Better Health for All

Commerzbank demonstrates exceptional mental health programs for its employees and their families, including a 24/7 Employee Assistance Program (EAP), a burnout and addiction support network, workshops on mental fitness, and an online mental health platform with resources like videos and podcasts.

The Horizon ERG specifically addresses burnout syndrome and aims to reduce stigma. The company also has a comprehensive focus on preventative health measures for its employees. This includes discounted Fitness First memberships, participation in the Virgin Pulse Global Challenge, Health Days, company sports activities with 6,000 participants, occupational health care, professional counselling on stress, preventive occupational health examinations, and health protection during business trips. Furthermore, Commerzbank provides comprehensive health education for employees through health learning events, expert talks, online platforms, support for external care courses, and information on addictive substances. It also maintains a comprehensive addiction prevention framework for employees, featuring a company agreement, a network of addiction support workers, and an Addiction Helpline. Regarding healthcare data, company doctors and addiction counsellors operate under medical confidentiality and strict confidence, demonstrating excellent data practices for employee health information. The company's core financial products and services are generally health-neutral, and it does not offer health-related products or services requiring price accessibility or carrying direct health risks for public disclosure. Its operations do not generate significant health externalities, nor does it engage in healthcare workforce support, health equity programs for the general public, or clinical trials.

Fair Money & Economic Opportunity

In 2015, Commerzbank agreed to forfeit $563 million

and pay a $79 million fine, totaling $642 million, for violations including processing transactions for sanctioned entities and failing to maintain adequate anti-money laundering policies at its New York branch, which allowed a multi-billion-dollar securities fraud scheme to operate . Commerzbank's financial education resources, covering topics like sustainable investing and savings strategies, attracted over one million visitors in 2023 . This reach represents approximately 9.09% of its around 11 million private and small-business customers in Germany . The bank also runs the 'Financial Heroines' initiative, established in 2018, to engage women in financial matters . However, the provided information does not detail specific outcome tracking or measurable impacts of these programs on customer financial behavior.

Fair Pay & Worker Respect

Commerzbank reports an adjusted pay equity ratio gap of less than 1% between males and females.

The bank aims for adequate and equal compensation for equivalent activities, designing all compensation structures to be gender-neutral and regularly reviewing measures against pay discrimination. The overall employee engagement score is 4.09 out of 5, aligning with the benchmarking database average. Approximately 34.2% of the Group’s employees are covered by collective bargaining agreements , including an in-house agreement for ComTS service companies valid until the end of 2025 , and the collective bargaining agreement for the private banking sector. A wage agreement in the German private banking sector in July 2024 resulted in a 10.5% salary increase. Commerzbank has a group-wide quota of 33.7% women in management , with a target of 40% by 2030. The bank offers flexible work arrangements , company pension schemes , and has committed to respecting human rights and environmental laws in its supply chain, addressing risks like discrimination and occupational safety.

Fair Trade & Ethical Sourcing

As a bank, the company does not procure or trade physical commodities, rendering fair-trade certification share and materials risk index KPIs not applicable. For its direct suppliers, all suppliers and service providers are contractually required to comply with ethical, social, and human rights standards, with non-compliance potentially leading to the termination of the business relationship.

Compliance with social standards is addressed in annual supplier meetings. The effectiveness of due diligence processes is reviewed at least once annually. No specific data is provided for the number of substantiated forced or child labor incidents, the percentage of suppliers with traceable provenance, the median days to close corrective action plans, or the percentage of the procurement budget directed to diverse suppliers.

Honest & Fair Business

Commerzbank AG was fined €1.45 million by BaFin in 2024 for anti-money laundering violations, specifically for failing to timely update customer data and compromising due diligence.

The company's ESG score is 57 from S&P Global Corporate Sustainability Assessment. Commerzbank has a comprehensive, global, ISO data protection certified digital whistleblowing system that allows anonymous reports, ensures confidentiality, and prohibits retaliation, with whistleblowers informed within 7 days of receipt and updated within three months. There have been zero financial restatements in the past five years. Despite having a comprehensive anti-corruption policy, the company has documented persistent failures in anti-money laundering systems and due diligence, leading to regulatory fines. Its non-financial and sustainability reports, which cover various ethical claims, are audited by Ernst & Young with "Limited Assurance," and its digital whistleblowing system is ISO data protection certified.

Kind to Animals

As a service-oriented company, Commerzbank AG does not engage in activities such as product manufacturing, animal testing, or direct animal agriculture, rendering many animal welfare KPIs not applicable. For public policy engagement, Commerzbank has faced criticism for lacking commitments to protect animal welfare or promote plant-based alternatives, with an average compliance rate of only 10%.

Its policies for forest-risk sectors such as beef and soy have been assessed with low scores. While the bank states a commitment to biodiversity, uses assessment tools, and invests in climate-friendly projects that indirectly benefit wildlife, no measurable data on wildlife conservation impact or specific financial allocation is provided.

No War, No Weapons

Commerzbank is identified as the second largest German investor in companies producing nuclear weapons and their delivery systems.

Prior to August 2014, the bank invested approximately 1.8 billion Euros in nine such companies through stocks, bonds, and loans. Despite having a company-wide and public policy on arms deals since 2008, which explicitly excludes financing "controversial weapons" (including nuclear, cluster bombs, anti-personnel mines, biological, and chemical weapons) and arms in conflict zones, a significant loophole exists. This policy, updated in 2023 to include autonomous weapons and surveillance technology, does not exclude financing multi-industry companies that derive part of their turnover from the nuclear weapons sector. The Board of Managing Directors approved the armaments policy in 2008 and receives quarterly reputational risk reports related to armaments.

Planet-Friendly Business

Commerzbank has SBTi-validated near-term emissions reduction targets for 2030

, covering operational (42% reduction for Scope 1+2 from a 2021 baseline) and portfolio emissions, with validation conducted in 2025 . The company sources 100% green electricity worldwide since 2024 . It aims to achieve net-zero CO₂ emissions in its operations by 2040 and for its credit and investment portfolio by 2050 , both with defined interim milestones. Commerzbank joined the TCFD in 2020 , published its first TCFD report in 2022 , and an independent nature and climate report in accordance with TCFD standards for the 2024 reporting year . It conducts scenario analysis by identifying CO2-intensive sectors, assessing exposure, and calculating mitigation paths aligned with the Paris Climate Agreement, committing to align portfolio temperature scores by 2026 .

Respect for Cultures & Communities

Commerzbank adopted the Equator Principles to manage environmental and social risks, aiming to protect cultural heritage

. However, a 2024 report by finance watchdog BankTrack found that the bank failed in due diligence around Indigenous peoples' free, prior, and informed consent (FPIC) and did not fully implement adequate safeguards in line with UN human rights principles . In response to concerns about financing activities affecting Brazilian indigenous lands, Commerzbank stated its commitment to upholding human rights and protecting indigenous peoples , and deployed policies on deforestation, agricultural commodities, and mining . Despite these responses, the BankTrack report indicates a failure in the implementation of safeguards .

Safe & Smart Tech

Commerzbank established AI principles with its Works Council in May 2024, focusing on protecting employee rights, ensuring trustworthy, responsible, and non-discriminatory AI use, with commitments to human control, fairness, transparency, robustness, security, and data protection

. The bank specifically committed to not using AI to analyze or manipulate employee emotions or personality traits . It also emphasizes data quality for ethical AI outcomes and bias mitigation . The company has adopted comprehensive security and privacy certifications, including ISO 27001, 27017, 27018, 27701, 20000-1, 22301, 31000, 27035, and 27036 . In March 2024, Commerzbank adopted Google Cloud's VPC Service Controls to prevent unauthorized data exfiltration by establishing isolation perimeters and defining data flow boundaries, addressing insider threats and credential compromises . No incidents of unauthorized data use are documented. In April 2024, BaFin fined Commerzbank €1.45 million for breaches in anti-money laundering obligations, including failing to update customer data in a timely manner and inadequate security measures in three instances . The bank stated it had revised its due diligence processes and completed all necessary data updates by 2022 . Commerzbank aligns with numerous regulations and frameworks, including GDPR, PCI DSS, DORA, KWG, MaRisk, TIBER-DE (in progress), NIST CSF, CIS Controls, and various ISO standards . In February 2023, Commerzbank released a white paper on the European Artificial Intelligence Act, advocating for a risk-based approach to AI implementation in banking and emphasizing data protection, human control, fairness, transparency, and reliability .

Zero Waste & Sustainable Products

Commerzbank uses 100% recycled paper in internal operations.

The bank has implemented several waste reduction initiatives, including the 'Tork PaperCircle' project which has diverted around 264 tons of paper towels from residual waste since 2016 , a program that planted 754 trees by 2022 for paper saved between 2017 and 2022 , and programs for recycling pens/markers and reusing smartphones. Commerzbank has a quantitative target to plant a tree for every ton of printer and copier paper saved between 2017 and 2022. The bank's 'Standard for Sustainable Procurement' requires all service providers and suppliers to comply with environmental protection standards, promote these standards along their own supply chains, and considers environmental labels and disposal costs in procurement decisions. Key suppliers are evaluated annually on sustainability criteria , and compliance with environmental management standards like ISO 14001 is requested during tenders.