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Forwarding a report of another person

The following pages are intended for executives and other management representatives of the Deutsche Bank who are receiving a report about a possible violation. You are obliged to forward reports about possible violations to the Central Function in accordance with the process set out in detail in the Raising Concerns (including Whistleblowing) Policy. By documenting the report in this system, you are fulfilling your obligation. If you neglect to forward a report in a suitable manner, however, this may lead to disciplinary action – as set out in the Code of Conduct – up to and including termination of employment, in accordance with local laws.
Also verify whether you are additionally obliged to report a suspicion to the responsible supervisory authority in accordance with the relevant anti-money laundering legislation, or due to a suspicion of market abuse/insider trading.

Anonymity

You cannot forward the report anonymously, because examiners may need to approach you for further inquiries.

Report

Document all information that you have received from the whistleblower in the 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.

Retention of documents

Please note that the information you have received and your reaction (especially in e-mails) may have to be disclosed at a later stage (e.g. towards internal or external stakeholders or in the context of legal proceedings).
Mark your documents as confidential. When you forward details about the possible violation, do not disclose the identity of the whistleblower outside of this reporting channel.

Prohibition of retaliatory measures

If a possible violation is reported to you, you must not initiate any retaliatory measures against the person who has reported this incident. Acts of retaliation are forbidden by Deutsche Bank and can lead to disciplinary action up to and including the termination of employment or contract for services, in accordance with local laws.