DWS Group GmbH & Co. KGaA (DWS) recognizes that significant business disruptions are a possibility. We have in place comprehensive business continuity procedures designed to minimize the impact of significant business disruption. This letter summarizes the measures DWS has taken through its global Business Continuity Management Program (BCM Program) to respond to significant business disruptions as well as our preparedness for any potential impact of COVID-19 (Coronavirus Disease 2019).
As COVID-19 expands its footprint, we want to reassure you of the preparedness and protocols that DWS has in place to ensure seamless continuity of operations and services. DWS is actively managing the possible impact for the company and is closely monitoring the development of the situation in all regions to protect our staff and clients. We are communicating frequently with our employees with updates on the rapidly developing novel coronavirus situation, including with precautionary health and hygiene reminders.
DWS encourages staff to take preventive actions to help limit the spread of respiratory viruses. This includes in particular heightened hygiene measures following the recommendation of the World Health Organization WHO.
DWS has restricted travel to absolutely critical business travel only. These business trips must be exceptionally pre-approved by DWS's senior management prior to booking. Travel restrictions are under constant review and will be updated as necessary. Audio and video conference meetings are encouraged where possible. Employees who have returned from affected areas in the last 14 days, or who have household members that returned from there in the last 14 days, are asked self-quarantine immediately after their return for a period of 14 days.
DWS is committed to protecting our employees while ensuring the continuity of our fiduciary responsibilities to our clients. The proactive precautions we are taking have no impact on our operations and all client service continues unaffected. All areas of our business remain fully operational and, as described above, we are fully prepared and equipped to address any adverse impact that COVID 19 may have on the delivery of services. DWS has implemented split-teams globally, with teams rotating between separated business locations (both normal and dedicated standby offices) or home. We are also capable of ensuring remote work environments for all our employees at the same time, if necessary – including portfolio management.
Please do not hesitate to contact us if you have questions or concerns.
Continuity Management Program
We are committed to protecting our staff and ensuring the continuity of critical group businesses and functions in order to protect our franchise, mitigate risks, safeguard client services and sustain both stable financial markets and customer confidence. We have developed, implemented and continue to test and maintain our global BCM Program to ensure it attains these objectives. The BCM Program outlines core procedures for the relocation or the recovery of operations in response to varying levels of disruption. A number of scenarios are considered including: staff unavailability, complete loss of a single production site, loss of vendor services and loss of application software. These procedures provide information for responsible personnel to evaluate the business disruption and initiate appropriate action, including:
- Safeguard employees' and our property,
- Communicate with our employees, regulators, and clients,
- Provide you, our client with access to your funds and securities, and
- Protect our books and records and recover/resume normal operations.
Each of our core businesses functions and infrastructure groups construct and maintain their business continuity plans (BCPs) to ensure a continuous, reliable service. BCPs are based on predefined strategies, roles and responsibilities. BCPs are designed to ensure provision of critical business processes and IT systems within predefined recovery time frames. BCPs are reviewed, updated and tested annually or when significant changes occur.
In support of our BCM Program, DWS / DB maintain technical disaster recovery plans to protect and recover applications, information assets and technical infrastructure in the event of a facility failure or technology outage. In addition and because of specific identified vulnerabilities, further contingency measures are undertaken to mitigate against the risk of a city wide outage.
Roles & Responsibilities
The BCM Program has defined roles and responsibilities, which are documented in corporate standards (including the Technical Disaster Recovery Standard). This fosters a constant and effective approach to the provision of resiliency throughout DWS and results in an efficient fit-for-purpose business continuity capability. The BCM Program is staffed and managed within each region by specialists who co-ordinate preparedness efforts with BCM-trained staff embedded in each business and infrastructure area. The regional business continuity teams provide expertise and guidance to all business functions within DWS in developing, implementing, testing and maintaining effective BCPs and recovery processes. Similarly, the technical disaster recovery standards are implemented regionally by our technology department. The DWS Executive Board has delegated responsibility for business process disruption risk to the global Chief Operating Officer (COO).
The DWS Executive Board retains overall responsibility for policy setting, supervision and effective implementation of the business continuity policy. Compliance with DB’s corporate standards is monitored regionally by a regional business continuity council, reporting on a quarterly basis to the global business continuity council.
Crisis Management & Implementation
The COO ensures that DWS has a clearly defined, documented and tested crisis management process for assessing, escalating and managing any business disruption that may affect DWS’s ability to continue its critical business operations. This includes a crisis contact and escalation process, which is tested on a regular basis. In addition, BCPs are designed to be implemented in response to varying levels of business disruptions. The nature of the business disruption will affect whether all or only parts of our plans are executed.
Business Continuity Recovery Solutions
DWS has a broad recovery program in place to deal with the impact of incident or crisis. DWS has a number of customized recovery solutions designed to facilitate the quickest possible resumption of work for the critical businesses and support functions. Examples of these are:
DWS uses self-managed, dedicated standby facilities. These recovery sites provide dedicated recovery seats and infrastructure to provide for the needs of the business. Additionally, DWS retains recovery sites contractually through service providers who concentrate on business resiliency. All recovery sites are physically separated from normal business locations to prevent both sites being affected by the same incident.
Technology Disaster Recovery
Information Technology Disaster Recovery (DR) planning takes into consideration possible disruption scenarios such as a loss of data center or the failure of specific IT assets and/or applications supporting critical business operations. In order to address these scenarios, confidential DR plans are in place to manage the recovery and continuation of operations from DR environments located at geographically separate sites. All DR plans are validated periodically and include the assessment of recovery time and recovery point objectives (RTO & RPO) as well as technical and business validation to ensure that the DR environments operate at the required level.
- Reciprocal Agreements
Some businesses have partnership agreements with other business units regarding the allocation of a required number of recovery seats or the ability to transfer work. The receiving business unit provides the necessary infrastructure, hardware facilities or staff. Both normal business locations are geographically separated from each other to prevent both sites being affected by the same incident.
- Displacement Strategy
Certain business processes can be switched from one location to another and in the longer term, key staff can move to another location unaffected by the incident.
- Remote Access
Staff may work remotely, where permitted, in the event of a disruption accessing DWS systems via VPN and can divert their telephones to a home or mobile number.
- Service Providers
Service providers are contractually obliged to have business continuity capabilities in place to ensure continuity of services provided to DWS if the ordinary operation of the service provider is disrupted and to modify their work stream in order to adapt with the business continuity organization of DWS. A vendor risk management process is in place to ensure compliance.
- Pandemic Planning
DWS maintains a risk-based approach to pandemic planning, using as a guide the World Health Organization (WHO) definitions of pandemic phases.
- Customer Access to Funds and Securities
If your usual access to funds and securities is impacted by a significant business disruption, we will advise you of the appropriate DWS contacts through expedient means at www.dws.com.
DWS’s BCM Program is subject to regular reviews by internal and external audit, and regulatory authorities.
In the case of conflict between the Business Continuity Policies and Standards or the Technical Disaster Recovery Standards and local regulatory obligations, the stricter obligation is adhered to.
- Sincerely yours,
DWS Executive Board