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 of 1977, the German Criminal Code, and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
Reflecting our commitment to comply with applicable laws and regulations, as well as best practices, a dedicated Anti-Bribery and Corruption (ABC) team is responsible for:
- reducing the risk that Deutsche Bank, or persons associated with the business, engages in bribery or corruption;
- ensuring that, if there is bribery and corruption, we limit our liability, so far as is possible; and
- protecting our reputation, ensuring shareholder confidence, reducing risk in our transactions, and securing our assets.
Our senior management is responsible for promoting the ABC Policy and for ensuring that a culture of integrity is fostered and maintained by all employees. In turn, every employee is responsible for the prevention, detection, and reporting of bribery and other forms of corruption. 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 deliver the policy, regional teams are responsible for analyzing risk, developing and monitoring controls, training, and awareness. As of November 2016, the ABC teams grew to over 30 people, more than double the 2015 headcount.
Fraudulent incidents have the potential to incur material loss by either Deutsche Bank or our clients, to negatively impact the bank’s reputation, or to stimulate regulatory and legal action. Anti-fraud prevention and investigation are therefore important to mitigating exposure. Our Group-wide Anti-Fraud policy applies to all Deutsche Bank employees. We request them to immediately escalate any known or suspected fraudulent incident, for instance via our whistleblower hotline. All issues raised are dealt with anonymously where requested, and we will not take any action against the originator if an allegation is made in good faith. We also expect our partners to have controls in place to minimize fraud and to provide access to their records as they relate to our dealings.
Investigation into internal and external fraud or attempts at fraud is led by our Anti-Fraud and Investigations team, which comprises investigative experts located in each region.
Mandatory Time Away is an important anti-fraud control for the prevention and detection of unauthorized or inappropriate activity by staff in sensitive positions that may result in serious financial loss or reputational damage to Deutsche Bank. We enforce this to deter and prevent employees in sensitive positions from undertaking any unauthorized or inappropriate scheme or activity that might require continuous on-site presence and/or system access.
The Global Head of AFC is also responsible for ensuring that we have the right measures to prevent “other criminal activities” derived from the German Penal Code and that could endanger institutional assets (see section 25 of the German Banking Act).