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Sustainability Disclosures – Deutsche Bank Luxembourg S.A.

 

Introduction

 

SFDR[1] came into effect on March 10, 2021. SFDR imposes new transparency obligations (Website disclsoures, PreContractual disclosures) & periodic reporting requirements on investment management firms at both a product and entity/manager level. This section relates to the “Website Disclosure” regulatory obligations arising out of SFDR Articles 3-10. More information can be found on the below links.

 

Definitions

 

For the purposes of this Regulation, the following definitions apply:

(1)   ‘financial market participant’ means:

(a)   an insurance undertaking which makes available an insurance‐based investment product (IBIP);
(b)   an investment firm which provides portfolio management;
(c)    an institution for occupational retirement provision (IORP);
(d)   a manufacturer of a pension product;
(e)   an alternative investment fund manager (AIFM);
(f)    a pan‐European personal pension product (PEPP) provider;
(g)   a manager of a qualifying venture capital fund registered in accordance with Article 14 of Regulation (EU) No 345/2013;
(h)   a manager of a qualifying social entrepreneurship fund registered in accordance with Article 15 of Regulation (EU) No 346/2013;
(i)     a management company of an undertaking for collective investment in transferable securities (UCITS management company); or
(j)     a credit institution which provides portfolio management;

 

(2)   ‘insurance undertaking’ means an insurance undertaking authorised in accordance with Article 18 of Directive 2009/138/EC;

 

(3)   ‘insurance‐based investment product’ or ‘IBIP’ means: 

(a)   an insurance‐based investment product as defined in point (2) of Article 4 of Regulation (EU) No 1286/2014 of the European Parliament and of the Council (19); or
(b)   an insurance product which is made available to a professional investor and which offers a maturity or surrender value that is wholly or partially exposed, directly or indirectly, to market fluctuations;

(4)   ‘alternative investment fund manager’ or ‘AIFM’ means an AIFM as defined in point (b) of Article 4(1) of Directive 2011/61/EU;
 

(5)   ‘investment firm’ means an investment firm as defined in point (1) of Article 4(1) of Directive 2014/65/EU;


(6)   ‘portfolio management’ means portfolio management as defined in in point (8) of Article 4(1) of Directive 2014/65/EU;


(7)   ‘institution for occupational retirement provision’ or ‘IORP’ means an institution for occupational retirement provision authorised or registered in accordance with Article 9 of Directive (EU) 2016/2341 except an institution in respect of which a Member State has chosen to apply Article 5 of that Directive or an institution that operates pension schemes which together have less than 15 members in total;


(8)   ‘pension product’ means:

(a)   a pension product as referred to in point (e) of Article 2(2) of Regulation (EU) No 1286/2014; or

(b)   an individual pension product as referred to in point (g) of Article 2(2) of Regulation (EU) No 1286/2014;

 

(9)   ‘pan‐European Personal Pension Product’ or ‘PEPP’ means a product as referred to in point (2) of Article 2 of Regulation (EU) 2019/1238;

 

(10)   ‘UCITS management company’ means:

(a)   a management company as defined in point (b) of Article 2(1) of Directive 2009/65/EC; or

(b)   an investment company authorised in accordance with Directive 2009/65/EC which has not designated a management company authorised under that Directive for its management;

 

(11)   ‘financial adviser’ means:

(a)   an insurance intermediary which provides insurance advice with regard to IBIPs;

(b)   an insurance undertaking which provides insurance advice with regard to IBIPs;

(c)    a credit institution which provides investment advice;

(d)   an investment firm which provides investment advice;

(e)   an AIFM which provides investment advice in accordance with point (b)(i) of Article 6(4) of Directive 2011/61/EU; or

(f)    a UCITS management company which provides investment advice in accordance with point (b)(i) of Article 6(3) of Directive 2009/65/EC;

 

(12)   ‘financial product’ means:

(a)   a portfolio managed in accordance with point (6) of this Article;

(b)   an alternative investment fund (AIF);

(c)   an IBIP;

(d)   a pension product;

(e)   a pension scheme;

(f)   a UCITS; or

(g)   a PEPP;

 

(13)   ‘alternative investment funds’ or ‘AIFs’ means AIFs as defined in point (a) of Article 4(1) of Directive 2011/61/EU;

 

(14)   ‘pension scheme’ means a pension scheme as defined in point (2) of Article 6 of Directive (EU) 2016/2341;

 

(15)   ‘undertaking for collective investment in transferable securities’ or ‘UCITS’ means an undertaking authorised in accordance with Article 5 of Directive 2009/65/EC;

 

(16)   ‘investment advice’ means investment advice as defined in point (4) of Article 4(1) of Directive 2014/65/EU;

 

(17)   ‘sustainable investment’ means an investment in an economic activity that contributes to an environmental objective, as measured, for example, by key resource efficiency indicators on the use of energy, renewable energy, raw materials, water and land, on the production of waste, and greenhouse gas emissions, or on its impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequality or that fosters social cohesion, social integration and labour relations, or an investment in human capital or economically or socially disadvantaged communities, provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance;

 

(18)   ‘professional investor’ means a client who meets the criteria laid down in Annex II to Directive 2014/65/EU;

 

(19)   ‘retail investor’ means an investor who is not a professional investor;

 

(20)   ‘insurance intermediary’ means an insurance intermediary as defined in point (3) of Article 2(1) of Directive (EU) 2016/97;

 

(21) ‘insurance advice’ means advice as defined in point (15) of Article 2(1) of Directive (EU) 2016/97;

 

(22) ‘sustainability risk’ means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment;

 

(23) ‘European long‐term investment fund’ or ‘ELTIF’ means a fund authorised in accordance with Article 6 of Regulation (EU) 2015/760;

 

(24) ‘sustainability factors’ mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

 

 

1.1 Sustainability Risk Policy

Article 3: Transparency of sustainability risk policies for financial market participants and financial advisors for Deutsche Bank Luxembourg S.A., March 2021

Introduction / Summary

On March 10, 2021 the Regulation (EU) 2019/2088 of November 27, 2019 on sustainability-related disclosures in the financial sector (Disclosure Regulation) has entered into force. This regulation aims to support sustainable investments by requiring Financial Market Participants (FMPs) and Financial Advisers (FAs) to disclose information regarding sustainability risks to investors and clients.

 

Article 3 of this regulation requires information to be shared with regards to the integration of sustainability risks within investment decision-making processes and investment advice. The approach taken by Deutsche Bank Luxembourg S.A. is further detailed below.

 

Deutsche Bank AG applies an overarching approach to the management of sustainability that is set out in a number of group level policies and procedures, which also apply to Deutsche Bank Luxembourg S.A. as member of Deutsche Bank Group. The group-wide Sustainability Policy delineates our main sustainability principles as well as the key requirements and responsibilities in connection with sustainability-related enquiries, non-financial sustainability reporting and ratings, environmental and social due diligence in the context of reputational risk management, and, together with relevant risk frameworks and broader commitments, provides relevant context regarding the Bank’s view on sustainability topics.

 

Whilst Deutsche Bank AG does not currently apply an overarching formal policy regarding the integration of sustainability risks in the investment decision‐making and advisory processes, Deutsche Bank AG still takes sustainability risks into account, as further described in following sections. In addition, business areas are working towards inclusion of the integration of sustainability risks within relevant policies and guidelines. These will be further enhanced on an ongoing basis as more sustainability related data becomes available over time.

 

Definition of sustainability risks

Sustainability risks (“ESG risks”) are designated as incidents or conditions in the areas of the Environment, Social or Corporate Governance, whose occurrence could have actual or potential significantly negative effects on the value of the investment. These risks can occur both separately and cumulatively; they can affect individual com­panies or also entire sectors/branches or regions and can have very different characteristics.

 

The following examples can help to clarify sustainability risks:

 

As a result of the occurrence of extreme weather events as a consequence of climate change (known as physical risks), for example, production locations of individual companies or entire regions can be impaired or destroyed, leading to production stoppages, rising costs to restore the production locations and higher insu­rance costs. Furthermore, extreme weather events as a consequence of climate change, such as long periods of low water during droughts, can impair the transport of goods or even make it impossible.

 

There are also risks in connection with the changeover to a low-carbon economy (known as transition risks): for example, political measures can lead to fossil fuels becoming more expensive and/or scarcer (examples: fossil-fuel phase-out, CO2 tax) or to high investment costs as a result of requirements to renovate buildings and plant. New technologies can displace familiar technologies (e.g. electric mobility), and changes in custo­mer preferences and expectations in society can endanger companies’ business models if they do not react in time and take counter measures (by adjusting their business model, for example).

 

A substantial increase in physical risks would require a more abrupt changeover in the economy, which in turn would lead to higher transition risks.

 

Social risks arise from aspects such as non-compliance with labour law standards (for example, child labour and forced labour) and compliance with occupational health and safety regulations.

 

Examples of risks that arise within the scope of corporate management due to inadequate corporate gover­nance and that can lead to high fines include non-compliance with taxpayer honesty and corruption.

 

Sustainability risks affect the following traditional risks of investments in securities in particular, and if they occur, could have a significantly negative effect on the yields of an investment in securities:

 

·       Sector risk

·       Price change risk

·       Issuer/Credit risk

·       Dividend risk

·       Liquidity risk

·       Currency risk

Method of including sustainability risks for Financial Markets Participants and Financial Advisors:

In order to evaluate sustainability risks, Deutsche Bank AG uses information such as that from external service providers that have specialised in the qualitative evaluation of ESG factors.

 

Because sustainability risks can have different effects on individual companies, sectors, investment regions, currencies and investment classes (for example, equities or bonds), when recommending financial instruments in the Bank follows the approach of diversifying investments as broadly as possible in order to reduce the effects of the occurrence of sustainability risks on the client´s portfolio. The Bank generally recommends distribution across a variety of investment classes in order to establish an individual client opportunity/risk pro­file. In addition, investment advice pursues a policy of a broad spread of investment classes in a variety of bran­ches/sectors, investment regions and currencies.

 

In addition to diversification, for Financial Market Participants, sustainability risks are taken into account at various points in the investment process when making investment decisions within the framework of financial portfolio management. Sustainability risks are taken into account during the macro-economic consideration and development of market opinion, when allocating assets to individual investment strategies and when selecting individual financial instruments.

 

1.2 Adverse sustainability impacts statement

1.2.1 Financial Market Participant

Financial market participant adverse sustainability impacts statement for Deutsche Bank Luxembourg S.A., March 2021

Introduction / Summary 

On March 10, 2021 the Regulation (EU) 2019/2088 of November 27, 2019 on sustainability-related disclosures in the financial sector (Disclosure Regulation) has entered into force. This regulation aims to support sustainable investments by requiring Financial Market Participants (FMPs) and Financial Advisers (FAs) to disclose information regarding sustainability risks and adverse sustainability impacts to investors and clients.

 

This is the adverse sustainability impact statement for Deutsche Bank Luxembourg S.A. in our capacity as Financial Market Participant, to disclose the bank’s approach on the consideration of principal adverse impacts of investment decisions on sustainability factors. Principal adverse impacts on sustainability factors are referred to in Article 4 of the Disclosure Regulation. They are further defined in implementing legislation, which at the time of publication of this statement has not entered into force, but are meant to cover negative effects of investments regarded as material from a sustainability perspective. This statement is made for all financial products as defined by the Disclosure Regulation (portfolio management, alternative investment fund (AIF), insurance-based investment products (IBIP), a pension product, a pension scheme, an undertaking for collective investments in transferable securities (UCITS), pan-european personal pension product (PEPP)[2]).

 

As of March 10, 2021, Deutsche Bank Luxembourg S.A. considers principal adverse impacts (PAIs) of its investment decisions on sustainability factors, as described in more detail in the full statement, and will disclose the extent of these impacts in future statements.

 

As described in the full statement below, although there currently is no formal policy to this effect, Deutsche Bank Luxembourg S.A. will take four specific impacts into account in relevant investment decisions. For this purpose, factors relating to the aforementioned principal adverse impacts will be made transparent against the investment universe. The consideration of these adverse impacts will be an additional factor for review in making investment decisions, but will not automatically outweigh other relevant factors. Deutsche Bank AG does not engage directly with investee companies and so do not influence business activity or risks, and follows certain internationally recognized principles for sustainable business and banking conduct, as specified in the full statement.

Description of policies to identify and prioritise principal adverse sustainability impacts

Deutsche Bank AG applies an overarching approach to the management of sustainability, which is set out in a number of group level policies and procedures, which also apply to Deutsche Bank Luxembourg S.A. as member of Deutsche Bank Group. The group-wide Sustainability Policy delineates our main sustainability principles as well as the key requirements and responsibilities in connection with sustainability-related enquiries, non-financial sustainability reporting and ratings, environmental and social due diligence in the context of reputational risk management, and sustainable finance.

 

Whilst currently Deutsche Bank AG does not apply environmental or social restrictions in the context of the financial products in scope of the Disclosure Regulation, the group level Sustainability policies, relevant Risk Frameworks and broader commitments provide relevant context regarding the bank’s view on these topics. And so although there is no formal policy to this effect, Deutsche Bank AG will still take certain principal adverse impacts into account, as further described in following sections.

Description of principal adverse sustainability impacts

The principal adverse impacts, including the identification, prioritisation and any designated action to be taken to manage exposure to these, will be reviewed by group wide governance forums on an annual basis in accordance with the Deutsche Bank AG Policy Framework.

 

The Principal Adverse Impacts that Deutsche Bank AG will take into account this reference period are:

  • Exposure to Fossil Fuels
    Industries that derive revenues from the exploration, mining, extraction, distribution or refining of hard, liquid or gaseous fuels (i.e. coal, oil, natural gas)
  • Carbon emissions
    The level of carbon dioxide equivalent that is released by a company, measured in volume and intensity
  • Compliance with United Nations Global Compact principles
    Observing that companies at a minimum, meet fundamental responsibilities in the areas of human rights, labour, environment and anti-corruption.
  • Exposure to controversial weapons
    Industries that derive revenues from the manufacture or selling of controversial weapons (i.e. anti-personnel landmines, cluster munitions, chemical, biological, radiological and nuclear weapons)

 

Description of actions to address principal adverse sustainability impacts

From March 10, 2021, Deutsche Bank Luxembourg S.A. will make factors relating to the aforementioned principal adverse impacts transparent against the investment universe, enabling informed decisions in the selection process for construction of relevant financial products.

 

The focus will be on making the data available within the processes for selection of underlying products for our managed funds and portfolios. As a fiduciary, it is of the utmost importance that we make all investment decisions in the best interest of the clients, considering all financial and risk factors. Therefore, the consideration of these adverse impacts will be an additional factor for review by our portfolio managers in making investment decisions, but will not automatically outweigh other relevant factors.

 

To support with obtaining required details, and monitoring our investable product universe, Deutsche Bank AG partners with third party data providers to include information on the business involvements and controversies across the universe on a monthly basis.

 

Engagement policies

Where Deutsche Bank Luxembourg S.A. acts as Financial Market Participant for financial products in scope of the Disclosure Regulation, we do not engage directly with investee companies and so do not influence business activity or risks.

 

References to international standards

The bank follows internationally recognized principles for sustainable business and banking conduct, such as the 10 principles of the UN Global Compact, the UN Principles for Responsible Investments, the UN Principles for Responsible Banking and the UN Guiding Principles on Business and Human Rights. A full list and further details of the standards adhered to can be found at: www.db.com/cr/en/docs/2021_Deutsche_Bank_selected_memberships.pdf

 

1.2.2 Financial Advisor

Financial advisor adverse sustainability impacts statement for Deutsche Bank Luxembourg S.A., March 2021

When providing financial advice, Deutsche Bank Luxembourg S.A. takes principal adverse impacts on sustainability factors into account, as described in more detail in the following. Principal adverse impacts on sustainability factors are referred to in Article 4 of Regulation (EU) 2019/2088 of November 27, 2019 on sustainability‐related disclosures in the financial services sector (the “Disclosure Regulation”). They are further defined in implementing legislation, which at the time of publication of this statement has not entered into force, but are meant to cover negative effects of investments regarded as material from a sustainability perspective.

 

At this point in time, Deutsche Bank Luxembourg S.A. in the capacity as financial advisor will take the following principal adverse impacts, as defined by draft implementing legislation, into account, for all financial products as defined by the Disclosure Regulation (portfolio management, alternative investment fund (AIF), insurance-based investment products (IBIP), a pension product, a pension scheme, an undertaking for collective investments in transferable securities (UCITS), pan-European personal pension product (PEPP)[3]) managed by EU entities:

  • Exposure to Fossil Fuels
    Industries that derive revenues from the exploration, mining, extraction, distribution or refining of hard, liquid or gaseous fuels (i.e. coal, oil, natural gas)
  • Carbon emissions
    The level of carbon dioxide equivalent that is released by a company, measured in volume and intensity
  • Compliance with United Nations Global Compact principles
    Observing that companies at a minimum, meet fundamental responsibilities in the areas of human rights, labour, environment and anti-corruption.
  • Exposure to controversial weapons
    Industries that derive revenues from the manufacture or selling of controversial weapons (i.e. Anti-Personnel Landmines, Cluster Munitions, Chemical, Biological, Radiological and Nuclear  weapons)

 

 

Overall the positive and negative impact of investments have become increasingly available to measure. The majority of the harmful impacts companies or real assets can have on the environment, their employees or communities they operate in, may result in direct or indirect financial risks, the risk of losing the license to operate, competitive disadvantages or the loss of customer or community support. In other words, they constitute an “ESG” – Environmental, Social or Governance- or “sustainability risk”.

 

As of the March 10, but by June 30, 2021 latest, EU managers or manufacturers of managed financial products (under the Disclosure Regulation, “Financial Market Participants”) exceeding on their balance sheet the criterion of the average number of 500 employees during the financial year, will be required to publish a statement on how they address and consider principal adverse impacts. We expect the first statement of Financial Market Participants to be a qualitative statement on how they consider principle adverse impacts in their investment decision making processes. The first quantitative assessment on the indicators are expected to be disclosed by June 30, 2022. After that date we expect that more and more data will become available to investors and financial advisors.

 

As part of our advisory due diligence process we will review the relevant principal adverse impact statements published by the Financial Market Participants, and also note where they consider principal adverse impacts that align with our own. The enhanced due diligence process will ensure that we have clarity and transparency on the relevant adverse impacts taken into account by the Financial Market Participants, and enables us to identify products that do not fulfil our qualitative requirements and therefore may result in us not recommending the respective financial products.

 

1.3 Remuneration Policy

Sustainability and Remuneration

The consideration of Sustainability and Sustainability Risks is an integral part of the performance-based determination of variable compensation at Deutsche Bank group, both for employees and the Management Board.

 

Where appropriate, we have set sustainability related targets which include financial and non-financial targets such as sustainable financing and investment volumes as well as culture and conduct.

 

Furthermore, we expect all employees of Deutsche Bank to adhere to the sustainability principles stipulated in our code of conduct, which aim to generate sustainable value for our clients, employees, investors and society at a large. The code of conduct is embedded in our governance, policies, processes, and control systems.

 

1.4 Sustainability-related product disclosure section

 

The information contained in this section is provided in accordance to Art. 10 of the REGULATION (EU) 2019/2088 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of November 27, 2019 on sustainability‐related disclosures in the financial services sector (the Disclosure Regulation).

1.4.1 Products promoting environmental or social characteristics

Financial Portfolio Management considers environmental and social characteristics:

 

Deutsche Bank acts in the capacity of a Financial Market Participant, and offers financial products in scope of the Disclosure Regulation. The following provides an overview of products offered that promote environmental and social characteristics (Article 8).

 

Active Asset Allocation (A3) ESG

 

Description of environmental or social characteristics

 

Deutsche Bank AG (hereinafter the “Bank”) considers environmental and social characteristics in selecting financial instruments as part of Active Asset Allocation (A3) ESG. However, discretionary portfolio management does not aim for sustainable investment or contribute to achieving an environmental or social objective.

 

The minimum requirement for the inclusion of an issuer, a financial instrument (excluding investment funds) or an underlying asset in a discretionary mandate which considers sustainability criteria is that MSCI ESG Research (UK) Limited and MSCI ESG Research LLC (hereinafter “MSCI”) issued an ESG rating of at least “A”.

 

The minimum requirement for an investment fund listed by MSCI in a peer group with a name containing the term “emerging markets” or “high yield” or an investment fund that, based on its peer group, invests exclusively or primarily in equities from a country whose public limited companies are included in the MSCI Emerging Markets (EM) index is an ESG score of ‘BBB’. An ESG rating from MSCI of at least “A” is a minimum requirement for all other investment funds.

 

Moreover, issuers, with the exception of governments and investment funds, should be excluded if the overall assessment of the issuer according to MSCI's analysis indicates that the issuer's business practices or the manufactured products materially violate national or international norms, laws and/or generally accepted global standards. Issuers should also be excluded if they are active in business areas that are controversial in the bank's view or if they generate significant revenue in these business areas.

 

Methods used to measure and monitor environmental or social characteristics

 

In order to assess whether an investment instrument meets the sustainability criteria, the bank relies exclusively on the positive lists that are prepared and regularly updated by MSCI. These are prepared in accordance with the bank's instructions regarding sustainability criteria and exclusions, and may contain information on issuers, financial instruments and underlying assets on which financial instruments may be based.

 

The bank does not monitor MSCI's compliance with sustainability and exclusion criteria. The bank cannot guarantee the accuracy of MSCI's assessment or the accuracy and completeness of the positive list generated by MSCI, but will use information from MSCI as a basis. Nor does the bank have any influence on any disruptions to MSCI's analysis and preparation for research.

 

MSCI makes regularly updated positive lists available to the bank. The bank's selection of financial instruments is based on the latest updated positive lists. In the event that an investment instrument ceases to comply with the sustainability criteria, the Bank will make best efforts to prioritise the disposal of this investment instrument from the portfolio while at the same time upholding the interests of the client.

 

Data sources and criteria for assessment of the underlying assets in terms of environmental or social characteristics

 

In the context of discretionary portfolio management, the bank will preferentially invest in investment instruments that meet certain sustainability criteria. In order to assess whether a financial instrument meets the sustainability criteria, the bank uses the ratings and assessments of MSCI.

 

The minimum requirement for an issuer, financial instrument, with the exception of investment funds, or underlying asset to be included in the above-mentioned positive list is an ESG rating from MSCI of at least “A” (on a scale where “AAA” is MSCI's best rating for sustainability and “CCC” its worst).

 

Investment funds listed by MSCI in a peer group with a name containing the term ‘emerging markets’ or ‘high yield’ and investment funds that, based on their peer group, invest exclusively or primarily in equities from a country whose public limited companies are included in the MSCI Emerging Markets (EM) index are also deemed eligible by the Bank if their ESG score according to the positive list is ‘BBB’. An ESG rating from MSCI of at least “A” is a minimum requirement for all other investment funds.

 

Special provisions for derivative transactions: When executing derivative transactions, the counterparty of the derivative transaction (the stock exchange) does not require an MSCI ESG rating, i.e. it is permitted to execute derivative transactions with stock exchanges that have no MSCI ESG rating or an MSCI ESG rating below ‘A’ and that are consequently not included on any positive list. It is also permitted to invest in derivative contracts that use as an underlying instrument one or multiple indices, even if no MSCI ESG rating is available for the relevant indices or if their MSCI ESG rating is lower than ‘A’ and they are consequently not included on any positive list. Other underlying instruments of derivative contracts (or issuers of such underlying instruments), for which MSCI has prepared a positive list, must meet the minimum requirement of an MSCI ESG rating of ‘A’ or higher.

 

MSCI uses a scoring model intended to identify and measure significant ESG opportunities and risks to determine the rating. This includes aspects of corporate governance. Regardless of the above-mentioned ESG rating, the bank additionally applies exclusion criteria provided by MSCI as agreed between the bank and MSCI.

Disclosure on the inclusion of environmental or social characteristics in pre-contractual information

 

PDF with pre-contractual disclosure pursuant to Art 8 SFDR

 

10 March 2021
 

1.4.2 Products with sustainable investment objective

Deutsche Bank Luxembourg S.A. acts in the capacity of a Financial Market Participant, and offers financial products in scope of the Disclosure Regulation. Currenty Deutsche Bank Luxembourg S.A. does not offer any products which have a sustainable investment objective (Article 9). The following provides an overview of products offered that have a sustainable investment objective (Article 9). 

 

·       No products currently in scope

 

References

1.
https://eur-lex.europa.eu/eli/reg/2019/2088/oj
2.
Not all of these products are currently in scope for Deutsche Bank AG as a Financial Market Participant.
3.
Not all of these products are currently in scope of the advisory business.


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