Statement on compliance with the Financial Reporting Council’s Stewardship Code


This document sets out the approach of DB UK Bank Limited and the Deutsche Bank Wealth Management division regarding the UK Financial Reporting Council’s Stewardship Code (”Code”).


DB UK Bank Limited and Deutsche Wealth Management


DB UK Bank Limited (“DBUK Bank”) is a subsidiary of Deutsche Bank AG and member of the Deutsche Bank group of companies, a global investment banking, securities and investment management firm that provides a broad range of financial services worldwide to a substantial and diversified client base that includes corporations, financial institutions, governments and individuals.


DB UK Bank is authorised by the Prudential Regulation Authority (“PRA”), and regulated by the Financial Conduct Authority (“FCA”) and the PRA. The registered office of DB UK Bank is 21 Moorfields,
London EC2Y 9DB, United Kingdom.


Deutsche Bank Wealth Management (“DBWM”) is a division of Deutsche Bank AG. Through a network of branches and subsidiaries it offers a wide range of financial services, including discretionary portfolio management, investment advisory as well as custody, execution, lending and other services to high net worth individuals, families and investment vehicles across multiple jurisdictions.


DB UK Bank is the entity through which DBWM offers onshore wealth management service in the UK.


DBWM and the application of the Code


Deutsche Bank Wealth Management’s client base includes clients categorised as both retail and professional. Deutsche Bank Wealth Management’s professional client base includes certain clients, which are not natural persons and which are provided with discretionary management services. Accordingly, pursuant to the FCA’s rules, Deutsche Bank Wealth Management is required to describe the nature of its commitment to the Code or its alternative strategy.


Commitment to the UK FRC’s Stewardship Code


While Deutsche Bank Wealth Management’s appreciates and respects the principles of the Code, due to the nature of its client base and business offering, it does not consider it appropriate to commit to the Code due to the type of services it offers in this context.


Deutsche Bank Wealth Management will not generally exercise voting rights. However, where it does exercise its discretion to vote for or against a particular proposal it will be in a manner consistent with its customers’ best interests. Deutsche Bank Wealth Management does not therefore directly commit to observe the Stewardship Code, though it does support the aims of the Code.


Instead, Deutsche Bank Wealth Management follows an alternative investment approach which is described in more detail in the following section.


Alternative Investment Approach


Where Deutsche Bank Wealth Management acts in a discretionary capacity for non-natural persons that are categorised as professional clients, it typically does so as delegated manager for the ultimate benefit of a wealthy individual or family (as distinct from traditional institutional investors).


Each client’s circumstances are unique and so the investment strategies required by these clients are not uniform, varying widely depending on their nature, location, risk profile, experience and investment objectives.


Consequently, based on these varied requirements, Deutsche Bank Wealth Management creates, or advises on, personalised investment portfolios for clients, and utilises a wide spectrum of investment approaches and asset classes in so doing. Discretionary investment decisions will be guided by Deutsche Bank Wealth Management’s proprietary investment process and by numerous other factors such as internally produced research.


In line with the terms agreed with clients, Deutsche Bank Wealth Management will generally refrain from exercising voting rights or engaging directly with the UK listed companies it may invest in on their behalf.


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