Deutsche Boerse AG

Climate-related issues, commitments, and targets are reflected in the current governance set up of Deutsche Börse Group. The information below provides a relevant overview on the set-up and associated tasks. The provided information has been predominantly sourced from the 2023 annual report. Sustainability is of significant importance for the corporate strategy of Deutsche Börse Group. It is therefore an essential element of corporate governance at the level of both the Executive Board and the Supervisory Board. The Executive Board of Deutsche Börse AG takes all strategic decisions concerning sustainability matters at Deutsche Börse Group. It was supported in the reporting year by the interdisciplinary Group Sustainability Board, which is chaired by the CFO. The Group Sustainability Board is the central management board for sustainability topics in Deutsche Börse Group. It deals with company initiatives relating to environmental, social and governance (ESG) topics. This includes advising on and monitoring the integration of sustainability into corporate planning and controlling. The Group Sustainability Board has been replaced by the Group Sustainability Committee as of 1 January 2024. The Group Sustainability Committee is the new central management unit for sustainability topics in Deutsche Börse Group. It is chaired by the Chief Sustainability Officer and supports and advises the Executive Board on all aspects of sustainability. The Group Sustainability Committee is intended to arrange the implementation of effective ESG practices in accordance with applicable policies and guidelines. The Group ESG Strategy department, which reports to the CEO, primarily provides support by continuously monitoring the ESG profile and climate strategy of Deutsche Börse Group. Responsibility for ESG reporting was transferred from Group ESG Strategy to the section Sustainability Reporting, which is part of the CFO function, on 1 October 2023. At the Supervisory Board level, the Strategy and Sustainability Committee has dealt, in particular, with sustainable corporate governance and activities in the field of ESG at Deutsche Börse Group since 2021. In addition to embedding ESG in the work of the Supervisory Board in this way, it is particularly important for the board as a whole and in the other Supervisory Board committees, especially the Audit Committee, the Risk Committee and the Nomination Committee. Current, relevant sustainability aspects also form part of the training programme for the Executive Board and Supervisory Board and are dealt with in workshops and seminars.

**ESG governance** As of 2021 our Executive Board is informed frequently of relevant market and sales performance with regard to ESG and ESG net revenue[1] and determines the strategic course on this basis. It is mainly monitored and managed by our CEO and CFO, as well as via the segments: As part of the Group Strategy department the Group ESG Strategy team is responsible for the ESG activities within the Group and the reporting. It executes our climate strategy, conducts market trend analysis and works closely with the business areas in implementing their product strategies. The Group Sustainability Board oversees the implementation of the ESG strategy and the development of the ESG variables being part of the Executive Board remuneration. The Board convenes four times a year and in 2022 its members comprised one representative from each of the Executive Board divisions, plus the Head of Group ESG Strategy and one Executive Board member (2022: CFO). The individual business areas are responsible for the concrete implementation of the ESG strategy. In addition to the individual product areas, our risk management function is also involved with ESG topics. (see chapter "Risk management"). At the Supervisory Board level, the Strategy and Sustainability Committee established in 2021 deals primarily with ESG and advises the Executive Board on matters of strategic importance.

### (4.11) In the reporting year, did your organization engage in activities that could directly or indirectly influence policy, law, or regulation that may (positively or negatively) impact the environment? [...] ### (4.11.8) Describe the process your organization has in place to ensure that your external engagement activities are consistent with your environmental commitments and/or transition plan [...] _Our organization is deeply committed to ensuring that our external engagement activities align with our environmental commitments and transition plan. To achieve_ _this, we have implemented a comprehensive process that includes the following key elements: Continuous Monitoring and Development: We are constantly_ _monitoring and developing our climate strategy to identify and implement suitable measures that help us reach our environmental goals. Transparency and Challenge_ _Management: We proactively identify various challenges within our climate strategy, make these challenges transparent, and develop strategies to address them_ _and continuously monitor their effectiveness. Future Challenge Mitigation: By continuously monitoring potential future challenges, we aim to mitigate our negative_ _impact on the environment over time. Sustainability Trends and Improvement: We stay abreast of new sustainability trends and regularly review our existing_ _measures to identify areas for improvement. This ensures that our strategies remain relevant and effective. Through these efforts, we strive to ensure that our_ _external engagement activities are not only consistent with our environmental commitments but also contribute positively to our overall transition plan._ [...] ### (4.11.1) On what policies, laws, or regulations that may (positively or negatively) impact the environment has your organization been engaging directly with policy makers in the reporting year? [...] ### (4.11.1.8) Type of direct engagement with policy makers on this policy, law, or regulation [...] _EEX Group advises policymakers on cost-efficient decarbonization, supports the Paris Agreement, and engages in EU policy implementation. Registered in the EU Transparency Register, it contributes to consultations, position papers, and meetings._

Role of the Supervisory Board

In the financial year 2022, our Supervisory Board had seven permanent committees. The committees are responsible primarily for preparing the decisions to be taken by, and topics to be discussed in the plenary meetings. Additionally, the Supervisory Board has delegated individual decision–making powers to the committees, to the extent that this is legally permissible. Four of the seven committees are amongst other topics dealing with ESG and climate–related issues. In the following table we provide an overview of the dedicated Supervisory Board committees and their climate–related tasks. For an overview of all key issues [that the committees are focused on, please refer to our annual report,](https://www.deutsche-boerse.com/resource/blob/3374218/126bfa0fca2b0adbb635212d5a2c0d77/data/DBG-annual-report-2022.pdf) section "Committee work".

**Supervisory Board Committees** **Climate–related tasks**

Strategy and Sustainability Committee - Update on ESG strategy, activities, and priorities

Audit Committee - Dealing with ESG reporting and potential ESG risks

Risk Committee - Discussion about the quarterly compliance and Risk Management reports including ESG and climate risks
Nomination Committee - Discussion, integration and reporting of ESG and climate-related KPI

The individual committee chairs report in detail to the plenary meetings on the work performed by their committees. In addition to those four permanent committees and regular discussions in the plenary meetings, the Supervisory Board held a dedicated workshop in March 2022 to discuss the impact of ESG issues on the whole group as well as to discuss the impact and challenges of upcoming ESG regulation on our ESG reporting. In June 2023, the Strategy and Sustainability Committee discussed the enhancement of climate strategy which is planned to be based upon near–term targets until 2030 and a net–zero target until 2045, which are described further in the following chapters 3 and 5. [...] Role of DBG's management in assessing and managing climate–related risks and opportunities

For an overview of our roles and responsibilities please see the following graph and explanations:

_Figure 3 – Overview of roles and responsibilities regarding sustainability at Deutsche Börse Group_
_(simplified visualisation)_

Executive Board

The Executive Board has ultimate joint responsibility as well as ownership of ESG topics, including Deutsche Börse Group's climate strategy and is responsible for setting the ambition level. The Board monitors and reviews the progress and decides on the strategic approach to risk and opportunities. To do so, it is informed bi–monthly by a dedicated report including relevant market and sales performance, product initiatives, regulatory development as well as our ESG net revenues.

Group Sustainability Board

The Group Sustainability Board advises and supports the Executive Board regarding the management of sustainability matters. It oversees the implementation of sustainability projects, including the climate strategy. It is a cross–functional committee chaired by the CFO and co–chaired by the Head of Group ESG Strategy (CEO Division). It convenes four times a year and currently has seven members and four permanent guests.

Group ESG Strategy

Group ESG Strategy is a unit responsible for the ESG activities within Deutsche Börse Group. It executes our climate strategy, conducts market trend analysis, and works closely with the business areas in implementing their product strategies. Group ESG Strategy is part of the CEO division.

Group Risk Committee

The Group Risk Committee is an internal Group Committee, chaired by the CFO. It reviews the risk position of Deutsche Börse Group regularly and involves the Executive Board in all important matters.

##### Governance

Sustainability is of significant importance for the corporate strategy of Deutsche Börse Group. It is therefore
an essential element of corporate governance and climate-related issues, commitments, and targets are
reflected in the current governance set up of Deutsche Börse Group. The information below provides a relevant
overview on the set-up and associated tasks. The provided information has been predominantly sourced from
the [annual report.](https://deutsche-boerse.com/resource/blob/3811980/019d843f83e8c963d75dda16dd3fc258/data/DBG-annual-report-2023.pdf)

Role of the Supervisory Board

In the financial year 2023, our Supervisory Board had seven permanent committees. The committees are
responsible primarily for preparing the decisions to be taken by, and topics to be discussed in the plenary
meetings. Additionally, the Supervisory Board has delegated individual decision-making powers to the
committees, to the extent that this is legally permissible. The Strategy and Sustainability Committee has
dealt, in particular, with sustainable corporate governance and activities in the field of ESG at Deutsche
Börse Group since 2021. In addition to embedding ESG in the work of the Supervisory Board in this way,
it is particularly important for the board as a whole and in the other Supervisory Board committees,
especially the Audit Committee, the Risk Committee and the Nomination Committee. The individual
committee chairs report in detail to the plenary meetings on the work performed by their committees.
Current, relevant sustainability aspects also form part of the training programme for the Supervisory Board
and are dealt with in workshops and seminars. In December 2023, the Strategy and Sustainability
Committee had a dedicated climate workshop. In this workshop, the following contents were addressed:

- Current ESG-related challenges for companies and ESG drivers

- Milestones in the historical development of climate action

- Market standards and best practice

- Deutsche Börse Group CO2 profile and long-term climate strategy

- Potential challenges and discussion

In the following table we provide an overview of the dedicated Supervisory Board committees and their
climate-related tasks. For an overview of all key issues that the committees are focused on, please refer to
our [annual report,](https://deutsche-boerse.com/resource/blob/3811980/25860424be5329255d4e78184b801324/data/DBG-annual-report-2023.pdf) section "Committee work".

**Supervisory Board Committees** **Climate-related tasks**

Strategy and Sustainability Committee - Update on ESG strategy, activities, and priorities

Audit Committee - Dealing with ESG reporting and potential ESG risks

Risk Committee - Discussion about the quarterly compliance and
Risk Management reports including ESG and
climate risks
Nomination Committee - Discussion, integration and reporting of ESG and
climate-related KPI

--NEW-PAGE--

Role of DBG's management in assessing and managing climate-related risks and opportunities

Executive Board

The Executive Board of Deutsche Börse AG takes all strategic decisions concerning sustainability matters
at Deutsche Börse Group,including Deutsche Börse Group's climate strategy and is responsible for setting
the ambition level. The Board monitors and reviews the progress and decides on the strategic approach to
risk and opportunities.

Group Sustainability Committee

The former Group Sustainability Board has been replaced by the Group Sustainability Committee (GSC) as
of 1 January 2024. The Group Sustainability Committee is a standing group of ESG experts of group and
business functions and acts as the new central management unit for sustainability topics in Deutsche
Börse Group. Consequently, it oversees the implementation of sustainability projects, including the
corporate sustainability strategy and the climate strategy. The Committee is chaired by the Chief
Sustainability Officer (CSO) and supports and advises the Executive Board on all aspects of sustainability.
The Group Sustainability Committee is intended to arrange the implementation of effective ESG practices
in accordance with applicable policies and guidelines.

Chief Sustainability Officer

The Chief Sustainability Officer reports directly to the CEO. Moreover, he chairs the Group Sustainability
Committee, and, in this role, he annually informs the Executive Board about its overall progress and
performance.

Group ESG Strategy

Group ESG Strategy is a unit responsible for the ESG activities within Deutsche Börse Group. It executes
our corporate sustainability and climate strategy, conducts market trend analysis, and works closely with
the business areas in implementing their product strategies. Group ESG Strategy is part of the CEO division.

Sustainability Reporting

Responsibility for DBG's ESG reporting, including the environmental reporting, was transferred from Group
ESG Strategy to the section Sustainability Reporting, which is part of the CFO function, on 1 October
2023.

Group Risk Committee

The Group Risk Committee is an internal Group Committee, chaired by the CFO. It reviews the risk position
of Deutsche Börse Group regularly and involves the Executive Board in all important matters.

Chief Risk Officer

The Chief Risk Officer leads the development of proposals for the Risk Management framework incl.
consideration and implementation of ESG, risk appetite, approaches and methods for risk monitoring and
control, capital allocation and the necessary processes. Risks are continuously analysed, evaluated, and
reported regularly to the Group Risk Committee, once a month or ad-hoc to the Executive Board, once a
quarter to the Risk Committee of the Supervisory Board and once a year to the Supervisory Board.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Deutsche Börse Group has a centralised Group Regulatory Strategy (GRS) area, which is responsible for numerous projects relating to changes in Deutsche Börse Group's
political and strategic environment. For matters relating to corporate sustainability or climate change, GRS has a specific and dedicated ESG Strategy Unit that responds
directly to the Chief Executive Office (CEO) Division of Deutsche Börse Group. Sustainability considerations run through the entire political and regulatory work of Deutsche
Börse Group. The core responsibility for public affairs related to commodity markets at large is delegated directly to EEX, the groups' commodity exchange. The working
methods are identical and closely inter-coordinated. The overall approach is to take on a specific position in close consultation with the management of the business areas of
the entire Group. Moreover, Group Regulatory Strategy at Deutsche Börse and EEX support and monitor political processes and regulatory developments. On an ongoing
basis, staff also make strategic assessments and prepare briefing documents on regulatory and policy matters for key decision makers of Deutsche Börse Group. The
centralised teams guarantee that position papers and other activities such as reports or presentations are developed together and hence are consistent and in line with the
strategy of Deutsche Börse Group.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes