Deutsche Bank

Red LineText of policiesCommentsScore
Regulatory requirements
Ensure Legality· Environmental and Social Policy Framework May 2018
Our understanding of responsibility is further informed by formal commitments we make to internationally recognized standards and principles such as the ten Principles of the United Nations (UN) Global Compact, the UN Environment Programme Finance Initiative and the Principles for Responsible Investment.
Deutsche Bank will not engage in any activities or relationships where there is clear evidence of severe human rights violations and/or damage to the environment. To this end,
(...)
It will consider the implementation of the mitigation hierarchy with further focus on:
— compliance with national laws and regulations;
We will not finance activities where there is clear and known evidence on (...) illegal logging or uncontrolled and/or illegal use of fire.
Deutsche Bank, we also expect our clients to consider international best practice approaches.
In addition to compliance with national legislation and the presence of all applicable permits we will look at a number of sector-specific factors including the client’s management systems and track record.
In our transactions with clients, we expect, as a minimum, that they meet applicable ES laws and regulations, and that they hold relevant licenses and permits. At Deutsche Bank, we also expect our clients to consider international best practice approaches.
DB expects clients to meet international laws and conventionswell
No Corruption and Tax Evasion· Financial crime - Prevention of bribery, corruption and fraud
We take a zero-tolerance approach to bribery and corruption, in line with our Code of Business Conduct and Ethics, values and beliefs, and international law, including the UK Bribery Act 2010, the US Foreign Corrupt Practices Act of 1977, the German Criminal Code, and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. (...) a dedicated Anti-Bribery and Corruption (ABC) team is responsible for:
* reducing the risk that Deutsche Bank, or persons associated with the business, engages in bribery or corruption;
* ensuring that, if there is bribery and corruption, we limit our liability, so far as is possible; and
* protecting our reputation, ensuring shareholder confidence, reducing risk in our transactions, and securing our assets.

Code of Conduct:
Our bank advocates the development of sound regulations and internal procedures to combat financial crime, including tax evasion.
Anti-bribery and corruption - Our bank is committed to complying with all applicable anti-bribery and corruption laws and regulations.

Non-Financial reporting
Know Your Customer (KYC) Policy - As part of our regular client due diligence, we screen our relationships against internal and external criteria (...)
The bank has a strong policy against financial crime, but it is mainly focused on the involvement of the bank itself in financial crime. It does not have clear requirements regarding its clients.partly
Ensure ESIA for mills and plantationsNo publicly available policies or documentation were found that cover this criteria.not
Social requirements
Ensure FPIC· Environmental and Social Policy Framework May 2018
We recognise the vulnerability of indigenous peoples and the connection to ancestral lands, as defined by the UN Declaration on the Rights of Indigenous Peoples. In cases where we can identify potential impacts on indigenous peoples, we expect our clients to act in alignment with the objectives and requirements of the IFC PS 7 on Indigenous People. For circumstances outlined in the IFC PS 7, we expect clients to obtain the Free Prior and Informed Consent of affected communities.
We recognise the vulnerability of indigenous peoples and the connection to ancestral lands, as defined by the UN Declaration on the Rights of Indigenous Peoples.
IFC standards protect parlty against operations without FPIC, as it onlu applies to indigenous people and not to other affected communities.partly
Respect Human Rights· Human Rights position
Deutsche Bank is guided by a wide range of international external standards and principles, including:
- UN Guiding Principles on Business and Human Rights
- Universal Declaration of Human Rights
- International Labour Organization’s Declaration on Fundamental Principles and Rights at Work
- Principles of the UN Global Compact
- UN Principles for Responsible Investment (PRI)
- OECD Guidelines for Multinational Enterprises
- IFC Performance Standards

In situations where national laws do not cover internationally recognised human rights or the implementation of such laws is weak the UN Guiding Principles clearly expect companies to operate according to a higher international standard. Therefore, to respect human rights, DB has a responsibility that goes beyond purely complying with the law.
Deutsche Bank will not engage in any activities or relationships when there is clear evidence of severe human rights violations.
In order to identify, prevent and mitigate adverse human rights impacts, we have integrated human rights considerations (e.g. land, labour, child rights, health and safety of workers and communities, the rights of indigenous people etc.) in the ES due diligence process.
We inter alia expect companies to integrate human rights aspects into strategic planning and operations.

· Environmental and Social Policy Framework May 2018
Deutsche Bank will not engage in any activities or relationships where there is clear evidence of severe human rights violations and/or damage to the environment. To this end, we will not knowingly finance:
— activities and/or clients that use child or forced labour as defined by the core conventions of the International Labour Organization;
We focus on the client’s measures to avoid any involvement in child and/or forced labour, (...)
The bank excludes clients where violations have been proven, and assess how the client includes protection for human rights in its operations (though it falls short from requiring clients to have policies).well
Respect Indigenous rights and customary land use rights· Environmental and Social Policy Framework May 2018
Deutsche Bank understands that our clients’ activities may impact the communities they operate in, and we expect clients to have processes in place to minimise any negative impact. In particular, during the due diligence we focus on policies and procedures that:
— protect the health and safety of affected communities;
— ensure respect for land rights and cultural heritage; and
— address engagement with communities, including responding to community concerns (for example through grievance mechanisms).
We recognise the vulnerability of indigenous peoples and the connection to ancestral lands, as defined by the UN Declaration on the Rights of Indigenous Peoples. In cases where we can identify potential impacts on indigenous peoples, we expect our clients to act in alignment with the objectives and requirements of the IFC PS 7 on Indigenous People. For circumstances outlined in the IFC PS 7, we expect clients to obtain the Free Prior and Informed Consent of affected communities
The bank requires clients to have policies on the protection of land rights, but it does not establish minimum criteria for these policiespartly
No forced resettlement· Environmental and Social Policy Framework May 2018
In cases involving resettlement, we expect our clients to act in accordance with national laws and regulations and, where applicable, in alignment with the objectives and requirements of IFC Performance Standard (PS) 5 on Land Acquisition and Involuntary Resettlement
IFC does not protect against forced resettlment without FPIC for non-indigenous communitiespartly
Environmental Requirements
No forest degradation and deforestation· Environmental and Social Policy Framework
Deusche Bank (...) will not knowingly finance: (...)
— activities within or in close proximity to a World Heritage Site unless there is a prior consensus with both Government and UNESCO that such operations will not adversely affect the Outstanding Universal Value of the Site;
— projects or activities located in or involving the clearing of primary forests, areas of HCV or peatlands, illegal logging or uncontrolled and/or illegal use of fire;
For transactions where we are able to identify impacts on areas of international or national biodiversity value and high-sensitivity ecosystems/habitats an enhanced ES review is required. (...) Areas of high biodiversity and/or high-sensitivity ecosystems/habitats include Biosphere Reserves Wetlands of International Importance, legally protected areas according to IUCN categories I-VI7 and other nationally protected or sensitive areas. We further recognise the need to protect and preserve areas of cultural heritage. (...) Further, we expect clients to demonstrate:
— their public commitment (ideally in a policy document) to the ‘No Deforestation, No Peat, No Exploitation’ standards
— policies on new developments including a commitment to conduct a HCV assessment before any new plantation development;
— water management and protection provision (e.g. considering water scarcity, recycling of wastewater, responsible use of pesticides and herbicides); and
— measures to protect biodiversity or endangered species and prevent soil erosion, land degradation and natural stock depletion.
The policy provides strong protection against deforestation and forest degradation, however it does not mention the protection of HCS area (though it mentions peat).well
Protect endangered species· Environmental and Social Policy Framework May 2018
Further, we expect clients to demonstrate:
— measures to protect biodiversity or endangered species (..)
The policy provides some protection, but does not mention IUCN red list speciespartly
No high-risk speciesNo publicly available policies or documentation were found that cover this criteria.not
No fire· Environmental and Social Policy Framework May 2018
We will not finance activities where there is clear and known evidence on clearing of primary forests, areas of High Conservation Value (HCV) or peatlands, illegal logging or uncontrolled and/or illegal use of fire.
The policy provides some protection, but still allows the use of controlled firepartly
Protect peat· Environmental and Social Policy Framework May 2018
Further, we expect clients to demonstrate:
— their public commitment (ideally in a policy document) to the ‘No Deforestation, No Peat, No Exploitation’ standards
— water management and protection provision (e.g. considering water scarcity, recycling of wastewater, responsible use of pesticides and herbicides); and
We will not finance activities where there is clear and known evidence on clearing of primary forests, areas of High Conservation Value (HCV) or peatlands, illegal logging or uncontrolled and/or illegal use of fire.
Requires clients to have a NDPE policywell
No persistent pollutionNo publicly available policies or documentation were found that cover this criteria.not
Corporate association / scope of the policy
Corporate association / scope of the policyEnvironmental and Social Policy Framework
The ES Policy Framework is applicable globally for corporate finance including project finance, trade finance, and investment banking.
No publicly available policies or documentation were found that cover this criteria.not