anyone who involuntarily has no, or only limited, access to financial

services.

Many of the bank’s branches offer disabled access. Details of the step-free access to self-service terminals as well as cash

and advisory functions are published for each branch in the Deutsche Bank branch finder. Where possible, new branches are

at ground level or in handicapped-accessible buildings. The arrangement of furniture ensures unhindered passage for

wheelchair clients. Moreover, branches are designed in such a way that people of all heights and wheelchair clients can easily

use them. The self-service devices are equipped with keyboard support for the visually impaired. Cash devices are equipped

with an additional voice output via headphones to guide a client through the menu and device input functions. Non-cash

devices offer direct dialing of individual services through special key combinations. Self-service device components, such as

card input, print output, cash input, and cash output, feature Braille lettering.

To ensure online banking is accessible to visually impaired people, the readability of pages via a screen reader is now an

explicit requirement in Postbank’s switchover to a new content management system, which is due to be completed by the end

of 2020. Deutsche Bank supports the voice-over feature in the banking app on iOS. This feature is designed to increase

accessibility for blind or low-vision users, as well as for dyslexic users.

Financial inclusion

GRI FS14

Deutsche Bank recognizes the transformative power of financial inclusion, in particular to underserved communities who often

lack access to financial services. To broaden access to such segments of the society, low-cost, fair and safe financial products

and services have been made available to the bank’s clientele through a variety of measures undertaken under its commitment

to financial inclusion. These measures include:

Microfinancing

Our Corporate Bank (CB) and Investment Bank (IB) divisions are committed to facilitating access to long-term financing for

microenterprises and SMEs. As such, they continue to provide support in establishing microfinance funds by raising private

debt capital for microenterprises and SMEs. In 2019, a new fund launched with a focus on fostering agricultural development

in Africa raised € 25 million as a contribution to the total of € 70 million capital raised in this area.

In our Asset Management (AM), the Sustainable Investment (SI) Funds include the Global Microfinance Funds III and Global

Commercial Microfinance Consortium II, which provide senior and subordinated debt financing for microfinance institutions

and banks in the developing world in order to increase their access to high-quality financial services. Each SI investment fund

is tracked and reported on the basis of the investees’ social and/or environmental performance. The indicators are sector-

specific and monitored using fund-specific tools. The Global Microfinance Funds III, for example is marketed to MiFID II

professional investors by the Institutional Wealth Partners (IWP) team in the bank’s Wealth Management (WM).

Blocked accounts

Deutsche Bank offers non-EU students the opportunity to open a bank account that is blocked in favor of the Federal Republic

of Germany. This enables them to start studying in Germany by fulfilling the visa requirements.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Tax

Financial literacy

GRI FS14

Ignorance of financial matters can lead to financial distress, especially for young people. Conversely, acquiring a basic

understanding of economic and financial issues, instruments, and mechanisms can therefore help people to become

independent, informed citizens. By utilizing the bank’s expertise and its employees’ commitment, initiatives to improve financial

literacy and inclusion are supported via the bank’s Born to Be

youth engagement program.

In Germany, the FinanzTuber project encourages sixth to eighth graders to learn more about money and financial topics by

producing short peer-education video clips on financial topics close to their heart. So geht Geld (That’s How Money Works)

offers Deutsche Bank and Postbank employees the opportunity to teach financial literacy to fifth graders upwards in all types

of schools. In Spain and the Netherlands Deutsche Bank volunteers teach pupils and foster financial literacy in the Your

Finance, Your Future, and Bankers in front of the classroom programs.

Pathways to Banking and Finance is a pioneering U.K. program that seeks to improve social mobility in the financial services

sector. Founded in 2017 by Deutsche Bank and the Sutton Trust, this program aims to increase access to banking and finance

and provides 300 high-achieving students from less advantaged backgrounds with industry insights through relevant skills

building, work placements, and guidance over a four-year period.

For over 25 years in the U.S., the Deutsche Bank Americas Foundation has been partnering with the non-profit-organization

Accion to catalyze equitable financial services and education for entrepreneurs. In 2019, multi-level support reached

2,100 small business owners. In addition to the partnership in New York, the Foundation was instrumental in Accion’s

expansion to Jacksonville, Florida. On top of that, 150 colleagues in four U.S. cities took part in a hackathon

to create a

financial literacy app for the education program Working in Support of Education (W!se).

In cooperation with Plan India, Deutsche Bank has provided vocational training courses for more than 3,000 young people

since 2016. Almost 80 % of the participants have found a job.

Tax

GRI 102-16

In the management of our tax affairs we apply the principles set out in our tax strategy document

. These tax principles, which

have been embedded in the bank’s control framework, have been approved by our Management Board. To summarize, we

manage our tax affairs in a way that aims to generate sustainable value for all stakeholders and to ensure that the tax

consequences of our business operations are appropriately aligned with their economic, regulatory, and commercial

consequences, with due regard being given to the potential perspective of the relevant tax authorities.

We aim for our dealings with tax authorities to be undertaken in a proactive, transparent, professional, courteous, and timely

manner. We seek to develop and foster good working relationships with tax authorities.

We operate a control framework and governance to ensure that in all material aspects we are compliant with applicable tax

laws, file accurate tax returns, and pay the amount of tax due.

Tax evasion is illegal and goes against our culture, values, and beliefs. Consequently, our policies strictly prohibit aiding or

abetting tax evasion. We are prepared to discontinue, and have discontinued, relationships with clients to safeguard our bank

against the risk of tax evasion.

Our income tax expenses and benefits across the jurisdictions in which we operate are disclosed in our Annual Report 2019

Note 43 – Country by Country Reporting.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

In-house ecology

GRI 103-1/2

At Deutsche Bank we see it as an integral part of our responsibility as a corporate citizen to manage and, where possible,

minimize the environmental impact of our business operations, such as in our offices and during business travel.

As a signatory to the Paris Pledge for Action, Deutsche Bank is committed to playing its part in achieving the overall targets

set by the Paris Agreement. With regard to in-house ecology, we have been doing this by reducing our carbon footprint, using

energy and other resources as efficiently as possible, buying renewable power, and offsetting the remaining emissions. Last

but not least, we are striving to use water and paper responsibly, to minimize the supply chain impact of our business

operations, and to reduce the amount of waste we generate. A new focus in our waste strategy has been to reduce

consumption of disposable plastics and use reusable materials, starting in Germany and the U.K.

Governance

GRI 103-1/2/3

We apply ISO 50001 in our energy management strategy in Germany. Across the 20 EU countries in which we operate, we

follow the European Energy Directive (EED) and base our efforts on the respective national energy audit requirements. In

applying the international GHG standard ISO 14064, we have developed an internal governance framework to manage data

collection and define our management approach to quantifying and reporting emissions. Additionally, in compliance with

ISO 50001, we assess our progress annually against energy and cost targets.

Within our Corporate Real Estate and Services function, the Eco-Performance Management Office (EcoPMO) Utility

Management key operating procedure defines how energy reduction initiatives are evaluated and approved. Facility

Management teams propose and implement energy, water efficiency, waste and recycling projects, and the EcoPMO

measures and verifies outcomes. We collect data from all these sources to monitor our environmental performance, and

produce monthly regional reports for energy and water measurements. These reports are reviewed by division managers to

continually monitor progress against targets.

We measure and report our Scope 1, Scope 2, and emissions of greenhouse gas (GHG) on business travel based on the

reporting boundary defined by the GHG Protocol operational control approach. Reporting scopes are defined according to the

GHG Protocol and also reported according to the GHG Protocol’s Scope 2 Guidance. We disclose to the CDP all the relevant

fuel type, energy, and emission sources, with the exception of Scope 3 investments, which are a significant source of

emissions “Climate risk”).

Our reporting scopes are defined as follows:

– Scope 1: Direct emissions from on-site combustion (liquid/gaseous fossil fuels, owned and leased vehicles, and refrigerant

leakage from cooling equipment);

– Scope 2: Indirect emissions from delivered energy (electricity, district heating, steam, and chilled water); and

– Scope 3: Indirect emissions from business travel (air, rail, taxis, and rented vehicles).

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

In-house ecology

Environmental measures

GRI 103-2/3, G4 DMA

The most relevant measures we have taken to minimize the environmental impact of our business operations are detailed

below.

Energy efficiency and conservation

GRI 302-4

According to the International Energy Agency (IEA), buildings and building construction are responsible for at least 36 % of

global energy consumption, and nearly 40 % of all energy and process-related GHG emissions in 2018. We have put a

particular emphasis on buildings in striving to improve our overall energy efficiency and reduce our energy consumption.

Against this background, we are continually enhancing our buildings’ energy efficiency and reducing our energy consumption

by using new and more efficient technology. For 2019, we set ourselves the goal of reducing energy consumption worldwide

by 2 % (excluding Postbank locations). Through purchasing renewable electricity in eleven countries, 78 % of all our electricity

worldwide was from renewable sources by year-end 2019. To date, 30 buildings or projects continue to have LEED certification

from the U.S. Green Building Council, and a further five have certification in progress.

For example, when refurbishing infrastructure in one of our Bangalore offices, we replaced ductable packaged air conditioning

units with highly energy-efficient variable refrigerant volume (VRV) units, and installed a power-over-ethernet intelligent lighting

system using LED lights, which has reduced the lighting load by 50 %. To date, this project has saved 1.45 gigawatt hours

(GWh), and reduced energy costs by € 180,000 annually.

Over the past three years, our energy consumption has been reduced by 9 %. In 2019, the actual reduction achieved was

5.5 %. Each year, our EcoPMO conducts an in-depth analysis to evaluate the performance of savings initiatives against

targets, and to leverage synergies between our geographical regions. Energy reductions achieved in offices total 8.6 GWh

from 220 initiatives (in-year savings, i.e. a saving completed in June only gets six months of savings towards 2019). The types

of energy included in the reductions are electricity, district cooling, district heat, and natural gas. These totals exclude savings

made by Postbank.

Carbon neutrality

GRI 201-2, 305-5

One of the most important environmental targets is the endorsement by the Deutsche Bank Management Board of our

commitment to carbon neutrality, which we achieved in 2012 and have maintained since then. In 2019, we continued to offset

unavoidable carbon emissions covering GHG Scopes 1 and 2 and business travel by purchasing and retiring high-quality

emission reduction certificates. The carbon credits purchased in 2019 reveal investments in a diversified product portfolio

supporting climate change mitigation and economic development in Africa, Latin America, and Asia. All offsetting projects

comply with well-recognized global standards, including the Gold Standard (62 %) and the Verified Carbon Standard.

offsetting portfolio ‒ supported projects and regional split

Dec 31,2019

Africa

Americas

Asia

Wind energy

35,000

15 %

Biomass/biogas

−

Efficient cook stoves

45,000

20 %

Geothermal energy

45,000

20 %

Hydropower

−

Sustainable forest management/REDD

15,000

25,000

18 %

Solar energy/photovoltaics

60,834

27 %

26.57 %

46.86 %

100 %

Total

60,000

105,834

225,834

Reducing Emissions from Deforestation and Forest Degradation.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

In-house ecology

Eco-efficiency tables

GRI 302-1/3/4, 305-1/2/3/4/5

GHG emissions

in t of CO2e

(unless stated differently)

Variance from

previous year

(in %)

Dec 31, 2019¹

Dec 31, 2018²

Dec 31, 2017²

Total GHG emissions (market-based)

(6.1)

201,201

214,322

220,215

Market-based emissions from building energy use

(2.3)

133,316

136,505

138,968

Emissions from business travel

(16.3)

61,108

72,975

77,290

Scope 1, direct GHG emissions

(3.4)

49,712

51,473

52,071

Natural gas consumption

(5.0)

28,855

30,358

30,670

Liquid fossil fuels

(25.1)

453

605

753

HFCs

39.9

6,777

4,843

3,956

Owned/leased vehicles

(13.0)

13,627

15,667

16,692

Scope 2, indirect GHG emissions

(1.5)

104,009

105,541

107,546

Market-based emissions from electricity consumption

0.6

68,308

67,901

67,717

Steam, district heating and cooling

(5.2)

35,701

37,640

39,829

Scope 3, other indirect GHG emissions

(17.1)

47,480

57,308

60,598

Air travel

(17.9)

43,782

53,341

56,284

Rented vehicles and taxis

6.9

2,484

2,324

2,684

Rail travel

(26.1)

1,214

1,643

1,630

Emissions reductions

N/M

Off set of market

-based GHG emissions by retirement of high-quality carbon

certificates

100

Market-based GHG emissions (incl. renewables, excluding carbon

credits)/rentable area per sqm

(3.2)

0.06402

0.06615

0.06463

Market-based GHG emissions (incl. renewables, excluding carbon credits)

per FTE

(1.0)

2.22351

2.24653

2.25709

Total energy consumption in GJ

(5.5)

3,148,899

3,331,138

3,455,721

Total energy consumption in GWh

(5.5)

875

925

960

Electricity consumption in GWh

(4.9)

508

534

552

Energy from primary fuel sources (oil, gas, etc.) in GWh

(7.0)

204

219

226

Delivered heat and cooling in GWh

(5.2)

163

172

181

Electricity from renewables in GWh

(5.2)

396

417

440

Space-normalized energy consumption in kWh per sqm

(2.5)

278

286

282

Normalized energy consumption in kWh per FTE

(0.3)

9,666

9,699

9,839

Data reported under 2019 relates to the period October 1, 2018 to September 30, 2019. Q4/2018 is used to represent activity of Q4/2019, with an average uncertainty of

+/- 5% across all KPIs.

Changes to the reported figures in previous years can be attributed to the following: a. updated power grid factors b. historic data updates (e.g. billing updates), and

c. methodology changes.

Total emissions are based on actual, estimated, or extrapolated data. All assumptions and calculation methodologies are in line with the ISO 14064 Standard Guidelines with

supporting documentation. The most appropriate emission factors have been used for each activity data type, from internationally recognized sources, e.g. DEFRA (2018 and

2019), GHG Protocol, eGRID (2016), and IEA (2019), RE-DISS (2018), or, if more relevant, from country or contract specific sources. The factors include all GHGs where

possible and the gases’ Global Warming Potential as per the IPCC AR5 assessments.

Emissions from liquid fossil fuels decreased in 2019, largely driven by the closure of accounts in Asia Pacific and the U.S.

Emissions from HFCs increased in 2019. The increase is in the expected range factoring in maintenance work conducted.

Emission factors from IEA (2019) for electricity were used for the countries where Deutsche Bank operates (except for the U.S. where the eGRID (2016) factors were used).

The former set of factors is only available in tons of CO

, while eGRID factors are specified in CO

e. However, as the proportion of non-CO

GHG emissions is minute

compared to CO

, we are reporting all emissions from electricity in CO

Emissions from rented vehicles and taxis have increased, driven by an increase in the distance traveled in rented vehicles in Germany.

For 2019, carbon neutrality was accomplished by the purchase and retirement of verified emissions’ reduction units.

All floor area metrics use an annual average derived from October 2018 to September 2019 data (3,14 million m

All FTE metrics use an annual average for 2019 (90,488).

Total energy consumption in GWh comprises all sources used in Scopes 1 and 2: natural gas, liquid fossil fuels (mobile and stationary), renewable and grid electricity, district

heating, cooling, and steam. Standard joule to kWh conversion factors were used. The only renewable energy source used is electricity and equals 395,694,776 GWh. There

was no sale of electricity, heating, cooling, or steam.

Calculated electricity and heating intensities are used to estimate electricity and heating demand where data is not available. Calculated intensities from refrigerant gas loss

are also used to extrapolate where data is not available.

In 2019, total emissions from market-based reporting (including the effect of buying renewable electricity) amounted to

201,200 metric tons of CO

e, while emissions from location-based reporting (excluding renewables) were 356,086 metric tons

of CO

e. The difference between market and location emissions is due to the renewable energy contracts, most significantly

in our three largest electricity-consuming countries: Germany, the U.K., and the U.S.

The electricity contracts with zero-carbon, supplier-specific emission factors are used in countries with renewable electricity,

and include Renewable Electricity Certificates (RECs) in the U.S. and Canada, Renewable Energy Guarantees of Origin

(REGOs) for selected sites in the U.K., Guarantees of Origin (GOs) in Germany, and International Renewable Energy

Certificates (IRECs) in Spain. Austria, Italy, Belgium, Luxembourg, the Netherlands, and Switzerland also have zero-carbon

electricity contracts.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

In-house ecology

Business travel

Deutsche Bank is reducing business travel (particularly by air) to reduce both emissions and cost. Our travel approval policy

focuses on limiting the number of business flights by Deutsche Bank employees. As a result, the volume of air travel continues

to decline. In 2019, we achieved a 17.8 % reduction in air travel in a year-on-year basis. The reductions in travel indicators

ranging from 9 % to 18.3 % are mostly the result of a more disciplined approach to travel. The average number of FTEs

declined 5.2 % during this period.

Distance traveled

in km

(unless stated differently)

Variance from

previous year

(in %)

Dec 31, 2019

Dec 31, 2018

Dec 31, 2017

Total distance travelled

(16.0)

532,099,332

633,103,924

667,184,227

Total air travel

(17.8)

396,726,240

482,841,207

508,925,234

Short-haul air travel

(17.5)

16,006,857

19,401,142

20,865,472

Medium-haul air travel

(14.7)

53,269,978

62,470,252

61,841,447

Long-haul air travel

(18.3)

327,449,404

400,969,812

426,218,316

FTE-normalized travel in km per FTE

(13.4)

4,384

5,061

5,216

Total rail travel

(12.0)

41,067,476

46,665,754

47,162,896

Total road travel

(9.0)

94,305,616

103,596,964

111,096,096

FTE-normalized total distance travelled in km per FTE

(11.4)

5,880

6,636

6,838

Domestic and international air travel is derived from 99.86 % of actual flight data; the remaining 0.14 % is extrapolated based on cost. Air Travel uses GHG Protocol emissions

factors. No radiative forcing factor is applied.

Rail travel is derived from 96.76 % of actual rail travel data; the remaining 3.24 % is extrapolated based on cost.

Taxi data reported includes data for countries based on cost, and is calculated using a country-level taxi tariff. For Czech Republic, France, Germany, Israel, Russian

Federation, U.S., United Arab Emirates and U.K., actual distance traveled and fuel data is used. Road travel uses DEFRA (2018 and 2019) emission factors.

Data reported under 2019 relates to the period October 1, 2018 to September 30, 2019. Q4/2018 is used to represent activity of Q4/2019, with an average uncertainty of

+/- 5 % across all KPIs.

Changes to the reported figures in previous years can be attributed to the following: a. historic data updates (e.g. billing updates, refunds), and b. methodology changes.

The publishing date of this report and the availability of data, such as energy bills, necessitated minor extrapolations to produce

the data for 2019. Whether this makes a material difference to the data is under continual assessment.

Waste, water, and paper consumption

GRI 301-1/2, 303-5, 306-2

We are also striving to reduce the amount of waste we produce, and to cut back on our water, paper, and plastic consumption,

particularly in preparation for the EU plastic reduction legislation.

Deutsche Bank

Supplement according to Global Reporting Initiative

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In-house ecology

Waste and paper

in t

(unless stated differently)

Variance from

previous year

(in %)

Dec 31, 2019

Dec 31, 2018

Dec 31, 2017

Waste

Waste disposed

(17.0)

7,596

9,157

9,276

Normalized waste disposed in t per FTE

(12.5)

0.08395

0.09599

0.09507

Waste produced

(16.8)

16,614

19,958

21,683

Normalized waste produced in t per FTE

(12.2)

0.18361

0.20920

0.22224

Waste recycled

(16.5)

9,018

10,801

12,407

Normalized waste recycled in t per FTE

(12.0)

0.09966

0.11321

0.12717

Waste recycled in %

0.3

54.3

54.1

57.2

Waste composted

(12.4)

3,999

4,565

3,440

Waste with energy recovery

(29.2)

2,377

3,358

4,539

Waste incinerated (without energy recovery)

(14.6)

722

845

982

Waste landfilled

28.2

498

389

314

Hazardous waste

(86.4)

253

189

Nonhazardous waste

(15.9)

16,580

19,705

21,493

Paper

Copy/print paper consumed

(6.8)

3,289

3,528

3,681

Recycled paper

81.6

247

136

172

Recycled content in %

94.7

7.5

3.9

4.7

Normalized paper consumption in t per FTE

(1.7)

0.03635

0.03698

0.03773

Data reported under 2019 relates to the period October 1, 2018 to September 30, 2019. Q4/2018 is used to represent activity of Q4/2019, with an average uncertainty of

+/- 5% across all KPIs.

Changes to the reported figures in previous years can be attributed to the following: a. historic energy data updates (e.g. billing updates), and b. methodology changes.

Waste data, incl. the disposal method and hazardous/non-hazardous split, has been determined by information provided by the waste contractor. Waste data is extrapolated

based on FTEs from Germany, the U.K., the U.S. and from seventeen other countries, covering 84.1% of FTEs. Waste data does not include project waste, e.g. from

refurbishments.

The 16.5% decrease in waste recycled was driven by waste reduction campaigns in the Americas, APAC and EMEA.

In 2019, there was a 14% decrease in composted waste in Germany which was driven by improved waste and resource management.

The decrease in incinerated waste was largely driven by the U.K., where there has been an overall 33 % reduction in waste generated due to office closures.

Hazardous waste quantities were significantly high in the previous reporting period due to a battery-recycling scheme at the Jacksonville, 5022 Gate Parkway, 32256 Florida

site.

Copier paper data (“materials used” in GRI G4 reporting terminology) is extrapolated based on consumption per FTE from 23 countries covering, on average, 83 % of FTEs.

The 6.8% decrease was mainly driven by a decrease in paper consumption across the Postbank portfolio, driven by portfolio restructuring and office closures. Average

Postbank FTEs decreased 17% compared to the previous reporting period.

Plastic

To significantly reduce single-use plastics Deutsche Bank has started to remove all plastic cups, utensils, straws, and sachets

from catering facilities, vending machines, and kitchens with cleaning facilities, and replaced them with reusable alternatives,

such as reusable cutlery and crockery. This initiative has been rolled out in sites across Germany and the U.K., and is part of

the bank’s waste reduction strategy. Posters, e-mail banners, and Corporate Services’ intranet have promoted the initiative

and educated staff on current challenges, with the focus on plastic disposal, much of which cannot be recycled due to poor

segregation and contamination of waste streams.

Paper

As key resources are consumed in making paper, we have worked to cut our paper consumption by using pull-print technology,

which has enabled the deployment of fewer printers, as well as introducing changes to staff printing habits, such as using

desktop-on-demand technology in meetings. This gives users a quick and easy login to access and view their files on screen

while in meeting rooms, and thus saves printouts of any documents required.

Water

in m³

(unless stated differently)

Variance from

previous year

(in %)

Dec 31, 2019

Dec 31, 2018

Dec 31, 2017

Total water consumed (potable)

(6.3)

1,614,603

1,723,236

1,965,340

Normalized water consumption in cbm per FTE

(1.2)

17.8

18.1

20.1

Space-normalized water consumption in cbm per sqm

(3.4)

0.51

0.53

0.58

Data reported under 2019 relates to the period October 1, 2018 to September 30, 2019. Q4/2018 is used to represent activity of Q4/2019, with an average uncertainty of

+/- 5 % across all KPIs.

Changes to the reported figures in previous years can be attributed to the following: a. historic energy data updates (e.g. billing updates), and b. methodology changes.

Actual water consumption data is based on meter readings and invoices. Water figures are extrapolated on a site level, based on rentable area, and refer to potable

(municipal) water only.

Water

As water is a scarce commodity in many countries around the world, we have introduced a variety of measures to save water.

Our water reduction initiatives include aeration faucets and water-efficient products being installed whenever new services

are required, or when facilities are refurbished. We have modified the set-point value of the absolute humidity rate for common

air conditioning systems from 8.5 to 7.0

grams per kilogram at our Frankfurt am Main location DBC South. This small change

reduced the volume of water used by over 2,000

cubic meters a year (about 0.1 % of total annual consumption), and reduce

our energy consumption.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Corporate social responsibility

Deutsche Bank’s social engagement contributes to the bank’s stated purpose of enabling economic growth and societal

progress. It does so by creating a positive impact on the communities we operate in. In spite of continued budget pressures,

we impacted 1.6 million lives through the bank’s corporate citizenship initiatives in 2019.

Deutsche Bank’s corporate social responsibility (CSR) mission is to enable communities and economies to prosper. Our

initiatives have a strategic focus on education, enterprise, and community, and we encourage our employees to underpin the

bank’s citizenship activities with their professional expertise, whenever they can. Postbank’s CSR initiatives are focused on

Germany and bundled under the motto “We for children”.

All of these programs help to build trust, employee and client loyalty, as well as to strengthen our reputation as a socially

minded enabler, reliable partner, and catalyst for societal change. To drive our CSR agenda and initiatives forward, we foster

employee involvement, interact with stakeholders, seek long-term partnerships with charities, and support advocacy initiatives

and intercompany efforts to promote impact orientation.

Stakeholder relevance of Deutsche Bank’s CSR commitment

Deutsche Bank supports education programs to

help young people develop their full potential.

Deutsche Bank enables social enterprise.

Deutsche Bank supports the underprivileged and

socially challenged.

0 25 50 75 100

Deutsche Bank’s CSR engagement helps to

enhance the bank’s reputation.

representative global employee survey, 2018 (top2-boxes on 5-point scale, in %).

representative global B2C survey, 2018 (top2-boxes on 5-point scale, in %).

Deutsche Bank acts to enable communities and

economies to prosper.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Corporate social responsibility

The consistent impact we make in society was evident again in 2019. We reached more than 3.2 million people in

all – 1.6 million through our CSR programs and another 1.6 million via our Art, Culture & Sports projects – and invested

€ 57.9 million in our initiatives. Almost 19,000 Deutsche Bank employees (25 % of staff worldwide) and 140 Postbank

employees in Germany engaged in civic projects as corporate volunteers.

CSR key performance indicators

2019

2018

2017

Total CSR investments, in € m.

57.9

53.7

64.2

External perception of Deutsche Bank as a responsible corporate citizen (global B2B market) /

(in %)

People reached with CSR initiatives in m.

3.2

4.2

5.2

thereof:

Born to Be, Made for Good, In the Community

1.6

1.8

2.1

Art, Culture & Sports

1.6

2.4

3.1

Representative global B2B survey in 14 countries; top2 ratings on 5-point scale.

Different assessment methodology.

This report highlights some of our CSR activities. For details of other activities, please visit our Deutsche Bank or Postbank

CSR websites.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Corporate social responsibility

Governance and impact tracking

Deutsche Bank’s Communications & CSR team reports directly to the CEO. Dedicated policies and procedures, such as the

Donations, Memberships, Sponsorships (DMS) Policy and CSR Cornerstones, constitute the mandatory operating framework

for Deutsche Bank, and external partners acting on their behalf. Our social engagement is implemented by our regional units

and endowed foundations. New CSR project proposals can be evaluated along a standardized framework and are subject to

sign-off by local CSR teams, regional CSR councils, and/or Board members, depending on the value of the investment. In

markets with defined legal or regulatory demands on social commitment, our CSR initiatives go beyond the minimum

regulatory requirements, as, whenever possible, we enhance our financial support with the professional expertise and

networks of the bank and its employees. We welcome the Companies Act 2013 in India, fully embrace the Black Economic

Empowerment (BEE) legislation in South Africa, and for over 25 years have received a consistent Outstanding rating for our

Community Reinvestment Act (CRA) performance from the Federal Reserve Bank of New York.

To ensure that resources are deployed efficiently and projects fully aligned with the strategic objectives of our CSR agenda,

we annually monitor the direct impact of our investments and systematically collect feedback from our community partners via

the Global Impact Tracking (GIT) tool. We also measure our projects’ social return on investment (SROI) according to the

London Benchmarking Group (LBG) methodology, as it is our bank’s aim to move from mere charitable donations to strategic

community investments. What we learn from these analyses has enabled us to improve our CSR portfolio over time. Our

assessment of the focus and efficiency of our programs is based on three steps. The first step (Input) looks at the cash or in-

kind donations, time, knowledge, and expertise invested in a project. The second step (Output) reflects the output numbers,

such as the number of beneficiaries, project partners, corporate volunteers, and workshops held, as well as the leverage we

activate from other sources, for instance. via fundraising contributions. Step three (Impact) documents the mid- to long-term

impacts on the various stakeholders, based on project achievements and satisfaction with the project objectives/cooperation.

It also assesses a project’s awareness rating and relevance along with its brand-building potential among all key stakeholders

(beneficiaries, project partners, society, company, and employees).

Born to Be – our youth engagement program

Deutsche Bank believes in the power of education. That is why Born to Be supports efforts to enable children and young

people to fulfill their potential and secure gainful and rewarding employment later on. After all, education is key to both social

and economic development and to social cohesion, as it empowers people from disadvantaged backgrounds to earn a decent

income and achieve a better quality of life. Born to Be does this by raising aspirations, attitudes, and progression, by

developing technical, academic, and employability skills, and by enabling access and pathways to education and employment.

Postbank focuses on supporting marginalized children with the help of fundraising contributions from employees and clients.

In 2019, our education programs reached some 460,000 children and young people via 122 projects in 25 countries. Since

2014, there have been 4.7 million Born to Be beneficiaries, so we are well under way to reaching our target of 5 million in

2020.

Born to Be – facts and figures

2019

2018

2017

Born to Be

Born to Be projects supported by corporate volunteers (in %)

Cumulative Born to Be beneficiaries in m. (since 2014)

4.7

4.4

3.9

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Corporate social responsibility

Born to Be – a U.S. project highlight

As part of our long-standing partnership with StreetWise, Deutsche Bank employees have provided volunteer leadership and

mentorship to CUNY community college students in the U.S. and have helped to build skills, resources, and access to networks

to advance their careers. The bank is also working with the Center for Urban Future

to illuminate a leading cause of low

graduation rates at NYC’s community colleges. We funded a new study entitled Overcoming Non-Tuition Financial Barriers

for Community College Students. This advocacy piece examines how challenges, such as food insecurity, transportation, and

child care, can impact the ability of students from low-income communities (more than 70 % earn less than $ 30,000 per year)

and makes recommendations to overcome these barriers to graduation.

Made for Good – our enterprise program for social good

Entrepreneurship plays a vital role in the growth and prosperity of economies and societies worldwide. Nowadays, more and

more entrepreneurs are opening up new ways to tackle poverty, unemployment, inequality, deprivation, and other

socioeconomic challenges. One in four start-ups in Europe is estimated to be a social business. Yet recent research by Small

Business Trends showed that 90 % of start-ups fail, and the hurdles are even greater for businesses with social goals. The

business skills, networks, and sources of funding we provide can help start-ups, microenterprises, nonprofits and the like to

scale their offers.

In line with Deutsche Bank’s commitment to championing initiatives that drive positive societal change, the Made for Good

program was set up four years ago to build the capacities of start-ups and early-stage enterprises that create social good.

Since 2016, Made for Good has supported over 19,200 social enterprises and reached nearly 940,000 people.

5,735 enterprises and social entrepreneurs in ten countries benefited from almost 14,000 hours of support provided by

Deutsche Bank employees in 2019. We have thus made substantial progress towards achieving our goal of reaching a total

of 20,000 enterprises by 2020.

Together with the Thomson Reuters Foundation, we conducted the second global experts’ poll on The best countries to be a

social entrepreneur 2019. Our findings highlight areas of strength and weakness in the world’s 45 biggest economies – and

how this has changed in the past three years. The poll’s results give social entrepreneurs, policymakers, and investors the

research findings they need to further discuss, explore, and pursue innovative ways of doing business for good. For the first

time, the

survey highlights countries where women and young social entrepreneurs are playing a bigger role and identifies the

cities deemed to be hotspots for new-style businesses seeking to have social impact.

Made for Good – facts and figures

2019

2018

2017

Made for Good

Made for Good enterprise projects supported by corporate volunteers (in %)

Cumulative number of participating social enterprises (since 2016)

19,232

14,733

11,754

Cumulative number of Made for Good beneficiaries (since 2016)

939,424

564,022

229,696

Prior-year numbers adjusted.

Made for Good – a German project highlight

Aligned to the UN Sustainable Development Goals, our Global Goals Lab connects the dots between the bank’s Made for

Good and its commercial start-ups programs. The program supports early-stage enterprises with a social mission via coaching

by Deutsche Bank employees and expert advice to develop their business plan, scale their offerings, access new networks,

or tap sources of funding. In March 2019, the Impact Fund donated a total of € 35,000 to three social enterprises working

towards greater equality of opportunity and more inclusion (SDGs 4, 10, and 11). In the year under review, the Global Goals

Lab focused on climate action and responsible consumption (SDGs 12 and 13).

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Corporate social responsibility

In the Community – strengthening neighborhoods

Deutsche Bank’s strategy for alleviating poverty extends beyond philanthropy to include high-level field leadership in the form

of coalition building, advocacy, and employee engagement. This broadens the scope of our programs and enhances our help

for the disadvantaged or disenfranchised. Through investments of both financial and human capital, we tackle issues like

poverty, joblessness, homelessness, and forced migration. We also provide relief in emergencies and encourage forward-

thinking on emerging challenges. In 2019, we supported 123 community projects in 21 countries, impacting the lives of almost

585,000 people. Since 2015, our community initiatives

have impacted 3.1 million lives, and we are well on the way to making

a positive impact on 4 million people by 2020.

In the Community – facts and figures

2019

2018

2017

In the Community

Community projects supported by corporate volunteers (in %)

Cumulative number of beneficiaries of community projects in m. (since 2015)

3.1

2.8

2.4

In the Community – an Asia Pacific/India project highlight

In India, we collaborate with Swades Foundation, a grassroots organization focusing on rural empowerment, and support a

water harvesting initiative to revive 2,000 villages in drought-prone Raigad, in Maharashtra, by providing access to drinking

water on tap and creating access to water for agricultural irrigation purposes. But the benefits extend far beyond these

measures, as the project seeks to achieve a wholesale revival of the ailing local economy through ongoing interventions. Since

2016, the project has impacted nearly 39,000 villagers and provided 200 liters of potable tap water per day. The bank’s

intervention has resulted in the villagers gaining access to 100 government water schemes, infrastructure development for

irrigation, and reservoir structures for rainwater harvesting, as well as economically uplifting 7,633 households. Additionally,

under the Plus You program, some 400 Deutsche Bank employees have volunteered their time with Swades to contribute to

the cause.

Plus You – our volunteering and giving community

For more than 25 years, Deutsche Bank has engaged employees in its corporate citizenship. Our people’s commitment to

helping others reflects the values Deutsche Bank lives by as well as our commitment to create a positive impact on society.

With a wide range of volunteering opportunities and giving schemes available, Deutsche Bank and Postbank employees can

take time out to share their professional and life skills or offer hands-on support to local community projects. Corporate

volunteering not only boosts the impact of our CSR programs, but also has a positive impact on the personal development,

motivation, and loyalty of our employees.

In 2019, almost 19,000 Deutsche Bank employees were engaged in volunteer projects, a participation rate of 25 %. And 140

Postbank employees supported 40 team challenges in Germany. A total of almost 220,000 hours – 52% during and 48 %

outside of office hours – were spent on volunteer work and around € 8.4 million generated through matched giving programs

and fundraising initiatives. The matched giving and payroll giving schemes extend the reach and impact of initiatives close to

the hearts of our people.

Despite the challenging environment, we were able to engage more colleagues in our Plus You

volunteering and giving

community than last year. Going forward, we aim to keep volunteering participation above 20 %, while continuing to focus on

skills-based opportunities and engaging our colleagues in an increasing share of projects. We will carry on encouraging

fundraising for charities and aim to maintain our annual matched giving totals at more than € 5 million. In the light of our

upcoming 150th anniversary, we hope to further boost engagement levels in spite of restructuring efforts and continued budget

restrictions.

Deutsche Bank

Supplement according to Global Reporting Initiative

Non-Financial Report 2019

Corporate social responsibility

Plus You – facts and figures

2019

2018

2017

Plus You - Volunteering and Giving (excl. Postbank brand)

Employees participating in the bank's volunteer programs

18,963

17,946

17,417

in % of total staff

Hours invested by corporate volunteers

219,517

209,122

235,783

Total employee donations and matching by Deutsche Bank, in € m.

8.4

7.6

10.5

Plus You – a UK project highlight

The Charities of the Year program in the U.K. supports small charities chosen by our employees for two years at a time.

Through fundraising and by sharing our resources and the skills of our people, we help these organizations to grow sustainably

and have more impact. In 2019, we raised nearly £ 2.1 million for the Charities of the Year, Cure Leukemia and Rays of

Sunshine, with £900,000 coming from the Donate One Day initiative. Cure Leukemia offers hope to patients with currently

incurable forms of blood cancer via potentially life-saving treatment and funding for specialist research nurses. The Rays of

Sunshine children’s charity brightens up the lives of courageous children with a serious or life-limiting illness, as well as their

families, by putting their illnesses on hold and fulfilling their greatest wishes. The funding will help both organizations to create

transformational change and ensure a legacy beyond the 24-month partnership. Since 1999, we have raised £ 24.6 million for

26 Charities of the Year. In 2020 and 2021, Deutsche Bank will partner with Hospice U.K. for two years to revolutionize hospice

care and change the conversation around death, bereavement, and grief.

Alfred Herrhausen Gesellschaft

The Alfred Herrhausen Gesellschaft works to promote a free and open society and its cohesion. Its work addresses individuals

in positions of responsibility – present and future decision-makers and thought leaders in politics, the economy, media, and

society, both in Germany and across the world. The Alfred Herrhausen Gesellschaft currently works in two specific project

areas, Europe and Cities, and in one more flexible area entitled Free Thinking. In the latter the multimedia project entitled

Think. Order. Form. Forwards. is continuing Alfred Herrhausen’s intellectual work by taking his essays and speeches as a

starting point and enabling more than 30 prominent contributors to reflect on issues like social market economy, democracy,

entrepreneurship, sustainability, and education, as well as European and international politics.

Yad Vashem

In May 2019 the foundation stone was laid for the new Shoah Heritage Collections Center at the Yad Vashem World Holocaust

Remembrance Center in Israel. The new building will house and display artefacts that Holocaust survivors have donated to

Yad Vashem. As a sign of our commitment to remembering the past and fighting anti-Semitism and racism we donated one

million euros.

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Supplement according to Global Reporting Initiative

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Art, culture and sports

With our Art, Culture & Sports commitment we are investing in the future of society by making our initiatives and projects

accessible to as many people as possible and supporting promising talent. Our Art, Culture & Sports policy defines control

principles and responsibilities for art-, culture-, and sports-related activities at Deutsche Bank.

PalaisPopulaire

PalaisPopulaire is our interdisciplinary and innovative forum for art, culture, and sports at a prime location in Berlin. Changing

exhibitions with different international partner institutions and works from the Deutsche Bank Collection are on display here.

Furthermore, we invite the public, clients, and employees to interactive cross-thematic talks and cultural evenings, such as

concerts, readings, or dynamic sports workshops. Additionally, PalaisPopulaire offers a broad educational program for children

and adults, as well as special barrier-free offerings for blind and visually impaired visitors. Free admission for everyone on

Mondays is part of our philosophy of an “open house for open minds”.

Art

For 40 years, we have been offering access to contemporary art to employees, clients, and the general public through

exhibiting our collection at more than 600 Deutsche Bank premises, PalaisPopulaire, and international exhibitions, as well as

through our educational programs. Deutsche Bank supports joint projects with museums, art fairs, and other institutions to

award and encourage emerging artists.

ArtWorks, our global art program, aims to make art accessible to everybody. Our headquarters in Frankfurt am Main is the

heart of our global art activities. In 2019, nearly 2,300 art enthusiasts visited our selection of some 1,800 artworks, with each

floor of the “Towers” dedicated to one artist.

Cultural commitment

Promoting culture is an essential pillar of our corporate responsibility activities. Here, the focus is not only on long-term

partnerships and important cultural institutions, such as the Berlin Philharmonic Orchestra, but also on the promotion of young

talents.

By partnering with the Berlin Philharmonic Orchestra, we have enabled educational programs that have introduced classical

music to nearly 65,000 children and young people. In 2019, we not only celebrated the 30th anniversary of our partnership,

but also announced the extension of our cooperation with the orchestra for a further five years. To mark these celebrations,

Deutsche Bank supported the free open-air concert at the Brandenburg Gate, which was attended by around 35,000 people.

Young musicians profit from Deutsche Bank’s partnerships with the Young German Philharmonic Orchestra and Schloss

Belvedere Music Academy. Whereas the Young German Philharmonic Orchestra prepares music students for careers in

orchestras, Schloss Belvedere Music Academy supports some 120 students who enjoy a highly qualified music education

while teaching them the skills needed for university.

Talent in competitive sports

Sports connect people across borders and motivate them to be fair and perform to the best of their ability, regardless of the

discipline. In accordance with this belief, Deutsche Bank has promoted competitive sports for decades.

Since 1955, we have supported the renowned World Equestrian Festival, CHIO Aachen. Additionally, we support young riders

through the Deutsche Bank Equestrian Sport Academy. Up to ten exceptional young dressage talents selected by the trainer

of the German national equestrian team receive targeted training, access to selected tournaments, and advice from

Deutsche Bank mentors. Academy participants will also become tutors themselves and train talented amateur riders to

encourage as broad a spectrum of young riders as possible.

Since 2001, we have supported the German Sports Aid Foundation, the most important privately funded sports initiative in

Germany. In 2019, we again sponsored Sports Aid athletes through the Deutsche Bank Sports Scholarships. We also

sponsored the initiative Sprungbrett Zukunft (Springboard to the Future) to help young top athletes to advance their careers.

In 2019, we cooperated with the German Sports Aid Foundation to launch the fundraising campaign #GripForGold in order to

promote and support German top athletes and young talents.

Appendix

86 Reports of the independent auditor

90 GRI and UN GlobalCompact

103 Abbreviations

106 Imprint / publications

Deutsche Bank

Appendix

Non-Financial Report 2019

Reports of the independent auditor

Limited Assurance Report of the Independent Auditor regarding the combined

separate non- financial report

To the Supervisory Board of Deutsche Bank Aktiengesellschaft, Frankfurt am Main

We have performed an independent limited assurance engagement on the combined separate non-financial report of

Deutsche Bank Aktiengesellschaft, Frankfurt am Main, (further “Deutsche Bank” or “Company”) and Deutsche Bank Group as

well as the by reference qualified part “Our Organization” (further „non-financial report”) according to §§ 315b, 315c in

conjunction with 289b to 289e of the German Commercial Code (HGB) for the period from January 1 to December 31, 2019.

Management’s Responsibility

The legal representatives of Deutsche Bank Aktiengesellschaft are responsible for the preparation of the non-financial report

in accordance with §§ 315b, 315c in conjunction with 289b to 289e HGB.

This responsibility of the legal representatives includes the selection and application of appropriate methods to prepare the

non-financial report and the use of assumptions and estimates for individual disclosures which are reasonable under the given

circumstances.

Furthermore, the responsibility includes designing, implementing and maintaining systems and processes relevant for the

preparation of the non-financial report in a way that is free of – intended or unintended – material misstatements.

Independence and Quality Assurance on the Part of the Auditing Firm

We are independent from the company in accordance with the requirements of independence and quality assurance set out

in legal provisions and professional pronouncements and have fulfilled our additional professional obligations in accordance

with these requirements.

Our audit firm applies the legal provisions and professional pronouncements for quality assurance, in particular the

Professional Code for German Public Auditors and Chartered Accountants (in Germany) and the quality assurance standard

of the German Institute of Public Auditors (Institut der Wirtschaftsprüfer, IDW) regarding quality assurance requirements in

audit practice (IDW QS 1).

Practitioner’s Responsibility

Our responsibility is to express a conclusion performed on the non-financial report based on our work performed within a

limited assurance engagement.

We conducted our work in accordance with the International Standard on Assurance Engagements (ISAE) 3000 (Revised):

“Assurance Engagements other than Audits or Reviews of Historical Financial Information” published by IAASB. This standard

requires that we plan and perform the assurance engagement to obtain limited assurance whether any matters have come to

our attention that cause us to believe that the non-financial report, has not been prepared, in all material respects, in

accordance with §§ 315b and 315c in conjunction with 289b to 289e HGB. We do not, however, issue a separate conclusion

for each disclosure. In a limited assurance engagement the evidence gathering procedures are more limited than in a

reasonable assurance engagement and therefore significantly less assurance is obtained than in a reasonable assurance

engagement. The choice of audit procedures is subject to the auditor’s own judgement.

Our engagement applied to the German version of the combined separate non-financial report. This text is a translation of the Independent Assurance Report issued in

German, whereas the German text is authoritative.

Deutsche Bank

Appendix

Non-Financial Report 2019

Reports of the independent auditor

Within the scope of our engagement, we performed amongst others the following procedures:

– Inquiries of personnel at Group level who are responsible for the materiality analysis to get an understanding of the process

for identifying material topics and respective report boundaries for Deutsche Bank

– A risk analysis, including a media research, to identify relevant information on Deutsche Bank’s sustainability performance

in the reporting period

– Evaluation of the design and implementation of the systems and processes for the collection, processing and control of

disclosure on environmental, employee and social matters, respect for human rights as well as combatting corruption and

bribery matters, and further matters including the collection and consolidation of quantitative data

– Inquiries of personnel who are responsible for determining disclosures on concepts, due diligence processes, results and

risks, the conduction of internal controls and consolidation of the disclosures

– Evaluation of selected internal and external documents

– Analytical evaluation of data and trends of quantitative disclosures which are reported by all sites on group level

– Assessment of the overall presentation of the disclosures

Conclusion

Based on the procedures performed and the evidence obtained, nothing has come to our attention that causes us to believe

that the non-financial report of Deutsche Bank Aktiengesellschaft for the period from January 1 to December 31, 2019 is not

prepared, in all material respects, in accordance with §§ 315b and 315c in conjunction with 289b to 289e HGB.

Restriction of Use/Clause on General Engagement Terms

This report is issued for purposes of the Supervisory Board of Deutsche Bank Aktiengesellschaft, Frankfurt am Main, only.

We assume no responsibility with regard to any third parties.

Our assignment for the Supervisory Board of Deutsche Bank Aktiengesellschaft, Frankfurt am Main, and professional liability

is governed by the General Engagement Terms for Wirtschaftsprüfer and Wirtschaftsprüfungsgesellschaften (Allgemeine

Auftragsbedingungen für Wirtschaftsprüfer und Wirtschaftsprüfungsgesellschaften) in the version dated January 1, 2017

(https://www.kpmg.de/bescheinigungen/lib/aab_english.pdf). By reading and using the information contained in this report,

each recipient confirms notice of provisions of the General Engagement Terms (including the limitation of our liability for

negligence to EUR 4 million as stipulated in No. 9) and accepts the validity of the General Engagement Terms with respect to

us.

Frankfurt am Main, March 13, 2020

KPMG AG

Wirtschaftsprüfungsgesellschaft

[Original German version signed by:]

Laue Glöckner

Wirtschaftsprüfer Wirtschaftsprüfer

[German Public Auditor] [German Public Auditor]

Deutsche Bank

Appendix

Non-Financial Report 2019

Limited Assurance Report of the Independent Auditor

To the Management Board of Deutsche Bank Aktiengesellschaft, Frankfurt am Main

We have performed an independent limited assurance engagement on the disclosures on sustainability performance in the

Non-Financial Report 2019 (further „Report”), of Deutsche Bank Aktiengesellschaft, Frankfurt am Main (further „Deutsche

Bank“) for the period from January 1 to December 31, 2019.

It was not part of our engagement to review product or service related information, references to external information sources,

expert opinions and future-related statements in the Report.

Management´s Responsibility for the Report

The legal representatives of Deutsche Bank are responsible for the accurate preparation of the Report in accordance with the

principles and standard disclosures of the Standards of the Global Reporting Initiative in combination with the Corporate

Accounting and Reporting Standard (Scope 1 and 2) and the Corporate Value Chain Standard (Scope 3) of World Resources

Institute/World Business Council for Sustainable Development and the ISO 14064- 3 for the calculation of the greenhouse gas

emissions for scope 1, 2 and 3, as described in the chapters “About this report” and “Reporting transparently” (further:

“Reporting Criteria”).

This responsibility includes the selection and application of appropriate methods to prepare the Report and the use of

assumptions and estimates for individual sustainability disclosures, which are reasonable in the circumstances. Furthermore,

the responsibility includes designing, implementing and maintaining systems and processes relevant for the preparation of the

Report in a way that is free of – intended or unintended – material misstatements.

Independence and Quality Assurance on the Part of the Auditing Firm

We are independent from the company in accordance with the requirements of independence and quality assurance set out

in legal provisions and professional pronouncements and have fulfilled our additional professional obligations in accordance

with these requirements.

Our audit firm applies the legal provisions and professional pronouncements for quality assurance, in particular the

Professional Code for German Public Auditors and Chartered Accountants (in Germany) and the quality assurance standard

of the German Institute of Public Auditors (Institut der Wirtschaftsprüfer, IDW) regarding quality assurance requirements in

audit practice (IDW QS 1).

Practitioner’s Responsibility

Our responsibility is to express a conclusion based on our work performed of the Report within a limited assurance

engagement.

We conducted our work in accordance with the International Standard on Assurance Engagements (ISAE) 3000 (Revised):

“Assurance Engagements other than Audits or Reviews of Historical Financial Information” and the International Standard on

Assurance Engagements (ISAE) 3410: “Assurance Engagements on Greenhouse Gas Statement” of the International Auditing

and Assurance Standards Board. These standards require that we plan and perform the assurance engagement to obtain

limited assurance whether any matters have come to our attention that cause us to believe that the Report has not been

prepared, in all material respects in accordance with the aforementioned Reporting Criteria. We do not, however, issue a

separate conclusion for each disclosure. In a limited assurance engagement the evidence gathering procedures are more

limited than in a reasonable assurance engagement and therefore significantly less assurance is obtained than in a reasonable

assurance engagement. The choice of audit procedures is subject to the auditor’s own judgement. This includes the

assessment of the risk of material misstatement in the Report under consideration of the reporting criteria.

Our engagement applied to the German version of the Non-Financial Report 2019. This text is a translation of the Independent Assurance Report issued in German, whereas

the German text is authoritative.

Deutsche Bank

Appendix

Non-Financial Report 2019

Limited Assurance Report of the Independent Auditor

Within the scope of our engagement, we performed amongst others the following procedures:

– Inquiries of personnel at Group level who are responsible for the materiality analysis to get an understanding of the process

for identifying material topics and respective report boundaries for Deutsche Bank

– A risk analysis, including a media research, to identify relevant information on Deutsche Bank’s sustainability performance

in the reporting period

– Evaluation of the design and implementation of the systems and processes for the collection, processing and control of the

sustainability disclosures, including the collection and consolidation of quantitative data

– Inquiries of personnel who are responsible for providing the data and information, carrying out internal control procedures

and consolidating the data and information

– Evaluation of selected internal and external documents

– Analytical evaluation of data and trends of quantitative disclosures which are reported by all sites on group level

– Assessment of the overall presentation of the disclosures in the Report

Conclusion

Based on the procedures performed and the evidence received to obtain assurance, nothing has come to our attention that

causes us to believe that the Non-Financial Report 2019 of Deutsche Bank Aktiengesellschaft for the period from January 1

to December 31, 2019 is not prepared, in all material respects, in accordance with the Reporting Criteria.

Restriction of Use / Clause on General Engagement Terms

This report is issued for purposes of the Management Board of Deutsche Bank Aktiengesellschaft, Frankfurt am Main, only.

We assume no responsibility with regard to any third parties.

Our assignment for the Management Board of Deutsche Bank Aktiengesellschaft, Frankfurt am Main, and professional liability

is governed by the General Engagement Terms for Wirtschaftsprüfer and Wirtschaftsprüfungsgesellschaften (Allgemeine

Auftragsbedingungen für Wirtschaftsprüfer und Wirtschaftsprüfungsgesellschaften) in the version dated January 1, 2017

(https://www.kpmg.de/bescheinigungen/lib/aab_english.pdf). By reading and using the information contained in this report,

each recipient confirms notice of provisions of the General Engagement Terms (including the limitation of our liability for

negligence to EUR 4 million as stipulated in No. 9) and accepts the validity of the General Engagement Terms with respect to

us.

Frankfurt am Main, March 13, 2020

KPMG AG

Wirtschaftsprüfungsgesellschaft

[Original German version signed by:]

Laue Glöckner

Wirtschaftsprüfer Wirtschaftsprüfer

[German Public Auditor] [German Public Auditor]

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI 102-55

Our Non-Financial Report provides a comprehensive disclosure of our material topics for our non-financial performance.

Information on financial data is available in our Annual Report 2019. Disclosures included in the report were selected based

on a materiality analysis conducted in 2019. Information on in-house ecology and information regarding corporate social

responsibility activities are not material based on the materiality assessment.

In order to give a better overview, the Non-Financial Report 2019 has been prepared in accordance with the GRI Standards:

Core option, including the specific Sector Disclosures for the financial service sector. Information can either be found on the

referenced pages in the report, via links, or directly in this table. The information outside the Non-Financial Report, for instance

information in our 2019 Human Resources Report, is not part of the external limited assurance.

Furthermore, the Non-Financial Report also serves as our Communication on Progress for the UN Global Compact (UNGC),

references are made in the index as well. By participating in the UNGC, we have committed ourselves to preserving

internationally recognized human rights, creating socially acceptable working conditions, protecting the environment, and

fighting corruption.

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

GRI 102: General Disclosures

Organization profile

102

-1

Name of the organization

Deutsche Bank Group

102-2

Activities, brands, products, and services

AR – Deutsche Bank Group

102-3

Location of headquarters

Frankfurt/Main, Germany

102-4

Location of operations

AR – Note 43 “Country by Country Reporting”

102-5

Ownership and legal form

Deutsche Bank Aktiengesellschaft

102

-6

Markets served

– Deutsche Bank Group

AR – Note 43 “Country by Country Reporting”

102

-7

Scale of the organization

Employment and employability

- Key employee

figures

– The Group at a glance

AR – Consolidated Financial Statements

102

-8

Information on employees and other workers

Employment and

employability – Workforce

management

Employment and employability

–

Key employee

figures

– Employees

HRR

– Delivering on our Strategy – the role of

HR – Workforce development

Unavailability of information. Standards for

steering have been established.

The

material KPIs are tracked and reported in

Deutsche Bank’s HR Report.

SDG 8

UNGC 6

102

-9

Supply chain

Human rights

– Supply chain

Partially reported. As a financial services

provider, the main elements of the supply

chain are related to products

that support

our core operations. These include but are

not limited to: facility services, logistics,

building maintenance, IT software and

hardware, Insurance, lease cars and

business travel, marketing and

communication

102

-10

Significant changes to

the organization and its

supply chain

Employment and employability

– Workforce

management

– Combined Management Report –

Operating and Financial Review

– Deutsche

Bank Group

102

-11

Precautionary Principle or approach

Product responsibility

– Product design and

approval

Product responsibility

–

Prevention of excessive

indebtedness

Reputational risk

– Environmental and social

due diligence

102

-12

External initiatives

Public policy and regulation

– Key topics in

2019

Reputational risk

– Environmental and social

due diligence

Sustainable finance

– Governance

Climate risks

– TCFD recommendations

Climate risks

– UNEP FI working group

Stakeholder engagement

Approach to sustainability

– Engagement

Approach to sustainability

– Impact

measurement

and SDGs

Employment and employability

–

Inclusive work

environment

102-13

Membership of associations

db.com/cr/memberships

Strategy

102

-14

Statement from senior decision

-maker

Letter of the chairman of the Management

Board

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

102

-15

Key impacts, risks, and opportunities

About this combined separate non

-financial

report

– Materiality and risks assessment

process

Approach to sustainability

– Governance

Public policy and regulation

Reputational risk

– Environmental and social

due diligence

Reputational risk

– Industry risk

Reputational risk

–

Emerging risks and recently

identified topics

Sustainable finance

– Investment products –

Asset management

Climate risks

– Risk management strategy and

rocesses

Human rights

– Developments in 2019

Product responsibility

– Product design and

approval

Anti

-financial crime – Governance

Anti

-financial crime – Risk monitoring

processes

Client Satisfaction

– Complaint management

Information security

Data protection

Ethics and integrity

102

-16

Values, principles, standards, and norms of

behavior

Culture and integrity

– Code of Conduct

Culture and integrity

– The Culture, Integrity

and Conduct program

Product responsibility

Product

responsibility – Product and advisory

principles

Sustainable finance

– Governance

Sustainable finance

– Lending and advisory

Sustainable finance

– Investment products

Data protection

– Governance for data

protection management

Employment and employability

– Governance

Approach to sustainability

– Governance

Due diligence of Reputational Risk

–

Environmental and social due diligence

Human rights

Tax

db.com/ir/code

-of-conduct

UNGC 10

102

-17

Mechanisms for advice and concerns about

ethics

Client

satisfaction – Complaint management

Culture and integrity

– Code of Conduct

Anti-financial crime – Governance

UNGC 10

Governance

102

-18

Governance structure

– Management Board

– Report of the Supervisory Board

– Supervisory Board

– Corporate Governance Statement

according to Sections 289f and 315d of the

German Commercial Code/Corporate

Governance Report

– Management Board and

Supervisory Board

Reputational risk

Culture and integrity

– The Culture, Integrity,

and Conduct p

rogram

Sustainable finance

– Governance

Approach to sustainability – Governance

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

102

-20

Executive

-level responsibility for economic,

environmental, and social topics

Culture and integrity

– The Culture, Integrity

and Conduct program

Anti

-financial crime – Governance

Data protection

– Governance for data

protection management

Reputational risk

– Environmental and social

due diligence

Information security

– Governance

Employment and employability

– Governance

Employment and employability

– Inclusive

ulture and work environment – Gender

diversity

Digital transformation

– Governance

Approach to sustainability

– Governance

Climate risks – Governance

102

-21

Consulting stakeholders on economic,

environmental, and social topics

Legal basis

– Materiality and risks assessment

process

Stakeholder engagement

Public policy and regulation

–Employee-

stakeholder interaction

Information security

– Dialog and collaboration

Sustainable finance – Training and awareness

102

-22

Composition of the high

est governance body

and its committees

– Management Board

– Report of the Supervisory Board

– Supervisory Board

– Management Board and Supervisory

Board

SDG 5

102

-23

Chair of the highest governance body

– Management Board

– Report of the Supervisory Board

– Supervisory Board

– Management Board and Supervisory

Board

102

-24

Nominating and selecting the highest

governance body

db.com/ir/en/supervisory

-board.htm

db.com/ir/en/management

-board.htm

db.com/ir/en/download/ToR_Nomination_

Committee._25_07_2019pdf.pdf

SDG 5

102

-25

Conflicts of interest

Product responsibility

– Conflicts of interest

Partially reported. Whether conflicts of

interest are disclosed to stakeholders,

including

cross-board memberships and

cross

-shareholding with suppliers and

other stakeholders are not reported.

102

-26

Role of highest governance body in setting

purpose, values, and strategy

Culture and integrity

– The Culture, Integrity

and Conduct program

Reputational risk

– Environmental and social

due diligence

Approach to sustainability

– Governance

Climate risks – Governance

db.com/ir/committees

-of-the-supervisory-

board

102

-27

Collective knowledge of the highest governance

body

Approach to

sustainability – Governance

102

-29

Identifying and managing economic,

environmental, and social impacts

Legal basis

– Materiality and risks assessment

process

Reputational risk

– Environmental and social

due diligence

Climate risks

– Risk management strategy and

processes

Anti

-financial crime – Governance

102

-31

Review of economic, environmental, and social

topics

About this combined separate non

-financial

report

– Materiality and risks assessment

process

Reputational risk

– Environmental and social

due diligence

– Transactional reviews

Reputational risk

–

Emerging risks and recently

identified topics

Climate risks

– Risk management strategy and

processes

Anti

-financial crime – Governance

Sustainable finance

– Investment products –

Asset manag

ement

Anti

-financial crime – Risk monitoring

processes

Client Satisfaction

– Complaint management

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

102

-32

Highest governance body’s role in sustainability

reporting

The Non

Financial Report Steering Group

has reviewed and pre

-approved the

contents

of the report. The CFO

Disclosure Review meeting chaired by the

CFO approves the Non

-Financial Report.

The final responsibility lies with the board

of directors. The Supervisory Board

reviews the content of the NFRep.

102

-35

Remuneration policies

– Compensation report

HRR – Rewarding performance

Stakeholder engagement

102-40

List of stakeholder groups

Stakeholder engagement

102

-41

Collective bargaining agreements

Employment and employability

– Workforce

management

– Restructuring

– Employees

Not reported. We work with works councils

that represent our employees’ interests in

negotiations with Deutsche Bank as

employer, but details remain confidential.

SDG 8

UNGC 3

102

-42

Identifying and selecting stakeholders

Stakeholder engagement

Client satisfaction

Product responsibility

We do not explicitly report on the

identification of stakeholders. However, as

a listed company, bank and financial

services provider, our business model is

particularly geared towards cl

ients,

shareholders, employees, regulators and

civil society.

102

-43

Approach to stakeholder engagement

Stakeholder engagement

Sustainable finance

– Training and awareness

102

-44

Key topics and concerns raised

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

Stakeholder engagement

Culture and integrity

– Culture, Integrity, and

Conduct program

– 2019 CIC focus values and

mandatory initiatives

Client satisfaction

Client satisfa

ction – Complaint management

Sustainable finance

– Investment products –

Asset management

Public policy and regulation

– Key topics in

2019

Reputational risks

– Emerging risks and

recently identified topics

Reporting practice

102

-45

Entities included in the Consolidated Financial

Statements

– Note 37 “Information on Subsidiaries”

– Note 38 “Structured Entities”

– Subsidiaries

AR – Consolidated Structured Entities

102

-46

Defining report content and topic Boundaries

Legal basis

– Materiality and risks assessment

process

The boundary internal and external (client,

shareholders, society) applies for: Anti

Financial Crime, Culture and integrity,

Climate

risks, Digital transformation, ES due

diligence, Information securi

ty, In-house

ecology, Public policy and regulation,

Sustainable Finance, and Tax.

The boundary internal and external (client,

society) applies for: Data protection,

Product responsibility, Social

responsibility.

The boundary internal applies for:

Employmen

t and employability.

The boundary external (client, society)

applies for: Human rights.

102

-47

List of material topics

Legal basis

– Materiality results for 2019

102

-48

Restatements of information

Legal basis

– Materiality results for 2019

-house ecology – Environmental measures –

Eco

-efficiency tables

Employment and employability

– Diversity

AR – Risk assessment

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

102

-49

Changes in reporting

Legal basis

About this report

102-50

Reporting period

Legal basis

102

-51

Date

of most recent report

The 2018 Non

-Financial Report was

published in March 2019.

102-52

Reporting cycle

About this report

102-53

Contact point for questions regarding the report

Imprint/Publications

102

-54

Claims of reporting in

accordance with the GRI

Standards

About this report

102-55

GRI content index

GRI and UN Global Compact

102

-56

External assurance

Limited assurance report of the independent

auditor

The information contained in this report is

subject to

additional external assurance.

Information in the HR Report are not part

of the external assurance.

Topic specific standard disclosures

GRI 200 Economy

GRI 201: Economic performance

103

-1

Explanation of the material topic

and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

SDG 8

103

-2

The management approach and its components

Sustainable finance

– Governance

Anti

-financial crime – Governance

Climate risks – Governance

103

-3

Evaluation of the management approach

Sustainable finance

– Governance

Anti

-financial crime – Governance

Climate risks – Governance

201

-1

Direct economic value generated and

distributed

– The Group at a glance

AR – Consolidated Financial Statements

SDG 5, 7, 8, 9

201

-2

Financial implications and other risks and

opportunities due to climate change

Sustainable finance

– Lending and advisory

Sustainable finance

– Investment products

Climate risks

– Risk management strategy and

processes

-house ecology – Environmental measures

Carbon neutrality

DWS Report

– Clients and Products:

Sustainable Finance, ESG Products and

Responsible Investing

Partially reported. We have not identified

substantial changes req

uired in

operations, revenue or expenditure posed

by climate change. Therefore, financial

implications or costs of actions are not

reported for 2019.

SDG 13

UNGC 7

GRI 205: Anti-corruption

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

Anti

-financial crime

SDG 16

103

-2

The management approach and its components

Anti

-financial crime – Governance

Anti

-financial crime – Anti-fraud, bribery and

corruption

103

-3

Evaluation of the management approach

Anti

-financial crime – Governance

Anti

-financial crime – Anti-fraud, bribery and

corruption

205

-1

Operations assessed for risks related to

corruption

Anti

-financial crime – Risk monitoring

processes

– Anti-fraud, bribery, and corruption

Not reported. Due to confidentiality

reasons, the number and percentage of

operations assessed are not disclosed.

We only report with regard to business

areas that are

assessed for corruption

risks.

UNGC 10

GRI 300 Environment

GRI 301: Materials

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

-house ecology – Governance

SDG 8, 12

103

-2

The management approach and its components

-house ecology – Governance

103

-3

Evaluation of the management approach

-house ecology – Governance

In-house ecology – Environmental measures

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

301

-1

Materials used by weight or volume

-house ecology – Environmental measures –

Waste, water, and paper consumption

Partially reported as reported data is not

distinguished between non

renewable and

renewable materials.

SDG 8, 12

UNGC 7, 8

301

-2

Recycled input materials used

-house ecology – Environmental measures –

Waste, water, and paper consumption

SDG 8, 12

UNGC 8

GRI 302: Energy

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

-house ecology – Governance

SDG 7, 8, 12

103

-2

The management approach and its components

-house ecology – Governance

-house ecology – Environmental measures

103

-3

Evaluation of the management approach

-house ecology – Governance

In-house ecology – Environmental measures

302

-1

Energy consumption within the organization

-house ecology – Environmental measures –

Eco

-efficiency tables

We do not report total

fuel consumption

from non

-renewable sources. We report

total energy consumption (in GJ and

GWh) and electricity from renewables.

SDG 7, 8, 12, 13

UNGC 7, 8

302

-3

Energy intensity

-house ecology – Environmental measures –

Eco-efficiency tables

SDG 7, 8, 12, 13

UNGC 8

302

-4

Reduction of energy consumption

-house ecology – Environmental measures –

Energy efficiency and conservation

-house ecology – Environmental measures –

Eco

-efficiency tables

SDG 7, 8, 12, 13

UNGC 8, 9

GRI 303: Water

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019 In-

house ecology

– Governance

SDG 8, 12

103

-2

The management approach and its components

-house ecology – Governance

-house ecology – Environmental measures

103

-3

Evaluation of the management approach

-house ecology – Governance

In-house ecology – Environmental measures

303

-5

Water consumption

-house ecology – Environmental measures –

Waste, water, and paper consumption

Partially reported. It is not considered

material as none of our sites are

significant consumers in any catchment

area under water stress.

SDG 6, 12

UNGC 7,8

GRI 305:

Emissions

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

-house ecology – Governance

SDG 8, 12

103

-2

The management approach and its components

-house ecology – Governance

-house ecology – Environmental measures

103

-3

Evaluation of the management approach

-house ecology –Governance

In-house ecology – Environmental measures

305

-1

Direct (Scope 1) GHG emissions

-house ecology – Environmental measures –

Eco-efficiency tables

We do not report on biogenic CO2

emissions, because we don't have any.

SDG 3, 12, 13, 14

UNGC 7,8

305

-2

Energy indirect (Scope 2) GHG emissions

-house ecology – Environmental measures –

Eco

-efficiency tables

SDG 3, 12, 13, 14,

UNGC 7,8

305

-3

Other indirect (Scope 3) GHG emissions

-house ecology – Environmental measures –

Eco

-efficiency tables

We do not report on biogenic CO2

emissions, because we don't have any.

SDG 3, 12, 13, 14,

UNGC 7,8

305

-4

GHG emissions intensity

-house ecology – Environmental measures –

Eco-efficiency tables

SDG 13, 14, 15

UNGC 8

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

305

-5

Reduction of GHG emissions

-house ecology – Environmental measures –

Carbon neutral commitment

-house ecology – Environmental measures –

Eco

-efficiency tables

Sustainable finance

– Investment products –

Asset management

Climate risks

– Risk management strategy and

processes

Emission reduction from 2018 to 2019 is

6.1%.

SDG 13, 14, 15

UNGC 8,9

GRI 306: Effluents and waste

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

-house ecology – Governance

SDG 8, 12

103

-2

The management approach and its components

-house ecology – Governance

In-house ecology – Environmental measures

103

-3

Evaluation of the management approach

-house ecology –Governance

In-house ecology – Environmental measures

306

-2

Waste

by type and disposal method

-house ecology – Environmental measures –

Waste, water, and paper consumption

We do not report on reused waste, on

site

storage, other, deep well injection, and the

missing split up of these amounts into

hazardous and

non-hazardous, because

we don't have any of those.

SDG 3, 6, 12

UNGC 8

GRI 400 Social

GRI 401: Employment

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal

basis – Materiality results for 2019 –

Employment and employability

– People

strategy

HR Report

– Fostering a Sustainable

Performance Culture

SDG 5, 8

103

-2

The management approach and its components

Employment and

employability – People

strategy

Employment and employability

– Governance

Employment and employability

– Workforce

management

HR Report

– Delivering on our Strategy – the

role of HR

– Effective workforce management

103

-3

Evaluation of the

management approach

Employment and employability

– Governance

Employment and employability

– Workforce

management

Employment and employability

–

Key employee

figures

HR Report

– Delivering on our Strategy – the

role of HR

– Workforce development

401

-1

New employee hires and employee turnover

Employment and employability

– Workforce

management

– Recruiting and talent

development

Employment and employability

–

Key employee

figures

– Employees

HR Report

– Delivering on our Strategy – the

role of HR

– Staff turnover

Partially reported due to confidentiality

constraints. Although we report voluntarily

staff turnover in %, assessment and

tracking of numbers related to turnover by

age group and gender are for internal use

only. The HR Report disclose

s staff

turnover by region.

SDG 8

UNGC 6

401

-2

Benefits provided to full

-time employees that

are not provided to temporary or part

-time

employees

Employment and employability

– Workforce

management

– Future-oriented work

environment

Employment and

employability – Workforce

management

– Restructuring

HR Report

– Benefits & Wellbeing

Partially reported: Benefits provided to

employees depend on country, region,

and jurisdiction. Therefore, not all benefits

are available to each employee.

SDG 8

GRI 404: Training and education

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

Employment and employability

Employment and

employability – People

strategy

Employment and employability

– Workforce

management

– Recruiting and talent

development

Sustainable finance

– Training and awareness

Anti

-financial crime – Training and awareness

HR Report

– Developing our People –

Learning

culture

SDG 4, 5, 8

103

-2

The management approach and its components

Employment and employability

– Workforce

management

– Recruiting and talent

development

HR Report

– Developing our People –

Learning

culture

103

-3

Evaluation of the

management approach

Employment and employability

– Workforce

management

– Recruiting and talent

development

Employment and employability

– People

strategy

Employment and employability

– Governance

Employment and employability

–

Key employee

figures

HR Rep

ort – Developing our People –

Learning

culture

404

-1

Average hours of training per year per

employee

HR Report

– Developing our People –

Learning

culture

– Training

We do not report average hours of training

in 2019 per employee, and do not

distinguish based on gender or employee

category. Our HR Report discloses both

training expenses (in € million) and

training attendance.

SDG 4, 5, 8

404

-2

Programs for upgrading employee skills and

transition assistance programs

Employment and employab

ility – Workforce

management

Employment and employability

– Workforce

management

– Future-oriented work

environment

Sustainable finance

– Training and awareness

Information security

– Defense against cyber

threats

Information security

– Training and awareness

Data protection

– Training and awareness

Culture and integrity

– Code of Conduct

Anti

-financial crime – Training and awareness

HR Report

– Developing our People –

Learning

culture

SDG 5, 8

404

-3

Percentage of employees receiving regular

performance and career development reviews

HR Report

– Rewarding performance –

Compensation strategy and framework

Not reported. Our HR Report discloses our

performance management processes;

however, it does not include percentages

of employees receiving

performance and

development reviews.

SDG 5, 8

UNGC 6

GRI 405: Diversity and equal opportunity

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

Employment and employability

– People

strategy

Employment and employability

– Workforce

management

– Inclusive culture and work

environment

Employment and employability

– Workforce

management

– Future-oriented work

environment

HR Report

– Diversity & Inclusion – HR

priorities for a better employee experience

–

Inclusive culture and environment

We do not report percentage of individuals

within the organization’s governance

bodies in each of the following diversity

categories: Age group: un

der 30 years

old, 30

-50 years old, over 50 years old

SDG 5, 8, 10

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

103

-2

The management approach and its components

Employment and employability

– People

strategy

Employment and employability

– Inclusive

culture and work environment

Employment and

employability – Inclusive

culture and environment

– Gender diversity

103

-3

Evaluation of the management approach

Employment and employability

– Inclusive

culture and work environment

Employment and employability

– Inclusive

culture and environment

– Gender diversity

Employment and employability

–

Key employee

figures

HR Report

– Diversity & Inclusion – HR

priorities for a better employee experience

–

Cultivating an inclusive culture and environment

405

-1

Diversity of governance bodies and

employees

Employment and employability

– Inclusive

culture and work environment

– Gender

diversity

Employment and employability

–

Key employee

figures

– Management Board

– Supervisory Board

SDG 5, 8, 10

UNGC 6

GRI 412: Human rights assessment

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

Human rights

– Developments in 2019

Reputational Risk

Culture and

integrity

The boundary external (client, society)

applies for: Human rights.

SDG 8, 16

103

-2

The management approach and its components

Human rights

– Developments in 2019

Reputational risk

– Environmental and social

due diligence

Culture and integrity

– Culture, Integrity and

Conduct program

103

-3

Evaluation of the management approach

Human rights

– Developments in 2019

Reputational risk

– Environmental and social

due diligence

Culture and integrity

– Culture, Integrity and

Conduct program

412

-2

Employee training on human rights policies or

procedures

Human rights

– Employees

Reputational risk

–Environmental and social

due diligence

Culture and integrity

– Culture, Integrity, and

Conduct program

Partially reported.

We report the business teams that receive

training and the number of training

sessions; not the number of hours or

percentage of employees trained. Due to

the nature of our business, human rights is

also only primarily addressed through

the

Code of Conduct and training.

UNGC 1

GRI 414: Supplier social assessment

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

Human rights

SDG 5, 8, 16

103

-2

The management approach and its components

Human rights

– Supply chain

103-3

Evaluation of the management approach

Human rights – Supply chain

414

-2

Negative social impacts in the supply chain and

actions

taken

Human rights

– Supply chain

Partially reported. We do not yet report the

significant actual and potential negative

human rights impacts in the supply chain

and actions taken, but continue to identify

vendors who might have potential

negative human

rights impacts. A

percentage of identified vendors is not

collected.

SDG 5, 8, 16

UNGC 2

100

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

GRI 417: Marketing and labeling

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

Product responsibility

– Product design and

approval

Product responsibility

– Communications and

marketing

103

-2

The management approach and its components

Product responsibility

– Product design and

approval

Product responsibility

– Communications and

marketing

103

-3

Evaluation of the management approach

Product responsibility

– Product design and

approval

Product responsibility

– Communications and

marketing

Partially reported.

417

-1

Requirements for product and service

information and labeling

Product responsibility

– Product design and

approval

Product responsibility

– Communications and

marketing

Sustainable finance

– Investment products

We follow product and advisory principles

in designing and selling products, but we

do not report the percentage of significant

product or service categories covered by

and assessed for compliance. The

sourcing of product components and their

disposal are not applicable to our

business.

GRI 418: Customer privacy

103

-1

Explanation of the material topic and its

Boundary

Legal basis

– Materiality and risks assessment

process

Legal basis

– Materiality results for 2019

Data protection

SDG 8

103

-2

The management approach and its components

Data protection

– Governance for data

protection management

Information security

– Governance

Digital transformation – Governance

103

-3

Evaluation of the management approach

Data protection

– Governance for data

protection management

Information security

– Governance

Information security

– Third party risk

Digital transformation

– Governance

Partially reported. There have been new

technologies and initiatives undertaken

across our various product houses

towards digital transformatio

n; however,

risk and privacy of data linked to

innovations have not been reported.

418

-1

Substantiated complaints concerning breaches

of customer privacy and losses of customer

data

Client satisfaction

– Complaint management

Data protection

In 2019, there were no substantial

breaches of data observed. However,

complaints on data protection aspects are

covered in our regular complaint

management procedures; they are not

filtered specifically. We do not report

absolute data regarding complaints.

Financial Services Standard Disclosures

Product responsibility disclosures

G4 DMA

Product and service labeling

Product responsibility

– Product design and

approval

Product responsibility

– Communications and

marketing

Culture and integrity

– Culture, Integrity, and

Conduct program

db.com/cr/en/concrete

-responsible-

marketing

-responsible-sales.htm

Product portfolio

G4 DMA

(formerly

FS1)

Policies with specific

environmental and social

components applied to business lines

Public policy and regulation

– Key topics in

2019

– Sustainable finance

Sustainable finance

– Investment products

Climate risks

– Risk management strategy and

processes

– ESG- led climate restrictions

Approach to sustainability

Reputational risks

– Environmental and social

due diligence

DWS Report

– Clients and Products:

Sustainable Finance, ESG Products and

Responsible Investing

db.com/cr/en/docs/DB

-ES-Policy-

Framework

-English.pdf

SDG 10

101

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

DMA

(formerly

FS3)

Processes for monitoring clients’

implementation of and compliance with

environmental and social requirements included

in agreements or transactions

Approach to sustainability

Reputational risks

– Environmental and social

due diligence

Sustainable finance

– Lending and advisory

Sustainable finance

– Investment products

Climate risks

– Risk management strategy and

processes

Data protection

Public policy and regulation – Governance

SDG 10

G4 DMA

(formerly

FS4)

Process(es) for

improving staff competency to

implement the environmental and social policies

and procedures as applied to business lines

Sustainable finance

– Training and awareness

Sustainable finance

– Investment products

Product responsibility

– Training and

awarenes

Public policy and regulation

– Key topics in

2019

– Sustainable finance

Climate risks

– Governance

DWS Report

– Clients and Products:

Sustainable Finance, ESG Products and

Responsible Investing

G4 DMA

(formerly

FS5)

Interactions with clients/ inves

tees/business

partners regarding environmental and social

risks and opportunities

Stakeholder engagement

Reputational risks

– Environmental and social

due diligence

Sustainable finance

– Lending and advisory

Sustainable finance

– Investment products

Publi

c policy and regulation –Sustainable

finance

Climate risks

– Risk management strategy and

processes

Human rights

– Developments 2019

DWS Report

– Clients and Products:

Sustainable Finance, ESG Products and

Responsible Investing

SDG 10

FS7

Monetary

value of products and services

designed to deliver a specific social benefit for

each business line broken down by purpose.

Sustainable finance

– Investment products –

ESG real estate and infrastructure investments

Partially reported: Where relevant we have

reported the associated monetary value.

A disclosure on the associated monetary

value of every product and service

designed to deliver a specific social

benefit broken down by business line does

not yet exist. We are investigating

possibilities to expa

nd the tracking

methodology and have started to run a

first impact assessment pilot.

SDG 8, 9, 10, 11

FS8

Monetary value of products and services

designed to deliver a specific environmental

benefit for each business line broken down by

purpose.

Sustainable finance

– Investment products

Sustainable finance

– Lending and advisory

Partially reported:

Where relevant we have reported the

associated monetary value.

A disclosure on the associated monetary

value of every product and service

designed to

deliver a specific

environmental benefit broken down by

business line does not yet exist. We

investigate possibilities to expand the

tracking methodology and started to run a

first impact assessment pilot.

Active ownership

FS11

Percentage of assets subject to positive and

negative environmental or social screening.

Sustainable finance

– Investment products –

Asset management

– Sustainable investment

funds

Sustainable finance

– Investment products –

Asset management

– ESG and sustainable

assets under management

Partly reported. We do not report

percentages and if positive or negative

screening is required by law.

SDG 10

G4 DMA

(formerly

FS12)

Voting policy(ies) applied to environmental or

social issues for shares over which

the

reporting organization holds the right to vote

shares or advises on voting.

Sustainable finance

– Investment products –

Asset management

DWS Report

– Clients and Products:

Sustainable Finance, ESG Products and

Responsible Investing

www.dws.com/global

assets/cio/dam-

us/pdfs/resources/dws

-proxy-voting-

policy

-and-guidelines.pdf

Society disclosures

Local communities

102

Deutsche Bank

Appendix

Non-Financial Report 2019

GRI and UN Global Compact

GRI Standards and Disclosures

Non-Financial Report and/or Link to Source

Remarks/Omissions

SDG and

UNGC Reference

FS14

Initiatives to improve access to financial

services for disadvantaged people

Access and inclusion

– Accessibility

Access and inclusion

– Financial Inclusion

Access and inclusion

– Financial literacy

Partly reported: We do not indicate the

availability of documents that address the

degree to which we have adapted facilities

and methods of providing standard service

offerings to support disadvantaged

people.

SDG 8, 10

103

Deutsche Bank

Appendix

Non-Financial Report 2019

Abbreviations

AATIF Africa Agriculture and Trade Investment Fund

ABC Anti-Bribery and Corruption

ACAMS Anti-Money Laundering Specialists

AFBC Anti-Fraud, Bribery, and Corruption

AFC Anti-Financial Crime

AFCI Anti-Financial Crime Investigations

AFME Association for Financial Markets in Europe

AI Artificial intelligence

AM Asset Management

AML Anti-Money Laundering

AMLD Anti-Money Laundering Directive

APAC Asia-Pacific

API Application Programming Interface

ATLAS Accomplished Top Leaders Advancement Strategy

AuM Assets under Management

BaFin Bundesanstalt für Finanzdienstleistungsaufsicht (Federal Financial Supervisory Authority)

BdB Bundesverband deutscher Banken (Association of German Banks)

BEE Black Economic Empowerment

BREEAM Building Research Establishment Environmental Assessment Methodology

CB Corporate Bank

CCP Corporate Community Partnership

CDP Former Carbon Disclosure Project

CEEF Clean Energy and Environment Fund

CEO Chief Executive Officer

CESGA Certified Environmental Social Governance Analyst

CFD Contract for Difference

CFO Chief Financial Officer

CIC Culture, Integrity and Conduct

C&I OpFo Conduct & Integrity Operating Forum

CIO Chief Investment Officer

CIRC Cyber Intelligence and Response Centers

CISO Chief Information Security Office

Carbon dioxide

CRA Community Reinvestment Act

CREF China Renewable Energy Fund

CRO Chief Risk Officer

CRU Capital Release Unit

CRM Credit Risk Management

CRRM Client Risk Rating Methodology

CSO Chief Security Office

CSR Corporate social responsibility

CSSA Cyber Security Sharing & Analytics

CTRR Climate Transition Risk and Opportunities

DDoS Distributed Denial of Services

DMS Donations, memberships, sponsorships

EBA European Banking Authority

EBF European Banking Federation

EC Eur

opean Commission

ECB European Central Bank

EcoPMO Eco-Performance Management Office

EED European Energy Directive

EEEF European Energy Efficiency Fund

EFFAS European Federation of Financial Analysts Societies

EFR Financial Services Roundtable

ERM Enterprise Risk Management

ERC Enterprise Risk Committees

ES Environmental and social

ESG Environmental, social and governance

ESMA European Securities and Markets Authority

104

Deutsche Bank

Appendix

Non-Financial Report 2019

Abbreviations

ETF Exchange-traded-fund

EU European Union

FCO Financial Crime Operations

FS-ISAC Financial Services Information Sharing and Analysis Centre

FTE Full-Time Equivalent

G20 Group of Twenty, an international forum that brings together the world’s 20 leading industrialized and emerging economies

GDP Group data privacy

GDPR General Data Protection Regulation

G&E Gifts and entertainment

GFG Global Funds Group

GHG Greenhouse gas

GIT Global Impact Tracking

GIZ German Development Agency

GMC Group Management Committee

GPGF Global Product Governance Forum

GRI Global Reporting Initiative

GRRC Group Reputational Risk Committee

GS Group Sustainability

GSIA Global Sustainable Investment Alliance

HGB German Commercial Code (Handelsgesetzbuch)

HR Human Resources

HRWG Human Rights Working Group

IB Investment Bank

ICMA International Capital Market Association

IFC International Finance Corporation

IIN Interbank Information Network

ILO International Labor Organization

IMV Impact Measurement and Valuation

IREC International Renewable Electricity Certificate

ISO International Organization for Standardization

IT Information Technology

JMLIT Joint Money Laundering Intelligence Taskforce

KfW Kreditanstalt für Wiederaufbau (Germany’s national promotional bank)

KPI Key Performance Indicator

KYC Know Your Client

LBG London Benchmarking Group

LEED Leadership in Energy and Environmental Design

LGBTQI Lesbian, Gay, Bisexual, Transgender, Queer, and Intersex

LGD Loss given default

LoD Lines of Defense

MESGS Minimum ESG Investment Standards

MiFID II Markets in Financial Instruments Directive II

MW Megawatt

NFRep Non-Financial Report

NGFS Network of Greening the Financial System

NGOs Nongovernmental organizations

NPA New product approval

NPS Net Promoter Score

OECD Or

ganisation for Economic Co-operation and Development

PB Private Bank

PD Probability of Default

PRA Prudential Regulation Authority

PRI Principles for Responsible Investment

PSD Payment Service Directive

REC Renewable Electricity Certificate

RE-DISS Reliable Disclosure Systems for Europe

REGO Renewable Energy Guarantee Origin

RI Responsible Investment

RMC Regulatory Management Council

RRAP Reputational Risk Assessment Process

RRRC Regional Reputational Risk Committee

SDG Sustainable Development Goal

105

Deutsche Bank

Appendix

Non-Financial Report 2019

Abbreviations

S&E Sanctions and embargoes

SI Sustainable Investments

SME Small and medium-sized enterprises

SPR Systematic Product Review

SROI Social return on investment

SWIFT Society for Worldwide Interbank Financial Telecommunication

TCFD Task Force on Climate-related Financial Disclosures

TEG Technical Expert Group

TM Transaction monitoring

UCITS Undertakings for Collective Investments in Transferable Securities

UK United Kingdom

UN United Nations

UNEP United Nations Environment Programme

UNEP FI United Nations Environment Programme Finance Initiative

UNGC United Nations Global Compact

U.S. United States

VBA Value Balancing Alliance

VCR Vendor control requirements

VP Vice President

WD Wealth Discretionary

WM Wealth Management

106

Deutsche Bank

Appendix

Non-Financial Report 2019

Imprint/Publications

Deutsche Bank Aktiengesellschaft

Taunusanlage 12

60325 Frankfurt am Main

Germany

Tel.: +49 69 91 00 0

deutsche.bank@db.com

Contact

Group Finance

Group Sustainability

corporate.responsibil[email protected]om

Feedback from our stakeholders improves further development of our non-financial reporting. We look forward to new impetus

and your opinion.

Publications

Publications relating to the financial statements

Annual Report 2019

(German / English)

Annual Financial Statements and Management Report of Deutsche Bank AG 2019

(German / English)

Non-Financial Report 2019

(German / English)

Human Resources Report 2019

(German / English)

List of Advisory Council Members

(German)

Online

All publications relating to our financial reporting are available on our homepage.

Photos

Deutsche Bank AG

Reproduction in full or in part only with the publisher’s prior written approval; photos and copy to be credited to

Deutsche Bank AG.

107

Deutsche Bank

Appendix

Non-Financial Report 2019

Imprint/Publications

Editorial comment

All the information in this report has been compiled in good faith and with the greatest care from various sources. To the best

of our knowledge, the information and data contained in this report reflect the truth. Nevertheless, we cannot assume liability

for the correctness or completeness of the information provided herein.

The publisher has made an effort to clarify all reproduction rights. We kindly request that any possible retroactive claims be

directed to corporate.responsi[email protected]om

Insofar as the masculine form is used in the contents of this report, it is assumed that this refers to both genders on equal

terms.

We would like to thank all colleagues and external partners for their friendly support in making this report possible.

Forward-looking statements

This report contains forward-looking statements. Forward-looking statements are statements that are not historical facts; they

include statements about our beliefs and expectations and the assumptions underlying them. These statements are based on

plans, estimates and projections as they are currently available to the management of Deutsche Bank. Forward-looking

statements therefore speak only as of the date they are made, and we undertake no obligation to update publicly any of them

in light of new information or future events.

By their very nature, forward-looking statements involve risks and uncertainties. A number of important factors could therefore

cause actual results to differ materially from those contained in any forward-looking statement. Such factors include the

conditions in the financial markets in Germany, in Europe, in the United States and elsewhere from which we derive a

substantial portion of our revenues and in which we hold a substantial portion of our assets, the development of asset prices

and market volatility, potential defaults of borrowers or trading counterparties, the implementation of our strategic initiatives,

the reliability of our risk management policies, procedures and methods, and other risks referenced in our filings with the U.S.

Securities and Exchange Commission. Such factors are described in detail in our SEC Form 20-F of 20 March 2020 under

the heading “Risk Factors”. Copies of this document are readily available upon request or can be downloaded

We are here to enable economic

growth and societal progress,

by creating positive impact for

our clients, our people, our

investors and our communities.

Our Purpose

This is why we‘re here. This is what we do.