Codes of Conduct

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

In addition, in relation to the LBMA Precious Metals Global 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.

DB is a member of the FICC Markets Standards Board (FMSB) and has published a Statement of Commitment in respect of certain Standards published by the FMSB which relate to conduct within the FICC markets. DB’s current FMSB Statement of Commitment can be accessed here. This Statement of Commitment applies to the Risk Management Transactions for New Issuance Standard published by the FMSB in 2018 and also reaffirms previous Statements of Commitment made by DB with respect to the following Standards published by the FMSB in 2016 and 2017 respectively: (i) Reference Price Transactions for the Fixed Income Markets, and (ii) New Issue Process Standard for the Fixed Income Markets. Copies of DB’s previous Statements of Commitment can be accessed here (2018 and 2017). Information about the FMSB, together with copies of all published Standards, can be found on their website.

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