To inform our approach to sustainability and our non-financial reporting, we identify topics deemed material by our internal and external stakeholders. In doing so, we are guided by the international sustainability standard of the Global Reporting Initiative (GRI). We consider the opinions of our stakeholders, and we analyze relevant sources—for example, topics discussed at our Annual General Meeting (AGM), the thematic components in sustainability ratings, internal and external media reports, and insight from competitor analyses. The topics in this Non-Financial Report reflect the results of the GRI materiality analysis, which has already been carried out in recent years. In 2017, we reviewed the list of material topics and re-categorized certain topics to make them more visible and understandable, and to give due consideration to what is required by the new requirements of the German Commercial Code (Handelsgesetzbuch, HGB) on the disclosure of non-financial information. In addition, we bundled ESG-related products, namely "social investments" and "impact investments", under "products and services" and we also clarified titles.
All topics that are relevant to understand the impacts of Deutsche Bank’s activities on the non-financial aspects are covered in this Non-Financial Report and are managed accordingly.
In accordance with § 315b (3) sentence 1 HGB, the Non-Financial Statement (which legally is referred to as separate Non-Financial Group Report) is part of the Non-Financial Report and is marked by a bracket in the margins throughout this Non-Financial Report. To identify the topics to be marked as part of the Non-Financial Statement, we have adapted our approach to materiality. According to §§ 315c in connection with 289c (3) HGB, for a topic to be marked as part of the Non-Financial Statement, it is additionally required that the information about the topic is necessary for understanding Deutsche Bank's situation (profit situation, net asset and funding position) and development. In order to assess this additional materiality criterion, we conducted interviews with the respective business divisions and infrastructure functions. On the basis of the assessment of non-financial risks, which includes an impact assessment on Deutsche Bank’s profit situation, net asset and funding position, an initial classification was made. This was supplemented by discussions with the internal subject matter experts for the non-financial topics who have confirmed this assessment or added new arguments to rethink the results.
As the assessment approach is not fully comparable to the one in the previous year, we are not presenting the topics in a materiality matrix this year (table below).
According to §§ 315c in connection with 289c (3) no. 3 and 4 HGB, Deutsche Bank is required to report on all known significant risks in connection with its own business activities and business relations, as well as its products and services that are very likely and have or will have a severely negative impact on material non-financial topics. No such risks were identified.
A description of the business model of Deutsche Bank Group according to §§ 315 (1) in connection with 289c (1) HGB can be found in the Group Management Report. The description of the business model is part of Deutsche Bank’s separate Non-Financial Statement.
As matters related to the environment and human rights at Deutsche Bank do not fulfil the materiality criteria of §§ 315c in connection with 289c HGB, we disclose relevant information such as our management approach, as well as results on matters related to environment and human rights, in our Non-Financial Report outside of the Non-Financial Statement.
We monitor all non-financial topics and their impacts on Deutsche Bank’s situation and development closely in order to be able to identify changes of materiality and disclose them accordingly in future reports.
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Materiality assessment for 2017 |
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Matters according to the EU CSR Directive |
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Relevant areas of activity |
Non-Financial Statement |
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Environmental matters |
In-house ecology |
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Boundary: internal and external |
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Environmental and social matters |
Climate risks |
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Boundary: internal and external |
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Environmental and social issues |
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Sustainable products and services |
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Social matters |
Client satisfaction |
Client satisfaction |
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Boundary: internal and external |
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Product suitability and appropriateness |
Product suitability and appropriateness |
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Complaint management |
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Data protection and data privacy |
Data protection |
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Corporate citizenship |
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Human-rights-related matters |
Human rights |
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Boundary: external |
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Employee-related matters |
Talent management |
Talent acquisition and development |
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Boundary: internal |
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Employee commitment |
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Compensation and benefits |
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Board diversity* and employee-related matters |
Diversity |
Gender diversity |
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Boundary: internal |
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Anti-corruption and bribery issues |
Anti-financial crime |
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Boundary: internal and external |
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Further DB related material topics |
Digitalization and innovation |
Digitization and innovation |
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Boundary: internal and external |
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Culture and conduct |
Culture and Conduct |
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Information security |
Information security |
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Public policy and regulation |
Regulatory change |