AmazonScience/document-haystack

1and includes a comprehensive training and control framework that is designed to identify and 2monitor anti-trust risks to prevent or mitigate breaches of anti-trust laws. 3There were no pending or completed legal actions against us during the reporting period 4regarding any anti-competitive behaviour or violations of antitrust and monopoly legislation in 5which the organization has been identified as a participant. 6Marketing and Labelling7Our governance structure including operational guidelines, defined policies, and our 8corporate values provides a structured framework for all employees that is designed to 9protect our brand and reputation. 10All marketing efforts must be fair, balanced and designed to ensure that risks are reasonably 11disclosed. Such materials are subject to regulatory requirements, which vary depending on 12the entity, product, intended audience, venue where the offer or sale occurs, and other 13criteria. Our employees should not only adhere to these requirements but also use 14professional judgment to present product and marketing content with honesty and 15transparency.16As part of the review process, our marketing and product materials are reviewed and 17approved by Compliance or respective business gatekeepers to ensure that all requirements 18are being followed. Our approval process is designed to ensure that only marketing and 19product material that has been reviewed and approved can be published or distributed 20externally to clients.21We promote responsible employee conduct by regular training events, communication and 22compliance with our Code of Conduct and legal requirements, which is the minimum 23standard for us and seeks to protect our clients’ interests as well as our brand and reputation. 24We also promote the standards of relevant policies and guidelines, our global framework on 25controls of marketing material and for some regions additional marketing policies that have 26been defined based on local requirements.27[Data Protection]28GRI 3-3; 418-129Highlights30– Continually strengthening governance and controls in line with regulatory developments on 31data protection32– Key advice in connection with the engagement of vendors as part of our multi-year 33transformation program34– No personal data breaches with material impact on individuals identified35In most countries where we conduct business there are data protection laws. These are 36derived from the privacy related statements in the EU Charter of Fundamental Rights, the UN 37Universal Declaration of Human Rights and the European Convention on Human Rights. We 38recognize that data protection is an important social value as clients, employees and other 39stakeholders expect that the personal data they entrusted to us is treated with the highest 40care. Therefore, we are committed to protecting personal data and complying with the 41General Data Protection Regulation and similar laws.42Management Approach/Governance43For data privacy, we are supported by Deutsche Bank Group Data Privacy, a specialised, 44independent control function that advises on and monitors the collection, processing, and use 45of personal data by our business divisions and infrastructure functions. As a second line of 46defence function, this team defines data protection principles and sets consistent 47requirements and minimum control standards with respect to data protection to ensure 48compliance with applicable laws and regulations. It is supported by local Data Protection 49Officers in the countries where we conduct business. Our Chief Administrative Officer 50receives an annual report on data privacy.51In 2023, a review and enhancement of the Deutsche Bank Group data protection policy 52framework and governance was initiated that also applies to us. The key data protection 53principles and how to comply with them are being refined in a separate overarching 54framework document. The existing Data Protection Policy is being revised to specify the data 55protection related requirements for employees and role holders in the organization. The 56policy establishes requirements for employees on the usage of personal data, the escalation 57of potential personal data breaches and specific requirements for vendor engagements. 58Further, it provides requirements for business divisions and infrastructure functions to deal 59        60To our Shareholders Summarised 61Management Report62Consolidated 63Financial Statements Compensation Report Corporate Govern-64ance Statement65Supplementary 66Information DWS 2023 Annual Report67 68Compliance and Control6961 Data Protection