Help us protect our values

Which kinds of reports should be submitted?

Concerns about possible violations can be raised about matters that have occurred, are ongoing, or are likely to occur. You do not need full knowledge of the matter, it is sufficient for you have reasonable grounds for your concerns and wish to make a report in good faith.

Possible violations include, but are not limited to concerns regarding:

• Laws, rules and regulations applicable to DB Group, any person acting for or on behalf of DB (employee, contingent worker or other) or any activity of DB Group;
• DB Group’s internal policies and procedures including the Code of Conduct, suspected integrity issues and/or unethical behaviour. This may include, and is not limited to, suspected fraud, theft, document falsification, inappropriate disclosures of customer or company information, and Retaliation for raising a possible violation or for participating in an investigation of a possible violation;
• Corporate accounting practices, internal accounting controls or auditing matters, including according to the Sarbanes-Oxley Act (‘SOx’);
• Possible human rights violations including a material risk of exploitation of individuals (including child labour or forced labour) in DB Group’s supply chain or relating to DB’s own business practices;
• Behaviour that harms or is likely to harm the reputation or financial wellbeing of DB Group;
• In relation to the activities of DB Group, a miscarriage of justice; putting the health and safety of an individual in danger; damage to the environment; and
• Any deliberate concealment of any of the above possible violations.

What is the process for submitting a report?

To submit an anonymous or personalized report, start by clicking the “Submit report” button located on the top of our introduction page.

The reporting process consists of 2 steps:

• You are first asked to read a text about the protection of your anonymity (where provided for by national law) and answer a security query.
• On the following submission page, please phrase your report in your own words and answer questions about the case. You can enter up to 5,000 characters of free text, which corresponds to one full page.
  You can also send a supporting file of up to 5 MB in size. But keep in mind that documents can contain information about their author (in their content or in the meta data of the file). Following the sending of your report, you will receive a reference number as confirmation that you have sent this report.

How do I receive feedback and remain anonymous at the same time?

The overriding principle of the BKMS^® procedure used here is the protection of the whistleblower. The functional preservation of anonymity has been certified by an independent authority.
Therefore, you can set up your own secured postbox after submitting your report, allowing you to communicate on an anonymous basis. When setting up your secured postbox, please select your own pseudonym/user name and password. Please keep a record of these details as they will be necessary to allow the operative to communicate with you further on a confidential basis. Your report is kept secure by means of encryption and other special security routines. At no point during the reporting process will you be asked for personal information, unless you are forwarding a report of another person.
Using your secured postbox which you can reach directly via the "Login" button, an examiner will send you feedback about the handling of your report or, if any details are unclear, ask you questions.
As long as you yourself do not enter any data that allow for conclusions about your person to be drawn, the BKMS^® System will protect your anonymity technologically.
Deutsche Bank is interested in reports that protect the company from harm, not in you as a whistleblower. When forwarding a report of another person, you must disclose your own name, but not that of your source.

What other options do I have for the submission of a report if I do not want to use this tool?

Submit reports via telephone
We are also happy to receive reports about possible violations over the telephone. You can find a button "Submit report via telephone" on the website as an additional channel of communication. You will be guided through an automated telephone dialogue. During this process, you can describe the incident in detail and are asked to answer a few questions about the situation.
The information you provide will be handled in confidence and only shared on a need to know basis in order to respond to the content of the report.
At the end of the report submission process, you can set up a secured postbox. You will receive feedback from us via this postbox, can use it to answer questions, and will receive information about the outcome of your report.

Reporting to other points of contact within the bank
Possible violations can also be reported directly to a manager (including outside of your reporting line), head of department or to representatives in other functions e.g. Compliance, Legal, HR and Anti-Financial Crime.
If for any reason you are uncomfortable contacting one of the persons or departments mentioned above, or if your request has not been followed up to your satisfaction, you are encouraged to use the electronic or telephone report submission systems.

Reporting to External Bodies
There are no limitations to the rights of a whistleblower reporting a possible violation to a government agency or regulatory authority. Reports of this kind do not require any prior permission from Deutsche Bank, and there is no obligation to alert Deutsche Bank to the submission of such reports.

What happens to reports submitted here?

The submitted reports are confidentially assessed by the Deutsche Bank Whistleblowing Central Function, to determine if the report qualifies as a Possible Violation as defined by section 3.1 Raising Concerns (including Whistleblowing) Policy. Qualifying reports will be created into a whistleblowing case and allocated to an internal investigative function for appropriate action. If a postbox facility has been selected, the Whistleblowing Central Function will inform you when the case is closed.
Reports which do not qualify as whistleblowing, will be processed as confidential non-qualifying matters and forwarded to relevant functions for appropriate action.

In my capacity as a manager or representative of a department, how do I act when an employee reports an incident to me?

Any report you receive from an employee must be forwarded in accordance with the Raising Concerns (including Whistleblowing) Policy of Deutsche Bank. By documenting the report in this system, using the button "Forward report", you are meeting this obligation.

Please comply with the following when entering a report:

• The name of the whistleblower must be protected. This means that you must not disclose the name of the whistleblower, outside of this reporting channel.
• You cannot forward the report anonymously, because examiners may need to approach you for further inquiries.
• Document all information that you have received from the whistleblower in this system. Once you have forwarded the report, responsibility to allocate the matter for investigation lies with the Whistleblowing Central Function. Do not attempt to investigate by yourself.

If you neglect to forward a report in a suitable manner, this may lead to disciplinary action – as set out in the Code of Conduct – up to and including termination of employment or contract for services, in accordance with local laws.