AmazonScience/document-haystack

1Compliance and Control2[Anti-Financial Crime and Compliance]3GRI 2-27; 3-3; 205-24Highlights5– An effective Anti-Financial Crime (AFC) and Compliance organisation safeguards our 6license to operate and addresses regulatory, reputational and operational business 7interests. It is essential to prevent financial crime and protect our clients, society and the 8Group.9– The development of sustainability risks and factors and their integration into existing 10processes continued in order to meet changing legal and regulatory requirements in 2023.11– Identifying and appropriately managing conflicts of interest is crucial to preventing adverse 12consequences for our customers, the Group and our employees.13– Our antitrust compliance programme and training aims to prevent or mitigate breaches of 14anti-trust laws.15Organisational Structure16The Executive Board is ultimately responsible for the management and mitigation of financial 17crime risks within the Group. It has delegated tasks relating to those obligations to the AFC 18and Compliance function. Our AFC and Compliance organization is part of the Chief 19Administrative Office and maintains close contact with the AFC and Compliance function of 20Deutsche Bank Group.21Risk Management22AFC and Compliance risks are part of the non-financial risk framework alongside liquidity-, 23financial and strategic risk. AFC and Compliance is the second line of defence control 24function, managing and mitigating the financial crime risks assigned to it in the non-financial 25risk management taxonomy.26Non-compliance with relevant laws and regulations and an inadequate control framework 27could expose us to significant legal, regulatory and reputational risk with a financial impact. 28Control management and execution is one cornerstone of the AFC and Compliance risk 29management framework as controls offer insights into risk trends and patterns and therefore 30enable us to manage risks and stay within risk appetite. Therefore under the AFC and 31Compliance risk management framework we monitor and assess our risk profile against the 32agreed risk appetite and the effectiveness of our risk mitigating controls.33Every employee is responsible for the prevention, detection, and reporting of internal and 34external fraud as well as bribery and corruption in connection with our business. We require 35all employees to conduct themselves with the highest standards of integrity and to follow the 36correct procedures if they believe that something is not right. A speak-up culture is essential 37to maintaining a positive compliance culture in which everyone not only adheres to our 38policies, but also adheres to applicable laws and regulations in all jurisdictions whilst offering 39a safe environment for employees to raise issues. Our anti-fraud policy applies to all 40employees, permanent and temporary, and explains how to immediately escalate any known 41or suspected fraudulent incident or any concern via our whistle-blower tool or hotline that 42protects the identity of the individuals raising the incident or concern. We take a zero-43tolerance approach to bribery and corruption in line with our Code of Conduct, our values and 44beliefs, and national and international laws and regulations. The Anti-Bribery and Corruption 45Policy sets out the minimum standards of behaviour expected of all employees and third 46parties as well as the minimum safeguarding measures to be implemented. Any non-47compliance with the anti-fraud as well as the anti-bribery and corruption policies will lead to 48consequences for the respective individuals.49Management Approach50The fight against financial crime is vital to ensure the stability and integrity of the 51international financial system. Failure to identify and manage risks relating to financial crime 52exposes us and our staff to potential corporate criminal and/or regulatory liability, civil 53lawsuits, financial losses, and reputational damage.54During 2023 we did not identify or report any material breaches of laws and regulatory 55requirements in relation to fraud, bribery, or corruption.56As a global asset manager, an effective compliance culture is key for safeguarding client 57assets. This includes the Compliance risk management processes such as risk identification, 58risk assessment and evaluation, risk monitoring and mitigation as well as a clear responsibility 59across all three lines of defence. This also includes communication, training and compliance 60with standards of behaviour which we expect our employees to adhere to. 61        62To our Shareholders Summarised 63Management Report64Consolidated 65Financial Statements Compensation Report Corporate Govern-66ance Statement67Supplementary 68Information DWS 2023 Annual Report69 70Compliance and Control7158 Anti-Financial Crime and Compliance72The secret shape is a "triangle".