Deutsche Bank Group Code of Conduct: Ethics, Values, and Compliance, Study notes of Business

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Deutsche Bank Group Code of Conduct Deutsche Bank Group Code of Conduct Table of contents A message from Christian Sewing, Chief Executive Officer Our purpose 1 Our values and beliefs 2 Applicability of and adherence to the Code; 3 Compliance with applicable law and regulation Valuing our employees and building trust 4 in the workplace Diversity and inclusion, equal opportunity, non-discrimination and building trust in the workplace Doing the right thing – acting ethically 5 Acting with integrity Ethical-decision making Taking personal responsibility Decision-making tree 6 Responsibilities as a manager 7 Risk awareness and acting as a risk manager 8 Speaking up and raising concerns 9 (including whistleblowing) Non-Retaliation Protecting and handling confidential information 10 Conflicts of interest 11 Financial crime prevention and detection 12 Anti-financial crime 12 Anti-money laundering/ 12 anti-terrorism financing Economic sanctions regulations 12 & anti-boycott rules Anti-bribery and corruption 13 Anti-fraud 13 Fair and free markets 14 Market conduct, market manipulation 14 and market abuse Abuse of information and insider trading 14 Antitrust 15 Treating clients fairly, communicating with 16 clients, and handling customer complaints Treating clients fairly 16 Communicating with clients 16 Customer complaints 17 Protecting customer assets and accounts 17 Employee related activities 18 Avoiding and disclosing personal conflicts 18 of interests Gifts and entertainment 18 Employee trading 19 Outside business interests 20 Political contributions 20 Communications, the media, social media 21 and interactions with our regulators Responding to media inquiries 21 Electronic and voice communications 21 Social media 22 Interactions with supervisory authorities 22 Sustainability and respecting human rights 23 Safeguarding our bank’s interests 24 Information security 24 Protecting Deutsche Bank’s assets 24 Data protection 24 Records 25 Authority to act 25 Key resources and contacts 25 Deutsche Bank Group Code of Conduct 1 Our purpose We are here to enable sustainable economic growth and societal progress by generating positive impact for our clients, our people, our investors and our communities. We achieve this by being a leading European bank with a global reach. We value our German roots and remain committed to our international presence. We serve stakeholders best by offering solutions to our clients and participating in value creation by them. In doing so, we seek to ensure that our bank is competitive and profitable while being underpinned by strong capital and liquidity. We are committed to a culture that appropriately aligns risks and rewards. To deliver this, we aim to attract and develop talented individuals. We foster teamwork, partnership and inclusion, trusting that each of us will deliver to the expected standards. Partnership Integrity D is ci pl in e In novation Client centricity Sust ai na b le perfo rm an ce Our values Deutsche Bank Group Code of Conduct 2 Our values and beliefs Our values We aim to create an environment in which “speak up” and challenge are not just welcomed and respected, but are also a core part of our responsibilities, especially where actions or failures to act are inconsistent with this Code. Integrity – We earn the trust of our clients, other stakeholders, communities and each other by acting with honesty and integrity and holding ourselves to high ethical standards. We seek to maintain open, credible, constructive and transparent relationships between ourselves, our clients and with our regulators. Sustainable performance – Our bank is committed to generating sustainable value by responsibly balancing risks and returns and by putting long-term success over short-term gain. We do so by implementing appropriate oversight, controls and governance. Client centricity – We place clients at the centre of our activities. To be successful, we must understand the rapidly changing needs of our clients. We aim to provide solutions to support our clients in value creation. In providing our services, we deliver what we promise to our clients and treat our clients fairly. Innovation – We continuously embrace new and better ways of doing things while fully taking account of potential risks. Innovation is essential to our success, but must be properly assessed in light of the interests of our clients and stakeholders, and must include assessment of financial, operational, regulatory and reputational risks. Discipline – We accept responsibility and assign clear accountability. We honour our commitments and meet deadlines, targets and deliverables. We learn from our mistakes. Partnership – We benefit from collaborating in an inclusive environment, where our diversity enriches our decision-making and idea-generation. We engage with and learn from others through open dialogue. We seek to work in a spirit of partnership, not just with our colleagues but also with our clients, stakeholders, political decision-makers and the wider community. What does it mean for you in practice? — Be honest — Do what is right — If it feels wrong, stop and seek advice — Speak up — Be open and transparent — Work in partnership — Place clients at the centre of your activities — Always honour your commitments — Always treat colleagues, customers and regulators with respect — Minimise repeated and avoidable errors and mistakes Deutsche Bank Group Code of Conduct 5 Doing the right thing – acting ethically We earn the trust of all our stakeholders by acting with integrity and holding ourselves to the highest ethical standards. Acting with integrity You must always act with integrity in your dealings with clients, colleagues, and stakeholders by adhering to this Code and applying its standards to everything that you do. You should raise concerns, ask questions and escalate matters, as necessary. Ethical decision-making Acting ethically is not only the right thing to do, but also the right way to do business – it serves the interests of our clients and stakeholders and is critical to achieving success in the longer term. In making decisions and determining the appropriate course of action, you must be guided by what is right and proper, not just by what is allowed or legal. If there appears to be a conflict between this Code and local laws, rules or regulations, the more restrictive provisions apply. When you are faced with questions that go beyond those addressed in this Code, you should follow both the spirit of the Code and related bank policies that cover the issue. Escalate concerns to your supervisor, Legal, Compliance, AFC or other relevant function, or report it through the Raise a Concern webpage on dbNetwork or to the Integrity Hotline. Taking personal responsibility You are accountable for your actions or omissions, and will be held responsible for any improper or illegal acts. Your conduct may be reported to regulators, which could ultimately result in civil or criminal penalties or suspension or loss of your individual licence/registration, if applicable. Remember: you are responsible for the standards you tolerate. Stop and seek advice OK once all necessary business and governance approvals are in place (if required) YES NO or NOT SURE Deutsche Bank Group Code of Conduct 6 Decision-making tree When faced with an ethical question or a challenging decision, you should ask yourself: Is it legal? Does it comply with our Code of Conduct and the bank’s policies and procedures? Can I justify this decision/action to my manager? Am I creating value for my clients and treating my clients fairly? Will our bank and shareholders avoid loss or harm, including reputational harm, as a result of my decision/action? You should be able to answer “yes” to all questions. If you cannot tick “yes” to all questions, stop and seek advice from your supervisor, Compliance, AFC or Legal. Deutsche Bank Group Code of Conduct 7 Responsibilities as a manager If you are a manager, your employees will look to you to set an example and to demonstrate the standards set out in the Code. You are responsible for creating an inclusive and diverse work environment that attracts and retains the best employees and permits your team to innovate, problem solve and successfully execute. You need to encourage your team to speak up and you need to be a good listener, who is committed to supporting your employees in their work and development. Your people-development skills should be a priority. Each of us, especially leaders and managers must act with integrity and inspire trust. As a manager, you are responsible for creating and maintaining an environment built on trust and safety, providing the foundation for giving and receiving regular feedback that is balanced, open and actionable. At the same time, you supervise the activities and conduct of your employees and are required to have an appropriate control environment for your business, designed to adhere to applicable regulatory requirements. Part of that control environment includes encouraging individuals to ask questions and challenge, and setting the right tone in how to act. Investment in skills and encouraging employees’ professional and personal development are essential components of our bank’s people agenda. This is reflected in the talent and development agenda, which helps to develop and nurture future leaders who are accountable, who champion the Code’s standards and who inspire the best in their colleagues. You should recognise and positively reinforce good behaviours as well as acting swiftly to intervene in the case of inappropriate behaviours. Note that you can be held responsible for the actions or omissions of those you supervise, particularly if you have not exercised the level of supervision expected by our bank and/or our regulators. Remember: to create an inclusive environment where people “speak up” and act ethically: — Lead by example, your team looks at your behaviour, including your standard of care and diligence — Encourage your team to work collaboratively — Remind employees of the importance of treating each other with respect — Include discussions about ethical issues and proper conduct in meetings — Encourage open and honest discussion — Maintain an open door policy — Remind employees they will not be subject to retaliation for raising concerns — Ensure your team is aware of their escalation obligations — Build a diverse team — Set reasonable goals based on available resources Deutsche Bank Group Code of Conduct 10 Protecting and handling confidential information Our clients expect that we maintain the confidentiality of their information, whether that information relates to financial, personal or business matters. Our bank also expects that you maintain the confidentiality of its own information. Confidential information can be written, oral or electronic and includes a wide variety of data deriving from sources such as IT applications, strategies and customer lists. When in doubt, assume all information you receive is confidential. Inside information is a subset of confidential information and discussed later in the code. You may not share, make available or disclose such confidential information to anyone inside or outside our bank, except on a “need to know” basis, i.e., with other staff who are involved in the transaction or providing the services and such disclosure is required for the proper execution of our bank’s responsibilities. Sharing it more broadly, even with other employees, could be inconsistent with a client’s expectations or in breach of legal requirements, including a confidentiality agreement with the client. Where information may be shared, you must limit the amount of information to what is required to achieve the stated business purpose and make sure the recipient knows that the information is confidential and subject to restrictions related to its use or dissemination. It is never appropriate to share confidential information with family and/or friends. Even if you believe that a family member or friend will not misuse the information, it is not your information to share. Data held by sensitive business areas are secured by Information Barriers (e.g., data relating to business areas classified as non-public are held behind the Information Barrier and are not accessible by other areas). Restrictions on disclosing confidential information are not intended to, and should not, prevent employees from reporting or escalating any concerns or responding to questions or requests from relevant regulators, law enforcement agencies or their formally appointed agents, courts of law or our bank’s monitors. For further information, reference the Use and Handling of Client Confidential and Deutsche Bank Proprietary Information Policy – Global. Also remember, information from prior employers (including information from the clients of prior employers) is confidential information and should not be shared with our bank or bank employees – to do so is unethical, unless it has already been made public through no action of your own. Q&A Q1. A colleague asks me to share customer information from my former employer. She explains that this would be a great opportunity for the bank to acquire new customers, cross-sell financial products, and for her to meet her quarterly targets. Is this the right thing to do? A1. No. You must not disclose that information. Customer information of your former employer is that employer’s confidential information and you have a legal obligation to protect the information, even after leaving that company. By disclosing the information, you are breaching this Code and exposing yourself and our bank to legal liabilities. Q2. Marie in Finance is working with the Deutsche Bank printers on the preparation of the bank’s annual results. She has just reviewed the latest proof and forwards it to other colleagues involved for their review. Having pressed Send, she notices that in error, she has sent the document to a JamesDSmith rather than JamesSmith. Has Marie acted illegally by sharing the bank’s annual results in advance? A2. She has not intentionally leaked the information so this would not be a criminal offence. Nonetheless, there is a problem. What has happened is the inadvertent leak of inside information. It is crucial that Marie immediately escalates the issue to Compliance, who will advise her how to proceed. Deutsche Bank Group Code of Conduct 11 Conflicts of interest We maintain organisational and systems-related arrangements and take other measures to help avoid, minimise or mitigate potential conflicts. We are committed to treating our clients fairly and appropriately handling clients’ interests, including, for example, where one client’s interest may be in conflict with another client’s interest. All potential conflicts of interest, including personal ones that you may have with our bank, another employee, a client, a vendor, etc., must be reported promptly to your supervisor and, as necessary, to the Business Selection and Conflicts Office, Compliance, Human Resources or Legal so that they can be addressed appropriately. Conflicts can be nuanced and, in dealing with potential conflicts, you should act with integrity and use good judgment in a manner consistent with this Code and our policies, and ask for guidance as necessary. For further information, reference the Conflicts of Interest Policy – Deutsche Bank Group. Many of the major problems that have occurred in the industry, including here at our bank, involved conflicts of interest. A conflict of interest arises where one or more persons or entities have competing interests and the serving of one interest may involve detriment to another. As a global financial services provider, our business inevitably gives rise to actual, potential and perceived conflicts. Examples of potential conflicts include: in Markets, acting as principal with a client or as an agent between a buying and selling client; in Banking, acting on behalf of an issuer of securities while managing our responsibilities to underlying investors in those securities; in Asset Management and Wealth Management, being incentivised to create or sell products that may be to the detriment of our clients or the market. When identifying conflicts, be sensitive to the fact that conflicts can arise in a variety of relationships, including: — Between our clients; — Between a client and our bank or our employees; — Between the bank and our employees; — Between a service provider and an employee or the bank; and — Between and among different group entities or business divisions of our bank. Q&A Q1. You are part of the COO function and you are selecting a new software supplier for the bank. Your spouse works for one of the vendors. Is this a conflict? A1. Yes, there is a potential conflict between you and the vendor because the fact that your spouse works for one of the vendors could be viewed as influencing your judgment. You should make sure that the bank is aware of the potential conflict, and you should not be involved in the selection of the vendor. Q2. An issuer client threatens to end its business relationship with our bank unless one of our research analysts takes a more positive view on its stock. Is this a potential conflict of interest? A2. Yes, this situation represents an actual conflict of interest between the bank and its client because acceding to the client’s demands would compromise the objectivity and independence of the research output. Any such attempt, by a client, internal stakeholder or otherwise, must be escalated in accordance with the bank’s policy. Q3. You work at a local branch in Berlin. You just received a call from a customer that is a small-sized business looking for some short-term working capital. The logical choice for the client is a short- term loan, but your colleague has suggested that you should pitch a credit card option, which would attract much higher fees for the bank. Should you advise the customer to opt for a credit card? A3. No. The best option for the customer is the loan. The suggestion that you should earn higher fees by recommending a credit card at the expense of the customer’s needs is not appropriate and would be a failure to manage the conflict arising between the interests of the client and the bank. Deutsche Bank Group Code of Conduct 12 Financial crime prevention and detection Anti-financial crime Our bank advocates the development of sound regulations and internal procedures to combat financial crime, including tax evasion. These requirements are also intended to prevent our bank from committing or facilitating – intentionally or negligently – criminal offences. You are personally accountable for adhering to all applicable statutory and regulatory responsibilities to prevent financial crime. To support you in meeting those obligations, our bank’s Anti-Financial Crime (AFC) department is mandated by the Management Board to develop and implement policies, procedures and processes to minimise AFC risk within our bank, and enhance them on a continuous basis, at both global and local levels. For further information, reference the Anti-Financial Crime Charter. Anti-money laundering/anti-terrorism financing Money laundering is the intentional movement of cash and/ or assets derived from illegal and criminal activities into the legal, financial and/or business system. The attempt to disguise the true source or ownership of the funds, to disguise the ultimate disposition of the funds and to eliminate audit trails is part of the laundering process. Underlying crimes are defined by local laws and could comprise, for example, forgery, counterfeiting, extortion, human trafficking, robbery, drug crime as well as fraud, corruption, organised crime, or terrorism. Terrorism financing is defined as the providing, depositing, distributing or collecting of funds, by any means, intended to be used, or knowing that they are to be wholly or partially used, for committing terrorist acts. It is not relevant whether such funds are of legal or illegal origin. To combat money laundering and terrorism financing (together, “AML”), our bank has developed a set of policies outlining its general AML standards and principles. You are required to adhere to these standards to protect our bank and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes. For further information, reference the Anti-Money Laundering Policy - Deutsche Bank Group. Economic sanctions regulations & anti-boycott rules National authorities and supranational organisations (e.g. the United Nations and the European Union) impose restrictive measures against targeted sectors as well as countries, organisations, groups, entities and individuals who infringe internationally accepted behaviours and norms, including those who have been identified as being involved in weapons proliferation as: — terrorists or supporters of terrorist organisations; — violators of human rights; or — being involved in bribery and corruption. Such measures are more commonly known as embargoes or sanctions. Our bank has identified Prohibited and Restricted Special Risk Countries in order to better safeguard against sanctions risks. You are required to comply with applicable embargoes and sanctions as well as our bank’s requirements on Special Risk Countries. Non-compliance can expose our bank, as well as you personally, to civil, regulatory and criminal penalties, including substantial monetary fines and, in the case of individuals, prison. Non-compliance with embargoes and sanctions also poses a substantial reputational risk for our bank. It is also important to note that there are anti-boycott Deutsche Bank Group Code of Conduct 15 Fair and free markets (continued) Antitrust Ensuring that employees at all levels comply with applicable antitrust laws is a key priority of the bank. The financial sector is under close scrutiny from antitrust authorities and public prosecutors. Understanding the basic concepts of the antitrust rules and the limitations that they can impose on your activities, and being able to identify activities or conduct where there could be risk is critical for you and our bank. Antitrust laws promote free competition by making certain anti-competitive practices illegal. The practices caught by antitrust laws encompass a wide range of market-distorting behaviour around the globe. This behaviour includes agreements and practices that restrict competition, trading in concert with a competitor, agreements with competitors on pricing, agreements to exclude others from a transaction, facilitating the exchange of competitively sensitive information, and violations of merger control rules. Antitrust laws of certain countries in which we conduct business have broad extraterritorial scope and application. It is our policy to comply with all laws which prohibit anti-competitive conduct in the countries in which we operate. The consequences of antitrust violations are serious and far-reaching. US, EU and other enforcement authorities vigorously prosecute anti-competitive conduct. Any infringement of antitrust laws can have serious consequences, including severe financial penalties for our bank and you. Multi-million euro fines have become routine for companies found guilty of infringing antitrust laws. Other serious consequences may also result from non-compliance with antitrust laws, including: — Individual imprisonment or long-term disqualification; — Paying compensation to affected parties; — Reputational damage; — Restrictions on business; and/or — Void or unenforceable contracts. For further information, reference the Antitrust Risk Management Framework Policy – Deutsche Bank Group. Q&A Q. As a Deutsche Bank Swap trader, you contribute streaming of live prices to three trading venues that are used by the administrator of a daily benchmark. The benchmark is calculated off tradable quotes from regulated, electronic, multilateral trading venues and represents the mid-price for Swaps (fixed leg) at particular times of the day. Early one morning a longstanding colleague, who now works for another bank, emails you with the following message: “Hi Matey, Need a favour from you. Can you nudge your GBP B/O down a couple of bps on Trad-X today? I know you don’t do much volume on that venue anyway so you’re unlikely to be hit and it would be a great help to me. I can return the favour sometime in the future to help you out.” Is it acceptable to agree to the proposition? A. No. Any form of collusion among competitors in order to manipulate, or to attempt to manipulate or help facilitate some to manipulate, benchmarks, price fixes or reference rates capable of distorting the normal course of pricing is not acceptable. Even if your attempt to influence the fix fails, the intention to influence normal market conditions is sufficient to make this behaviour illegal and be in violation of antitrust law. Deutsche Bank Group Code of Conduct 16 Treating clients fairly, communicating with clients, and handling customer complaints Treating clients fairly As a bank, we have defined ourselves as client centric, and part of our success is through creating value to our clients by the solutions we provide and services we offer. Critical to our strategy is delivering what we committed to our clients and treating them fairly and transparently. In practical terms, it means that we may not take unfair advantage of anyone or disadvantage them through manipulation, concealment, abuse of confidential information, sharing or using it improperly, misrepresentation of material facts or unfair dealings or practices. For customer-facing employees, you should understand your customers’ needs, expectations and interests in order to provide them with appropriate solutions that lead to the right outcomes for them based on their stated requirements, sophistication and attitude to risk. You must always act fairly, honestly and transparently and avoid providing customers with undue preferential treatment, including over other clients. Communicating with clients It is important when dealing with our clients that our communications – both oral and written, are fair, clear and accurate. Statements that can be viewed as misleading or fail to include information important to making an investment decision – whether the client is retail, professional or institutional – can violate applicable law. Fair, clear and accurate communications protect the bank and you. For example: US regulators have been focusing on communications with institutional investors in illiquid markets where sales persons are alleged to have misrepresented facts surrounding the securities being purchased. In the case of communications such as offering circulars and research, they promote market efficiency by ensuring that all market participants have the opportunity to act on information that is accurate, complete and not false or misleading. All bank communications must meet certain minimum content standards and requirements, including specific information classification standards. In addition, specific requirements relating to certain categories of communications such as research, sales, marketing and advertising, as well as electronic communications, are the subject of supplemental policies. For further information, reference the Business Communications Policy – Global. Q&A Q. Theo works in a retail branch. He has been told that the incentive this year is a 6% pay rise if he meets the target before year end. An existing retail client visits the branch seeking to invest all of a small inheritance he received – he says this is his retirement money when he retires in a couple of years. Theo advises him on a non-principal-protected product intended only for high net-worth individuals, who are “sophisticated clients,” for which he will receive a higher commission. He explains that they are similar to retail bonds but have a high coupon payout structure and states that they are not any riskier than bonds of a blue chip corporate. — Were the rationale and risks of the product sold in line with the risk appetite of the retail client, i.e., was it suitable? — Did he explain the product thoroughly? — Was he truthful? — Was his judgment clouded by his own personal interests? — Should the bank have considered whether the incentive programme could influence bad outcomes for clients? A. Theo mis-sold the product and misrepresented the importance of the risks embedded in the product. He did not consider whether this was a suitable product for the client and sold a product for which he would receive a higher commission and, therefore, a better chance of meeting a target set by the bank. Deutsche Bank Group Code of Conduct 17 Treating clients fairly, communicating with clients, and handling customer complaints (continued) Customer complaints A complaint means any expression of dissatisfaction or grievance, regardless of whether justified or not, from or on behalf of a customer or counterparty about our bank’s provision of, or failure to provide, financial services (for example, the execution of any transaction, or the disposition of securities or funds). This may also include public relations matters regarding our bank’s business practices that have the potential of damaging our bank’s reputation, brand and market value. Complaints may be received from a complainant directly or through an authorised third party and can be transmitted via various means, including letter, telephone, email, or in person. They may also involve a demand, express or implied, for a payment or adjustment. You must promptly refer all complaints to your supervisor. Actual or potential errors or complaints that could result in a client dispute must be referred to Legal and Compliance and any complaints, errors or irregularities relating to customers that cause breaches of regulatory or legal requirements or obligations must be reported immediately to your supervisor, Legal and Compliance. All errors and complaints must be addressed as soon as practicable. For further information, reference the Minimum Requirements for Handling and Recording of Complaints – Global. Q&A Q. You have received a call from a client concerned that there are unusual transactions which they do not recognise on the account, and their statements are arriving much later than usual. — Is this a complaint if you think the delays are due to system problems? — Do you report the complaint to your supervisor immediately or only if the client complains again? — Do you register this as a complaint for Complaints Handling process used by your business? A. You report the complaint to your supervisor immediately and ensure that it is properly reflected as a complaint in your business’ Complaint Handling procedures. In most jurisdictions, there are requirements about responding to and reporting complaints. Further, complaints can be an indication of a broader problem. The sooner the problem is reported, the sooner the bank can take action. Protecting customer assets and accounts The protection of customer assets and accounts is paramount. Each division is responsible for implementing policies necessary to ensure client monies and assets are appropriately safeguarded, and the dispositions of customer assets are only made by the holders of accounts, and in the case of custody accounts, by their agents on the basis of a power of attorney, or by virtue of a court order or other official measures. Balances on customers’ dormant accounts and custody accounts with no known address may not be booked to revenues by our bank. For further information, reference the MiFID II Safeguarding Client Assets and Funds (SCAF) Policy – Businesses globally and the Business Relationships with Interrupted Customer Contact (Unclaimed Assets) Policy. Deutsche Bank Group Code of Conduct 20 Employee related activities (continued) Political contributions Our bank is a politically neutral organisation and does not engage in party political campaigning or make party political donations. Our bank conducts dialogue with governments on issues relevant to our businesses and any communication undertaken is honest and accurate. Our bank permits its employees to be active in the political process. If you are involved in political activity in a personal capacity you have a responsibility to make sure that this is kept entirely separate from your duties as an employee and that our bank’s funds or resources (including time) are not used for political purposes. It is not permitted for any employee to coerce or pressurize other employees to make political contributions. In certain jurisdictions, there are limitations, restrictions and reporting requirements on the exercise of political activities. In the US, such regulations apply to all US citizens and US permanent residents regardless of work location. Please contact local Compliance for advice prior to engaging in any political activities. So that conflicts of interest are avoided, colleagues are expected to exercise discretion and not become involved in matters of political controversy that may compromise the interests of our bank and/or their role. Any material political activity must be approved in advance by your supervisor and Compliance. Outside business interests You are expected to devote your best efforts and abilities to our bank. Outside Business Interests are certain interests or activities undertaken by employees outside their role at or with our bank, whether or not compensated, that may create a potential conflict of interest. These are generally positions in external organisations such as directorships or partnerships, external/other employment or appointments to public offices. Minimum standards have been set to avoid or manage conflicts with any Outside Business Interest and the duties of the employee, to protect our bank and its staff against reputational risk, avoid interference with your responsibilities to our bank, and to assist Compliance in the identification and prevention or mitigation of conflicts. You are required to disclose and obtain approval prior to engaging or agreeing to engage in an Outside Business Interest via GECCo. For further information, reference the Outside Business Interests Policy – Deutsche Bank Group. Deutsche Bank Group Code of Conduct 21 Communications, the media, social media and interactions with our regulators Responding to media inquiries Unless authorised to speak to the media, you must refer all media enquiries concerning business activities, clients, employees, officers or members of the Management Board or Supervisory Board of our bank to the appropriate Communications team. If you plan to have or you had contact with a media representative you have to inform Corporate Communications in a timely manner. You must not make any statements in the name of our bank or release any information or documents to the media either directly or through a third party, unless expressly authorised to do so by the appropriate Communications team. For further information, reference the Media Policy – Deutsche Bank Group. Electronic and voice communications The use of electronic or voice communication and the recording of voice communications can be subject to the laws and regulations of multiple jurisdictions. Principles have therefore been established to safeguard information and to set minimum requirements for appropriate access, monitoring and usage. Only Deutsche Bank-approved communication devices and applications may be used for the conduct of any bank business whether by email, chat or other electronic messaging. If you are required to use recorded lines, you must comply with the policies of your business to ensure that your conversations are taped. Participating in multi-person/multi-bank chat rooms and other public chat rooms in connection with any bank business or with our bank’s equipment is generally prohibited (certain exceptions apply with relevant pre-approvals). Our bank is required to retain records relating to electronic and voice communications generated by employees and undertakes surveillance of them. Additionally, electronic and voice communications may be subject to disclosure or other requirements in litigation, regulatory and law enforcement inquiries, internal investigations and/or other proceedings, and/or subject to monitoring or surveillance. Our bank reserves the right to monitor, review, access, record and disclose information and data, which is created, sent, received, downloaded or stored on our bank’s electronic or telephonic systems or on the bank’s premises, subject to local data privacy restrictions. For further information, reference the Electronic Communication Systems Policy – Deutsche Bank Group and the Use of Mobile Devices Policy – Deutsche Bank Group. Q&A Q. You have received a phone call from a journalist who is asking the whereabouts of a client. You met with the client in the morning and she told you she was travelling today to Eastern Europe for business. The journalist says that your client is in the middle of striking a very important business deal and promises that he will write a positive piece about Deutsche Bank if you help him out with the information he needs. You are not an authorised spokesperson for the bank. Is it appropriate to reveal your client’s whereabouts? A. No. You must decline to speak to him and refer him to your local Press Office. Client information must be treated in confidence. It would be a major breach of trust to pass this information to anyone outside the bank. You are not permitted to speak to the external media unless you have been approved and received formal training as an authorised Deutsche Bank spokesperson and media contacts should always be referred to or logged with your local Press Office. Deutsche Bank Group Code of Conduct 22 Communications, the media, social media and interactions with our regulators (continued) Social media Recent years have shown a growth of social media services, which has fundamentally changed interpersonal communications, built online communities, and increased virtual interactions. Our reputation is dependent upon appropriate and professional media and public relations. In order to protect our reputation and brand, only authorised employees may set up and operate a social media channel in the name of our bank. This restriction does not apply to discussion of personal matters outside of work and on non-bank equipment. You should always use good judgment in your use of social media and other online activities, even in connection with personal matters. Postings on internet and/or social media sites referencing our bank, your responsibilities, our clients or your bank colleagues may have an impact not only on you but our bank as well, and may constitute a breach of privacy laws, misuse of confidential information or other policies. Your social media activities are also governed by the laws applicable in the country where you work as an employee. The policies and guidelines of your respective division or the region in which you work also apply. For questions about the use of social media, please contact Digital Communications. For further information, reference the Media Policy – Deutsche Bank Group and the Electronic Communication Systems Policy – Deutsche Bank Group. Interactions with supervisory authorities Our bank is committed to act in an open and transparent way with all its Supervisory Authorities and to promote trust-based cooperation. Failure to do so could result in regulatory sanctions, reputational damage and/or significant financial penalties. Relationships with the supervisory departments of our bank’s Supervisory Authorities are managed by Regulation, Compliance, Country Management or other teams responsible for regulatory relationship; and subject matter experts (representing the business divisions and infrastructure functions). Each Supervisory Authority generally has a bank Principal Point of Contact. Any communications that are received by anyone other than the Principal Point of Contact should be escalated to Compliance or the relevant team responsible for regulatory relationship who will re-route the communication to the relevant Principal Point of Contact. Communication to the Supervisory Authorities by any department or individual, other than the Principal Point of Contact should first be escalated and routed through the Principal Point of Contact. You must adhere to certain minimum standards in any interaction with our bank’s Supervisory Authorities. For further information, reference the Supervisory Authorities Engagement Policy – Deutsche Bank Group. If you are authorised to interact with our bank’s supervisory authorities, remember: — Communicate in an open, succinct, candid, accurate and complete way — Execute and deliver on agreed actions in a timely and prompt fashion — Provide realistic deadlines and timelines and any indication that these will not be met should be escalated — Review requests received with a view to establishing a shared understanding of what is expected — Provide notification of relevant matters, events, issues or incidents in a timely manner — Make sure that communications, when presented globally to regulators, are consistent — Facilitate tracking and internal reporting requirements In addition, we are required to maintain the confidentiality of any examination or supervisory information received from Supervisory Authorities (“Confidential Supervisory Information”). The definition of Confidential Supervisory Information is broad and includes any information that is prepared by, on behalf of, or for the use of a Supervisory Authority, including information “related to” an examination, inspection, or visitation of an institution. The various Supervisory Authorities have similar, but not identical, requirements regarding the disclosure of Confidential Supervisory Information. However, as a general principle, Confidential Supervisory Information may not be disclosed to a third party, including an agent of our bank, without the express written consent of the relevant Supervisory Authority. You should contact the relevant team responsible for regulatory relationship before sharing any regulatory information. Deutsche Bank Group Code of Conduct 25 Safeguarding our bank’s interests (continued) Records Maintaining accurate books and records is fundamental to meeting our legal, regulatory and business requirements. You are responsible for maintaining accurate and complete records and for complying with all the controls and policies our bank has in place. You should never falsify any book, record or account that relates to the business of our bank, its customers, employees (including your own activities within our bank) or suppliers. You must never dispose of records or information that may be relevant to pending or threatened litigation or a regulatory proceeding unless you are authorised to do so by the Legal Department. You must also comply with applicable record retention policies. For further information, reference the Records Management Policy – Deutsche Bank Group. Authority to act Your authority to act on behalf of our bank is limited by various laws, rules, regulations, corporate charters, by-laws and board resolutions as well as our bank’s policies. You need to be aware of these, how they impact your role, and of the responsibilities attached to it. You should never sign any documents or otherwise represent our bank, or authorise any action on our bank’s behalf, unless you are specifically authorised and have the required knowledge to do so. You should know the limits of your authority and act within those limits. Correspondence and documents containing legally binding statements must generally bear two authorized signatures of the bank. For further information, reference the Internal Governance Policy – Deutsche Bank Group. Key resources and contacts Anti-Financial Crime Business Selection and Conflicts Office Communications & Corporate Social Responsibility Compliance Group Tax Human Resources Legal (incl. Group Governance) Risk Integrated Consequence Management Framework Risk Awareness on myDB Be on the right side. #PositiveImpact Falling short. Getting it right.