Commerzbank : UK Modern Slavery Act Statement der Commerzbank 2023 downloaden (uk modern slavery act statement 2023)

2023 Modern Slavery

and Human Trafficking Statement

Commerzbank AG

Introduction

Welcome to our eighth Modern Slavery and Human Trafficking statement.

This statement is made by Commerzbank AG (the "Bank") pursuant to Section 54 of the United Kingdom's Modern Slavery Act 2015 and applies to Commerzbank Aktiengesellschaft, Commerzbank UK Limited and Commerzbank Finance Limited for the financial year ending 31 December 2023.

This statement details the actions the Bank has taken during the 2023 financial year and continues to take to mitigate the risks of slavery and human trafficking being facilitated through the Bank's business, operations and supply chains.

Whilst covered in part in this statement, detailed information on our broader approach to managing

environmental and social risks can be found in our Annual Report 2023

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Contents

04	05	06		07				08	09

Our Commitment	Our Strategy	Our Values	Our Code		Our Business		Products
															of Conduct		and Clients		and Services
0317								16	15		13	11	10

Governance:	Governance:			Policies	Our Suppliers	Our Workforce	Client Controls
Oversight Controls	Responsibilities	and Procedures					Product Controls
18	19	20	21	22	23

Reporting MS&HT	Monitoring	Training	External Engagement	Commerzbank		Initiatives,
	and Investigation	and Awareness Raising	and Collaborations	Foundation		Memberships
						and Certifications
	29	28	27	26	25	24

Appendix A	Approval	Looking	German Supply Chain	ESG & Modern	Sustainability
	Slavery
		Ahead	Due Diligence Act	& Modern Slavery

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Our Commitment

Corporate responsibility is a guiding principle of Commerzbank: environmental, social and ethical aspects have a crucial role in the way we manage our company.

We believe companies can only be successful in business if their day-to-day activities are accepted by society and they meet their responsibility towards the environment and society. That is why we have firmly anchored sustainability as one of the four cornerstones of our strategy at Commerzbank. With our new net zero commitment among other things, we seek to live up to this responsibility and to actively contribute to the sustainable transformation of society and the economy. We have long had binding rules in place for handling environmental and social risks. Transparency and fairness towards our customers are one of the key pillars of sustainable business development.

Commerzbank's position on human rights is consistent with and follows internationally accepted human rights and corporate responsibility standards, including:

By participating in the UN Global Compact, Commerzbank has committed itself to*:

the Universal Declaration		the OECD's guidelines for
of Human Rights		Multinational Enterprises
the OECD's framework		the International Covenant
'Due Diligence for		on Economic, Social and
Responsible Corporate		Cultural Rights
Lending and Securities
Underwriting'
		United Nations Guiding
the International Covenant		Principles for Business and
	Human Rights
on Civil and Political Rights

the International Labour Standards of the International Labour Organisation

supporting	ensuring not to	safeguarding	standing up for	standing up for	promoting the
and respecting	be complicit in	the freedom of	the elimination	the abolition of	elimination of
the protection	human rights	association and	of all forms of	child labour	discrimination
of the	abuses	the effective	forced labour		in regard to
internationally		recognition			employment
proclaimed		of the right			and occupation
human rights		to collective
		bargaining

*Within the framework of the applicable laws and regulations, we have implemented these standards.

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Our Strategy

About 150 years ago, merchants from Hamburg, Germany founded Commerzbank with the aim of creating new prospects. The principles of the honourable merchant are still the foundation on which we stand.

Sustainability has been an integral part of our corporate strategy since 2020. Our current strategy "Moving Forward" is based on three pillars: Growth, Excellence, and Responsibility. At the core of our sustainability strategy is our commitment to becoming a net-zero bank. This applies to our own operations as well as to our loan and investment portfolio. To achieve this goal, we provide our clients with innovative product solutions and actively support them in their transformation toward sustainability.

Integrity is the foundation	Performance is our engine	Responsibility is our
of our business model	We do our best every day.	mission
To be in accordance with our	We enjoy taking ourselves	We are proud to take
values and rules, even if no one	further, and with it our team	responsibility. For our teams,
is watching - that is our basic	and Commerzbank. Because	our customers, our industry and
conviction. Integrity is what	only when our customers	society. Our future is borne by
can be expected of us since we	realize that they are becoming	all of us and Commerzbank is
expect it from ourselves.	more successful thanks to	committed to its contribution.
	Commerzbank, we are more
	successful as well.

Our Purpose:

"We create prospects for ambitious people

and companies."

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Our Values

Our corporate values shape our interaction both for co-operation and in our behaviour towards our customers, business partners and society. The values show that we are aware of our corporate responsibility and are guided by traditional values.

TRUST is the anchor of any promotion.	TRANSPARENCY and appreciation	RESPONSIBILITY shapes promotion.
This is about the reliability of a relationship. Right	are closely related.	Our foundation enables, supports and helps in
from the start, we spend a lot of time exchanging	The basis for this is, for example, open interaction with	relevant social areas, because we believe: Support
ideas and talking to our funding partners. Both sides	one another and dialog about expectations.	creates the future.
benefit from this.

RESPECT between the funding foundation	COURAGE is part of every	SUSTAINABILITY is the theme
and the project partner is the most	foundation's actions.	of our present and future.
important thing.	We see ourselves as a learning foundation. For us,	For us, it starts with structural and strategic issues in
By this we mean a mindful interest in each other,	it is important to keep trying out new things. A	the context of a funding partnership.
meeting at eye level, as well as opening up spaces	constructive culture of making mistakes is just as
for each other.	much a part of this as the joy of discovery.

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Our Code of Conduct

The Bank's Code of Conduct, which is globally binding for all its employees, sets out the Bank's values and its expectations of staff and includes a clear commitment to human rights.

Who it effects:

direct

employees

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04

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We behave as we expect others to behave.

We are attentive to the interests of our customers, act carefully and in accordance with the rules.

We are committed to society and take on responsibility.

We critically assess ourselves and manage risks and conflicts constructively.

We do not accept bribes and act honestly and in compliance with tax law.

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We do not give unauthorised persons access to data.

We respect digital values and are transparent with our customers on the use of their data.

We use service providers professionally and require their integrity.

We are mindful of our behaviour in public and seek out support when necessary.

For us, leadership means setting an example, trusting others and taking responsibility.

	Code of
customers	Conduct	suppliers
investors			shareholders
service providers	interested parties

Who it effects:

indirect

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Our Business and Clients

Commerzbank is the leading bank for the German Mittelstand (SMEs) and a strong partner for around 25,500 corporate client groups and almost 11 million private and small-business customers in Germany.

Outside Germany, the Bank

is represented through:

		Commerzbank	is	a
		leading		international
	"	commercial	bank	with
Commerz-	branches and offices in
almost 40 countries. In
bank AG is	the two business segments Private
and Small Business Customers, as
a listed
well as Corporate Clients, the Bank
" public	offers a comprehensive portfolio of
limited		financial services which is precisely
	aligned to the clients' needs.
company.
It is one of
the 40
companies
in the DAX		The			Polish
index of		subsidiary	mBank
Deutsche		is	an	innovative
	digital	bank.	It
Börse.
	serves around 5.8 million private
		and	corporate	customers, mainly
		in Poland but also in the Czech
		Republic and Slovakia.
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As a financial

institution and provider of capital,

we have an important role in

tackling MS&HT. Commerzbank does not want to become linked through our business relationships to any form of modern slavery. Commerzbank expressly stands up for its corporate responsibility and for the sustainable orientation of its business activities. For this reason, Commerzbank implements a variety of measures in various areas and carefully considers the economic, ecological and social consequences of how we do business with our clients. Our client due diligence and screening controls therefore encapsulate MS&HT considerations and risk assessments.

14	32	5
OPERATIONAL	REPRESENTATIVE	MATERIAL
FOREIGN BRANCHES	OFFICES	SUBSIDIARIES

on all continents; in the Corporate Clients' business, the Bank is present internationally in more than 40 countries

Complete list of holdings in affiliated and other companies

Products and Services

We combine advantages of a digitalised bank with personal advisory services, consistent customer focus, and sustainability. We intend to support our customers with relevant products and solutions and to further improve the customer experience across all channels and therefore strengthen our revenue base.

Our Products and Services

Private and Small-Business

Customers segment

We will expand the range of optimised and digital banking solutions for the Bank's almost 11 million customers. With a holistic approach and its two brands, Commerzbank and comdirect, all customer needs will be met - be it online or mobile, in our advisory centre, or across around 400 existing branches. Commerzbank is committed to offering every customer the right model for their daily banking needs. As a premium provider, Commerzbank aims to be first point of contact for demanding customers. Comdirect will strengthen its position as the primary digital bank with an expanded product range and its excellent brokerage platform.

Corporate Clients segment

Client orientation is our strength - we are the Bank for Germany. As the leading bank for the Mittelstand, Commerzbank will continue to closely support its corporate clients during their ongoing transformation. In line with our strategic plan until 2027, the Bank will maintain its strategy in corporate banking by targeted investments in products and digital solutions. We consistently consider all activities, products and processes from the client's perspective, as the needs of our corporate clients are the basis of our strategic orientation. In our international business, we accompany clients with a business relationship to Germany, Austria or Switzerland as well as from future industries.

TRANSACTION BANKING	INVESTMENT SOLUTIONS
Corporate Account	Investment Management
Cash Management	Pensions Management
Trade Finance	Equities & Liquidity Management
Electronic Banking	Risk Management

CORPORATE FINANCING
Working Capital Financing	CORPORATE FINANCE ADVISORY
Sureties & Guarantees	Advisory Services
Capital Expenditure	M&A Advisory
& Structured Finance
Capital Markets Financing

• Commerzbank transacts " approximately 30% of Germany's foreign trade.

Sustainable Products:

We are continuously expanding the share of sustainable products for our customers. One of our key sustainability goals is to reduce CO2 emissions from our credit and investment portfolio to "net zero" by 2050. See our ESG Framework where we set out the criteria we use to classify financial commitments and products as sustainable, and how we are making the composition of the sustainable business portfolio transparent.

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Client Controls	Product Controls

Using a risk based approach, where material issues, relating to any topic, are identified pre or post onboarding, a client/ transaction may be escalated to the

Regional Customer Governance Committee London ('RCGC') to assess the Bank's appetite for that relationship. MS&HT risks (e.g. slavery related adverse news against a counterparty) are raised and discussed by senior management (including the UK MLRO) during compliance governance meetings.

					Publication of a MS&HT statement
					is a standard agenda item discussed
					on 'Compliance2Compliance' due
Risk based enhanced due diligence	diligence calls held with high risk
clients. Commerzbank is proactive in
reviews of high risk customer files
engaging in MS&HT discussions with
	cover MS&HT red flags.
	our clients.

Local adverse media screening "top	Our pre and post client onboarding
ups" covering MS&HT are applied to	'Know Your Client' due diligence
pre-onboarding and rolling reviews	includes open source research
for all London Branch clients.	including Factiva and Dow Jones
Positive string searches will pick up	screening. This involves looking for
terms like "slave" and are escalated	references to potential slavery issues
to Financial Crime Compliance for	such as poor labour practices.
review.

The New Product Process ('NPP') is a Commerzbank Group wide approach which covers the setup and approval for new products and changes to existing products. The objective of the NPP is to identify, analyse and assess the embedded risks of any new activities including the impact on the overall risk profile and on the risk appetite of the Bank. Various departments are required to review and vote on each NPP request via the Bank's NPP tool, this includes Financial Crime Compliance.

For example, where a London nexus exists, the London Compliance Policy and Advisory team are required to assess the financial crime risks (including MS&HT risks) posed by each new product or change in product.

Each Support Unit's (i.e Compliance, Tax, Reputational Risk, Finance etc.) risk rating and overall assessment of NPPs may result in process amendments, changes in the IT environment, reporting requirements and any other risk-based controls/set conditions we see fit to manage any identified risks. Senior management approval and oversight is also part of the end-to-end NPP process.

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