Deutsche Bank – Responsibility

Compliance: Conformity with the law and adherence to regulations and standards

In our view, responsible corporate governance does not only mean adherence to laws, regulations, and standards. It requires a stringent compliance system. We have defined strict rules and guidelines for our staff across the entire spectrum of our areas of activity. Through our conformity with the law, we ensure that the company, its shareholders, clients and employees are protected as comprehensively as possible.

We expect all of the employees of Deutsche Bank to adhere to our compliance standards – by conducting themselves honestly, responsibly and ethically. Our Code of Ethics describes the values and standards for ethical business conduct and serves as the guiding principle for all of our interactions – regardless of whether they are with clients, competitors, business partners, government and regulatory authorities, shareholders or among one another. At the same time, it forms the foundation of our compliance principles, which provide our staff with precise guidelines for proper behavior. That is how we strive to ensure conformity with all applicable laws, regulations and standards.

In order to promote our responsible behavior on the part of our staff, we have expanded our mandatory training on compliance issues. For example, we completed 115,000 mandatory training modules in 2013 – up from 39,000 in 2012. Failure to complete mandatory compliance trainings now carries clear consequences, for example in regard to compensation.

Furthermore, to support our controls systems we have substantially expanded our “Red Flag” monitoring system. It reports all violations of compliance requirements in specific areas. Violations of guidelines and procedures have always been the target of substantial disciplinary measures. We have intensified that approach by comprehensively integrating the results of monitoring into management and reporting structures as well as decisions by management relating to performance assessment, promotion and remuneration. This has already led to a perceptible improvement in conformity with the law: At the end of 2012, “Red Flag” incidents in our Corporate Banking and Securities and Global Transaction Banking departments dropped by 53 percent in comparison with the previous year.

Our Compliance Control Framework

The Compliance department of Deutsche Bank is independent of our operational business. Using our Compliance Control Framework as a basis, we are raising the level of awareness of conformity with the law in our operational business areas. The framework specifies the functions of the Compliance team in detail.

The team is responsible for:
  • providing advice to individual business units on applicable laws, directives, standards, and regulations as well as providing compliance support
  • monitoring trades, transactions and business processes in order to identify any potential compliance risk
  • developing globally or locally applicable principles, standards and guidelines for Compliance, communicating them and verifying adherence
  • maintaining the Bank’s internal watch and restricted lists of projects to which special attention must be paid
  • helping to achieve adherence to the Bank’s internal confidentiality regulations (‘Chinese walls’)
  • implementing any measures arising from the anti-money laundering program
  • ensuring that any occurrences which give reason to suspect money laundering or the financing of terrorism are identified and reported to law enforcement authorities
  • providing regular training and education for staff on the applicable regulations, rules and internal standards
  • coordinating risk control and monitoring the management of reputational risk
  • communicating with regulatory agencies around the world on a daily basis

“We are spen­ding 1 bn € to re­in­force our sys­tems and con­trols and adapt these to changes in re­gu­la­tion by 2015. We si­gni­fi­cant­ly streng­thened our com­pli­ance de­part­ment, adding some 200 people in 2013 and with plans to hire a similar number in 2014.”

Jürgen Fitschen Co-Chairman of the Management Board, in February 2014

Mandatory training

115,000 man­da­to­ry trai­ning mo­dules

on compliance issues were completed by our staff in 2013

Our anti-money laundering (AML) program

Our anti-money laundering program provides strong support for international efforts to combat money laundering, financing terrorism and other criminal acts. We scrutinize clients and current transactions using meticulous procedures and an automated monitoring system through this compliance program.

The Deutsche Bank anti-money laundering standard complies with the German Anti-Money Laundering Act and the guidelines of the German banking supervisory authority. It is also in line with the recommendations of the Financial Action Task Force on Money Laundering, an intergovernmental organization.

Our anti-money laundering requirements apply worldwide to all business units of the bank, regardless of their location. All our employees and senior managers are required to comply with them to prevent our name or our products and services from being misused for money laundering purposes. To ensure that we always apply the best possible compliance practices, we routinely review our goals and strategies for the prevention of money laundering.

Within the scope of our compliance program, Deutsche Bank has committed itself to fully complying with all local and international anti-corruption and anti-bribery laws. Our employees and senior managers are strictly prohibited from receiving, accepting, offering, paying or authorizing any bribe or any other form of corruption. Deutsche Bank also expects transparency and integrity in all business dealings to avoid any improper advantage or the appearance of questionable conduct on the part of employees or third parties with whom we do business.

To ensure compliance, Deutsche Bank has an anti-corruption policy that is backed by:

  • appropriate compliance training measures for staff
  • recording and monitoring of gifts and invitations
  • a worldwide whistleblowing hotline for reporting suspicious cases anonymously
  • risk-based procedures for monitoring third parties

How we combat financial crime

Deutsche Bank is committed to ensuring the robust risk management of financial crime. We have established an Anti Financial Crime Committee (AFCC), a group-wide oversight and governance body. Its responsibilities include ensuring conformity with the law, preventing criminal acts or exposing and investigating them – ranging from fraud and money laundering to insider trading and data theft. The AFCC examines and assesses all risks relating to such actions within the Deutsche Bank Group.

How we assess and accept clients

We have developed effective procedures for assessing clients (Know Your Customer or KYC) and a process for accepting new clients in order to facilitate comprehensive compliance. Furthermore they help us to minimize risks relating to money laundering, financing of terrorism and other economic crime. Our KYC procedures start with intensive checks before accepting a client and continue in the form of regular reviews. Our procedures apply not only to individuals and corporations that are or may become our direct business partners, but also to people and entities that stand behind them or are indirectly linked to them.

How we check and approve new products

Our New Product Approval process (NPA) stipulates how we examine and approve new business ideas and products before they are launched. NPA also covers changes in the ongoing business of the Bank and is an important element of our risk management.

Data protection: Preventing abuse, protecting rights of self-determination

Comprehensive data protection policies, rules, standards and processes apply to data protection in our day-to-day operations. They ensure compliance with all relevant statutory regulations, which may vary considerably from one country to another.

Preventative measures and thorough controls help prevent loss of data and violations of data protection regulations. We always investigate complaints thoroughly. We provide regular training in order to raise awareness of data protection among our staff and to ensure compliance with regulations.

Our Group Data Protection (GDP) office coordinates, assesses and monitors practices in this field. It works closely with a network of global data protection experts within the Bank.

The European Union is currently planning a revision of its data protection directive. Deutsche Bank has already implemented essential elements of the accountability principle that is being discussed in this context.

Whether in the area of money laundering, corruption, or financial crime – the compliance management system of Deutsche Bank is geared to strict conformity with the law and has been achieving good results for years.

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