In 2017, we took further steps to strengthen how we respond to regulatory change and leverage synergies within the bank. This included merging our Regulatory Affairs, Group Structuring, and the Government & Public Affairs unit, which now work in close cooperation, reporting to the Global Head of Government & Public Affairs and Group Structuring and, ultimately, ito the Group Chief Regulatory Officer. Through these units, we identify relevant political and regulatory developments at an early stage and coordinate Group policy positions accordingly. Our vision is to ”ensure preparedness for critical regulatory change and simplify the Group, supporting Deutsche Bank’s strategy.” Our aim is to ensure both compliance with relevant political and regulatory requirements (inbound) as well as to include industry-relevant topics in public discussions (outbound). Our Government & Public Affairs offices in Berlin, Brussels, and Washington, D.C. manage our relationships with key policy makers and provide them with information and data to further inform the policy-making, while setting out the bank’s business strategy and its determinants. In addition, we liaise with our Chief Regulatory Office (CRegO) colleagues in the Beijing office to cover China.
We define a set of key topics that will inform our focus in the following twelve months. In 2017, these related to the German G20 presidency, the digitization of banking and society, the renewal of the Euro zone, Brexit, and the green / sustainable finance agenda. On each issue, we convened and participated in seminars, public panels, and individual conversations with policy-makers.
The risk of changing rules and regulations is inherent to our daily business. To address this adequately, we have developed a holistic framework to identify and implement new or changed regulations using a systematic approach that prioritizes significant regulatory risks to Deutsche Bank and allocates clear accountability for the identification, impact assessment and implementation of regulatory changes.
The framework governs how we manage regulatory change risk and helps to build our profile in regulatory policy debates, so that we engage constructively with regulatory stakeholders. It also ensures informed strategic decision-making and provides oversight and control over how key initiatives are implemented, as well as insight for senior management on upcoming issues of public policy. To further contribute to the policy-making process, we provide political and regulatory stakeholders with information and data that set out our business strategy and determinants.
We set clear rules and procedures for interactions between our employees and external political and regulatory stakeholders. All staff must adhere to our global “Gifts, Entertainment and Business Events Policy,” which regulates the conduct and recording of any gifts and event participations offered by or accepted by Deutsche Bank representatives. For interactions with EU institutions, our policy “Pre-Clearance of All Communications with EU Institutions to Discuss Policy Issues” is mandatory, ensuring a consistent communication at EU level and that all contacts to EU officials are centrally cleared. In the US we act in line with our internal policy regarding “Political Contributions in the US and US Lobbying Activities.”
We are signatory to the EU Transparency Register, which requires us to disclose certain financial information and comply with a code of conduct. In the US, we are registered with the Office of the Clerk of the Senate and the office of the Clerk of the House of Representatives and file a quarterly disclosure on all legislative issues with the Office of the Clerk of the House of Representatives.