Deutsche Bank Code of Business Conduct and Ethics, Lecture notes of Business

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Deutsche Bank Code of Business Conduct and Ethics for Deutsche Bank Group Table of contents Our vision 1 Our Values and Beliefs 2 Safeguarding our Values and Beliefs 9 Adherence to this Code 10 Updated September 2015 3 Our Values and Beliefs Integrity Your responsibility — Make judgement calls based on the principle of integrity. — Challenge anything that you come across that does not conform to what is right and escalate and report promptly any potential violations of laws, rules or policies. — Always act in an open and honest manner and always represent yourself and the Bank accurately. — Review, understand and comply with the requirements in the Anti-Money Laundering and Anti-Bribery and Corruption Programmes and any applicable local policies. — Do not make available confidential information to third parties except where permitted in the proper course of business. — Protect confidential information, never use it for your own benefit and do not email it to your personal email account. — Fully understand and comply with market integrity standards locally and globally in your area of business. We earn the trust of all of our stakeholders by always acting with integrity and holding ourselves to high standards. We seek to go beyond what is allowed and to do what is right. We aim to create an environment in which challenge is not just welcomed and respected but is also a core part of everyone’s job. Professionalism We insist on the highest standard of professionalism and integrity in all of our business activities. We expect staff to refrain from any conduct that could be viewed unfavourably by our clients, employees or the public at large. Earning and fostering trust We are committed to earning and fostering the trust and confidence of our clients, government authorities, regulators, investors and the public. We require full cooperation and provision of complete and accurate information from employees during government, regulatory or internal enquiries, investigations and audits. We do not tolerate corruption or any form of bribery and we do not provide or accept improper inducements in the course of our business dealings. We are an active participant in international and local efforts to combat financial crime, including fraud, corruption, money laundering and the funding of terrorist and criminal activities. We also have an ongoing commitment to maintain effective controls to help prevent and detect illegal and unethical business practices. The integrity of markets and of competition is critical for the trust placed in our actions. We are committed to ensuring the integrity of financial markets and adhering to the highest standards to avoid market manipulation. Protection of information — Deutsche Bank information We expect our employees and those we engage to work on our behalf to protect information about Deutsche Bank, treat it as confidential and use it solely for its intended business purpose and not for any unlawful or improper purpose. — Price sensitive information We employ measures to safeguard price sensitive information allowing disclosure only to those who “need to know” and prohibiting the use of this information for improper gain. Ask yourself — Are you prepared to challenge something you do not think is right? — Are you welcoming opinion and respecting challenge from others? — Are you going to access or discuss confidential information for a legitimate business purpose? — Are you considering sharing price sensitive information and if so, is the intended recipient an employee who has a need to know? 4 Our Values and Beliefs Sustainable Performance Your responsibility — Focus on generating long-term results and value for clients and other stakeholders. — Do not narrowly focus on short-term performance that may compromise our long-term success. — Always look at the big picture and consider all possible scenarios. — Focus on the long-term development of yourself and your staff. We are committed to long-term thinking and to an entrepreneurial spirit that properly balances risks and returns. We also recognise that our strategy requires consistent adherence over a long period and may not be easily achieved in the short term. Deutsche Bank is committed to generating sustainable value for our clients, employees, shareholders and society by responsibly balancing risks and returns and by putting long-term success over short-term gain. We do so by ensuring we have appropriate oversight, controls and governance in place. We seek to outperform our competitors through the excellence of our products, services and people and never because of unfair or dishonest business practices. We are committed to a results-oriented culture. Sustainability is at the heart of our corporate responsibility principles. We believe that being economically successful and internationally competitive generates value for our shareholders, clients and society at large. We consider the environmental and social impact of our actions and apply high environmental and social standards to our business to support a sustainable future. Our people are important A core element of our sustainable performance is our focus on recruiting, retaining and developing highly qualified and dedicated individuals for our workforce. We nurture and invest in the best talent and manage based on merit. We combine a culture of performance with a culture of responsibility. We take responsibility when acting today and thinking about tomorrow. We show ourselves accountable for our acts. Progress and prosperity drive us when we initiate and support educational, social and cultural projects that help people everywhere fulfil their potential. Our employees have valuable skills and we encourage them to build social capital by using these skills to benefit others through involvement in community projects and social enterprises that produce lasting change. Ask yourself — Does a proposed transaction or initiative present any risks to the environment or society? — Are there appropriate controls in place to manage the risks associated with the proposed transaction? — Are you focusing only on near-term results without looking at potential long- term risks? — Are you taking appropriate steps to develop and nurture the talents of your staff? — Are you using your skills to build social capital and to benefit society? 5 Our Values and Beliefs Client Centricity Your responsibility — Always be balanced, fair, clear and accurate when communicating with your clients. — If in doubt as to whether a conflict exists, raise the question for consideration with your supervisor and/or Compliance, HR or Legal. — Do not personally compete with Deutsche Bank or engage in self- dealing. — Disclose personal and other relationships that may create a conflict of interest. — Understand the legal safeguards and data protection rules in the countries in which you operate. — Report promptly any client complaints to your supervisor. We place clients at the centre of our activities. We understand our clients’ needs and act first and foremost in our clients’ interests. We aim to ensure that our clients benefit from the value created by the products and services we provide to them. Preventing and managing conflicts of interest As a global financial services provider, we periodically face actual and potential conflicts of interest. Conflicts may arise between, for example, Deutsche Bank’s clients; clients and Deutsche Bank; former and current Deutsche Bank clients and employees; Deutsche Bank and its employees; and different Deutsche Bank entities or business divisions. We maintain organisational and systems-related arrangements and other measures to help minimise and resolve potential conflicts. When Deutsche Bank acts in a fiduciary capacity, we are committed to acting in the best interests of our clients, not favouring one client over another and managing conflicts of interests with our clients. We require that all potential conflicts of interest be reported promptly to supervisors and, as necessary, to Compliance, Human Resources or Legal so that they can be addressed appropriately. In dealing with these potential conflicts, we require integrity and the use of good judgement and discretion exercised in a manner expected by this Code, our policies and our values. Protection of client information We require complete, current and accurate information about our clients, aiming to provide them with appropriate financial services while safeguarding their assets. We make sure that the collection, use, retrieval and transfer of client information complies with data protection laws, our policies and any contractual obligations. Client confidentiality is critical and we seek to protect it at all times. Client complaints We take complaints or concerns from our clients seriously and we handle them fairly and promptly, seeking to avoid such complaints in the future. Ask yourself — Are you striking the proper balance when creating value for the client? — Do you understand your client’s needs and is the product you are offering suitable for your client? — Are you considering trading for your personal account as a consequence of information that you learned in connection with your employment? — Are you intending to use your position at Deutsche Bank for personal gain? 8 Our Values and Beliefs Partnership Your responsibility — Treat your colleagues fairly and respectfully and recognise and respect clients and other external stakeholders as partners. — Appreciate diverse points of view and make decisions based on merit and integrity. — Understand local practices and customs that may impact decisions. — Avoid silo mentality and cooperate with each other in a spirit of partnership, trust and respect. — Do not discriminate against or harass your colleagues. — Actively seek to lead, create and join diverse teams. — Respect what society expects of us. We seek to work in a spirit of partnership, not just with each other but also with our external stakeholders, including our clients, investors, political decision-makers and the wider communities they represent, entertaining a trust-based relationship with our regulators and supervisors. Deutsche Bank benefits from working across silos and its unique diversity of many different nationalities and cultures enriches our decision-making and idea-generation. We recognise that we have a duty to all our stakeholders to be a reliable partner with the highest integrity and ethics. We engage with and learn from others through open dialogue. Diversity in the workplace We value the diversity of our people. We believe that diversity among employees, with their varying perspectives, talents and contributions, enriches our products and services to our clients, our work life and the communities in which we live and work. We support our employees’ talents and strive to be an employer of choice. We believe in the value of diverse teams. Collaboration and equal opportunity We collaborate with each other based on trust and mutual respect. We comply with all applicable laws providing equal opportunity and advancement opportunities for all individuals. We work together without discrimination based upon an individual’s race, colour, sex, national origin, age, religion, disability, marital status, pregnancy, sexual orientation, gender identity and expression, citizenship or any other characteristic protected by law. Non-discrimination policy We do not tolerate any form of discrimination or harassment or any threatening, hostile or abusive behaviour in the workplace. We have procedures in place to resolve employment-related problems as quickly and as confidentially as possible and in a manner that is respectful to our employees. We do not tolerate retaliation against anyone for making a complaint or cooperating with an investigation concerning discrimination or harassment. Ask yourself — Are you considering the views of your colleagues? — Could your behaviour be perceived as embarrassing or threatening? — Are your personal feelings, prejudices or preferences having an influence on your business decisions? — Are you acting cooperatively with our stakeholders? — Are you reaching out to colleagues from across the Bank to discuss issues or potential resolutions? — Are you keeping your supervisors and/or Compliance and Legal informed of interactions with regulators as a result of a regulatory inquiry or commencement of any action related to Deutsche Bank business? 9 Safeguarding our Values and Beliefs Effective corporate governance and risk management Effective corporate governance and risk management are integral to managing Deutsche Bank. Our Management Board and Supervisory Board, as well as the senior management of our Group, recognise the importance of this Code and our values to our corporate governance and risk management controls and have instituted various measures to uphold them. — We aspire to have clear organisational structures with transparent and consistent lines of responsibility and accountability, presence of key control structures and a well-functioning framework of checks and balances. — We foster supportive relationships between the Management Board and the Supervisory Board as well as with our shareholders and other stakeholders. — We monitor compliance with the provisions of this Code and require that any material issues or concerns, including any remediation measures taken, be reported. — We designate certain employees as “supervisors” who, among other things, are responsible for instituting reasonable measures to facilitate and promote compliance with Deutsche Bank’s applicable laws, rules, regulations and policies and who oversee such compliance. — We expect our supervisors and senior employees to set an ethical example for how to behave in the workplace and set the “tone at the top.” — We communicate what is expected of our employees through this Code, our policies, our values and other channels, including keeping employees up-to-date on any changes to these standards. — We reinforce our standards through periodic training, the provision of reliable mechanisms for reporting violations and taking appropriate actions for misconduct. — We maintain an open and supportive environment that encourages the raising of questions and concerns. Deutsche Bank has a strong risk management culture and expects its employees to be aware of risks in their everyday businesses. Examples of the strong risk management cultural behaviours expected of our employees include: — inviting, providing and respecting challenge; — being rigorous, forward-looking and comprehensive in the assessment of risk; — troubleshooting collectively; — being fully responsible for Deutsche Bank’s risks; and — placing Deutsche Bank and its reputation at the heart of all decisions. 10 Adherence to this Code Deutsche Bank requires all of its employees to read and follow the letter and spirit of this Code. Failure to comply with any provision of this Code is a serious violation and may result in disciplinary action, up to and including termination of employment. Employees are required to report promptly any concerns or possible violations of laws, rules, regulations, our policies (which can be obtained from the intranet or local supervisors) or this Code to their supervisors, other representatives of management, Compliance, Corporate Security & Business Continuity, Employee Relations, Group Audit, Human Resources, Legal, Global Corporate Governance or the Employee Hotline. Information on the Employee Hotline can be obtained from the intranet or your local Compliance Officer. Reports can be made anonymously (when permissible under local law), but reports should provide enough information to allow Deutsche Bank to investigate the matter properly. In addition, Deutsche Bank policy prohibits retaliation against any employee for reporting, when based on a reasonable belief that a suspected violation has occurred, is ongoing or is likely to occur. Compliance with this Code is not a guarantee of continued or indefinite employment. The Code does not create a contract, does not alter the terms and conditions of an employee’s employment with Deutsche Bank and may be changed at any time, without notice, by Deutsche Bank. If you have any questions or concerns about a potential course of action, you should check with the relevant policy and/or escalate your concerns to your supervisor and/or to Compliance or Legal.