Dialogue with our stakeholder groups
Conducting wide-ranging dialogue allows us to work with these groups to define or improve standards and voluntary commitments and to discuss ways to apply them in the financial sector. It also supports mutual learning, develops an appreciation of the significance and complexity of the issues, and helps to identify potential solutions. As a result of such dialogue, we can work constructively and communicate openly with our critics, articulating our position on key issues and explaining the limitations inherent to banking products and services.
We are aware that the expectations and interests of shareholders, clients, employees and the general public are sometime in conflict and we must resolve differing stakeholder expectations fairly. Where that proves impossible, we discuss the reasons openly and transparently and accept public criticism.
We attach importance to a fair and open exchange with all of our company’s stakeholder groups. We want to understand their particular expectations of us and explain our position to them to win their acceptance of our actions. For this reason, we carry on a regular dialog with our stakeholder groups.
Dialog with policy makers and regulatory authorities
- Analysing the development of legislative proposals to ensure that Deutsche Bank fully complies with upcoming regulatory requirements globally;
- Providing political and regulatory stakeholders with information and data as part of the policy-making process;
- Managing Deutsche Bank’s regulatory relationships, including interface with regulators and supervisory engagement;
- Monitoring the cross-bank implementation of agreed regulation to ensure delivery meets regulatory expectations;
- Being a source of expert information across internal divisions and for senior management on issues of public policy; and
- Tracking interactions between Deutsche Bank employees and external political and regulatory stakeholders.
Deutsche Bank strongly supports and is a signatory to the EU Transparency Register. Our EU Transparency Register ID Number is 271912611231-56. Deutsche Bank employees in the United States (US), or US citizens based outside of the US, also have to adhere to internal policies regarding political donations.
GRAD engages with policymakers in a number of ways, including:
- Organising public events: Deutsche Bank organises events that bring policymakers together with academic and industry representatives to discuss a range of current policy issues.
- Consultation responses: Government and regulatory officials frequently engage with industry as part of the policymaking process, including through public consultations. Last year, globally, GRAD formally responded to 69 public consultations and contributed to many more through our membership of regional trade associations; and
- Regulatory dialogue: GRAD manages day-to-day regulatory and supervisory engagement with key regulators across different locations, including in Europe, the US and Asia.
Engaging with civil society
We seek constructive discussions and exchanges with non-governmental organizations (NGOs) and other stakeholders – although we do not necessarily agree with certain conclusions that they draw, we value their input. For example we regularly discuss the potential environmental and social impacts of our business with them and have established annual SRI roadshows (investor events covering the issue of responsible investment) within the US and Europe in order to show our investors how we meet our environmental responsibility.
Dialog with NGOs – example palmoil
In 2013, an important international NGO contacted Deutsche Bank regarding a large Asian company active in the palm oil sector. The NGO called on us to terminate any business relationship with this client. While complying with our legal obligation to treat information on clients and client relationships confidentially, we agreed to meet with representatives of this NGO and discuss the issues in the palm oil sector in more detail and learn about the situation in several countries, especially Indonesia. The representatives explained the changes they wanted to see, both with this specific client and in the sector more broadly. We explained our views, the nature of our client relationships in general, how we have dealt with the issues so far and that we had decided to seek dialogue with the client before any further action. The meeting with the NGO did not result in agreement, but we made clear that we are aware of the importance of this issue and helped the NGO to understand our business, our role and the limitations of our influence in the short term.
Multistakeholder dialog on cluster munition
Collaboration with financial institutions
We believe that our impact is stronger if we collaborate with other banks – both Individually and within groups – as well as interested organizations on ES topics in general or on transaction-specific issues.
The Banking Environment Initiative
Deutsche Bank is a member of the Banking Environment Initiative (BEI), which examines how to support efforts by the Consumer Goods Forum (CGF) to drive deforestation out of companies’ supply chains. This initiative covers palm oil and other commodities such as timber, soy and beef, which together account for about half of global carbon emissions arising from deforestation. Member banks work with the CGF committee on supply chains, aiming to bring all high-risk operations to verify that they are Consistent with zero net deforestation by 2020, as based on the standards that the CGF is promoting.
Improving disclosure of environmental and social risks
We also collaborated with other banks to improve disclosure of environmental and social risks in offer documents for capital markets transactions. The initial effort has focused on the extractive sector. The aim is to help investors make more informed decisions by encouraging issuers to be clear about material environmental and social issues and management plans to mitigate the risks.
The Thun Group
We also conducted extensive dialog with banks active in the Thun Group, which is composed of banks interested in a better understanding of the UN Guiding Principles on Business and Human Rights and how they can be best implemented in the banking business. The group was supported by the University of Zurich Competence Center for Human Rights, a member of the Swiss Center of Expertise for Human Rights in developing a Discussion Paper that focuses on supporting the integration of key Guiding Principles into the policies and practices of banking institutions. We will use the proposed guidance to improve our own implementation of the Principles.
As a leading global bank, we inevitably have relationships with some companies that are involved in activities with potentially significant environmental or social risks. We monitor developments in these industries and aim to engage with clients in these sectors. Following initial analysis, we seek dialog with clients to promote transparency and mutual understanding and to address difficult environmental and social issues over the medium term. We believe that conducting constructive dialog best serves the transformation to a more sustainable future.
Example: The textile industry in Bangladesh
Our memberships: together with our partners for a sustainable development
The banking sector alone is not in a position to drive the transition towards a more sustainable economy and society. Progress needs to be supported by industry, government and society at large. Through our memberships and regular exchange with industry and trade bodies, think tanks, NGOs, as well as charitable associations, we are making a contribution towards sustainable development.
Building on our expert knowledge, we seek to identify, stimulate, and actively support measures to which counteract climate change and support sustainable growth. We also use our memberships to engage with partners who are specialists in their fields to develop our thinking and to make sure we are following expert advice when evolving our strategy and activities.
Institutional Investors Group on Climate Change (IIGCC)
IIGCC provides investors with a collaborative platform to encourage public policies, investment practices, and corporate behaviour that address long-term risks and opportunities associated with climate change.
UK Sustainable Investment and Finance Association (UKSIF)
Banking Environment Initiative (BEI)
The BEI was convened in 2010 to identify ways in which banks can collectively redirect capital away from environmentally damaging activities towards environmentally beneficial ones, including sustainable, low carbon growth.
dena – German Energy Agency
German Sustainable Building Council
Deutscher Industrie- und Handelskammertag e. V.
econsense – Forum for Sustainable Development of German Business e. V.
Forum für Zukunftsenergien e. V.
Global Reporting Initiative
Global Reporting Initiative (GRI) is a network-based non governmental organization that aims to drive sustainability and Environmental, Social and Governance (ESG) reporting. GRI produces the world’s most widely used sustainability reporting framework to enable this drive towards greater transparency. The framework, incorporating the ‘G3 Guidelines’, sets out the principles and indicators that orga¬nizations can use to measure and report their economic, environmental, and social performance. GRI is committed to continuously improving and increasing the use of the Guidelines, which are freely available to the public.
Investor Network on Climate Risk (INCR)
Principles for Responsible Investment
Principles for Responsible Investment, an investor-led initiative convened by UNEP FI and the UN Global Compact, was established to help investors achieve better long-term investment returns and sustainable markets through improved analysis of environmental, social and governance issues. The Initiative has over 870 signatories from 45 countries with more than US-Dollar 25 trillion of assets under management.
Sustainable Business Institute, Plattform nachhaltiges-investment.org
UNEP Finance Initiative
UN Global Compact
Launched in 2000, the United Nations Global Compact is a call to companies around the world to align their strategies and operations with ten universal principles in the areas of human rights, labour, environment and anti-corruption, and to take action in support of broader UN goals. Through the development, implementation, and disclosure of responsible corporate policies and practices, business can help ensure that markets advance in ways that benefit economies and societies everywhere. With more than 6,000 corporate signatories in over 135 countries, it is the world’s largest corporate responsibility initiative.
Verein für Umweltmanagement in Banken, Sparkassen und Versicherungen e. V.
World Economic Forum
Materiality: Identifying issues that are material
Materiality analysis helps us ensure that our approach to sustainability fulfils the expectations of our internal as well as external stakeholders. Our assessment is conducted using the criteria of “materiality” and “stakeholder inclusiveness,” established by the Global Reporting Initiative (GRI).
The analysis helps us to determine which issues:
- clients, employees, investors, and society as a whole deem to be significant with regard to sustainability
- require our special strategic and operational attention, because they entail opportunities and risks relevant to sustainability
- we report and communicate externally
Analysis and principles
We carried out our analysis in three steps, based on the process laid out in the GRI G4 guidelines:
- Identify the relevant non-financial topics and their impacts – both within and outside the boundaries of our company,
- prioritize these topics and
- validate them to define the content of our reporting.
We identified the relevant reporting topics based on the G4 principle on sustainability context and in light of our understanding of sustainability. To identify relevant topics, we evaluated a number of aspects including the results of our regular stakeholder engagement processes, such as discussions with investors, minutes from SRI Roadshows and investor enquiries about non-financial topics at the Annual General Meeting. We also analyzed relevant studies by international institutions, organizations and research institutes. Furthermore we incorporated key topics identified by our stakeholders, other banks and corporations and external organizations such as the Sustainability Accounting Standards Board (SASB).
In order to prioritize and validate the topics, we worked with employees and managers from all divisions and infrastructure functions at an international level. We prioritized the topics, according to the materiality principle by examining them in terms of their impact on the ability of Deutsche Bank to create, maintain or possibly endanger economic, environmental or social values – for our business, our stakeholders and our society as a whole.
We used an internal survey to validate these topics in terms of their influence on our results, our reputation and our customer relationships. Please see our Corporate Responsibility Report 2014 for more information.
To ensure completeness of the topics being considered, we included all of our divisions and infrastructure functions as well as relevant external stakeholders at an international level. While validating the results, we asked our internal stakeholders to supplement the analysis with any other significant topics. We will expand upon this by adding external perspectives in the next step.
For 2015, we aim to carry out further validation as well as a full review of our reporting. To do so, we will carry out targeted surveys and systematically evaluate the feedback on our report.