The financial sector, as with any other sector, is vulnerable to incidents of bribery and corruption. By bribery, we mean the practice of offering, promising, giving, authorizing, soliciting, agreeing, or receiving or accepting anything of value to or/from another person or entity—whether directly or indirectly—in order to gain some form of advantage. Corruption refers to any activity that involves the abuse of position or power for an improper personal or business advantage, whether in the public or private sector. We take a zero-tolerance approach to bribery and corruption, in line with our Code of Business Conduct and Ethics, values and beliefs, and international law, including the UK Bribery Act 2010, the US Foreign Corrupt Practices Act 1977, the German Criminal Code, and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
Reflecting our commitment to compliance with applicable law and regulations as well as best practice standards, a dedicated ABC Team has a mandate to:
- reduce the risk that Deutsche Bank, or persons associated with the business, will engage in bribery or corruption;
- ensure that, if there is bribery and corruption, Deutsche Bank has limited its liability, so far as is possible; and
- protect Deutsche Bank’s reputation, ensure shareholder confidence, reduce risk in Deutsche Bank’s business dealings, and secure Deutsche Bank assets.
Our ABC Policy sets out the minimum standards of behavior expected by all employees and third parties associated with Deutsche Bank.
Our senior management is responsible for promoting our ABC Policy and ensuring that a culture of integrity—which makes bribery and corruption unacceptable—is fostered and maintained by all employees and across Deutsche Bank. In turn, every employee is responsible for the prevention, detection, and reporting of bribery and other forms of corruption in connection with Deutsche Bank’s business. Any employee who breaches this policy will face disciplinary action, which could result in dismissal. We may also terminate our relationship with any third party found to be in breach of the principles and rules set out in this policy or applicable bribery and corruption laws and regulations.
To make the policy a reality, regional teams are responsible for analyzing risk, developing and monitoring controls, training, and awareness. These teams almost doubled in size in 2015, to 15 employees (compared to nine in 2014).
Anti-fraud is a priority for AFC. Its framework includes a strategy to prevent, detect, and investigate fraud. Investigation into internal and external fraud and attempted fraud is led by the Anti-Fraud and Investigations Team, which comprises experts at regional level and specific business divisions.
Besides tackling fraud and bribery as well as corruption offenses, the Global Head of AFC is responsible for ensuring that our measures to prevent “other criminal activities”, which could endanger institutional assets (see section 25 of the German Banking Act), are fit for purpose. A dedicated central unit coordination team was created in 2015 to establish the collection and analysis of information relating to the measures that are in place to prevent all “other criminal activities,” to be reviewed at the Group Financial Crime Governance Committee, chaired by the Global Head of AFC.