Dialog 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. In addition to the usual exchanges with shareholders at our annual general meeting, we communicate with stakeholder groups in four ways:
- We plan and organize events on sustainability themes.
- We participate in sustainability initiatives and take part in forums and events organized by others.
- We aim to engage constructively and consistently with policymakers and regulators internationally and nationally.
- We engage in an active dialog with our competitors on sensitive issues and support various initiatives relating to themes such as human rights and nuclear energy.
- Our materiality analysis helps ensure that our approach to sustainability is in line with the expectations of our stakeholders.
We are currently reviewing our approach to engagement and are developing a more systematic process that will capture the wide range of stakeholder views and allow us to build a clearer picture of the key issues and voices.
“There is a huge discrepancy between what people expect of banks and how banks are perceived. We have to get out of our towers and engage in dialog with all our stakeholders on an equal footing.”
Dialog with policy makers and regulatory authorities
Deutsche Bank aims to engage constructively and consistently with policymakers and regulators internationally and nationally in order to help secure competitive and sustainable financial markets.
Our Global Regulatory Policy team aims to be a trusted voice and thought leader in policy debates globally. It ensures the bank is informed and active in all significant national, international and global efforts to strengthen the financial regulatory framework.
We engage directly with issues of cross-border significance, such as standards issued by global bodies such as the Basel Committee on Banking Supervision (BCBS), the Financial Stability Board or the International Organization of Securities Commissions (IOSCO). As around 70% of all financial market laws and regulations in Europe originate in Brussels, we also engage directly with the institutions of the European Union, together with the Deutsche Bank EU Representation. The Deutsche Bank EU Representation monitors political and regulatory developments and feeds the expertise of Deutsche Bank into the EU decision-making process.
The Regulatory Contact Office (RCO), based in Frankfurt, assists Deutsche Bank’s communication with home and host supervisors. It‘s main focus is on the three most important supervisory authorities: the German Bundesanstalt für Finanzdienstleistungsaufsicht (Bafin), the New York Federal Reserve and the UK Financial Services Authority.
DB also engages with political and regulatory developments through senior level representation in international trade associations and professional bodies. We also provide expertise at industry conferences to communicate our positions to a wide range of regulatory and political audiences.
In 2012, we continued to provide analysis and support to EU, US, Asian and other regulators in their work implementing the G20 reforms, such as the Basel III framework to improve bank capital and liquidity and central clearing and reporting of OTC derivatives. DB has provided input to the FSB, BCBS and IOSCO on their work to improve the oversight and regulation of shadow banking, to promote consistent approaches to bank recovery and resolution planning, and set global minimum standards for margining practices for non-cleared derivatives.
In 2013, Deutsche Bank provided input to a global initiative to update the UN Millennium Development Goals (MDGs) which expire in 2015. These goals aim to improve social and economic conditions in the world’s poorest countries. Incorporating environmental protection goals is also a focus for this work. The UN High level panel published its report containing recommendations to the Secretary-General. The report recommended 12 new global goals and indicators such as:
- Ending poverty
- Empower Girls and Women and Achieve Gender Equality
- Achieve Universal Access to Water and Sanitation
- Secure sustainable energy
- Create a Global Enabling Environment and Catalyse Long-Term Finance
Engaging with civil society
- We seek constructive discussions and exchanges with non-governmental organizations (NGOs) – although we do not necessarily agree with certain conclusions that NGOs draw, we value their input. In 2013, meetings with individual NGOs revolved around topics such as monocultures, land grabbing and palm oil. In October 2013, we hosted the eighth dialogue session within the forum Bankendialog. The event was organized by an environmental NGO at our company headquarters in Frankfurt. During the session, representatives of various European banks discussed with NGOs how well banks know their clients, their approach to analyzing the potential environmental and social impacts associated with clients’ activities and whether exclusion or engagement is the best way to help clients who exhibit negative sustainability performance.
- In 2012 we participated in an NGO dialog on the topic of mining, and following that we hosted a bank forum for German-speaking banks. One point of discussion focused on how companies in the mining sector can improve their negative environmental track record. Amnesty International, the Indian Legal Initiative for Forest and Environment and the German NGO Urgewald participated in that discussion.
- In 2012, we jointly hosted a conference on the potential impact of taking ESG factors into account with the UN Principles for Responsible Investment initiative.
- In 2012 we agreed on a long-term co-operation arrangement with the School of Business and Economics at the University of Maastricht (MUSBE) in the Netherlands. The primary focus is on promoting and supporting research on environmental, social and governance issues (ESG) in the business sector.
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. While many offer documents already include comprehensive disclosure, others fall short – for example by avoiding discussion of risks such as climate change or failing to include adequate management responses to identified ES 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.
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.
German Environmental Management Association (B.A.U.M.) e. V.
Climate Markets and Investment Association (CMIA)
The Climate Markets & Investment Association (CMIA) is an international trade association representing firms that finance, invest in, and provide enabling support to activities that reduce emissions. CMIA's membership accounted for 75 per cent of the global carbon market in 2010, valued at approximately US-Dollar 120 billion.
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 Business Council for Sustainable Development
The WBCSD is a CEO-led, global coalition of some 200 companies advocating for progress on sustainable development. Its mission is to be a catalyst for innovation and sustainable growth in a world where resources are increasingly limited. The Council provides a platform for companies to share experiences and best practices on sustainable development issues and advocate for their implementation, working with governments, non-governmental and intergovernmental organizations. The membership has annual revenues of US-Dollar 7 trillion, spans more than 35 countries and represents 20 major industrial sectors. The Council also benefits from a network of 60 national and regional business councils and partner organizations, a majority of which are based in developing countries.
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
We are currently reviewing our approach to stakeholder engagement and developing a more systematic process for incorporating the wide range of views to assemble a clearer picture of the key issues and voices. The results will be reflected in our materiality matrix.
We do not conduct a full analysis every year. The materiality matrix (below) shows the results of the most recent evaluation, in 2010. However, partial aspects are being supplemented constantly. The matrix is divided into three sections based on relevance for sustainability. The issues in the top right-hand quartile demand the most attention because they are significant both for the bank and for our stakeholders.
Material issues are identified using the following sources:
- the evaluation of structured interviews relating to the sustainability responsibility of Deutsche Bank that an external service provider conducted with representatives of sustainability rating agencies, investors, non-governmental organizations, and senior managers of the bank
- an evaluation of inquiries that external stakeholders addressed to Deutsche Bank
- results of our global employee survey 2012
- evaluations of feedback from clients and business partners
- analyses performed by Deutsche Bank Research on behalf of Deutsche Bank that follow relevant trends in the financial market, the economy, and society including their opportunities and risks
- corporate strategy priorities