Deutsche Bank

Sustainability governance structure

Reference: p.208-211 (Governance – Sustainability Governance).

Deutsche Bank AG has a two-tier board structure: the Management Board, which "assumes ultimate responsibility for matters relating to sustainability," and the Supervisory Board, which advises on such topics. Sustainability has been "a central part of Deutsche Bank's strategy since July 2019."

Key bodies:

• Group Sustainability Committee (GSC) – chaired by the CEO, vice-chaired by the Chief Sustainability Officer; scope is Group excluding DWS. It is "the main governance body for sustainability-related matters across Deutsche Bank Group." In 2025 it met six times (four by circulation) and approved the bank's Sustainability Strategy 2030, including the new cumulative EUR 900 billion sustainable and transition finance target and the nature ambition of 300 transactions by end-2027, and acknowledged the updated Transition Plan.
• Group Risk Committee (GRC) – chaired by the CRO; reviews climate-related matters and receives regular updates on net zero targets and transition risk.
• Culture, Integrity and Conduct Committee – oversees the culture, integrity and conduct framework, including sustainability-related matters.
• Chief Sustainability Office (CSO), whose Head reports to the CEO; supported by the Sustainability Strategy Steering Committee and the Group Net Zero Forum.
• On the Supervisory Board side, the Strategy and Sustainability Committee is central, supported by the Compensation Control, Audit and Risk Committees.

Information flow to the administrative and management bodies

Reference: p.215 (Governance – Internal Controls over Sustainability Reporting); p.280 (Climate change – Resources); Data protection p.380; Information security p.384 (per the ESRS DR index).

The Management Board receives monthly updates on financed emissions and net zero alignment via the Risk and Capital Profile report. The Audit Committee of the Supervisory Board "supports the Supervisory Board in monitoring the effectiveness of the processes for preparing the Sustainability Statement," and is informed of significant developments.

Topic-level accountability is delegated to named senior roles who report into the Management Board structure, each described in the respective chapter's "Governance" sub-section: the Head of Global Real Estate (climate/own operations), the Global Head of Human Resources (own workforce), the Group Anti-Money Laundering Officer (anti-financial crime), and equivalents for Data protection and Information security. In 2025, sustainability matters addressed by the GSC included approval of the Sustainability Strategy 2030 (EUR 900bn cumulative target), the nature ambition (300 transactions by 2027), the Transition Finance Framework, and the updated Transition Plan.

ESG targets in Management Board variable compensation

Reference: p.214 (Governance – Integration of sustainability-related performance in incentive schemes).

For the LTI plans 2024-2026 and 2025-2027, the Supervisory Board sets ESG objectives forming 20% of total variable compensation, split:

• Environmental target (8% weighting): driving climate risk management, linked to disclosed carbon-reduction pathways for carbon-intensive sectors (the Transition Plan) plus an allowed deviation (risk appetite). For 2024-2026: 0% achievement at a trajectory <=50% of permitted deviation; 100% achievement at 70%; 150% achievement at 85%.
• Social target (4% weighting): increasing gender diversity at the two levels below the Management Board (MB-1/MB-2) per the Second German Gender Quota Law (FüPoG II). 0% achievement at <=30% women; 100% at 32.5%; 150% at 35%.
• Governance target (8% weighting): Control Risk Management Grade (CRMG) progress plus AML/KYC remediation progress; for 2025-2027 the criteria were widened to include external stakeholders' assessment of regulatory development.

The variable compensation split is 40% Short-Term Incentive / 60% Long-Term Incentive. The Supervisory Board's Compensation Control Committee prepares proposals; the full Supervisory Board decides.

Statement on due diligence – core elements mapping

Reference: p.232 (ESG due diligence chapter).

Deutsche Bank maps the five due-diligence core elements to specific Sustainability Statement chapters:

• (a) Embedding in governance, strategy, business model: Governance; Double materiality assessment; Sustainability strategy
• (b) Engaging with affected stakeholders: Stakeholder engagement and thought leadership; Supply chain management
• (c) Identifying and assessing adverse impacts: Double materiality assessment; ESG due diligence
• (d) Taking actions to address adverse impacts: Sustainability strategy; ESG due diligence; Climate change; Own workforce; Client centricity; Culture, integrity and conduct; Anti-financial crime; Competitive behavior; Supply chain management; Data protection; Information security
• (e) Tracking effectiveness and communicating: same chapter set as (d)

Downstream due diligence (clients) is governed by the Summary Framework on Environmental and Social Due Diligence; upstream (suppliers) due diligence sits in "Supply chain management"; own-operations due diligence is covered in "Own workforce" and "Client centricity.

Internal controls over sustainability reporting

Reference: p.215 (Governance – Internal Controls over Sustainability Reporting).

The Management Board is responsible for establishing and maintaining adequate internal controls over sustainability reporting under the oversight of the Chief Financial Officer; the Audit Committee supports the Supervisory Board in monitoring effectiveness.

The primary risk identified is that the Sustainability Statement "may not present a true and fair view due to inadvertent or intentional errors" or is not published on time. Controls comprise preventive, detective and corrective layers across data collection, handling and disclosure, with a four-eyes principle and segregation of duties between producer and reviewer.

Effectiveness is assessed annually using evidence including regulatory audit reports, external auditor reports, and outsourcing-effectiveness reviews. "The Chief Financial Officer was informed of the assessment results ... as of December 31, 2025. No issues were identified that would compromise the completeness and accuracy of the disclosures presented in the Sustainability Statement."

Strategy pillars and business model

Reference: p.222-227 (Sustainability strategy).

Deutsche Bank positions itself as the "Global Hausbank," aspiring to become the "European champion." Its sustainability strategy rests on four pillars: Sustainable Finance, Policies & Commitments, People & Own Operations, and Thought Leadership & Stakeholder Engagement.

Sustainable finance: cumulative sustainable financing and ESG investment volumes reached EUR 471 billion from Jan-2020 to end-2025 (against an original EUR 500bn target, not met on the original 2025 deadline but expected to be surpassed in H1 2026). The target has been raised to EUR 900 billion by 2030, now also including transition financing, plus an ambition to facilitate 300 nature-related transactions by end-2027.

Own operations/supply chain: separate 46% emission-reduction targets by 2030 (2019 baseline) for Scope 1, Scope 2 (market-based) and Scope 3 (categories 1-14); 100% renewable electricity achieved in 2025.

The bank's business model, organizational segments (Corporate Bank, Investment Bank, Private Bank, Asset Management/DWS) and value chain description are incorporated by reference from the "Deutsche Bank Group" section of the Combined Management Report, per the phase-in/incorporation option under ESRS 2 BP-2 §16.

Stakeholder engagement channels

Reference: p.228-231 (Stakeholder engagement and thought leadership).

Core stakeholder groups: clients, employees, investors, policymakers/regulators, media, and NGOs/society. The double materiality assessment is the main mechanism for surfacing stakeholder-relevant topics; the client complaint channel and employee whistleblowing channel provide structured, continuous feedback.

• Clients: engagement via meetings, surveys, branch/hotline feedback (detail in "Client centricity").
• Employees: annual People Survey, exit/pulse surveys, town halls (detail in "Own workforce").
• Investors: written and verbal dialogue on sustainable-finance progress, Transition Finance Framework, governance reporting.
• Policymakers: engagement in 2025 covered Basel III implementation, CSDR, EMIR 3.0, the EU Omnibus Simplification Package/SFDR, and the Digital Euro, among others.
• Media: communications on the EUR 900bn target, the Transition Finance Framework, and the EuroDaT/safeAML anti-money-laundering initiative.
• NGOs: dialogue on climate/fossil-fuel financing, deforestation (Latin America/Amazon) and mining-sector human rights and biodiversity impacts.

Material topics and their IROs (2025 DMA outcome)

Reference: p.219-221 (Double materiality assessment – Material sustainability topics 2025).

Material: ESRS 2 (always); E1 Climate change (adaptation, mitigation, energy); S1 Own workforce (working conditions; equal treatment and opportunities for all); Client centricity (Deutsche Bank-specific, guided by ESRS S4 principles: product responsibility, client satisfaction, client complaint management); G1 Business conduct (corruption and bribery; corporate culture; protection of whistleblowers); plus entity-specific Anti-financial crime (money laundering/sanctions/fraud), Competitive behavior, Data protection and Information security.

Not material (reassessed 2025, unchanged): E2, E3, E4, E5, S2 (workers in the value chain), S3 (affected communities). Newly confirmed not material in 2025: standalone Tax compliance, and Political engagement/lobbying (ESRS G1) — "limited influence on ESG-related legislative developments."

Key IROs: negative impact/risk from financing high-carbon clients without credible transition plans (E1); positive impact/opportunity from working conditions and equal treatment (S1); mis-selling risk (Client centricity); risk from clients tied to corruption, money laundering or tax-evasion facilitation (G1/AFC).

Phase-in: ESRS 2 SBM-3 §48(e) and ESRS E1-9, under the extended phase-in option of Delegated Regulation (EU) 2025/1416.

Double materiality assessment process

Reference: p.217-219 (Double materiality assessment).

Responsibility sits with the Chief Sustainability Office. The 2025 DMA process followed: Preparation -> Identification -> Assessment -> Validation and sign-off -> Disclosure.

• Identification: a long list drawn from all ESRS topics, the 2024 DMA, sector frameworks, ratings questionnaires, NGO publications and peer benchmarking was consolidated into "15 potentially material topics with 46 sub-topics, and 71 sub-sub-topics."
• Assessment: severity/likelihood methodology per ESRS 1; negative-impact severity assessed on scale, scope and irremediability; risk severity/likelihood assessed on a six-step scale via the Operational Risk Rating Grid; a new opportunity grid was introduced in 2025; a human-rights flag gives severity precedence over likelihood for potential severe human-rights impacts.
• Validation: a quantitative materiality threshold of >3 on a five-point scale, with a threshold corridor narrowed in 2025 to 1.7-3.0; validation interviews with seven senior validation managers; final material topics determined by the Chief Sustainability Office.
• Sign-off: four-eyes principle, Senior Confirmation Officers, then approval by the Group Sustainability Committee, the Management Board, and presentation to the Audit Committee of the Supervisory Board.

Stakeholder views were gathered via SME proxies plus direct engagement, including the bank's Nature Advisory Panel (for E2-E5 topics) and NGO dialogue on human rights.

ESRS coverage and phase-in / incorporation-by-reference

Reference: p.205-206 (Basis for preparation – Incorporation by reference; Use of phase-in provisions).

Topical standards reported: ESRS 2 (all GOV/SBM/IRO disclosures); ESRS E1 (E1-1 to E1-7 reported; E1-9 phased-in; E1-8 not disclosed); ESRS S1 (S1-1 to S1-9, S1-12, S1-13, S1-15 to S1-17 reported; S1-10, S1-11, S1-14 not disclosed); client-centricity disclosures guided by ESRS S4 (S4-1 to S4-4 reported; S4-5 not disclosed); ESRS G1 (G1-1 to G1-4 and G1-6 reported; G1-5 not material).

Not material / not covered: ESRS E2, E3, E4, E5, S2, S3.

Incorporated by reference (per ESRS 2 BP-2 §16): the bank's business model and value chain (in "Deutsche Bank Group" section of the Combined Management Report); the roles of the Supervisory Board/Management Board (in the "Corporate Governance Statement"); and the governance/strategy/IRO/metrics for Information security, which are disclosed in the "Information security" section of the Risk Report rather than the Sustainability Statement narrative.

Phase-in used: ESRS 2 SBM-3 §48(e) and ESRS E1-9, both under the extended phase-in option of Delegated Regulation (EU) 2025/1416 adopted by the European Commission in July 2025.

Transition Plan

Reference: p.265-267 (Climate change – Transition Plan; Key enablers and decarbonization levers).

Deutsche Bank targets net zero by 2050. "In compliance with requirement ESRS E1-1, Deutsche Bank hereby discloses that it is not excluded from EU Paris-aligned Benchmarks." The Initial Transition Plan (Oct 2023) was updated in 2025 and covers three decarbonization dimensions: own operations (Scope 1&2), supply chain (Scope 3, categories 1-14), and financing to clients (Scope 3, category 15, ex-DWS).

At year-end 2025, Scope 3 Category 15 (financed emissions, real estate + corporate loans) represented 390.62 MtCO2e — 99.74% of total emissions, making it the primary reduction lever via sectoral net zero pathways.

Deutsche Bank has published 2030 (interim) and 2050 (final) decarbonization targets for eight carbon-intensive sectors: Oil and Gas (Upstream), Power Generation, Automotive (Light Duty), Steel, Coal Mining, Cement, Shipping and Commercial Aviation, using the IEA NZE scenario, Poseidon Principles and the Mission Possible Partnership Prudent Scenario respectively. "In 2025, Deutsche Bank did not incur any material CapEx or OpEx to implement its sustainability strategy and transition plan." An automated Transition Maturity Score for assessing counterparties' transition plans is scheduled for 2026 implementation.

Climate policies

Reference: p.267-268 (Own operations and supply chain – Strategy); p.312 (DWS Coal Policy).

Own operations: governed by the Global Real Estate Engineering Standards, which embed energy-efficiency measures and prescribe renewable-electricity procurement in line with RE100 guidelines; energy management in Germany is ISO 50001 certified.

Financing activities: the Transition Finance Framework (published November 2025, effective January 1, 2026) complements the existing Sustainable Finance Framework. The Sustainable Instruments Framework was updated in January 2026 to add hydrogen, steel and electricity transmission/distribution as eligible environmental categories, one social category (access to basic infrastructure), and to establish a methodology for issuing European Green Bonds (EuGB) under Regulation (EU) 2023/2631.

DWS Coal Policy: governs investment in and funding of thermal coal; restricts in-scope products from coal developers and companies with >25% coal-derived revenue; targets full phase-out of thermal coal exposure from EU/OECD countries by 2030 and the rest of the world by 2040.

Key actions and resources

Reference: p.267-269 (Own operations and supply chain); p.286 (Climate and other environmental risks – Actions and resources).

Own operations: the Eco-Performance Management Office (EcoPMO) ran 86 efficiency-related initiatives in 2025, cutting energy consumption by 123 GWh (-23% year-on-year) and helping the bank exceed its 2025 target of a 30% reduction in energy consumption versus the 2019 baseline (834 GWh); building-operations energy fell 51% versus baseline. 100% renewable electricity coverage was achieved globally in 2025.

Supply chain: the bank requested its largest 500 suppliers to disclose emissions via CDP Supply Chain; 182 suppliers responded, representing 56% of total addressable supplier spend — short of the 80% coverage target, attributed to external factors limiting supplier response.

Financing/risk: dedicated Net Zero Fora (Corporate Bank and Investment Bank divisional fora) assess new lending with a significant impact on financed emissions; risk-appetite thresholds tied to net zero targets are monitored with breaches escalated to the Group Risk Committee and Group Sustainability Committee. "In 2025, Deutsche Bank did not incur any material CapEx or OpEx to implement its sustainability strategy and transition plan."

Decarbonization targets

Reference: p.289-290 (Metrics and targets – Targets related to climate change mitigation).

Own operations & supply chain (SBTi Absolute Contraction Approach, 1.5C-aligned): -46% by 2030 (2019 baseline) for Scope 1, Scope 2 (market-based) and Scope 3 (categories 1-14). 2025 performance: Scope 1 down 66%, Scope 2 (market-based) down 82%, Scope 3 (cat.1-14) down 47% versus 2019 — all at or ahead of the 2030 trajectory.

Financed emissions — 8 sector 2030 interim targets (vs. baseline year, IEA NZE unless noted): Oil & Gas (Upstream) -23%; Power Generation -69%; Automotive (Light Duty) -59%; Steel -34%; Coal Mining -49%; Cement -29%; Shipping and Commercial Aviation targets expressed as percentage-point reductions against Poseidon Principles / Mission Possible Partnership benchmarks. 2025 sector movement: Oil & Gas Scope 1&2 financed emissions down 5.3 MtCO2e/y year-on-year; Automotive Scope 3 financed emissions up 12 MtCO2e/y, driven by a single client's data-quality-driven emission-factor increase.

No intensity-based targets are applied for Scope 1/2/3 (cat.1-14); absolute-reduction targets are used as the primary metric.

Energy consumption and mix

Reference: p.268-269 (Energy consumption and mix).

Total energy consumption fell to 407,989 MWh in 2025, down 23% from 530,917 MWh in 2024. Fossil-source consumption fell only slightly (177,067 MWh vs. 183,986 MWh, -4%), while renewable-source consumption fell more sharply (230,888 MWh vs. 346,563 MWh, -33%) as overall demand contracted — as a result, the fossil share of the (smaller) total energy mix rose to 43% (2024: 35%) even as renewable electricity coverage reached 100%; nuclear-sourced share fell to 0.01%.

Contractual instruments covered 76% of Scope 2 energy consumption (2024: 51%, +48% YoY), split between Green Contracts (19%) and unbundled Electricity Attribute Certificates (57%); Renewable electricity coverage was not possible in Russia and Colombia (0.1% of total electricity consumption) due to the absence of eligible market-based instruments.

Gross Scope 1, 2, 3 GHG emissions (own operations and supply chain)

Reference: p.274-275 (Gross Scope 1, 2, 3 and Total GHG emissions).

The 2030 target requires a 46% absolute reduction across each scope versus the 2019 baseline — all three scopes are at or ahead of the required trajectory. Methodology follows the GHG Protocol Corporate Standard, with 84% of Scope 3 (cat.1-14) emissions in 2025 calculated using primary data. GHG intensity per net revenue rose sharply (location-based: 19,784 tCO2eq/EUR m in 2025 vs. 15,235 in 2024) but is flagged by the bank as "N/M" (not meaningful), reflecting the inclusion of Asset Management financed emissions in the Group total for the first time. Categories 10 (processing of sold products) and 14 (franchises) were assessed as not relevant.

Carbon credits

Reference: p.276 (GHG removals and GHG mitigation projects).

Deutsche Bank purchases voluntary carbon credits to compensate for residual/unavoidable Scope 1, Scope 2, and Scope 3 business-travel emissions only; other Scope 3 categories are not compensated. In 2025 the Group purchased and retired 101,585 tCO2eq of credits across Asia, Africa and Latin America — 17% from removal projects (mainly biochar and nature-based), 83% from avoidance projects. Certification standards used: Gold Standard (75%), Verified Carbon Standard/VERRA (12%), Global C-Sink Registry (8%), Puro Earth (5%), assessed against the Core Carbon Principles (CCP) framework.

"Deutsche Bank does not generate, convert or sell greenhouse gas removals or mitigation outcomes as carbon credits to third parties" and does not develop or finance carbon-removal projects itself; accordingly, ESRS E1-7 disclosures on removal technologies, storage, permanence and reversal risk are not applicable. No credits were carried for future retirement beyond those needed to neutralize current residual emissions.

Policies related to own workforce

Reference: p.319 (Own workforce – Policies related to own workforce).

Policies are set under the global "Policy on Requirements for Policies, Procedures, Key Operating Documents and Frameworks" and approved by the Global Head of HR (reviewed at least annually). Deutsche Bank "voluntarily endorses and aligns with the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the ILO's Core Labour Standards, and the UN Global Compact," anchored in the bank's Statement on Human Rights (approved by the Management Board, signed by the CEO) and its Code of Conduct (100% training completion rate in both 2025 and 2024).

In 2025 the Hiring Policy, Background Screening Policy, Workforce Referral & Connected Candidates Policy and Offboarding Policy were consolidated into a single Hiring, Onboarding and Offboarding Policy; the Contingent Worker Resource Policy was likewise revised. Workers' representatives are consulted on material policy revisions, e.g. via German works agreements (Betriebsvereinbarungen).

Engagement channels

Reference: p.321-322 (Processes for engaging with own workforce and workers' representatives about impacts).

The central channel is the voluntary, confidential annual People Survey, which in 2025 achieved its highest participation rate since 2011 at 69% (2024: 65%); commitment score rose to 68% and enablement to 71% (+1pp each). The Culture Pulse Survey runs three times a year and produced a Culture Pulse Index of 72.05%, against a 2025 Group target of 61.97%. A new "Your Direct Line to the Board" format launched in 2025, letting employees pose questions directly to Management Board members.

Workers' representatives: in Germany (39.8% of the global workforce) the Works Constitution Act governs works councils, which negotiated several group works agreements in 2025 (performance/compensation framework, part-time and home-office arrangements). Employees are also represented via the European Works Council (established 1996).

Remediation and Speak-up channels

Reference: p.322-323 (Processes to remediate negative impacts and channels for own workforce to raise concerns).

Governed by the "Speak-up and Whistleblowing Framework" and the Raising Concerns (including Whistleblowing) Policy (ownership moved from Compliance to Anti-Financial Crime in 2025). Employees can contact the Whistleblowing Central Function (dedicated staff in Frankfurt and London) directly, by email, or via the multilingual Integrity Hotline, including anonymously where local law allows.

Deutsche Bank "prohibits retaliation in any form," backed by an anti-retaliation framework and a biweekly Anti-Retaliation Advisory Group. Investigations follow the Handling of Internal Investigation Key Operating Document. A global Human Rights Forum, co-chaired by the Heads of Group Sustainability and Human Rights, oversees human-rights-related concerns. Additional listening channels: Exit Survey and New Joiner Survey (at 30/90 days).

Actions taken

Reference: p.320 (Own workforce – Actions in relation to own workforce).

Actions span global programs (learning offerings), regional/divisional programs (apprenticeships, childcare in major hubs) and group-specific programs (leadership development, acceleration programs for top talent). Named initiatives include the "35 by 25" gender-representation program, the Global Neurodiversity Working Group (launched 2025), the dbPride LGBTQI+ Employee Resource Group (25th anniversary in 2025), and expanded well-being support — the number of Mental Health First Aiders rose to 807 (2024: 737). Restructuring is managed via German-law social plans providing tailored coaching and internal redeployment support; a collective bargaining agreement excludes operational dismissals for former-Postbank employees until December 31, 2027.

Workforce-related targets

Reference: p.223-224, p.320-345 (Sustainability strategy; Own workforce chapter, various).

• Culture Pulse Index: 2025 target 61.97% — achieved 72.05%.
• Gender diversity (MB-1/MB-2): 30% by year-end 2025 — Supervisory Board met at Group level, MB-2 reached 28.2%; goal extended to 32.5% by year-end 2026.
• "35 by 25": 35% women among global MD/Director/VP population (ex-DWS) by year-end 2025 — reached 34.1% (+4.2pp since 2021).
• Black heritage representation (UK): >30% increase versus the 2021 baseline of 3.0% by December 31, 2025 — achieved 4.0% (2024: 3.7%), a 30% increase, meeting the goal.
• Renewable electricity / energy efficiency targets sit under E1 but are cross-referenced as part of the "People & Own Operations" pillar.

Employee headcount

Reference: p.324-326 (Characteristics of Deutsche Bank's employees).

Total headcount: 95,980 (Dec 2025) vs. 95,898 (Dec 2024), essentially flat (+0.1%); increases in India and Romania offset reductions in Germany. Gender split: 46.4% female / 53.6% male (2024: 46.5%/53.5%).

Top locations (Dec 2025 vs Dec 2024): Germany 38,191 (39.8% of total, down from 40,308/42.0%); India 24,563 (25.6%, up from 22,578/23.5%); Great Britain 7,750; United States 7,716; Italy 2,905; Spain 2,382; Romania 2,076 (up from 1,799). Germany and India together represent roughly two-thirds of the global workforce. Roles are differentiated into managerial/non-managerial and client-facing/non-client-facing categories.

Non-employee workforce

Reference: p.328 (Characteristics of non-employees in Deutsche Bank's own workforce).

Non-employees (self-employed individuals or people provided by third-party undertakings, mainly on time-and-material contracts) totaled 9,603 FTE at year-end 2025, up 3,234 (+50.8%) from 6,369 in 2024 — the report attributes the jump mainly to reclassifying IT vendors from fixed-price to time-and-material contracts. Breakdown (FTE, 2025 vs 2024): IT Vendor Resource (T&M) 6,452 vs 2,219; Non-IT Contractor 1,296 vs 1,484; Non-IT Temporary Admin & Clerical 678 vs 1,017; Non-IT Other Professional Services 288 vs 521; Non-IT Banking/Outsourced Services 742 vs 881; IT Contractor 148 vs 248. Governed by the revised Contingent Worker Resource Policy.

Collective bargaining and social dialogue

Reference: p.333 (Collective bargaining coverage and social dialogue).

Global collective bargaining coverage: 28.6% of employees, reflecting that roughly half the workforce is in countries without collective bargaining agreements. European Economic Area coverage: 56.3%. For countries meeting the ESRS S1 "significant employment" threshold (>=50 employees, >=10% of total): Germany 53.4% (2024: 55.7%), including civil servants; India 0% — "none of the employees ... were affiliated to any union in India in line with market practice."

Workplace representation (Germany, EEA): 96% of employees covered by works councils/agreements plus 4% by the executive-employee Sprecherausschuss — 100% of German employees covered by employee representation (unchanged from 2024). Employees are additionally represented via the European Works Council.

Board and workforce diversity

Reference: p.344 (Gender diversity); p.345 (Building an inclusive culture).

Supervisory Board: 7 of 20 members (35%) were women at year-end 2025, unchanged from 2024, against a 30% statutory requirement (German Gender Quota Law, FüPoG I). Management Board: 2 of 9 members (22%) were women (2024: 2 of 10, 20%), which the bank states is "above the requirements of the current German Gender Quota Law" (FüPoG II).

Workforce is described as multicultural: "160 nationalities represented across 55 countries in 2025." The diversity and inclusion strategy rests on five pillars (leadership accountability, adapting processes, behavioral change, thought leadership, legal compliance) and is endorsed by the Management Board. Top management level for ESRS S1-9 purposes is defined as the Management Board itself.

Employees with disabilities

Reference: p.345-346 (Building an inclusive culture where everyone is treated fairly).

2,720 employees with disabilities at year-end 2025 (2024: 3,057) — 1,571 female / 1,149 male (2.8% of total headcount, down from 3.2%). In Germany, 2,185 employees with disabilities (5.7% of German headcount; 2024: 2,511 / 6.2%), disclosed under Germany's Social Code IX; the year-on-year reduction of 337 (326 of them in Germany) is attributed mainly to retirements. The bank notes measurement is limited by voluntary self-disclosure and data-protection law (GDPR). Support includes accessible workstations, reasonable accommodations, universal-design offices, and a longstanding cooperation with the Association of Sheltered Workgroups (GDW) in Germany.

Training and performance reviews

Reference: p.334 (Talent development); p.338 (Performance reviews).

Training expenses: EUR 43.4 million in 2025 (2024: EUR 37.6 million), or EUR 483 per FTE on average (2024: EUR 417) — based purely on external vendor spend. Trainings are offered equally to full-time and part-time employees across classroom, e-learning, video/podcast and virtual formats.

Performance reviews: the overall completion rate held at 90% in both 2025 and 2024 (Female 89%, Male 92%), calculated across the entire employee population including staff out of scope for the process (e.g. long-term leave), which the bank notes structurally caps the rate below 100%. Deutsche Bank has held ISO 30414 Human Capital Reporting certification for five consecutive years.

Work-life balance

Reference: p.339 (Work-life balance; Family-related leave).

96% of employees were entitled to family-related leave in 2025 (unchanged from 2024). Of entitled employees, 19.8% took leave in 2025 (2024: 17.1%) — female 21.1% (2024: 18.7%), male 18.7% (2024: 15.8%). The bank operates more than 850 employee benefit plans globally (life insurance, healthcare, disability cover, parental leave, retirement, childcare support, etc.).

Hybrid working model: in place across 43 locations, covering approximately 84,000 employees, allowing up to two remote days per week depending on role, subject to divisional and country guidelines (excludes roles needing continuous on-site presence, e.g. certain retail branch functions).

Remuneration ratio and pay gap

Reference: p.338-339 (Annual total remuneration ratio; Gender diversity — Gender pay gap).

Annual total remuneration ratio (highest-paid individual vs. median of all other employees): 246 in 2025 (2024: 237); on an average-employee basis the ratio was 166. The increase reflects a rise in the highest-paid individual's remuneration while the median remained broadly stable; the highest-paid employee "is not the CEO." The bank "acknowledges that there is more work needed to reduce the unadjusted and adjusted gender pay gap" and expects its diversity initiatives (including the MB-1/MB-2 gender goals) to narrow the gap over time; specific pay-gap percentage figures were not found quoted in the extracted text.

Incidents and complaints

Reference: p.347 (Incidents and complaints).

2025 (vs 2024): 70 incidents of discrimination, including harassment, upheld or partially upheld (2024: 57) — less than 0.1% of total employees; 252 additional complaints of discrimination/harassment/working conditions (2024: 202) not upheld or still in process — less than 0.3% of employees; EUR 0.91 million in fines, penalties and compensation for damages (2024: EUR 0.25 million). Zero complaints were submitted to National Contact Points for OECD Multinational Enterprises in either year. Complaints are handled via the bank's global case-management system, Employment Relations review, and can lead to disciplinary action ranging from warnings to dismissal.

Product responsibility policies

Reference: p.352-353 (Client centricity – Product responsibility).

Deutsche Bank interprets "Consumers and End Users" under ESRS S4 as equivalent to its Private Bank clients, retained as the bank-specific topic "Client centricity," refined in 2025 into sub-topics: product responsibility, client satisfaction, client complaint management.

Key policies: the Suitability & Appropriateness (Client & Product) Policy (MiFID-aligned; minimum standards for suitability/appropriateness assessments, applies bank-wide ex-DWS, equivalent policy at DWS); the Communications with Clients/Public and Marketing Materials Policy (fair, clear, non-misleading marketing); and the Conflicts of Interest Policy. New-product approval and periodic product-review processes are overseen by the New Business Office and Product and Structured Transactions Lifecycle teams, with products sponsored by an accountable business managing director.

Client engagement / satisfaction measurement

Reference: p.354-355 (Client satisfaction, by division).

• Corporate Bank: Corporate Cash Management client surveys since 2018 (1,600+ clients in 2025), extended in 2025 to Trust & Securities Services.
• Investment Bank: Broker Reviews and direct client feedback via Fixed Income & Currencies coverage teams.
• Private Bank: Net Promoter Score (NPS) is the primary metric. U/HNW Wealth Management global NPS 75 (2024: 71), ~80% Promoters (2024: 75%); Deutsche Bank brand (Germany, ex-U/HNW) NPS 62 (2024: 67) from 173,500+ responses; Postbank brand NPS improved to 22 (2024: 13); Spain NPS 15 (2024: 12); Belgium NPS 12 (2024: 10).
• Asset Management (DWS): annual top-client NPS survey (300+ clients in 2025) scored 63 (2024: 53).

Client complaint-handling framework

Reference: p.356 (Client complaint management).

Governed globally by the Client Complaints Policy and Client Complaints Procedure, aligned with the joint ESMA/EBA Guidelines for complaints-handling and BaFin's interpretation; each business unit appoints a global head of complaint management. Complaints can be raised in branch, by email, online or phone; increased-risk complaints (potential significant harm, alleged criminal activity) are escalated promptly. Metrics tracked include volumes raised/closed, average handling time and paid redress over consecutive quarters. DWS clients/investors can also escalate to the Ombudsman of the BVI or BaFin, and a civil complaint can be filed at any time; DWS defines a "material risk" complaint threshold at EUR 50,000+ potential loss or allegations of market manipulation, fraud, bribery or corruption.

Complaint trends by division (2025 vs 2024)

Reference: p.357-359 (Client complaint management, by division).

• Corporate Bank: complaints down 3%; a temporary rise occurred in Corporate Bank Germany tied to Digital Upgrade/Online Banking migration.
• Investment Bank: complaints down 0.5%; key drivers were operational issues, trade execution and service matters.
• Private Bank: complaints down 20% overall — Germany -19% (fewer Postbank-migration issues), Spain -57% (fewer mortgage-fee-repayment claims), Belgium -5%, but Italy +12% (KYC remediation program) and India +11% (payments-related complaints, improving by Q4 after remediation).
• Asset Management (DWS): complaints up 3.6%, "no exceptional incidents reported," mostly from retail fund investors.

Aspirational culture, Code of Conduct, whistleblowing

Reference: p.361-366 (Culture, integrity and conduct).

Deutsche Bank's culture message, "Empowered to excel together every day," rests on four guiding principles and sixteen critical behaviors, overseen by the Culture, Integrity and Conduct Committee (co-chaired by two Management Board members; 15 voting members, 5 women).

The Code of Conduct (updated 2025) had >99% employee completion; the annual Culture, Integrity and Conduct book of work drives divisional Culture Plans — streamlined from 74 initiatives (2024) to 47 (2025). The Speak-up and Whistleblowing Framework (policy ownership moved to Anti-Financial Crime in 2025) is supported by the Whistleblowing Central Function and Integrity Hotline.

Whistleblowing cases opened by region in 2025: Germany 34% (2024: 35%), APAC 26% (22%), UK & Ireland 15% (17%), Americas 13% (13%), Europe ex-UKI 10% (11%), Middle East & Africa 1% (2%). Substantiation rate: 51% of closed cases (2024: 52%).

Supplier relationship management

Reference: p.376-377 (Supply chain management – Governance, Strategy).

The "Supply chain management" chapter was relocated from General information to the Governance section for 2025, "underscor[ing] the central role of governance in overseeing supply chain management." Oversight sits with Global Procurement and Vendor Management, coordinated with the Chief Sustainability Officer; the Third-Party ESG Oversight Forum (Operational Risk Management, Group Legal, Global Procurement, Chief Sustainability Office) coordinates third-party sustainability risk oversight.

Supplier relationships are governed through the Third-Party Risk Management (TPRM) lifecycle (due diligence, onboarding, contracting, post-deal monitoring) under the Supplier Code of Conduct. Deutsche Bank founded and chairs the Finance Initiative for Sustainable Procurement (FISP) Peer Group (facilitated by Accenture). A supplier ESG-score KPI is tracked internally but was excluded from 2025 external reporting scope, "reflecting the outcome of the Double Materiality Assessment, which determined that the KPI is not material for the upstream value chain."

Anti-bribery and corruption program

Reference: p.371-372 (Anti-financial crime – Prevention and detection of fraud, corruption, and bribery; Metrics and targets).

Governed by the Anti-Bribery & Corruption Policy within the Financial Crime Risk Management Framework; the Anti-Financial Crime function had 2,058 employees at year-end 2025 (2024: 2,052), supported by ~578 contingent workers (2024: ~440). Deutsche Bank performs an annual bribery/corruption risk assessment covering gifts/entertainment, charitable donations, client onboarding, hiring, joint ventures and vendor risk.

Training completion (2025 vs 2024): anti-bribery and anti-corruption 96.51% of 111,231 staff (2024: 99.88% of 103,112); anti-money-laundering/counter-terrorist-financing 99.44% of 109,577 (2024: 99.82%); prevention of facilitation of tax evasion (2-year cycle) 99.71% of 50,675 (2024: 99.98%); sanctions and embargoes 99.18% of 65,500 (2024: 99.52%).

Convictions and fines

Reference: p.372 (Anti-financial crime – Convictions and fines related to violations of anti-corruption laws).

"In 2025, there were no convictions for violations of anti-corruption and anti-bribery laws either disclosed to Deutsche Bank by its employees or where Deutsche Bank has assumed the legal costs of underlying proceedings. In 2025, there were no fines levied against Deutsche Bank for violation of anti-corruption or anti-bribery laws." Potential instances are independently investigated with disciplinary consequences ranging from training/red flags to termination of employment, under the bank's holistic Fraud Risk Management framework spanning all three lines of defense.

Payment practices (voluntary disclosure)

Reference: p.379 (Supply chain management – Payment statistics).

Deutsche Bank "voluntarily discloses its payment statistics," based on 465,577 invoices reviewed in 2025 (2024: 396,046). Suppliers with <EUR 100k annual spend: 93% of payments aligned with the standard 0-30 day payment term. Suppliers with >=EUR 100k annual spend: contractual standard terms are <=60 days (EU) or <=90 days (rest of world); 100% of these suppliers' payments were aligned with their respective contractual terms in both regions. DWS follows equivalent payment governance and is reported separately under an Asset Management column.