A wide range of international standards and principles provide the framework for safeguarding human rights – including the supply chain. We committed ourselves many years ago to a number of these principles and regulations which fit our business model and are internationally recognised:

The Equator Principles are a voluntary set of rules issued by banks that comply with defined environmental and social standards in the area of project financing. As a participating institution, we undertake to finance only those projects in which the borrowers meet the environmental and social criteria of the Principles.

In the banking sector, respect for human rights is particularly important when financing infrastructure projects. This often involves dealing with local communities. In projects of this type, we adhere to the Equator Principles, thereby ensuring that all aspects of human rights are taken into account in our financing. We do this for two reasons: firstly, in order to avoid risks – both to the realisation of the projects and to the bank’s reputation. Secondly, to prevent negative consequences for the people affected by the financed projects.

The ILO core labour standards are social standards within the framework of the world trade order. They are intended to guarantee humane working conditions and adequate protection. DekaBank observes the core labour standards in various areas:

DekaBank’s suppliers are obliged to comply with the core labour standards of the International Labour Organisation. In addition, we do not provide financing to companies that violate the standards.

The entire Deka Group has put on its negative list the financing of companies that do not comply with the standards. These transactions may only be performed with special permission by the Board of Management.

We have supported the principles of the UN Global Compact since 2011. By committing ourselves to the ten principles, we obligate the bank, as part of responsible corporate governance, to respect human and labour rights, protect the environment and fight corruption and bribery. The principles refer to the aspects that are also defined as relevant in the CSR-RUG (CSR Directive Implementation Act).

Companies that sign the Global Compact should

• support and respect the protection of internationally proclaimed human rights
• make sure that they are not complicit in human rights abuses
• uphold the freedom of association and the effective recognition of the right to collective bargaining
• uphold the elimination of all forms of forced and compulsory labour
• uphold the effective abolition of child labour
• uphold the elimination of discrimination in respect of employment and occupation
• support a precautionary approach to environmental challenges
• undertake initiatives to promote greater environmental responsibility
• encourage the development and diffusion of environmentally friendly technologies
• work against corruption in all its forms, including extortion and bribery

 
DekaBank has been using its own sustainability filter to assess its own new investments since 2014. In line with the UN Global Compact, the filter comprises a catalogue of exclusion criteria for the areas of the environment, human and labour rights and corruption.

We also ensure that human rights are respected in our supply chain. DekaBank has defined requirements for the selection of suppliers that guarantee sustainability both in the quality of the products and services purchased and in the management of suppliers and service providers.

We present our sustainability declaration to our suppliers for signature before we enter into a business relationship with them. Among other things, suppliers undertake to comply with the core labour standards of the International Labour Organisation (ILO).

The German Supply Chain Act (Lieferkettensorgfaltspflichtengesetz—LkSG) came fully into force on January 1, 2023. The aim of the law is to protect fundamental human rights in companies' supply chains and, in particular, to enforce the prohibition of child and forced labour. Environmental concerns are also relevant here if they lead to human rights violations or serve to protect human health. In the first phase, the LkSG applies to companies that generally employ at least 3,000 workers in Germany. This means that DekaBank also falls within the scope of the LkSG. The implementation of the associated requirements has been carried out for DekaBank and its suppliers as well as for the subsidiaries, over which DekaBank exercises a determining influence.
 
To prepare for the implementation of the law, the initial situation and scope of application for the LkSG were analysed and the specific need for action was defined for DekaBank and the other relevant companies in the Deka Group. Responsibilities for the initial implementation of the legal requirements and for ensuring compliance with these requirements on a permanent basis were also defined. In the course of implementing the legal requirements, a chief human rights officer, Christoph Kehr-von Plettenberg, was appointed by the end of the 2022 financial year and a complaints procedure was set up in accordance with the requirements of the LkSG. In 2023 appropriate measures have been initiated to implement the LkSG, including risk analyses for the bank's own business division and direct suppliers. As required by the LkSG DekaBank reports transparently on the results of the analyses and the measures derived and published the policy statement required by the LkSG.

It also reports on the fulfillment of the due diligence obligations for the period from January 1 to December 31, 2023 in the questionnaire provided by the Federal Office of Economics and Export Control (BAFA).

The United Kingdom’s Modern Slavery Act 2015 refers to the responsibility of companies to abolish slave labour in the supply chain. It obligates all companies doing business in the United Kingdom to make a declaration in which they indicate what measures they take to ensure that there is no “slave labour” in their supply chain. The Deka Group has provided such a declaration.

Our Code of Ethics serves as a guideline for all employees, managers, members of the Board of Management and all those acting on behalf of the Deka Group. It is binding and ensures that everyone conducts him- or herself and acts ethically and morally.

If an employee does not comply with the Code of Ethics, this directly affects his or her salary: As part of the annual performance review, employees review with their manager whether they have behaved in accordance with the Code of Ethics. The variable remuneration may be reduced as a result of this review.

Particularly serious breaches of the Code of Ethics can lead to action under labour law, civil and criminal proceedings and even the termination of the contractual relationship.

Deka is active in a large number of different industry initiatives and associations. Within this framework, we exchange views with other industry players on sustainability-related issues and develop joint solutions.

The Sustainable Finance Advisory Council of the German federal government was founded in 2019, and Ingo Speich, Head of the Sustainability and Corporate Governance Department of Deka Investment GmbH, was appointed as a member.
He is also a member of the Consultative Working Group (CWG) of the Investor Protection and Intermediaries Standing Committee (IPISC) of the European Securities and Markets Authority (ESMA) and a member of the DVFA Commission Governance & Stewardship. The Sustainable Finance Advisory Council is committed to responsible interaction between companies and investors in the German capital market.

The Green and Sustainable Finance Cluster Germany (GSFCG) has been active since 2018. The Hub for Sustainable Finance (H4SF), established in summer 2017 by Deutsche Börse and the German Council for Sustainable Development (RNE), is an open network of financial market players and other stakeholders who actively contribute to a sustainable financial system in Germany. The Deka Group is a sponsor and represented on the cluster's standing committee.

DekaBank has been involved in the Verein für Umweltmanagement und Nachhaltigkeit in Finanzinstituten e.V. (VfU; Association for Environmental Management and Sustainability in Financial Institutions) since 2007. Johannes Behrens-Türk, Head of Sustainability Management at DekaBank, has been a voluntary member of the VfU’s Board of Management since 2016. DekaBank is also a member of Forum Nachhaltige Geldanlagen e.V. (FNG; Forum for Sustainable Investment) and the Corporate Responsibility Interface Center e.V. (CRIC), a non-profit association for the promotion of ethics and sustainability in financial investments.

Other international initiatives:

• As part of the PRI membership, Deka Investment GmbH also participates in joint engagement initiatives with other global investors like on the topic of cobalt and human rights. Among other things, it requested German automobile companies to increase the transparency about the supply chain for the procurement of cobalt in order to better identify and combat human rights violations.
• DekaBank has been a member of the ICMA’s Green Bond Principles since 2016. These principles serve internationally as a guideline for the issue process of “green securities”.
• DekaBank has been a partner of the Climate Bonds Initiative (CBI) since the end of 2018. The aim of the initiative is to integrate the international bond market more closely into the financing of climate protection and to support the market development of green and climate bonds. In cooperation with the CBI, DekaBank has already held various customer events on green bonds and developments in the sustainable finance market and supported a study on the German sustainable finance market.