COMMERZBANK AKTIENGESELLSCHAFT

Corporate Responsibility
One bank. One partner. One future.
Commerzbank is presenting its corporate responsibility activities in the areas of Private
Customers, Mittelstandsbank, Employees, Ecology and Society for the fifth time in its 2011
Corporate Responsibility Report (sustainability report) under the title of “One bank, one
partner, one future.” The report was reviewed by the Global Reporting Initiative, the internationally
recognised standard on sustainability reporting, and once again it met the top
“A” standard. The new sustainability report can also be seen as a progress report (COP –
“Communication on Progress”) for the United Nations Global Compact, which Commerzbank
signed up to in 2006. The report can be downloaded from the Internet under
http://nachhaltigkeit2011.commerzbank.de in German and English. Further information on
corporate responsibility can be found on Commerzbank’s sustainability portal, which is constantly
updated: www.nachhaltigkeit.commerzbank.de.
Commerzbank is keen to continue integrating sustainability even further into its structures,
processes and relevant areas of action, as we believe that a consistently sustained
business strategy is a key success factor for the Bank’s development. Renewable energies
are the best example of this: sustainability has become a key element of our core business.
Reputation risk management
As a leading bank for private and corporate customers in Germany, Commerzbank has a special
financial and social responsibility within the scope of its influence. Accepting this responsibility
principally means that we can identify potential ecological, social and ethical implications
early in our core business and respond to them. As part of Group-wide reputation
risk management, we conduct an individual qualitative review to evaluate the sustainability
aspects of transactions and customer relationships. This includes reviewing the principles set
down in the UN Global Compact. Internal guidelines and positions are also applied, particularly
on human rights, armaments, areas of conflict, fossil fuels, energy generation, indigenous
populations, agriculture and forestry, coal mining and toxic substances. After intensive
research, the analysis and ultimately a sophisticated evaluation are produced that may result
in the transaction being refused or termination of the customer relationship. At the moment,
over 150 transactions or customer relationships on average are reviewed every month.
Around 10% of operations receive a negative rating for social, ecological or ethical reasons.
Compliance
One of the core tasks of the Compliance function is to ensure that legal and supervisory requirements
are met so as to prevent money laundering and the financing of terrorism. Commerzbank
applies the “know your customer” principle to ensure the greatest possible transparency
in business relationships and financial transactions; this involves not only verifying
and documenting the client’s identity, but also, where necessary, obtaining clarification on
the origin of the assets employed within the business relationship or transaction. Commerzbank
is constantly upgrading its anti-money laundering measures to keep pace with changes
in national and international regulations. Consistently following the “know your customer”
principle and other measures should also help prevent the Bank from being misused for
transactions to fund terrorism. In the fight against money laundering and terrorism finance,
the Bank exercises special care in business with politically exposed people, as these transac-
Financial Statements and Management Report 2011 5