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

The Government and Regulatory Affairs Division (GRAD) has a range of responsibilities, including:
  • 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.

Our Engagement

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.

Current activities

momentum 1/2015: The financial industry and the digital revolution. (in German)
momentum 1/2015: The financial industry and the digital revolution. (in German)
momentum 3/2015: Capital Markets Union - Driver for European Growth? (in German)
momentum 3/2015: Capital Markets Union - Driver for European Growth? (in German)

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

NGO dialog

In October 2013, we hosted a dialog session between NGOs and various European banks to discuss controversial topics including the approaches banks take to analyzing the potential environmental impacts of client activities.

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.

Engaging clients

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

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 dialogue best serves the transformation to a more sustainable future. In 2013, we examined the textile industry in great detail following the Rana Plaza factory fire in Bangladesh. We found that the companies that assign production to such factories have appropriate policies in place, have made commitments and support relevant standards. In practice, however, these principles and standards were not always fully implemented. To understand the reasons behind this, we initiated discussions with specific clients in this sector. The lessons we drew from this dialogue will inform our ES risk assessments going forward.

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)


UKSIF promotes responsible investment and other forms of finance that support sustainable economic development, enhance quality of life and safeguard the environment.

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.

since 2010

dena – German Energy Agency


An institution of the German federal government and a leading financial services provider for the promotion of energy efficiency and renewable energies.

since 2001

German Sustainable Building Council


Established in 2007 to promote sustainable construction, it comprises over 900 organizations in the construction and real estate sectors.

since 2007

Deutscher Industrie- und Handelskammertag e. V.


Lobby of the German business sector operating among decision makers in local, state, and federal politics, and in European institutions.
more (in German)

since 1997

econsense – Forum for Sustainable Development of German Business e. V.


Initiative of leading German companies and organizations to pursue a sustainability oriented corporate strategy.

since 2000

Forum für Zukunftsenergien e. V.


Forum promoting safe, cost-effective, and resource-friendly energy supplies.
more (in German)

since 2000

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.

since 2002

Investor Network on Climate Risk (INCR)


Network of investors and credit institutions aimed at promoting an understanding of loan risks and investment opportunities against the background of climate change.

since 2008

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.

since 2008

Sustainable Business Institute, Plattform nachhaltiges-investment.org


Non-profit organization with ties to universities, with the aim of spreading the concept of sustainability in business and public life.

since 2003

UNEP Finance Initiative


Partnership between UNEP (UN Environment Programme) and the finance sector; specialist working groups on asset management, climate change, environmental management, and reporting.

since 1992

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.

since 2000

Verein für Umweltmanagement in Banken, Sparkassen und Versicherungen e. V.


Forum in which financial industry specialists share opinions and experience in connection with ecological and sustainability issues.
more (in German)

since 2004

World Economic Forum


International platform for a dialog between business and political leaders with the aim of resolving global problems.

since 1995

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:

  1. Identify the relevant non-financial topics and their impacts – both within and outside the boundaries of our company,
  2. prioritize these topics and
  3. validate them to define the content of our reporting.

Analysis and principles

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.



Do you have questions about dialog with stakeholder groups? Please send your e-mail to:



Land of Ideas Book 2019 (German only) (PDF)

Environmental and Social (ES) Policy Framework (PDF)

Sustainability at Deutsche Bank – information for investors (PDF)

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