Americas Region Reputational Risk Committee Policy

Americas Region Reputational Risk Committee Policy Deutsche Bank Presentations to the ARRC must be made by at least one person of Managing Director or Director level. The person making the presentation must: • clearly identify the issues; • set out what has been done, or is proposed to be done, to deal with the issues; and • carefully consider why DB should go ahead with the proposal in light of the issues posed. Primary drafting responsibility lies with the business line presenting the proposal, however, assistance may be sought from Legal and Compliance. A comprehensive proposal paper must be prepared and circulated within a reasonable time prior to the ARRC meeting through the Committee Secretary. There is no fixed format for a proposal paper, which should be tailored to the particular circumstances of the proposal, and should address the following issues, at a minimum: • A clear description of the proposal/transaction; • Explanation of what work has been done so far and a list of which infrastructure sign offs have been obtained (particularly Legal and Compliance); • Description of the diligence done on the counterparty or other relevant players; • Identification of the legal entities involved in the transaction or business; and • Identification of the reputational risk issues, analysis of such risks and details of the business line's view of how such risks can be mitigated or managed. The paper supporting the proposal should anticipate as much as possible the wide range of questions that a proposal of its nature might expect to attract at an ARRC meeting. For all CB&S proposals, a pre-clearance from Jeff Mayer, business head for CB&S, is required before the transaction is reviewed by the ARRC. For all LATAM proposals, a pre-clearance from Bernardo Parnes, the regional CEO of the Latin America region, is required. For all DBAG NY Branch proposals, a pre-clearance from Bill Woodley, the branch general manager, is required. For all Canada or Cayman proposals, a pre-clearance from Scott Lampard or Janet Hislop, the Chief Country Officers of Canada and Cayman respectively, is required. For all DBAG Cayman Islands Branch proposals, a pre-clearance from Carol Saracco, the branch general manager, is required. The presenter(s) of the proposal will be informed of the ARRC's decision after the meeting, by the Committee Secretary, the Chairman or by a nominated member. 5.4 Quarterly Meetings Quarterly meetings will be held to review the regional reputational risk profile and direction; trends in reputational risk and any adjustments required to the regional reputational risk appetite. The agenda for the quarterly meetings will include: • Review of risk appetite; • Review of global and regional trends; • Update of regional reputational risk tolerances; • Update on the past quarter's reviewed transactions, including evidence of closure for conditions of approval; • Topical review of articles on competitors, industry trends; • Review of AWM reputational risk issues; and • Adjustment, if necessary, of regional reputational risk appetite. 6 For internal use only CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0028804 CONFIDENTIAL SDNY_GM_00174988 EFTA01343866