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Responding department: Group Sustainability

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

Yes, we have a stand-alone “human rights” policy.

Deutsche Bank Statement on Human Rights

How are human rights governed in your company?

We have integrated human rights risks into the due diligence process of our group-wide Environmental and Social (ES) Policy Framework.

Our approach to managing ES risks is based on our ES Policy Framework which specifies the requirements for ES due diligence, and the criteria for mandatory referral to Group Sustainability. It forms part of our global Reputational Risk Framework.

The ES Policy Framework is available to all employees on our policy portal and intranet. The ES Policy Framework which is available on this website ([link]) explains the policies and guidelines in more detail.

Deutsche Bank’s statement on human rights was approved by our Group Reputational Risk Committee (GRRC) ([link]).

This body holds ultimate responsibility for overseeing reputational risk at Deutsche Bank. It is chaired by a member of the Board ([link]).

This makes clear that the statement was approved on most senior level.

Environmental and Social Policy Framework

How are human rights managed within your company?

The Deutsche Bank Statement on Human Rights as well as the ES Policy Framework published on our website explains our approach in more detail.

Deutsche Bank Statement on Human Rights

Environmental and Social Policy Framework

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?

Our ES Policy Framework explains our approach in more detail.

Environmental and Social Policy Framework

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

The company selected the following from a check list:

  • Health (including workplace health & safety, prevention of pollution)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Freedom of association and trade union rights
  • Displacement and community relocation
  • Relations with security forces
  • Conflict minerals
  • Children (including child labour)
  • Indigenous peoples

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

Deutsche Bank reports on its approach to respecting human rights on its Corporate Responsibility website ([link]) and annually in its Corporate Responsibility Report.

Corporate Responsibility 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 Deutsche Bank Statement on Human Rights as well as the ES Policy Framework published on our website explains our approach in more detail.

Deutsche Bank Statement on Human Rights

Environmental and Social Policy Framework

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

We continuously follow developments around the implementation of the UN Guiding Principles on Business and Human Rights. We held internal discussions on what that means for our own activities, taking thought leadership from the Thun Group.

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.

Development and publication of our statement on human rights as well as the advancement of our ES policy framework including its recent publication.

Deutsche Bank Statement on Human Rights

Environmental and Social Policy Framework

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

As a global bank that offers a wide range of products and services in corporate investment and retail banking, as well as in asset and wealth management, we have clients across all sectors including those that may be linked to significant ES impacts. We therefore need to understand the ES risks associated with an industry, a client or a transaction, just as we do with traditional banking risks.

Doing this effectively is essential to avoid any negative impacts on the environment or society, and to uphold our commitments to international standards.

It is a complex task to comprehensively meet the requirements of all recommendations, guidelines, principles and standards related to human rights. We aim to continually improve our approach to, and the internal guidance on, human rights issues.