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Responding department: Corporate Responsibility

Does your company have a publicly available commitment to respect human rights?

Commerzbank commits itself to respecting human rights. Commerzbank’s position on human rights relates to internationally accepted human rights standards including the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights (ICCP), the International Covenant on Economic, Social and Cultural Rights (ICESCR), and the International Labour Standards of the International Labour Organization (ILO). As a company headquartered in Germany, Commerzbank is tied to the Guidelines for Multinational Enterprises of the Organisation for Economic Co-operation and Development (OECD). Furthermore, the Bank follows the UN nited Nations Guiding Principles for Business and Human Rights.

Human Rights position

Code of Conduct / Corporate Responsibilty Guidelines

How are human rights governed in your company?

Within its sphere of influence, Commerzbank contributes to the protection and promotion of human rights. Primarily, we can exert a differentiated influence in regard to the following relevant stakeholders:

  • employees
  • suppliers
  • clients

2.1 Employees

Commerzbank respects and supports the human rights of its employees. The overwhelming majority of our staff works in member states of the European Union (approximately 97 percent at the end of 2015). These states have already enshrined the UN’s and ILO’s human rights standards in law.

As well as complying with Germany’s national statutory requirements, the Bank has also introduced a Code of Conduct ([link]) which, in order to safeguard human rights, is globally binding for all its employees. This Code of Conduct ([link]) is part of Commerzbank’s corporate culture and documents the commitment to making integrity an active part of its daily business. The guidelines clearly formulate existing rules of conduct and thus provide all employees with a binding guidance framework for acting with integrity – amongst others in relation to human rights. The guidelines apply without exception to all Commerzbank employees, from senior management to apprentices.

Furthermore, we have implemented agreements on fair and partner-like behaviour and on the integration for people with disabilities. Commerzbank has also implemented the right to freedom of thought, conscience, and religion within the scope of Germany’s Diversity Charter. A comprehensive diversity management ([link]) also promotes individuality among employees.

The vast majority of Commerzbank employees work in member states of the European Union (some 97 per cent as at the end of 2015). These countries have already enshrined the human rights standards of the UN and the ILO in their laws, and Commerzbank implements these national legal requirements as a matter of course. Furthermore, through its binding Code of Conduct ([link]), the Bank requires its employees worldwide to respect human rights. The policy clearly sets forth the existing rules governing conduct and provides employees with binding guidance on how to act with integrity − including with respect to human rights. The Code of Conduct applies without exception to all Commerzbank employees. The right to freedom of thought, conscience and religion is guaranteed at Commerzbank as part of the Diversity Charter. In addition, comprehensive diversity management ([link]) promotes the individuality and diversity of employees.

2.2 Suppliers

Commerzbank helps, within its scope of activity, to promote and protect human rights, e.g., when it comes to selecting service providers or suppliers. The Code of Conduct stipulates that the Bank respects human and personal rights as fundamental rules of society worldwide and expects its business partners to do the same. The adherence to social standards by our suppliers is an integral part of Commerzbank’s Purchasing and Procurement Guidelines ([link]).

The sustainable procurement standard clearly regulates the ecologic, social, and ethical requirements for Commerzbank’s suppliers and service providers. All suppliers and service providers commercially engaged with Commerzbank ensure that they comply with the specific social requirements of this regulatory system (chapter 4.2 Sustainable Procurement Standard) and guarantee to also commit their own suppliers and service providers to these standards. The compliance with social standards is part of annual meetings with our suppliers. Furthermore, when selecting suppliers, the Reputational Risk Management department conducts special-purpose analyses as needed. Breaches against the Sustainable Procurement Standard by the suppliers or service providers can lead to the termination of the business relationship.

2.3 Clients

Commerzbank also factors in human rights aspects in its business activities with its clients.
Universal human rights are protected by national and international laws. Commerzbank is vigilant about its customers not breaching any human rights when conducting business. All Commerzbank employees and the Compliance department in particular monitor that the Bank as well as its business partners observe all national and international laws and regulations. Thus, the Compliance employees contribute to the realisation of Commerzbank’s corporate responsibility. They ensure – amongst others – compliance with sanctions and embargoes against regimes which are violating human rights as well as the prevention of money laundering and terrorist financing.
Furthermore, the Reputational Risk Management department intensively researches, analyses, and assesses transactions and business relationships in which human rights play a significant role (e.g. mining, resource extraction or cotton production). This may lead to the rejection of the relevant transaction or even the termination of a relationship.

How are human rights managed within your company?

Commerzbank also takes care that customer transactions do not violate human rights. The Compliance division in particular examines whether the Bank and its business partners comply with all national and international laws and guidelines. Among other things, Compliance staff ensure compliance with embargoes and sanctions on regimes that violate human rights and are responsible for preventing money laundering and funding for terrorism.

Commerzbank also works towards complying with human rights through its reputational risk management. Within the context of these efforts, business transactions and business relationships where human rights play a significant role are thoroughly researched, analysed and evaluated using a sophisticated system (e.g. the mining industry, the exploitation of raw materials and the cotton sector). The findings can result in the rejection of a business transaction or opportunity or even the termination of business relations. In financial year 2015, the Reputational Risk department assessed some 5,400 transactions, products and customer relationships in which sustainability considerations played a key role (2014: 5,000). This marks a slight increase in the number of assessments. Requests that are incompatible with our understanding of corporate responsibility received a negative evaluation due to social, environmental or ethical concerns.

When selecting service providers and suppliers, Commerzbank also contributes to respecting and promoting human rights within the scope of the opportunities available to it. Commerzbank’s Code of Conduct includes the binding provision that the Bank expects its business partners to respect human and personal rights as well. Suppliers’ compliance with social standards is an integral part of Commerzbank’s sustainable procurement standard. All suppliers and service providers who do business with Commerzbank guarantee that they will observe the social requirements specified by this set of rules and agree to impose compliance with the corresponding requirements on their own suppliers and service providers. Compliance with social standards is the focus of annual meetings with Commerzbank’s main suppliers. Reputational Risk Management also performs ad hoc analyses during the process of selecting suppliers. Suppliers are researched, analysed and evaluated as part of case-by-case decisions. The findings can result in the rejection of a business transaction or opportunity or even the termination of business relations.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Commerzbank maintains relationships with all organisations and groups that come to the Bank with requests, wishes or suggestions. Our main focus is on activities aimed at entering into dialogue with stakeholders that have a strong influence on the economic, environmental or social performance of Commerzbank, as well as those stakeholder groups that are strongly affected by the economic, environmental or social performance of Commerzbank.

In its Corporate Responsibility Guidelines ([link]), Commerzbank commits itself to open and constructive dialogue with its stakeholder groups ([link]). This exchange is of great importance, especially considering the loss of public trust in the wake of the financial crisis. We believe it is our job to actively shape this dialogue with stakeholders and leverage the outcome in the interest of our corporate responsibility. To this end, we discuss the potential impact of our business activities on people and the environment, for example, with non-governmental organisations (NGOs) on a regular basis.

Another example is the customer advisory council ([link]). Headed by the member of the Board of Managing Directors responsible for Private Customers, the customer advisory council comprises 25 voluntary members who represent our customers in the Private Customers segment. All new members were appointed to the council in 2015 with a three-year term. The customer advisory council has the freedom to influence and help shape those aspects that affect the Bank’s customers, such as how the Bank advises its customers, in addition to products and services. It fields a wide range of questions and discusses various issues in a direct dialogue with bank experts.

In terms of our employees’ involvement in the company’s operations, we not only rely on staff surveys, such as the Commerzbank Monitor, but also on our WikIdee ideas management platform ([link]), which has received multiple awards. All employees are able to submit suggestions and join in discussions on this online platform. More than 3,100 ideas were submitted last year.

For the purposes of political dialogue, Commerzbank maintains liaison offices in Berlin and Brussels. Commerzbank has been listed in the EU’s transparency register ([link])since 2010 and reports on activities, active persons and annual contributions as part of its political opinion-forming efforts.

In the “Commerzbank in Dialogue” event series, we engage in discussion with various interest groups on urgent social, business and financial policy topics. As a part of this initiative, events on topics such as the “Digitalisation of banks: between innovation and responsibility” and “Consumer model” were held in the reporting period. Through the Political Breakfast initiative, we promote dialogue on social and business policy topics. During a week when parliament is in session, guest speakers report on and discuss specific issues in front of representatives from politics, academia and business. Last year, the agenda included topics such as financial market regulation, the energy transition, foreign policy and innovation. We have also been organising what is known as “mittags.werkstatt” since 2014. This series of talks addressed residential real estate loans, among other topics, in 2015.

In the interest of our customers, and to facilitate long-term planning, we also regularly hold discussions with national and international regulators, supervisory authorities and decision makers in the political arena so we can work towards clarity and consistency in the regulation of products and services.

Details about shareholder communications can be found on page 33 of the Annual Report 2015 ([link]). Information on the inclusion of stakeholders in the materiality analysis is available in our GRI-Report: G4-18 ([link]).

Priority human rights issues: What are some of the priority human rights issues for your company?

Within its sphere of influence, Commerzbank contributes to the protection and promotion of human rights. Primarily, we can exert a differentiated influence in regard to the following relevant stakeholders:

  • employees
  • suppliers
  • clients

For more information please have a look at question No. 2.

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Commerzbank regularly reports on the development and improvements in the field of human rights in its UN Global Compact progress report, which is published in the report on corporate responsibility ([link]).

This position on human rights is continuously reviewed and revised. The current position and information on further positions and directives of Commerzbank can be found on our website ([link]).

Corporate Responsibility Report 2015

Annual Report 2015


What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

The Bank experiences very few cases of discrimination, as many of the cases that do arise are generally dealt with immediately at the local office concerned. Cases that cannot be easily dealt with are handled by the head office. It is not possible to give a precise figure for the total number of cases because discrimination comes under the broader issue of bullying at the workplace. However, it is estimated that the total number of discrimination reports handled by the head office each year is in the single digits. Staff who feel discriminated against or bullied can make use of the Employee Assistance Programme (EAP). In 2015, there were a total of 43 contacts for the overarching topic of bullying, discrimination and sexual harassment (2014: 71 contacts), which corresponds to 1.5 per cent of the approximately 3,000 total EAP contacts in 2015.

Complaint Management (German sites only): [link].

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

In addition to our own standards, we take part in renowned initiatives to promote and enact sustainability. Besides the signing of the UN Global Compact in 2006, Commerzbank has committed to comply to the German Sustainability Code ([link]), which describes the essential requirements for corporate sustainability and enables the comparability of participating companies' sustainability performances. Furthermore, we are, as the first German bank, member of the Roundtable on Sustainable Palm Oil ([link]) and thereby contribute to a sustainable development of the palm oil sector and the support of sustainable palm oil production. Please find additional memberships in our overview ([link]).

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

Providing sustainability-relevant information is an integral part of the standard tender procedure. For quality assurance purposes, we distribute electronic self-disclosure forms for suppliers, which include questions relating to sustainability criteria. Since 2015, an “integrity, environment and social responsibility” clause has also been included in new contracts.

As part of supplier management, questions relating to sustainability are a criterion of the annual assessment of key suppliers. In the event of violations of the sustainable procurement standard ([link]), suppliers are specifically notified of the need for improvement. In the reporting year, no contracts with suppliers were terminated due to the failure to observe human rights.