Deutsche Bank AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Deutsche Bank AG demonstrates a structured approach to sustainability governance, with mechanisms such as the Group Sustainability Committee and the Net-Zero Forum overseeing sustainability-related decisions and transactions. The Group Sustainability Committee, chaired by the CEO, ensures alignment of sustainability strategies with corporate goals and provides oversight of sustainability strategy implementation. The Net-Zero Forum, established in 2022, reviews high-impact transactions in carbon-intensive industries and assesses their alignment with net-zero targets, demonstrating a focus on environmental considerations. Additionally, the Environmental and Social Policy Framework outlines due diligence processes for environmental and social risks, with escalation procedures to the Group Reputational Risk Committee for unresolved issues. However, while these structures indicate robust governance for sustainability and reputational risk, there is limited evidence of a specific governance framework explicitly addressing the alignment of lobbying activities, particularly climate-related lobbying. The Political Affairs function, led by the Global Head of Political Affairs reporting to the CEO, conducts advocacy and monitors regulatory developments but does not disclose processes for ensuring alignment of lobbying with climate goals. Furthermore, while external engagement with regulators and climate forums is mentioned, the company does not disclose mechanisms for reviewing or managing indirect lobbying through trade associations or industry bodies. Overall, the disclosures highlight strong sustainability governance but lack explicit details on lobbying governance processes, particularly in the context of climate-related advocacy. View Sources	D

Overall Assessment

Analysis

Score

Limited

Deutsche Bank AG demonstrates a structured approach to sustainability governance, with mechanisms such as the Group Sustainability Committee and the Net-Zero Forum overseeing sustainability-related decisions and transactions. The Group Sustainability Committee, chaired by the CEO, ensures alignment of sustainability strategies with corporate goals and provides oversight of sustainability strategy implementation. The Net-Zero Forum, established in 2022, reviews high-impact transactions in carbon-intensive industries and assesses their alignment with net-zero targets, demonstrating a focus on environmental considerations. Additionally, the Environmental and Social Policy Framework outlines due diligence processes for environmental and social risks, with escalation procedures to the Group Reputational Risk Committee for unresolved issues. However, while these structures indicate robust governance for sustainability and reputational risk, there is limited evidence of a specific governance framework explicitly addressing the alignment of lobbying activities, particularly climate-related lobbying. The Political Affairs function, led by the Global Head of Political Affairs reporting to the CEO, conducts advocacy and monitors regulatory developments but does not disclose processes for ensuring alignment of lobbying with climate goals. Furthermore, while external engagement with regulators and climate forums is mentioned, the company does not disclose mechanisms for reviewing or managing indirect lobbying through trade associations or industry bodies. Overall, the disclosures highlight strong sustainability governance but lack explicit details on lobbying governance processes, particularly in the context of climate-related advocacy.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Deutsche Bank provides only limited insight into its climate-policy lobbying. The bank indicates that it engages with regulators and legislators on sustainability issues, but it does not name any specific laws, regulations, or legislative proposals it has tried to influence, instead referring only to broad themes such as carbon pricing, the EU emissions-trading framework, or energy-efficiency rules. Its description of how it engages policymakers is similarly high-level: the bank says it undertakes advocacy “directly (bilateral meetings) as well as via trade associations (meetings jointly with peers, joint position papers, etc.)” and that it “convenes and participates in seminars and public panels, [and] engages with policymakers on climate change and the role of sustainable finance,” yet it does not identify which ministries, parliamentary committees, or other government bodies are the targets of these approaches. Finally, the disclosures do not spell out the concrete policy outcomes the bank is seeking; they speak only of general objectives such as supporting the transition to net-zero, avoiding unintended financial impacts on homeowners, or broadening sustainable-finance frameworks, without specifying any amendments, targets, or timelines it advocates. Taken together, the bank acknowledges some lobbying activity but provides little detail on the precise policies, mechanisms, or results it pursues, resulting in a low level of transparency.	D