Deutsche Bank's response
6 December 2021
Thank you for email dated November 18, 2021 in relation to the human rights situation in Myanmar. Please find our response to the questions raised in your letter below.
In general, Deutsche Bank AG (“DB”) cannot comment on any existing or potential client relationships and thus cannot provide client-specific information in response to the questions you have raised. However, we adhere to our existing policies and controls in conducting business and we continue to monitor the situation in Myanmar closely, including information and reports related to human rights abuses. This also comprises monitoring of relevant legal developments in relation to the country such as applicable sanctions laws and regulations. DB is firmly committed to respect human rights and has been a member of the United Nations’ Global Compact (UNGC) for more than 20 years. Its framework endorses international standards, such as the United Nations’ Guiding Principles on Business and Human Rights. Thus, our institution recognizes our role in aligning strategies and operations with universal principles of human rights and in helping to prevent apparent human rights abuses.
DB maintains no business operations in Myanmar. With regard to business maintained by its clients, DB has policies, processes and controls in place designed to achieve compliance with the sanctions imposed by the UN, the EU and Germany globally as well as U.S. and U.K. sanctions and other sanctions laws where they apply. In addition to regulatory requirements, as a matter of bank policy, DB conducts risk-based enhanced due diligence on transactions involving Myanmar in order to identify and prevent transactions related to the military complex in Myanmar and entities it owns.
In addition, as it relates to its clients, potential human rights risks are governed and managed by DB’s bank-wide Environmental and Social Policy Framework. The Framework outlines requirements for environmental and social issues, including human rights due diligence, and defines procedures and responsibilities for risk identification, assessment, and decision-making. Information on DB’s approach to uphold its responsibility to respect human rights is published on our website.
Portfolio management decisions in DB’s wealth management business must always be made in the best interest of DB’s clients. Such decision must always comply with the investment guidelines agreed with the client and may consider how clients might view Environmental, Social and Governance (ESG) related issues. Determination regarding socially responsible investments are complex and will be ultimately made by each Portfolio Manager on a case-by-case basis.
The DWS Group (“DWS”), which is part of Deutsche Bank Group, is focused on asset management. DWS has no direct exposure to the Myanmar government. DWS invests into globally operating companies that may also be doing business in Myanmar for many years. Following our approach of integrating ESG criteria in our investment process, we evaluate our investments based on data, including ESG data, from a series of external providers. In case of severe norm violations and/or climate transition risk, we follow our established processes up to and including re-assessing exposure, engagement of investee companies, and divestment.
In summary, DB continues to monitor the factual situation and regulatory sanctions developments related to Myanmar, adjusting its control framework in an ongoing manner based on additional requirements and intelligence. Further, DB is committed to its responsibilities to respect human rights. 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 related issues.