In 2015, we continued to follow developments around the implementation of the UN Guiding Principles on Business and Human Rights (UNGP HR). At the same time, we held internal discussions on what that means for our own activities, taking thought leadership from the Thun Group.
In line with the UNGP HR, and reflecting our long-standing commitment to human rights, we published a Human Rights Statement in November 2015. This addresses the human rights of our employees as well as of individuals, groups, or communities that might be affected by our activities. It is approved by our Group Reputational Risk Committee (GRRC).
Governance and commitment
Our interactions with NGOs, external data sources, our peers and investors indicate that the greatest risk of human rights abuses are within our client and vendor relationships. To this end, we have integrated human rights risks into the due diligence process of our group-wide Environmental and Social (ES) Policy Framework. In addition, we are strengthening the due diligence process for vendors to ensure compliance with our Human Rights Statement and our Code of Business Conduct and Ethics.
Because our clients operate in all sectors of the economy and in almost every region of the world, our approach is universal. However, we have defined industry sectors that require a greater analysis due to their risks of human rights abuses. In cases where we decide that measures are needed to prevent or mitigate human rights abuses, we will approve those measures with the client and monitor their implementation. If tensions arise between human rights issues and other objectives, there is the option to escalate to a Regional Reputational Risk Committee for a final decision. In 2015, there were no severe incidences of human rights infringements that needed to be escalated to the GRRC.
Awareness and improvement
Employee awareness around human rights risk is key to a credible due diligence process. The ES Policy Framework is available to all employees on our policy portal and intranet. The recent update of the framework and the publication of the Human Rights Statement were communicated internally to remind all employees of the importance to ensure respect for human rights in our activities. Furthermore, human rights aspects were also included in our global ES risk training.
By analyzing potential human rights issues in our business transactions, we continually improve our understanding, which, in turn, informs our due diligence process, guidelines, and policies.
Anyone can bring human rights issues to our attention through our dedicated grievance channels. These include Deutsche Bank branches, telephone, the website, social media, and in writing. Any grievances, including those concerning human rights, are initially dealt with by the business divisions’ complaint management process in line with our Complaints Management policy.
As per the UNGP, the responsibility for enabling effective remedy lies with the entity that is causing or contributing to any human rights violation. Industry discussions on appropriate grievance mechanisms and access to remedy during 2015 revealed a pressing need to establish a common understanding for the definition of the terms “cause,” “contribute,” and “directly linked” in the context of banking. We have been working with the Thun Group to bring some clarity to this, and we will be further contributing to the dialog.