dbÕæÈËÊÔÍæ

At dbÕæÈËÊÔÍæ, we encourage anybody connected with our business activities to 'speak up' through various channels, including the dbÕæÈËÊÔÍæ Global Compliance Hotline. The Hotline enables anyone who has a concern about the action of dbÕæÈËÊÔÍæ or its employees or representatives to submit a report securely and confidentially on potential issues, such as bribery, health and safety, environment, and human rights or any conduct that would not comply with dbÕæÈËÊÔÍæ business policies or with applicable laws and regulations.

Please note that the dbÕæÈËÊÔÍæ Global Compliance Hotline shall not be used for general complaints. If you would like to submit a general complaint, please contact the relevant department or business unit at dbÕæÈËÊÔÍæ.

Who can make a report via the dbÕæÈËÊÔÍæ Global Compliance Hotline?

The dbÕæÈËÊÔÍæ Global Compliance Hotline is intended to receive reports from anybody who has a concern, including but not limited to employees, contractors, suppliers, business partners, and third-party individuals, such as an employee of an dbÕæÈËÊÔÍæ customer or supplier.

What types of issues can be reported?

A report may concern any conduct that does not comply with dbÕæÈËÊÔÍæ’s Code of Conduct or other dbÕæÈËÊÔÍæ internal business polices, as well as any other violation of laws and regulations, particularly in the following areas:

• Bribery, corruption, influence peddling
• Fraud
• Money laundering, financial and accounting misconduct
• Conflicts of interest
• Anti-trust/competition issues
• Export control
• Information and data protection issues
• Product quality concern/ customer relations
• Retaliation against whistleblowers
• Health and safety
• Information security and physical security
• Harassment/Discrimination/Workplace related issues
• Human Rights
• Environmental issues

How can I report via the dbÕæÈËÊÔÍæ Global Compliance Hotline?

The dbÕæÈËÊÔÍæ Global Compliance Hotline is .

The Hotline is operated by a third-party vendor and is available 24 hours a day in several languages including French, German, Hebrew, Portuguese, and Spanish.

When submitting a report via the hotline, you will be asked to complete an electronic form, including the country where the events occurred, the nature of the issue and your identity if you choose to be identified in the report.

Once the form has been submitted, you will receive a unique code called a "report key", which, together with the password that you have chosen, will allow you to check your report for feedback or questions.

How will I be protected from retaliation?

dbÕæÈËÊÔÍæ prohibits any employee from retaliating or taking adverse action against anyone for raising or helping to resolve, in good faith, a concern related to the Code of Conduct or other dbÕæÈËÊÔÍæ internal business policies. Any such retaliation or threat of retaliation will be deemed to be a violation of the Code of Conduct and will be addressed.

Is it possible to submit an anonymous report?

The Hotline allows anonymous reporting.

The dbÕæÈËÊÔÍæ Global Compliance Hotline is a dedicated confidential resource accessible to all dbÕæÈËÊÔÍæ stakeholders worldwide. The third-party provider of the Hotline maintains strict confidentiality for all reports.

The Hotline allows for further exchanges with the author of the report while ensuring him/her to remain anonymous if he/she so wishes.

Anonymous calls are routed through dedicated dbÕæÈËÊÔÍæ telephone lines and personal information is not shared with anyone at dbÕæÈËÊÔÍæ.

How are reports reviewed and what are the timelines?

The report you submit through the dbÕæÈËÊÔÍæ Global Compliance Hotline is received in a secure environment and handled by a restricted number of trained personnel from the Compliance team. The head of the Compliance team will assign the report to the appropriate investigation team based on the nature of the report. The investigation team in charge will review the report expeditiously and ensure allegations are treated objectively and impartially. A member of the Compliance team will acknowledge receipt of the report within three business days. Within 15 business days of the acknowledgement, the Compliance team will assess if the report is actionable. If it determines that the report is not actionable, the author of the report will be informed of the decision and the reasons why. If the report is actionable, the Compliance team will work to complete an investigation with 3 months of receiving the report.

Contact detail

For any question or concern related to the dbÕæÈËÊÔÍæ Global Compliance Hotline or our general complaints mechanism you can contact Petra Vorwig by sending an e-mail to the following address:
[email protected]