MIFIDPRU 8.6 Disclosure

Scope and purpose

This disclosure relates to DB Investment Partners Ltd (“DBIP” or the “Firm”), which is classified as a small and non-interconnected (SNI) MIFIDPRU Investment Firm and is required under MIFIDPRU 8.6 to disclose information relating to remuneration policies and practices. DBIP is subject to the Deutsche Bank ("DB") compensation framework and therefore all disclosures detailed below have been made in relation to the wider DB compensation framework.

Decision-making Procedures and Compensation Governance

DB has a robust governance structure enabling it to operate within the clear parameters of the DB compensation strategy and policy. DBIP is subject to the remuneration decisions made by the DB group ("Group") management board ("DB Group Management Board"), which is supported by a specific remuneration committee, the Senior Executive Compensation Committee ("SECC"), which is a delegated committee established by the DB Group Management Board. In order to maintain its independence, only representatives from infrastructure and control functions who are not aligned to any of the business divisions are members of the SECC. In 2023, the SECC's membership comprised DB AG Management Board member responsible for Human Resources and Chief Financial Officer as Co-Chairpersons, the Global Head of Compliance, the Global Head of Performance & Reward as well as an additional representative from both Finance and Risk as voting members. The Compensation Officer, the Deputy Compensation Officer and an additional representative from Finance participated as nonvoting members. In line with their responsibilities, the Group's control functions are involved in the design and application of the bank’s remuneration systems and in determining the total amount of variable compensation (“VC”). This includes assessing the impact of employees’ behaviour and the business-related risks, performance criteria, granting of remuneration and severance as well as ex-post risk adjustments.

Objectives of Financial Incentives

DB recognises that its compensation framework and financial incentives play a vital role in supporting its strategic objectives. It enables the bank to attract and retain the individuals required to achieve the bank’s objectives. DB's compensation and benefits strategy is built on three core pillars that support the bank’s global, client-centric business and risk strategy, reinforced by safe and sound compensation practices that operate within the bank’s profitability, solvency, and liquidity position.

Approach to and Characteristics of Compensation

The compensation framework, generally applicable globally across all regions and business lines, emphasises an appropriate balance between fixed pay (“FP”) and VC – together forming Total Compensation (“TC”). It aligns incentives for sustainable performance at all levels of DB whilst ensuring the transparency of compensation decisions and their impact on shareholders and employees. The underlying principles of the compensation framework are applied to all employees equally, irrespective of differences in seniority, tenure, gender or ethnicity. The Group has assigned a Reference Total Compensation (“RTC”) to eligible employees that describes a reference value for their role. This value provides employees with orientation on their FP and VC. Actual individual TC can be at, above or below the RTC, depending on VC decisions.

FP is used to compensate employees for their skills, experience and competencies, commensurate with the requirements, size and scope of their role. VC reflects affordability and performance at Group, divisional, and individual level. VC is granted as Individual VC and considers the applicable divisional and the employee’s individual performance, conduct, and adherence to values and beliefs. In addition, it is subject to Group affordability and linked to Group performance. In case of negative performance contributions or misconduct, an employee’s VC can be reduced accordingly and can go down to zero. Under the compensation framework, there continues to be no guarantee of VC in an existing employment relationship. Such arrangements are utilised only on a very limited basis for new hires in the first year of employment and are subject to the bank’s standard deferral requirements. Employee benefits complement TC and are considered FP from a regulatory perspective, as they have no direct link to performance or discretion. Pension expenses represent the main element of the bank’s benefits portfolio globally.

Determination of performance-based variable compensation

DB Group puts a strong focus on its governance related to compensation decision-making processes. A robust set of rule-based principles for compensation decisions with close links to the performance of both business and individual are applied, taking into account both financial and non-financial criteria. All compensation decisions are made within the boundaries of regulatory requirements with these requirements forming the overarching framework for determining compensation at DB.

The total amount of VC for any given performance year is derived from an assessment of the Group’s profitability, solvency, and liquidity position, and the determination of VC pools for divisions and infrastructure functions based on their performance in support of achieving the bank’s strategic objectives. At the level of the individual employee, the "Variable Compensation Guiding Principles" have been established, which detail the factors and metrics that have to be taken into account when making Individual VC decisions. Managers must fully appreciate the risk-taking activities of individuals to ensure that VC allocations are balanced and risk-taking is not inappropriately incentivised. The factors and metrics to be considered include, but are not limited to, (i) business delivery (“What”) i.e., quantitative and qualitative financial, risk-adjusted and non-financial performance metrics and (ii) behaviour (“How”) i.e., culture, conduct and control considerations such as qualitative inputs from control functions or disciplinary sanctions.

Remuneration for year ending 31st December 2023

The below figures show the total remuneration awarded by DBIP to its staff from the date 1st January 2023 to 31st December 2023.

1 The table may contain marginal rounding differences; FTE (full-time equivalent) as of December 31, 2023.
2 FX conversion rate is as on 31.12.2023 EUR 1 = GBP 0.86767
3 Compensation data indicates remuneration of staff at 100% FTE, this includes compensation data of 2 Directors of the entity who spend 10 hours per quarter in the entity.