Deutsche Bank – Responsibility

1. Has Deutsche Bank stopped financing Cluster Munitions?

The Deutsche Bank Group Cluster Munitions Policy has been in effect since autumn 2011following the earlier decision of the Management Board to exit relationships and not engage in new business with clients involved in this line of business.

The Deutsche Bank Group Cluster Munitions Policy reflects the complexity of the issue and goes beyond our previous approach whereby the Bank did not provide direct funding for cluster munitions (production or trade).

2. Does the Policy on Cluster Munitions apply to all transactions?

The policy prohibits doing business with conglomerates (and their subsidiaries) that manufacture or distribute cluster munitions, banned under the Oslo Convention on Cluster Munitions or similar to those, as well as key components.

3. How does Deutsche Bank implement the Policy on Cluster Munitions?

Deutsche Bank has exited banking relationships with most identified conglomerates. Residual relationships relate to pre-existing contracts, which will not be extended.

We consider doing business with clients in this segment only if we obtain confirmation that the client’s cluster munitions-related business has been terminated. If clients have existing contracts, we may accept the time-bound intent to terminate production.

4. How is Asset Management covered by the Cluster Munitions Policy?

Following the establishment of an ESG4 Head Office in our Deutsche Asset & Wealth management division (DeAWM), ESG policies applicable for portfolio managers are currently reviewed and in the process of a global extension. The policies will take into account the fiduciary nature of the business duty but at the same time will outline an exclusion process for companies involved in cluster munitions.

5. Who monitors compliance with Deutsche Bank’s Policy on Cluster Munitions?

The Group Reputational Risk Committee reviews the implementation of the policy on a quarterly basis.

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