Deutsche Bank is fully committed to its responsibilities to respect human rights. It is an integral part of our Values and Beliefs that are at the core of all we aspire to do and are designed to ensure that we conduct ourselves in a manner that is consistent with high ethical standards.
It is a complex task to comprehensively meet the requirements of all recommendations, guidelines, principles and standards related to human rights. We aim to continually improve our approach to, and the internal guidance on, human rights issues. A number of our core internal documents including the Deutsche Bank Code of Business Conduct and Ethics as well as our policies and guidelines reflect our commitment to respect human rights. In addition, Deutsche Bank is guided by a wide range of international external standards and principles, including:
- UN Guiding Principles on Business and Human Rights
- Universal Declaration of Human Rights
- International Labour Organization’s Declaration on Fundamental Principles and Rights at Work
- Principles of the UN Global Compact
- UN Principles for Responsible Investment (PRI)
- OECD Guidelines for Multinational Enterprises
- IFC Performance Standards
The UK Modern Slavery Act
Deutsche Bank published a statement on the measures undertaken in 2016 against modern slavery and human trafficking in its own operations and supply chains as well as in its business activities.
With the publication of the statement Deutsche Bank meets the requirement of a law, that the British Parliament passed in 2015: The “UK Modern Slavery Act” shall combat slavery, servitude, forced or compulsory labor and human trafficking and protect the victims.
The statement is available here.
Scope and Implementation
Deutsche Bank consistently pays attention to how its business activities may affect human rights.
Deutsche Bank will not engage in any activities or relationships when there is clear evidence of severe human rights violations.
Our governance and mitigation measures have a specific focus on the following spheres of activity:
- respect human rights of Employees
- avoidance of human rights violations through our business relationships with Clients
- avoidance of human rights violations through our direct business relationships with Vendors
Deutsche Bank aims to be an “employer of choice” for existing and future employees. The human rights topic in this context is a wide-ranging and includes, but is not limited to, the exclusion of forced and child labour, fair compensation and working hours, freedom of association and respect and freedom to act.
Our approach in general is based on the ILO Declaration on Fundamental Principles and Rights at Work as well as applicable labour laws in the different jurisdictions we operate in. More detailed information on the bank's commitment are provided in Deutsche Bank's Statement on Human Rights.
Our corporate clients operate in all sectors of the economy, including sectors where the risk of negative human rights impacts can be high. In this context we seek to understand the ES (environmental and social) risks associated with an industry, client or transaction just as we do for traditional financial risks.
In order to identify, prevent and mitigate adverse human rights impacts, we have integrated human rights considerations (e.g. land, labour, child rights, health and safety of workers and communities, the rights of indigenous people etc.) in the ES due diligence process. ES due diligence is required by our ES Risk Framework which is integral to Deutsche Bank’s Global Reputational Risk Framework. The ES Risk Framework has global applicability.
Our specific industry sector guidelines contain further guidance on how we evaluate and assess clients’ and transactions’ risks and performance with regard to human rights. The ES Policy Framework explains the policies and guidelines in more detail.
In addition, our internal due diligence is complemented by direct interaction with clients and external tools/databases which are available to support the risk evaluation process such as MSCI Rating. We may also consult independent subject matter experts.
To account for business specifics, especially the independent fiduciary obligations of asset managers, the asset management of Deutsche Bank established the Centre for Sustainable Finance (“The Centre”). The Centre is responsible for providing ESG standards and solutions to be integrated into the investment and risk management process, based on objective and leading research on ESG topics including human rights. This work is made available to the whole organisation including all portfolio managers.
The Centre continues to define and set common ESG standards for the asset management of Deutsche Bank including those for human rights topics in alignment with Deutsche Bank Group requirements that can be objectively reviewed for compliance.
Deutsche Bank strives to work with vendors whose policies and practices regarding human rights are consistent with our own.
We expect that our vendor partners and their supply-chains abide by all applicable laws and regulations in the jurisdictions, countries and regions where they conduct business, specifically by labour laws, e.g. they should not employ forced or child labour, adhere to standards regarding health and safety at the workplace and compensate employees adequately.
We engage in long term relationships with our vendors wherever possible. If a partner fails to comply with applicable laws and regulation, and/or our requirements, upon notification we insist on improvements and reserve the right to terminate the relationship if our standards and law/or regulation gaps are not addressed.
Grievance Mechanisms and Reporting
Deutsche Bank encourages all its stakeholders to contact the bank in case they have clear evidence of failure of Deutsche Bank´s responsibility to avoid any harm of human rights or its involvement in a human rights issue.
Clients and the public can contact us or make complaints through all channels into Deutsche Bank. This includes branches, telephone, the website, social media presences and letters to any office of Deutsche Bank.
Any grievances, including those concerning human rights, are initially dealt with by the business divisions through, for example, their complaints management processes. Deutsche Bank’s Complaints Management Policy, which was implemented in 2008, requires the business divisions to establish their own divisional policies and procedures to handle complaints.