Codes of Conduct

Deutsche Bank AG (“DB”) has published Statements of Commitment to the following codes of conduct (each a “Code”) and standards:

LBMA Global Precious Metals Code

In addition, in relation to the LBMA Global Precious Metals Code (“PM Code”), DB has reviewed the content of the PM Code and acknowledges that the PM Code represents a set of principles generally recognised as good practice in the wholesale Precious Metals Market (“Market”).

DB confirms that it acts as a Market Participant as defined by the PM Code, and is committed to conducting its Market activities (“Activities”) in a manner consistent with the principles of the PM Code. To this end, DB has taken appropriate steps, based on the size and complexity of its Activities, and the nature of its engagement in the Market, to align its Activities with the principles of the PM Code.

FMSB Standards

DB is a member of the Financial Markets Standards Board (FMSB) and confirms that it is committed to conduct its wholesale financial market activities (its ‘Activities’) in a manner consistent with the Core Principles contained in FMSB Standards, and to have internal policies, procedures and controls reasonably designed to give effect to those Core Principles where they are applicable to its Activities, in a manner that is commensurate with the nature of its Activities in the relevant entity or jurisdiction. As a member, DB has provided a Statement of Commitment, on compliance with applicable FMSB Standards, at the latest of either i) around the end of the following year after which each Standard was published or ii) the first annual attestation after when the Standard became applicable, as relevant to the Standard relating to Precious Metals, where the attestation date is shown below.

DB is applicable to the following FMSB Standards:

  • Binary Options standard for the Commodities markets
  • New Issue Process standard for the Fixed Income markets
  • Reference Price Transactions standard of the Fixed Income markets
  • Risk Management Transactions for New Issuance Standard
  • Secondary Market Trading Error Compensation Standard
  • Standard for Client Onboarding Documentation and Processes and its Annexes
  • Standard for the Conduct of Participants in LBMA Precious Metal Auctions (attested on 11 December 2025)
  • Standard for the execution of Large Trades in FICC markets
  • Standard on use of Term SONIA reference rates

Find Deutsche Bank Statement of Commitment confirming adherence to FMSB Standards on the FMSB website.

Other codes of conduct

DB may from time to time adhere to other codes of conduct applicable to other products, markets or geographies in similar or different terms.

Deutsche Bank code of conduct

In addition, DB has published its own Deutsche Bank code of conduct, which is separate and distinct from its adherence to the Codes referenced above.