AmazonScience/document-haystack

1The Code of Conduct sets out these standards of behaviour and requirements for our 2employees. It is designed to ensure that we conduct ourselves in compliance with law and 3regulation as well as ethically – with integrity, and in accordance with our and Deutsche 4Bank’s policies and procedures. 5As part of our risk management approach, we focus in particular on the following topics:6– Regulatory adherence7– Conflicts of interest8– Anti-competitive behaviours9Public Policy and Regulation10Regulatory reforms in the EU and internationally introduce changing legal and regulatory 11requirements for our clients and us. Failure to comply with laws and regulations applicable to 12us could result in regulatory penalties or fines, harm to our reputation and a material adverse 13effect on the results of our operations. The compliance framework is designed to identify 14such changes, to inform the business promptly and to allocate responsibility for assessing the 15impact of such changes and, where necessary, amending policies and procedures to ensure 16that they are implemented.17Since the risk of changing rules and regulations is inherent to our daily business, we have 18developed a framework to identify and implement new or changed regulations and allocate 19clear accountability for the identification, impact assessment, and implementation.20It helps to build our profile in public policy and regulatory interactions in general, so we 21engage constructively with regulatory stakeholders as well as contribute to informed strategic 22decision-making, provide oversight of key initiatives, and insight for senior management on 23upcoming regulatory changes. 24On a monthly basis, information on new and changed regulations is communicated to the 25business divisions and stakeholders. Within Compliance, a global regulatory practice group 26was established consisting of regional regulatory Compliance experts to provide updates on 27key items in the respective jurisdictions and any potential extra-territorial impact. Information 28on regulatory developments and changes is included in our quarterly reports to management.29How regulatory changes are implemented depends on their complexity and impact of the 30changes. Major regulatory changes such as prudential requirements applicable to investment 31firms are executed through programmes to manage cross-divisional implementation and 32ensure the involvement of relevant stakeholders. 33In 2023, the public affairs and regulatory strategy team provided ad hoc updates on political 34and regulatory developments to senior management, coordinated the development and 35delivery of our positions on important regulatory topics, and acted as a clearing house for 36memberships in trade bodies and business organisations close to political stakeholders.37ESG Regulatory Compliance38GRI 3-339Sustainable Finance Disclosure Regulation, EU Taxonomy Regulation, 40UK Sustainability Disclosure Requirements41In 2023, our primary focus was on the implementation of regulatory requirements derived 42from the Sustainable Finance Disclosure Regulation, with a particular emphasis on the 43statement on Principal Adverse Impacts of investment (PAI Statement) and the periodic 44disclosure for financial products. Other regulatory focal points included the implementation of 45the Taxonomy Regulation, as well as the analysis and initial implementation of upcoming 46regulatory requirements resulting from the Corporate Sustainability Reporting Directive, 47which must be transposed into national law, and UK Sustainable Disclosure Requirements.48A significant milestone was the final implementation and publication of PAI Statements on 4930 June 2023. We continued to enhance our pre-contractual documents, periodic reports, and 50website disclosures on the product level to meet additional requirements of national 51competent authorities, such as Commission de Surveillance du Secteur Financier from 52Luxembourg. As a result, a separate procedures document was released on our products web 53pages that contains details on our ESG data and methodology in relation to those products 54subject to Sustainable Finance Disclosure Regulation. 55In June 2023, we updated our European ESG Template to the latest version 1.1.1. The template 56serves as a standardized framework for exchanging ESG data between product manufacturers 57and distributors. Developed by FinDatEx in cooperation with market associations for the 58banking, fund, and insurance sectors, it aligns with data definitions specified by relevant EU 59legislative acts, including Sustainable Finance Disclosure Regulation, EU Taxonomy 60Regulation, the amended European Union Markets in Financial Instruments Directive II and 61Insurance Distribution Directive. 62Besides product and legal entity disclosures, we have provided key performance indicators 63related to taxonomy alignment at group level within the Annual Report. This requirement 64stems from the EU Taxonomy Regulation Article 8 – for more details, please refer to the 65section ‘Complementary Information – Disclosures in Accordance with Article 8 Taxonomy 66Regulation and Delegated Regulation (EU) 2021/2178’. 67        68To our Shareholders Summarised 69Management Report70Consolidated 71Financial Statements Compensation Report Corporate Govern-72ance Statement73Supplementary 74Information DWS 2023 Annual Report75 76Compliance and Control7759 Anti-Financial Crime and Compliance