Sustainable corporate governance
A legally compliant and socially acceptable corporate governance forms the basis of the economic success of the Deka Group, as well as for the fostering of sustainable development. Important principles and elements of sustainable corporate governance are documented in the following. These include, in particular, the management of sustainability-related reputational risks, as well as the question of how to develop and implement viable measures to improve the sustainability performance of the Deka Group as part of systematic idea and innovation management. ESG rating agencies provide honest feedback on the sustainability-related measures of the Deka Group, with independent analyses and evaluations of our services.
Prevention of money laundering and terrorist financing
Basic information in the Sustainability Report 2024
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
Through the work directive “Group-wide minimum standards for the prevention of money laundering and terrorist financing”, DekaBank as the parent company defines the mandatory obligations in line with the German Money Laundering Act (Geldwäschegesetz, GwG) and the German Banking Act (Kreditwesengesetz, KWG) on the basis of the annual risk analysis. This ensures transparency for customers and regarding the underlying shareholder structure in Germany, as well as at the subsidiaries. The overall risk of the Deka Group being misused for the purposes of money laundering and terrorist financing is categorised as low, with no change compared to the previous year, on the basis of the annual risk analysis.
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
Through the work directive “Group-wide minimum standards for the prevention of money laundering and terrorist financing”, DekaBank as the parent company defines the mandatory obligations in line with the German Money Laundering Act (Geldwäschegesetz, GwG) and the German Banking Act (Kreditwesengesetz, KWG) on the basis of the annual risk analysis. This ensures transparency for customers and regarding the underlying shareholder structure in Germany, as well as at the subsidiaries. The overall risk of the Deka Group being misused for the purposes of money laundering and terrorist financing is categorised as low, with no change compared to the previous year, on the basis of the annual risk analysis.
Further information
You can find further information on the addressed topics on the Deka Group’s website and/or in relevant documents.
Deka Group’s website:
You can find further information on the addressed topics on the Deka Group’s website and/or in relevant documents.
Deka Group’s website:
Compliance with sanctions and embargoes
Basic information in the Sustainability Report 2024
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
As the parent company, DekaBank defines requirements for compliance with applicable sanctions and embargoes, as well as for the implementation of measures under sanction law, through the “Group-wide minimum standards for financial sanctions”. In particular, in light of the complex development of the sanction environment – especially due to the Russian war of aggression against Ukraine and the ongoing Middle East conflict and associated tense geopolitical situation – the identification of risks and compliance with sanctions are essential for the Deka Group. In order to identify and control risks in connection with sanctions and embargoes, transactions and customer/business partner relations are inspected in relation to applicable sanction lists, amongst other measures. In addition, a technical solution is implemented to identify sanctions in relation to trading with financial instruments.
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
As the parent company, DekaBank defines requirements for compliance with applicable sanctions and embargoes, as well as for the implementation of measures under sanction law, through the “Group-wide minimum standards for financial sanctions”. In particular, in light of the complex development of the sanction environment – especially due to the Russian war of aggression against Ukraine and the ongoing Middle East conflict and associated tense geopolitical situation – the identification of risks and compliance with sanctions are essential for the Deka Group. In order to identify and control risks in connection with sanctions and embargoes, transactions and customer/business partner relations are inspected in relation to applicable sanction lists, amongst other measures. In addition, a technical solution is implemented to identify sanctions in relation to trading with financial instruments.
Further information
You can find further information on the addressed topics on the Deka Group’s website and/or in relevant documents.
Deka Group’s website:
You can find further information on the addressed topics on the Deka Group’s website and/or in relevant documents.
Deka Group’s website:
Handling conflicts of interest
Basic information in the Sustainability Report 2024
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
The Board of Management is responsible for establishing, approving and monitoring the implementation and upholding of effective directives for the identification, assessment, management and mitigation of actual and potential conflicts of interest and has tasked the Compliance unit to manage conflicts of interest.
Principles for handling conflicts of interest are implemented in the Deka Group that apply to all employees and all relevant companies within the group. According to the principles, all appropriate measures must be taken to identify conflicts of interest and to avoid or resolve them. If conflicts of interest cannot be avoided or sufficiently resolved, they must be disclosed as ultima ratio.
The Deka Group principles for handling conflicts of interest specify
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
The Board of Management is responsible for establishing, approving and monitoring the implementation and upholding of effective directives for the identification, assessment, management and mitigation of actual and potential conflicts of interest and has tasked the Compliance unit to manage conflicts of interest.
Principles for handling conflicts of interest are implemented in the Deka Group that apply to all employees and all relevant companies within the group. According to the principles, all appropriate measures must be taken to identify conflicts of interest and to avoid or resolve them. If conflicts of interest cannot be avoided or sufficiently resolved, they must be disclosed as ultima ratio.
The Deka Group principles for handling conflicts of interest specify
- under what circumstances a conflict of interest that could significantly damage the interests of one or more customers has occurred or could occur;
- what procedures should be initiated and what measures should be taken to prevent or manage these conflicts.
If employees of the Deka Group have evidence that points to actual or potential conflicts of interest, these must be notified immediately to the Compliance corporate center, to assess whether it is indeed a conflict of interest. In addition, the Compliance unit evaluates with the input of the respective unit whether the measures already taken or those that are planned are adequate for prevention, resolution or observation, whether the management or other internal units should be informed, and whether the conflict of interest must be disclosed.
The management of conflicts of interests is addressed in the regular compliance reports. The reports contain ongoing information about the activities where a conflict of interest occurred or may occur, as well as about the measures that have been taken to resolve, avoid or mitigate the conflict of interest. If needed, there may be ad hoc reporting.
Further information
You can find further information on the addressed topics on the Deka Group’s website and/or in relevant documents.
Deka Group’s website:
You can find further information on the addressed topics on the Deka Group’s website and/or in relevant documents.
Deka Group’s website:
Management of sustainability-related reputational risks
Basic information in the Sustainability Report 2024
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
The interdependencies between ESG and reputational risks are taken into account by means of holistic reputational risk management. To be able to counter reputational risks effectively and consistently, the Deka Group has established a groupwide uniform methodology and governance for the management of reputational risks in connection with its business activities. In this context, ESG-driven reputational risks are taken account of as part of the risk inventory and business processes.
Three-Lines-of-Defense Model (3LoD Model) for the management of ESG risks
ESG-driven reputational risks are explicitly reflected as basic risk scenarios in the reputational risk management and are part of the strategic corporate governance in the form of risk quantification. Apart from dealing with the status quo, the Deka Group ensures the proactive management especially also of ESG-related reputational risks. On the basis of the 3LoD Model, 1LoD identifies the reputational risk inherent in the activities it is responsible for and carries out an initial assessment – for address risks with incorporation of 2LoD as a back-office function. If a set risk level is exceeded, a business activity may no longer be approved. If 1LoD continues to pursue its plan, 2LoD – in this case in the reputation management function – must carry out an independent second assessment of the business activity. If this confirms a significantly high critical level from the point of view of the corporate group, the Board of Management holds the final approval authority.
The reputational risk management mandate for the independent second assessment is handled in joint responsibility by the Risk Controlling and Board Staff & Communications units in the Reputational Risk Task Force. Their mandate comprises the independent and objective assessment of the short-term to medium-term consequences of all relevant business activities for the reputation of the Deka Group with regard to its stakeholders. For activities that are considered critical, there is a reservation of authority by the Board of Management or, in the case of subsidiaries, a reservation of authority by the management.
Definition of a reputational risk tolerance
The business and risk strategy of the company constitutes the assessment framework for these votes. It is to be extended, following ongoing discussions between the business units of the group over the course of 2025, with an explicit reputational risk tolerance – analogous to the concept of risk appetite – as an operative guidance framework for the careful handling of particularly sensitive areas of business activities, from a reputational risk point of view. The aim of this measure is not only a coherent outward image that is transparent for stakeholders but at the same time explicit effectiveness with regard to the employees and therefore the fostering of an effective risk culture.
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
The interdependencies between ESG and reputational risks are taken into account by means of holistic reputational risk management. To be able to counter reputational risks effectively and consistently, the Deka Group has established a groupwide uniform methodology and governance for the management of reputational risks in connection with its business activities. In this context, ESG-driven reputational risks are taken account of as part of the risk inventory and business processes.
Three-Lines-of-Defense Model (3LoD Model) for the management of ESG risks
ESG-driven reputational risks are explicitly reflected as basic risk scenarios in the reputational risk management and are part of the strategic corporate governance in the form of risk quantification. Apart from dealing with the status quo, the Deka Group ensures the proactive management especially also of ESG-related reputational risks. On the basis of the 3LoD Model, 1LoD identifies the reputational risk inherent in the activities it is responsible for and carries out an initial assessment – for address risks with incorporation of 2LoD as a back-office function. If a set risk level is exceeded, a business activity may no longer be approved. If 1LoD continues to pursue its plan, 2LoD – in this case in the reputation management function – must carry out an independent second assessment of the business activity. If this confirms a significantly high critical level from the point of view of the corporate group, the Board of Management holds the final approval authority.
The reputational risk management mandate for the independent second assessment is handled in joint responsibility by the Risk Controlling and Board Staff & Communications units in the Reputational Risk Task Force. Their mandate comprises the independent and objective assessment of the short-term to medium-term consequences of all relevant business activities for the reputation of the Deka Group with regard to its stakeholders. For activities that are considered critical, there is a reservation of authority by the Board of Management or, in the case of subsidiaries, a reservation of authority by the management.
Definition of a reputational risk tolerance
The business and risk strategy of the company constitutes the assessment framework for these votes. It is to be extended, following ongoing discussions between the business units of the group over the course of 2025, with an explicit reputational risk tolerance – analogous to the concept of risk appetite – as an operative guidance framework for the careful handling of particularly sensitive areas of business activities, from a reputational risk point of view. The aim of this measure is not only a coherent outward image that is transparent for stakeholders but at the same time explicit effectiveness with regard to the employees and therefore the fostering of an effective risk culture.
Further information
No further information is currently available on this specific topic.
No further information is currently available on this specific topic.
Taxes
Basic information in the Sustainability Report 2024
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
General principles
As part of the Sparkassen-Finanzgruppe with its public-law sponsorship, the Deka Group fully complies with all requirements under tax law, in all relevant business activities and in all its companies. Wherever it operates, the Deka Group complies with the applicable tax laws and regulations with regard to its own tax liabilities and all banking services and products offered.
The Deka Group unequivocally refutes offensive tax evasion strategies and profiting economically from its own tax status, Artificial, abusive tax structuring without non-tax substance and without a business basis is not carried out by foreign subsidiaries, branches and representative offices either in Germany or abroad.
The stated principles reflect the tax compliance culture of the Deka Group as part of its Tax Compliance Management System (Tax CMS). The Tax CMS was last certified in the year 2023 by an external assessor in terms of its appropriateness and effectiveness in accordance with the principles of proper auditing of compliance management systems of the Institute of Public Auditors in Germany (IDW PS 980).
Group transfer prices
The Deka Group consists of DekaBank Deutsche Girozentrale (DekaBank) and its domestic and foreign subsidiaries. In addition, it runs sites and has representatives abroad. The Deka Group is committed to the basic principle that the profits of a company should be taxed where value is created. The business relations with its local foreign units are organised according to the Arm’s Length Principle and the regulations of international tax law, as well as local tax laws.
The activities within the Deka Group are calculated as source-specific with the help of the cost-plus method. In justified exceptional cases, there is a deviation from the cost-plus method in favour of the profit-split method. The internationally applicable transfer price regulations are observed for all decisions in order to set proper transfer prices that are accepted by all the involved tax authorities. In Germany, the transfer prices are reviewed annually as part of the company audit by the Federal Central Tax Office.
Low-tax countries and preferential tax regime locations that offer tax benefits for business relocations are avoided. Nor is any income generated from low-tax countries or preferential tax regime locations as defined by the Foreign Tax Act. These principles are implemented by means of numerous written directives and procedures for the fulfilment of tax duties, with clear assignments of responsibility and with concrete instructions and guidelines for the employees. In accordance with this, the following actions, alongside others, are not permitted:
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
General principles
As part of the Sparkassen-Finanzgruppe with its public-law sponsorship, the Deka Group fully complies with all requirements under tax law, in all relevant business activities and in all its companies. Wherever it operates, the Deka Group complies with the applicable tax laws and regulations with regard to its own tax liabilities and all banking services and products offered.
The Deka Group unequivocally refutes offensive tax evasion strategies and profiting economically from its own tax status, Artificial, abusive tax structuring without non-tax substance and without a business basis is not carried out by foreign subsidiaries, branches and representative offices either in Germany or abroad.
The stated principles reflect the tax compliance culture of the Deka Group as part of its Tax Compliance Management System (Tax CMS). The Tax CMS was last certified in the year 2023 by an external assessor in terms of its appropriateness and effectiveness in accordance with the principles of proper auditing of compliance management systems of the Institute of Public Auditors in Germany (IDW PS 980).
Group transfer prices
The Deka Group consists of DekaBank Deutsche Girozentrale (DekaBank) and its domestic and foreign subsidiaries. In addition, it runs sites and has representatives abroad. The Deka Group is committed to the basic principle that the profits of a company should be taxed where value is created. The business relations with its local foreign units are organised according to the Arm’s Length Principle and the regulations of international tax law, as well as local tax laws.
The activities within the Deka Group are calculated as source-specific with the help of the cost-plus method. In justified exceptional cases, there is a deviation from the cost-plus method in favour of the profit-split method. The internationally applicable transfer price regulations are observed for all decisions in order to set proper transfer prices that are accepted by all the involved tax authorities. In Germany, the transfer prices are reviewed annually as part of the company audit by the Federal Central Tax Office.
Low-tax countries and preferential tax regime locations that offer tax benefits for business relocations are avoided. Nor is any income generated from low-tax countries or preferential tax regime locations as defined by the Foreign Tax Act. These principles are implemented by means of numerous written directives and procedures for the fulfilment of tax duties, with clear assignments of responsibility and with concrete instructions and guidelines for the employees. In accordance with this, the following actions, alongside others, are not permitted:
- Support for transactions that create the appearance of tax evasion
- Assessment of remuneration based on tax savings of customers or business partners
- Participation in transactions with the purpose of anonymous participation in offshore companies in violation of notification obligations
- Collaboration with a customer or business partner to abuse foreign legal systems
- Dividend arbitrage transactions in any form
On the basis of these guidelines, the Deka Group does not act or advise in the interests of establishing international structures with the aim of evading taxes. There is no participation in transactions with international structures if it is evident that they intend to avoid taxes. he Deka Group observes both (supreme court) financial case law and (financial) administrative opinion in the form of guidelines, decrees, rulings and letters and takes a risk-averse interpretation of the law in cases of doubt. It communicates actively, transparently and constructively with the relevant tax authorities on an ad hoc basis.
In addition, DekaBank is in direct and close professional contact with the tax authorities responsible for tax matters, the Hessian Ministry of Finance (HMdF), as well as the Federal Ministry of Finance (BMF). DekaBank can express its standpoint on specific tax matters indirectly through the associations, e.g. German Savings Banks Association (Deutscher Sparkassen- und Giroverband e. V., DSGV), German Investment Funds Association (Bundesverband Investment und Asset Management e. V., BVI), Association of German Public Banks (Bundesverband Öffentlicher Banken Deutschlands, VÖB) and German Structured Securities Association (Bundesverband für strukturierte Wertpapiere, BSW). Further professional communication on tax matters of DekaBank can take place through its own statements, articles and participation in the workgroups of the associations, especially if DekaBank and/or its stakeholders could be affected by changes in tax law or its interpretation.
Further information
No further information is currently available on this specific topic.
No further information is currently available on this specific topic.
Idea management
Basic information in the Sustainability Report 2024
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
The DekaBank idea management for the Deka Group takes place via a web-based platform, through which the employees of the Deka Group can input their ideas for improving processes or for new products and services. The crowd-sourcing approach of this platform allows employees to participate actively in the further development and evaluation of the ideas published on the platform. Indications of potential problems and risks are also helpful for the respective division that decides whether to implement an idea.
In the year 2024 alone, employees submitted a total of 104 ideas (compared to 81 in 2023). A total of six ideas were awarded cash prizes for a total of 1,500 euros. The savings or additional revenue due to the suggestions amounted to 142,200 euros. The high sum is due to the ideas submitted in the two previous years, whose annual savings are each spread over three years.
S Broker AG & Co KG joined the DekaBank idea management as of 1 January 2024.
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
The DekaBank idea management for the Deka Group takes place via a web-based platform, through which the employees of the Deka Group can input their ideas for improving processes or for new products and services. The crowd-sourcing approach of this platform allows employees to participate actively in the further development and evaluation of the ideas published on the platform. Indications of potential problems and risks are also helpful for the respective division that decides whether to implement an idea.
In the year 2024 alone, employees submitted a total of 104 ideas (compared to 81 in 2023). A total of six ideas were awarded cash prizes for a total of 1,500 euros. The savings or additional revenue due to the suggestions amounted to 142,200 euros. The high sum is due to the ideas submitted in the two previous years, whose annual savings are each spread over three years.
S Broker AG & Co KG joined the DekaBank idea management as of 1 January 2024.
Further information
No further information is currently available on this specific topic.
No further information is currently available on this specific topic.
Innovation management
Basic information in the Sustainability Report 2024
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
Innovation management is an active and important building block for further developing the business and process model of the Deka Group. It is accompanied by the Open Digital Factory (ODF) that is specialised in innovation and is linked within the group by means of the innovation board. This strengthens the innovation culture of the Deka Group and draws the attention of all employees to possible innovations. In addition, new trends and technologies are identified, evaluated and their implementation is tested in derived use cases.
A formal innovation process was instigated some years ago as a central tool in innovation management and it has been regularly developed further. It is performed three times a year. It is available in all areas of the Deka Group and actively involves employees from the teams involved in the respective innovation case.
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
Innovation management is an active and important building block for further developing the business and process model of the Deka Group. It is accompanied by the Open Digital Factory (ODF) that is specialised in innovation and is linked within the group by means of the innovation board. This strengthens the innovation culture of the Deka Group and draws the attention of all employees to possible innovations. In addition, new trends and technologies are identified, evaluated and their implementation is tested in derived use cases.
A formal innovation process was instigated some years ago as a central tool in innovation management and it has been regularly developed further. It is performed three times a year. It is available in all areas of the Deka Group and actively involves employees from the teams involved in the respective innovation case.
Further information
No further information is currently available on this specific topic.
No further information is currently available on this specific topic.
ESG-Ratings
Basic information in the Sustainability Report 2024
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
DekaBank is an issuer of public bonds, mortgage bonds, bearer bonds and certificates under the Green Bond Framework. The successful placement of these securities also depends increasingly on whether DekaBank can meet the requirements of the increasing number of sustainability-orientated investors, who regularly consult ESG ratings as a decision-making aid during their investment process.
DekaBank therefore pays close attention to compliance with the criteria of the ESG rating agencies to be able to place their bonds successfully on the market. Furthermore, the criteria of the agencies reflect the requirements of important stakeholders of the Deka Group – for example of environmental associations, human rights organisations and trade unions. DekaBank also uses the ESG ratings as a basis for a regular strengths-weaknesses analysis regarding its own ESG potential – also compared to other banks.
The Deka Group is currently analysed and assessed by the following ESG rating agencies. It should be noted that the ESG ratings are not updated annually as a rule, so that the most up-to-date evaluation could also refer to the year 2023 or 2024:
There is no information on this specific topic in the Sustainability Report 2024.
Supplementary information
DekaBank is an issuer of public bonds, mortgage bonds, bearer bonds and certificates under the Green Bond Framework. The successful placement of these securities also depends increasingly on whether DekaBank can meet the requirements of the increasing number of sustainability-orientated investors, who regularly consult ESG ratings as a decision-making aid during their investment process.
DekaBank therefore pays close attention to compliance with the criteria of the ESG rating agencies to be able to place their bonds successfully on the market. Furthermore, the criteria of the agencies reflect the requirements of important stakeholders of the Deka Group – for example of environmental associations, human rights organisations and trade unions. DekaBank also uses the ESG ratings as a basis for a regular strengths-weaknesses analysis regarding its own ESG potential – also compared to other banks.
The Deka Group is currently analysed and assessed by the following ESG rating agencies. It should be noted that the ESG ratings are not updated annually as a rule, so that the most up-to-date evaluation could also refer to the year 2023 or 2024:
- The ESG rating agency ISS ESG evaluated the Deka Group with the effective date of August 2023 with grade C on the scale ranging from A+ (best grade) to D-. On the basis of this evaluation, the Deka Group is given “prime status” by ISS ESG. It is accorded to companies that comprehensively fulfil the core requirements for dealing with the subject of sustainability defined by the agency.
- The ESG rating agency MSCI ESG rated the Deka Group with the third best grade A on the scale of AAA to CCC (effective date: September 2024), confirming once again the consistent high level of the sustainability-related measures within the Deka Group.
- The ESG rating agency Sustainalytics belonging to Morningstar certified the Deka Group with a rating of 16.3 “Low Risk” on the scale ranging from 40+ to 0 (best grade) as having low exposure to ESG risks (effective date January 2024). It therefore acknowledges the comprehensive measures of the Deka Group for handling ESG-related risks.
- Moody’s ESG Solutions has no longer been publishing its own ESG ratings of ESG performance since the turn of 2024/2025. It will use the MSCI ratings in future. The rating by Moody’s ESG Solutions (effective date December 2024) with a result of ESG overall Score: Robust 55/100 was therefore the last rating by this rating agency.
Further information
You can find further information on the addressed topics on the Deka Group’s website and/or in relevant documents.
Deka Group’s website: