Deutsche Bank : Report review with Limited Assurance ISS Corporate 2023

REPORT REVIEW

Deutsche Bank AG Green Financing Instruments Report

Green Financing Instruments Report Deutsche Bank AG

7 June 2024

VERIFICATION PARAMETERS

Type(s) of reporting

Relevant standard(s)

Scope of verification

• Green Bond Allocation and Impact Report
• Harmonised Framework for Impact Reporting (HFIR), updated June 2023, as administered by International Capital Market Association (ICMA)
• Deutsche Bank AG's Green Financing Instruments
  Report (as of June 4, 2024)
• Deutsche Bank AG's Green Financing Framework as of
  June 2022)

Lifecycle

Validity

• Green Instruments Identification: ISIN, Maturity, and Volume are displayed in Annex 1
• Post-issuanceverification
• As long as no changes are undertaken by the Issuer to its Green Financing Instruments Report as of June 4, 2024

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Green Financing Instruments Report Deutsche Bank

C O N T E N T S

SCOPE OF WORK	3
ASSESSMENT SUMMARY	4
REPORT REVIEW ASSESSMENT	6
PART I: ALIGNMENT WITH COMMITMENTS SET FORTH IN THE GREEN FINANCING
FRAMEWORK	6
PART II: ASSESSMENT AGAINST THE ICMA HARMONISED FRAMEWORK FOR IMPACT
REPORTING	9
PART III: DISCLOSURE OF PROCEEDS ALLOCATION AND SOUNDNESS OF THE IMPACT
REPORTING INDICATORS	13
ANNEX 1: 2023 Green Financing Instruments	18
ANNEX 2: Methodology	19
ANNEX 3: Quality management processes	20
About this Report Review	21

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SCOPE OF WORK

Deutsche Bank AG ("the Issuer" or "Deutsche Bank") commissioned ISS-Corporate to provide a Report Review1 on its Green Financing Instruments Report by assessing:

1. The alignment of Deutsche Bank's Green Financing Instruments Report with the commitments set forth in Deutsche Bank's Green Financing Framework (as of June 2022).2
2. Deutsche Bank's Green Financing Instruments Report, benchmarked against the Harmonised Framework for Impact Reporting (HFIR), updated June 2023.
3. The disclosure of proceeds allocation and soundness of reporting indicators - whether the impact metrics align with best market practices and are relevant to the green bonds issued.

1. A limited assurance is provided on the information presented in Deutsche Bank's Green Financing Instruments Report and Green Asset Pool. A review of the post-issuance disclosure practices is conducted against ICMA's Standards (Green Bond/Social
   Bond Principles), core principles and recommendations where applicable, and the criteria outlined in the underlying Framework. The assessment is solely based on the information provided in the annual report, and the scope of work of the limited assurance is limited solely to the eligibility criteria of assets in the Issuer's Green Asset Pool. The Issuer (Deutsche Bank) is responsible for the preparation of the report, including the application of methods and internal control procedures designed to ensure that the subject matter information is free from material misstatement.
2. The Framework was assessed as aligned with the Green Bond Principles as of June 2022.

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ASSESSMENT SUMMARY

REVIEW

SECTION

SUMMARY

EVALUATION

Part 1.

Alignment withthe Issuer's commitments set forth in theFramework

Deutsche Bank's Green Financing Instruments Report meets the Issuer's commitments set forth in the Green Financing Framework. The proceeds have been used to (re)finance the Green Asset Pool in accordance with theAligned eligibility criteria defined in the Framework.

Part 2.		The Green Financing Instruments Report is in line with
Alignment with		the HFIR. The Issuer follows core principles and, where
	applicable, key recommendations.
the Harmonised
Framework for		The Issuer reports annually and transparently illustrates		Aligned
Impact		the environmental impacts at the category level.
Reporting		Moreover, the Issuer has a system in place to identify
(HFIR)		and manage ESG risks connected to the projects
				financed and reports the allocation of proceeds in a
				single currency, euros.
	Part 3.			The allocation of the green financing instruments'
	Disclosure of			proceeds has been disclosed, with a detailed breakdown
			across different eligible project categories as proposed
	proceeds			in the Framework.3
	allocation and			Deutsche Bank's Green Financing Instruments Report			Positive
	soundness of
	reporting			has adopted an appropriate methodology to report the
	indicators			impact generated by providing comprehensive
				disclosure on data sourcing, calculations methodologies
				and granularity, reflecting best market practices.
Limited		Based on ISS-Corporate's Limited Assurance methodology,4 Parts I and
Assurance		II, and the sampling check assessment results, nothing has come to ISS-
Conclusion		Corporate's attention indicating that the information provided by

1. The assessment is based on the information provided in the Issuer's report. The Issuer is responsible for the preparation of the report, including the application of methods and procedures designed to ensure that the subject matter information is free from material misstatement.
2. ISS-Corporate'slimited assurance procedure is based on common market practices and voluntary guidelines, such as ISAE 3000. It solely relies on the analysis of the information provided by the Issuer, which remains the responsibility of the Issuer, including data on the allocation of proceeds, project descriptions, sample portfolios and impacts of projects. The External Review was conducted through desk- based analysis, and no on-site visits were conducted. However, limited assurance reviews have inherent limitations, and they may not be able to detect all instances of noncompliance in the matters being reviewed, including fraud, error, or noncompliance. ISS-Corporate prepared this External Review for the Issuer and does not assume any responsibility for any reliance on this report by any persons or users other than the party for whom it was prepared.

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Deutsche Bank in its Report does not present fairly, in all material respects, the allocation of the instruments' proceeds to eligible green projects as described in Deutsche Bank's Green Financing Framework.

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REPORT REVIEW ASSESSMENT

PART I: ALIGNMENT WITH COMMITMENTS SET FORTH IN THE GREEN FINANCING FRAMEWORK5

The following table evaluates the Green Financing Instruments Report against the commitments set forth in Deutsche Bank's Framework, which are based on the core requirements of the Green Bond Principles and best market practices.

	GBP			OPINION			ALIGNMENT
										WITH
										COMMITME
										NT
	1.	Use of			Deutsche Bank confirms to follow the Use of Proceeds'
			description provided by the Green Financing Framework.
			Proceeds
					The report is in line with the initial commitments set in
						Deutsche Bank's Green Financing Framework, as the
						proceeds have been used to finance assets from the
						Green Asset Pool.
						The Issuer's green categories align with the project
						categories and are in accordance with the eligibility
						criteria set in Deutsche Bank's Green Financing
						Framework. Environmental benefits at category level are
						described and quantified subject to data availability
						(consistent with the expectations set in the Green
						Financing Framework). Benefits for the Renewable
						Energy and Green Buildings categories have been fully
						quantified. For information	and communications
						technology (ICT), energy efficiency and clean
						transportation categories, no data is available.
						The Issuer defines exclusion criteria for harmful project
						categories, in line with best market practice.
2.	Process for		Deutsche Bank has revised the project evaluation and
	selection process with respect to the initial description
			Project
				provided by the Green Financing Framework. The Green
			Evaluation
				Financing Forum has been replaced by a formalized
			and
				Green Asset Pool inclusion process. The process entails
			Selection
				the following steps:

5 Deutsche Bank's Green Financing Framework was assessed as aligned with the GBP as of June 2022.

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• Screening and pre-selection of green assets conducted by the operating business units
• Internal validation of the pre-selected assets conducted by Group Sustainability and Treasury

The change has been stated in the Issuer's Green Financing Instruments Report and detailed information on the updated process can be found in the Issuer's Sustainable Instruments Framework.6

The selected projects are defined and structured in a congruous manner. The Issuer ensures compliance with the Eligibility Criteria. ESG risks associated with the project categories are identified and managed appropriately via an environmental and social due diligence.

3. Manageme		Deutsche Bank	confirms to	follow the	Process	for
	Management of	Proceeds	description	provided	by
nt of
	Deutsche Bank's Green Financing Framework. The report
Proceeds
	is in line with the initial commitments set in the Green
		Financing Framework.

The proceeds collected represent 100% of the amount allocated to eligible projects of the Green Asset Pool, with no exceptions. The proceeds are tracked appropriately and recorded in the Issuer's Green Asset Inventory. The Issuer conducts routine internalmonitoring of the Green Asset Inventory.

4. Reporting	Deutsche Bank's Green Financing Instruments Report is
consistent with the reporting description provided by its
	Green Financing Framework. The report is in line with the
	initial commitments set in the Green Financing
	Framework:
	▪ It is presented clearly that 100% of the proceeds
	are allocated to assets of the Green Asset Pool.
	▪ The reporting is conducted annually.
	▪ The amount of Green Liabilities is reported by
	instrument type (Bonds, Structured Notes, or

6 Deutsche Bank Sustainable Instruments Framework (January 2024) - Section 2.3: https://investor-relations.db.com/files/documents/Sustainable-Financing/SustainableInstrumentsFramework-January2024.pdf.

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				Deposits). However, as anticipated in the Issuer's
				Green Financing Framework, while proceeds are
				used entirely to finance assets pertaining to the
				Green Assets Pool, the allocation is not done at
				the asset level. Although proceeds might have
				been used to refinance projects from previous
				years, all financed assets meet the eligibility
				criteria stipulated in the Issuer's Green Financing
				Framework and are included in the Issuer's Green
				Asset Pool. The Green Asset Pool is
				overcollateralized, ensuring that there are always
				green assets to be financed.
				The "Allocation Reporting" and "Impact Reporting"
				sections of the Green Financing Instruments Report
				comply with the pre-issuance commitment expressed in
				the Framework. The report is intended to be publicly
				available on the Issuer's website in the section dedicated
				to investor relations.
				Deutsche Bank is transparent regarding the level of
				impact reporting and the information reported, in line
				with best market practices. Moreover, the Issuer defines
				the frequency of the impact reporting (annually) and its
				duration (until there are no green financing instruments
				outstanding), according to best market practices.
				Further analysis of this section is available in Part III of this
				report.
	5. Verification			ISS-Corporate has provided a Second Party Opinion (SPO) on Deutsche
			Bank's Green Financing Framework.

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PART II: ASSESSMENT AGAINST THE ICMA HARMONISED FRAMEWORK FOR IMPACT REPORTING

Reporting is a core component of the Green Bond Principles and transparency is of particular value in communicating the expected and/or achieved impact of projects in the form of annual reporting. Green bond issuers are required to report on both the use of green bond proceeds and the environmental impacts at least annually until full allocation or maturity of the bond. The HFIR has been chosen as benchmark for this analysis as it represents the most widely adopted standard.

The table below evaluates Deutsche Bank's Green Financing Instruments Report against the HFIR.

CORE PRINCIPLES

	ICMA HFIR			GREEN FINANCING INSTRUMENTS REPORT		ASSESSMENT
				Deutsche Bank has reported within one year of
Reporting on an		issuance and all proceeds have been fully
annual basis		allocated. The report will be available on
				Deutsche Bank's website.
				The assessment and measurement of the
				impacts generated by Deutsche Bank's Green
				Financing Instruments is presented at category
				level, with results reported for the Green Asset
				Pool during 2023. The following areas are
				covered:
				▪ Renewable Energy (solar, wind, biomass
				and hydropower), including	installed
				capacity (in MW), production (in
	Illustrating the			MWh/year), and avoided emissions (in
	environmental impacts			tCO2e/year).
	or outcomes			▪ Green Buildings, including final energy
				savings (in MWh/year) and	avoided

emissions (in tCO2e/year).

• ICT (data centers), including average annual power usage effectiveness (PUE). Avoided emissions have not been calculated due to lack of data.
• For clean transportation and energy efficiency, no impact has been calculated due to lack of data.

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The categories that have no impact reported due to a lack of data represent a small share, 5.8%, ofthe Issuer's Green Asset Pool.

The Issuer has a due diligence process in place

ESG Risk Management

to identify and manage ESG risks connected to

the projects financed. Group Sustainability

oversees the process.

Allocation of proceeds

All proceeds have been reported in euros.

- Transparency on the

currency

RECOMMENDATIONS

ICMA HFIR

GREEN FINANCING INSTRUMENTS REPORT

ASSESSMENT

Define and

The entirety of proceeds has been allocated to

disclose period

Green Assets. The Green Financing Instruments

and process for

Report covers the reporting period from Jan. 1,

Project Evaluation

2023, to Dec. 31, 2023. The allocation and

and Selection

impact of Deutsche Bank's Green Financing

Instruments is detailed by the information

provided.

Disclose total

A total of EUR 5.965 billion has been raised

amount of

through the Issuer's Green Financing

proceeds allocated

Instruments. 100% of their proceeds have been

to eligible

allocated to the Issuer's Green Asset Pool.

disbursements

Formal internal

The Issuer followed a transparent process for the

process for the

allocation of proceeds.

allocation of

proceeds and to

report on the

allocation of

proceeds

Reporting is conducted at the portfolio level.

Report at project

The

Green

Financing

Instruments Report

includes the total amount of proceeds allocated

or portfolio level

to the Green Asset Pool and the total assets in

the

pool

by eligible

category and

per

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