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Americas Reputational Risk
Committee (ARRC)
Terms of Reference
Level 3
The information contained herein is the property of Deutsche Bank Group and
may not be copied, used or disclosed ... Deutsche Bank Group without
prior written permission.
For internal use only
EFTA01350631
Americas Region Reputational Risk Committee Policy
Section 1: Scope and Responsibility
The Americas Region supports business practices that ... comply with the Group
Reputational Risk
Management Program, as outlined in the DB Group Reputational Risk Management
Program Policy
dated May 9, 2011.
Within the Americas region, consideration
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01350631.pdf
EFTA01343920Set 10
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Americas Region Reputational Risk Committee Policy Deutsche Bank
Section 1: Scope and Responsibility
The Americas Region supports business practices that comply with the Group Reputational Risk
Management Program, as outlined ... Group Reputational Risk Management Program Policy
dated May 9, 2011.
Within the Americas region, consideration of all reputational risk issues is the responsibility of the
Americas Regional Governance Board ... delegated such consideration to the
Americas Reputational Risk Committee (ARRC), a permanent sub-committee of the RGB.
The governance requirements described in this remit are applicable to all businesses, infrastructure
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01343920.pdf
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Americas Region Reputational Risk Committee Policy Deutsche Bank
Section 1: Scope and Responsibility
The Americas Region supports business practices that comply with the Group Reputational Risk
Management Program, as outlined ... Group Reputational Risk Management Program Policy
dated May 9, 2011, and also complies with the requirements of the Group "Conduct of Meetings" policy.
Within the Americas region, consideration ... reputational risk issues is the responsibility of the
Americas Regional Governance Board (RGB). The RGB has delegated such consideration to the
Americas Reputational Risk Committee (ARRC), a permanent sub-committee
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01343863.pdf
Unit / region / country should
present as a sponsor 2 with guest status on Reputational Risk issues
relevant to the respective Unit, to the Committee (i) providing complete,
accurate and update ... with the issue as
described to and approved by the Committee (ex post). The Reputational
Risk issues and requirements, upon which the decision has been / is
conditioned, have ... submitted to the Committee, as appropriate
• To manage the process where reported / escalated Reputational Risk issue
has been identified as impacting more than one region and the Committee
has been
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01343850.pdf
Management
• To review, decide / approve, manage in a diligent manner and monitor (a) all
Reputational Risk issues reported / escalated by the Units' to the Committee. The
senior representative ... Unit / region / country should present as a sponsor2with
guest status on Reputational Risk issues relevant to the respective Unit, to the
Committee (i) providing complete, accurate and update I current ... information and
arguments (ex ante), Reputational Risk issues (i) impacting a single Region to the
respective RRRC and Reputational Risk issues impacting multiple Regions / global
risks to the RRRC
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01343896.pdf
Americas Region Reputational Risk Committee Policy Deutsche Bank
6.7 Role of Chairman
The Chairman of the ARRC is the General Counsel for the Americas. The Chairman chairs each
meeting ... Section 7: Risk Appetite
7.1 Definition
The concept of risk when applied to reputational risk is different than credit, market or operational risk in
that reputational risk (or 'headline' risk ... entity might identify KRIS around EC components, operational risk, and liquidity.
Risk appetites, including reputational risk, will be developed at the legal entity level for the four Tier 1
entities
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01343868.pdf
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with
Mr. Epstein in both AWM and CB & S be presented to the Americas Reputational
Risk Committee (and possibly a Global Reputational Risk Committee, if
necessary) for additional review.
However ... Epstein and his entities has been fully reviewed by DB Senior Management
in the Reputational Risk Committee, the existing Epstein relationship can
continue to conduct trades and transactions in existing ... with Mr. Epstein in both AWM and CB & S be presented to the Americas
Reputational Risk Committee (and possibly a Global Reputational Risk
Committee, if necessary) for additional review.
Please
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01420399.pdf
EFTA00151495Set 9
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Bank
Americas, who at that time served as chair of the Bank's Americas Reputational Risk Committee
("ARRC")]. Neither suggest [that the Epstein relationship] requires rep risk ... referenced in the Approval Email referred to a review by the
relevant regional reputational risk committee. Deutsche Bank's policies and procedures provide
7
EFTA00151501
that, should a Deutsche Bank ... business or compliance unit identify a client that they believe could
pose a reputational risk to the Bank, they must escalate that client for review by the attendant
reputational risk
https://www.justice.gov/epstein/files/DataSet%209/EFTA00151495.pdf
Americas Region Reputational Risk Committee Policy Deutsche Bank
6.4 Escalation Procedures
The ARRC escalates unresolved issues first to the RGB and then if necessary to the North America
Executive Committee ... regionally, and to the Group Reputational Risk Committee globally.
In the event that a business line does not agree with the decision of the ARRC, an appeal may be made ... Group Reputational Risk Committee (GRRC) through the RRN. The presentation papers
submitted to the ARRC shall be circulated to the RRN by the Committee Secretary for its consideration,
together with
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01343923.pdf
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which uses the Advanced Methodology Approach).
conduct of our business. Such risks, which include reputational
risk concentration risk, securitisation risk, business risk, pension
Liquidity and funding risk obligation risk
https://www.justice.gov/epstein/files/DataSet%209/EFTA01114823.pdf
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with Mr. Epstein in both AWM and CB & S be presented to
the Americas Reputational Risk Committee (and possibly a Global Reputational Risk Committee, if necessary) for
additional review.
However ... Epstein and his entities has been
fully reviewed by DB Senior Management in the Reputational Risk Committee, the existing Epstein relationship can
continue to conduct trades and transactions in existing ... with Mr. Epstein in both AWM and CB & S be presented to the Americas
Reputational Risk Committee (and possibly a Global Reputational Risk Committee, if necessary) for additional review.
Please
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01374406.pdf
Americas Region Reputational Risk Committee Policy Deutsche Bank
1.3 Responsibilities of Business and Support
Primary responsibility for the identification, escalation and resolution of reputational risk issues
resides with the businesses ... should do so.
1.4 Delegation and Sub-Committees
Within the region, consideration of all reputational risk issues is the responsibility of the RGB. The RGB
has delegated such consideration ... Americas Reputational Risk Committee (ARRC), a permanent
sub-committee of the RGB.
The ARRC escalates unresolved issues first to the RGB and then if necessary to the North America
Executive
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01343864.pdf
Americas Region Reputational Risk Committee Policy Deutsche Bank
See Section 7 for Risk Appetite.
Section 6: Committee Operations
6.1 Agenda
A meeting agenda and supporting materials will be distributed ... Secretary, in response to requests by the businesses,
support groups or members, for a reputational risk review of potential transactions or relationships.
The agenda/materials will be maintained by the Secretary ... then if necessary to the North America
Executive Committee regionally, and to the Group Reputational Risk Committee globally.
In the event that a business line does not agree with
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01343867.pdf