Deutsche Bank : Second Party Opinion ISS October 2023

REPORT REVIEW

Deutsche Bank Impact Reporting Methodology report

Impact Reporting Methodology Deutsche Bank

12 October 2023

VERIFICATION PARAMETERS

Type(s) of reporting

Relevant standard(s)

Scope of verification

Lifecycle

Validity

• Impact Reporting Methodology
• Harmonised Framework for Impact Reporting (HFIR), updated June 2023, as administered by International Capital Market Association (ICMA)
• Harmonised Framework for Impact Reporting for Social Bonds (HFIRSB), updated June 2023, administered by the International Capital Market Association (ICMA)
• Deutsche Bank's Impact Reporting Methodology (as of October 5, 2023)
• Deutsche Bank's Sustainable Instruments Framework (as of October 5, 2023)
• Pre-issuanceverification
• As long as no changes are undertaken by the Issuer to its Impact Reporting Methodology as of October 5, 2023

© 2023 | Institutional Shareholder Services and/or its affiliates

R E P O R T R E V I E W

Impact Reporting Methodology

Deutsche Bank

C O N T E N T S
SCOPE OF WORK	3
ASSESSMENT SUMMARY	4
REPORT REVIEW ASSESSMENT	5
PART I: ALIGNMENT WITH COMMITMENTS SET FORTH IN THE SUSTAINABLE INSTRUMENTS
FRAMEWORK	5

PART II: ASSESSMENT AGAINST THE ICMA HARMONISED FRAMEWORK FOR IMPACT REPORTING (HFIR) AND HARMONISED FRAMEWORK FOR IMPACT REPORTING FOR SOCIAL BONDS (HFIRSB)... 6

PART III: DISCLOSURE OF PROCEEDS ALLOCATION AND SOUNDNESS OF THE IMPACT REPORTING
INDICATORS	14
ANNEX 1: Methodology	22
ANNEX 2: Quality management processes	23
About this Report Review	24

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Impact Reporting Methodology

Deutsche Bank

SCOPE OF WORK

Deutsche Bank AG ("the Issuer" or "Deutsche Bank") commissioned ISS Corporate Solutions (ICS) to provide a Report Review1 on its Impact Reporting Methodology by assessing:

1. The alignment of the Deutsche Bank's Impact Reporting Methodology with the commitments set forth in Deutsche Bank Sustainable Instruments Framework (as of October 5, 2023) 2.
2. Deutsche Bank's Impact Reporting Methodology - benchmarked against Harmonised Framework for Impact Reporting (HFIR) and Harmonised Framework for Impact Reporting for Social Bonds (HFIRSB), administered by the International Capital Market Association (ICMA) updated as of June 2023.
3. The disclosure of proceeds allocation and soundness of reporting indicators - whether the impact metrics align with best market practices and are relevant to the Sustainable Instruments to be issued.

1. A limited or reasonable assurance is not provided on the information presented in Deutsche Bank Impact Reporting Methodology. A review of the use of proceeds' impact reporting methodology is solely conducted against ICMA's Standards (Harmonised Framework for Impact Reporting for Green Bond and Social Bond ) core principles and recommendations where applicable, and the criteria outlined in the underlying Framework. The assessment is solely based on the information provided in the impact reporting methodology. The Issuer [Deutsche Bank] is responsible for the preparation of the report including the application of methods and internal control procedures designed to ensure that the subject matter information is free from material misstatement.
2. The Deutsche Bank Sustainable Instruments Framework was assessed as aligned with the GBP and SBP (as of June 2021 with June 2022 Appendix 1) as of October 5, 2023.

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Impact Reporting Methodology

Deutsche Bank

ASSESSMENT SUMMARY

REVIEW SECTION

SUMMARY

EVALUATION

Part 1.

Deutsche Bank confirms to follow the commitments set forth in the

Sustainable Instruments Framework.

Alignment with the

Issuer's commitments

set forth in the

Framework

Part 2.

The Impact Reporting Methodology is in line with

ICMA's HFIR and HFIRSB. The Issuer follows core

Alignment with the

principles

and

where

applicable

key

Harmonised

recommendations.

Framework for Impact

Aligned

Reporting (HFIR) And

Harmonised

Framework for Impact

Reporting for Social

Bonds (HFIRSB)

Part 3.

The allocation of the bond's proceeds will be disclosed,

with a detailed breakdown across different eligible

Disclosure of proceeds

project categories as proposed in the Framework3.

allocation and

soundness of

The Deutsche Bank's Sustainable Instruments

Positive

reporting indicators

Framework has adopted an appropriate methodology

to report the impact generated by providing

comprehensive disclosure on data sourcing,

calculations methodologies and granularity reflecting

best market practices.

3 The assessment is based on the information provided in the Issuer's report. The Issuer is responsible for the preparation of the report including the application of methods and procedures designed to ensure that the subject matter information is free from material misstatement.

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Impact Reporting Methodology

Deutsche Bank

REPORT REVIEW ASSESSMENT

PART I: ALIGNMENT WITH COMMITMENTS SET FORTH IN THE SUSTAINABLE INSTRUMENTS FRAMEWORK4

The following table displays the Issuer's commitment in the allocation and impact report against the commitments set forth in Deutsche Bank's Framework, which are based on the core requirements of the Green Bond Principles and Social Bond Principles as well as best market practices.

GBP AND SBP

OPINION

	1.	Use of Proceeds			Deutsche Bank confirms to follow the Use of Proceeds' description
			provided by Deutsche Bank's Sustainable Instruments Framework. The
					report will be in line with the initial commitments set in the Deutsche
					Bank's Sustainable Instruments Framework.
2.	Process for		Deutsche Bank confirms to follow the Use of Proceeds' description
	provided by Deutsche Bank's Sustainable Instruments Framework. The
		Project
			report will be in line with the initial commitments set in the Deutsche
		Evaluation and
			Bank's Sustainable Instruments Framework.
		Selection
	3.	Management of			Deutsche Bank confirms to follow the Use of Proceeds' description
			provided by Deutsche Bank's Sustainable Instruments Framework. The
		Proceeds
				report will be in line with the initial commitments set in the Deutsche
					Bank's Sustainable Instruments Framework.
4.	Reporting		Deutsche Bank confirms to follow the Use of Proceeds' description
	provided by Deutsche Bank's Sustainable Instruments Framework. The
					report will be in line with the initial commitments set in the Deutsche
					Bank's Sustainable Instruments Framework.
	5.	Verification			Deutsche Bank commits to engage an independent external auditor or any
					other verifier to provide a limited assurance on the annual allocation
					reporting of proceeds from Sustainable Financing Instruments to Eligible
					Assets

4 The Deutsche Bank Sustainable Instruments Framework was assessed as aligned with the GBP and SBP (as of June 2021 with June 2022 Appendix 1) as of October 5, 2023.

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Impact Reporting Methodology

Deutsche Bank

PART II: ASSESSMENT AGAINST THE ICMA HARMONISED FRAMEWORK FOR IMPACT REPORTING (HFIR) AND HARMONISED FRAMEWORK FOR IMPACT REPORTING FOR SOCIAL BONDS (HFIRSB)

FOR GREEN BONDS

Reporting is a core component of the GBP and transparency is of particular value in communicating the expected and/or achieved impact of projects in the form of an annual reporting. Green bond Issuers are required to report on both the use of green bond proceeds, as well as the environmental impacts at least on an annual basis until full allocation or maturity of the bond. Harmonised Framework for Impact Reporting (HFIR) has been chosen as benchmark for this analysis as it represents the most widely adopted standard.

The table below evaluates Deutsche Bank Impact Reporting Methodology against ICMA Harmonised Framework for Impact Reporting (HFIR).

CORE PRINCIPLES

	ICMA HFIR			IMPACT REPORTING METHODOLOGY			ASSESSMENT
Reporting on an annual		Deutsche Bank commits to report within one year
	from	issuance. The report	will	be available on
basis
	Deutsche Bank's website.
				The assessment and measurement of the impacts
				generated by Deutsche Bank Green Bond(s) will
				cover the following areas:
				1.	Renewable Energy
					▪ (Expected) annual GHG emissions
						reduced/avoided (metric	tons of
						CO2e)
					▪ Annual	renewable	energy
						generation (MWh)
	Illustrating the				▪	Installed capacity	of renewable
	environmental impacts
					energy constructed or rehabilitated
	or outcomes
					(MW)
				2. Clean Transportation- Electric vehicles (EVs)
					▪ (Expected) annual GHG emissions
						reduced/avoided (metric	tons of
						CO2e)
					▪ Optional: Number of EVs financed
				3. Clean Transportation- Electric vehicles (EVs)
					▪ (Expected) annual GHG emissions
						reduced/avoided (metric	tons of
						CO2e)

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Impact Reporting Methodology

Deutsche Bank

▪ For passenger travel:	pkm	(i.e.
transport of one passenger over one
kilometer) and/or passengers
i.	For cargo transport: ton-km
	(i.e. the transport of one ton
	over one kilometre/ ton-
	km) and/or metric tons
ii.	Optional:	Total	in
	kilometers	of	new	or
	improved train lines

1. Green Building
2. • Residential Real Estate (RRE)
   • 1. Expected energy savings in MWh per year
     2. (Expected) annual GHG emissions avoided (metric tons of CO2e)
   • Commercial Real Estate (CRE)
   • 1. Expected energy savings in kWh per year
     2. (Expected) annual GHG emissions avoided (metric tons of CO2e)
3. Energy Efficiency
4. • (Expected) annual energy consumption saved through measures in kWh
   • (Expected) annual GHG emissions reduced/avoided (metric tons of CO2e)
5. Information and Communications Technology (ICT)
6. • (Expected) annual energy consumption saved through measures in kWh
   • (Expected) annual GHG emissions reduced/avoided (metric tons of CO2e)
   • Design average annual PUE

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R E P O R T R E V I E W

Impact Reporting Methodology

Deutsche Bank

		Deutsche Bank commits to evaluate potential
		environmental and social risks that could arise from
ESG Risk Management		potentially eligible projects against the Issuer's
	Environmental and Social Policy Framework, in line
		with the commitment set forth in the Sustainable
		Instruments Framework.
		Deutsche Bank does not report on individual
Allocation of proceeds -		projects since the project data is confidential. The
Transparency on the		reporting is at portfolio level. The Issuer commits to
currency		be transparent on reporting the cash flows in one
		currency.

RECOMMENDATIONS

ICMA HFIR	IMPACT REPORTING METHODOLOGY		ASSESSMENT
Define and disclose	Deutsche Bank will define and disclose period and
period and process	process for Project Evaluation and Selection
for Project
Evaluation and
Selection
Disclose total	Deutsche Bank will disclose the total amount of
amount of proceeds	proceeds raised and allocated to eligible
allocated to eligible	disbursement.
disbursements
Formal internal	Deutsche Bank will follow a transparent process for
process for the	the allocation of proceeds.
allocation of
proceeds and to
report on the
allocation of
proceeds
Report at project or	Deutsche Bank will report on the total amount of
portfolio level	proceeds allocated per eligible project category.
Describe the	Deutsche Bank will adjust the impact calculation by
approach to impact	the share of financing attributable to the Issuer.
reporting
Report the
estimated lifetime	Deutsche Bank does not plan to report on the		-
results and/or	average portfolio lifetime results or economic life (in
project economic	years).
life (in years)

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Impact Reporting Methodology

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Ex-post verification		Deutsche Bank does not plan to sample ex-post
	verification of specific projects and includes relevant	-
of specific projects
	results in the reporting
Report on at least a		Deutsche Bank will report on sector specific core
limited number of		indicators, whenever the required input variables or
sector specific core		external data sources are available.
indicators
		Deutsche Bank discloses the assumptions and
		impact calculation methodologies for Renewable
		Energy and Clean Transportation.
		For Green Building, the Issuer will engage an
		external consultant for Commercial Real Estate
		(CRE) to evaluate the impacts, through a
		comparison with national reference benchmarks,
		e.g. Building Performance Database of USA,
		National Energy Code of Canada for Buildings, and
		Energy Start Portfolio Manager of USA and Canada.
		For Residential Real Estate (RRE), the Issuer uses
If there is no single		real annual energy consumption and CO2 emissions
commonly-used		when EPC data are available, otherwise an
standard, Issuers		estimation approach. The expected GHG emissions
may follow and		avoided of RRE assets will be calculated through a
disclose their own		comparison with average national carbon
calculation		emissions taken from PCAF database of an average
methodologies		RRE portfolio of the same size and regional
		distribution. The expected energy savings in MWh
		per year will be calculated based on the expected
		GHG emission avoided and average conversation
		factors. For Germany, the conversion factor is
		based on the Bank's own calculations on the basis
		of existing internal EPC data.
		For Energy Efficiency and Information and
		Communications Technology, the Issuer will
		disclose the calculation methodology or data
		source according to the specific type of activities
		that the proceeds will be allocated to.
Disclosure on the
conversion		The Issuer will disclose on the conversion approach
approach (if		for the impacts units.
applicable)
Projects with partial		For projects with partial eligibility the Bank will only
	pro-rata count the affordable part into its asset pool
eligibility
	internally and also only report impact pro-rata.

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R E P O R T R E V I E W

Impact Reporting Methodology Deutsche Bank

When the expected impacts of different project componentsmay not be reported separately,Issuers may use (and disclose) the attribution approach

The impact of Deutsche Bank's projects will be reported separately per category and sub category on an aggregated basis. In case separate impact reporting is not possible, disclosure via attributionapproach should remain an option.

OPINION

Deutsche Bank follows Harmonised Framework for Impact Reporting's core principles and key recommendations. The Issuer provides transparency on the level of expected reporting as well as on the frequency, scope and duration, aligned with best practices.

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