Corporate Governance

Letters to Investee Companies

Each year we send out various letters to investee companies and request to have a constructive dialogue. The letters address changes to our corporate governance and proxy voting policies, as well as developments in our governance and sustainability activities or expectations on focus topics (thematic).

2024
2023
2022
2021

We at DWS Investment GmbH reiterate our commitment to fulfill our fiduciary duties in the best interest of our clients. We believe that sound corporate governance practices among our investee companies are both precondition and catalyst to achieving meaningful progress and create long-term sustainable value.

Pre-Season Letter 2024

Thematic engagement: Net-Zero by 2050

We expect companies that face substantial climate transition risks to accelerate their efforts in setting ambitious emission reduction targets and providing enhanced transparency on their roadmap towards climate neutrality.

Letter sent to 30 companies from various industries worldwide.

Net Zero letter 2024

We at DWS Investment GmbH (DWS) remain fully committed to fulfill our duties as a fiduciary and we aim to protect the assets entrusted to us by our clients. Therefore, we continue to promote sound, robust governance standards and responsible transformations of business models. As a global fiduciary, we regard it as our responsibility to address challenges in the market.

Pre-Season Letter 2021

Thematic engagement: Net-Zero by 2050

We expect companies that face substantial climate transition risks to accelerate their efforts in setting ambitious emission reduction targets and providing enhanced transparency on their roadmap towards climate neutrality.

Letter sent to more than 220 companies from various industries worldwide in June 2021.
Analysis focuses on Scope 1 and 2 emissions, climate transition risk rating, and Climate Action 100+ Net Zero Benchmark constituents

Net-Zero Letter: June, 2021

Thematic engagement: Human rights situation in Myanmar and Belarus

The significant deterioration of the human rights situation unfolding in Myanmar and Belarus in 2020 and 2021 is of great concern to DWS. The authorities’ policies of repressing and ideologically controlling the society also poses an increased risk to the private sector. Accordingly, it is crucial that corporations with direct operations, supply chains or other business relationships put heightened emphasis on these issues to seek to ensure compliance with principles and guidance on human rights and responsible business conduct (e.g. International Bill of Human Rights, European Convention on Human Rights, United Nations Guiding Principles on Business and Human Rights, OECD guidance on responsible business conduct and human rights and UN Global Compact principles).

We have sent out 38 thematic engagement letters to companies operating in these countries. DWS initiated follow-up engagements throughout 2022 and beyond.
Our thematic engagement activities aim to understand the investee companies’ established human rights due diligence processes, including the assessment of adverse human rights impacts and how violations are addressed, mitigated and prevented through their actions. It is important for us to have transparency on how they protect their employees and support the protection of human rights in general.

Thematic Engagement on Human Rights - Myanmar Thematic Engagement on Human Rights - Belarus

" We are convinced that governance remains the key element for unlocking the potentials and overseeing the risks arising from the environmental and social dimensions of sustainability.

Nicolas Huber Head of Corporate Governance Center

DWS ESG engagements and proxy voting activities 2022

Our 2022 Active Ownership report provides a detailed overview of our focus on effective governance as a crucial aspect to foster good management of environmental and social risks. DWS continued engagements with investee companies held both in actively and passively managed funds, as well as fixed income issuers. Our thematic engagements on net zero, human rights and blue economy have largely continued the work that began in 2021.

Our involvement in annual general meetings

Based on our continuous corporate governance activities and in line with our fiduciary duty, we have sent the following questions to the boards of some of our portfolio companies in written form:

2025
2024
2023
2022
2021
2020

DWS AGM speech Siemens Energy AG (German only)

DWS AGM speech Siemens Healthineers AG (German only)

DWS AGM speech Siemens AG (German only)

DWS AGM speech TUI AG (German only)

DWS AGM speech thyssenkrupp AGM (German only)

Corporate Governance Services

DWS Corporate Governance and Proxy Voting Policy - Core Values

Boards of Directors

Qualified, experienced, diverse and independent directors are mandatory for competent boards for an efficient decision-making process and long-term sustainable company performance. We understand diversity as a broader concept that encompasses gender, age, nationality, professional background, qualifications, and tenure:
- extended transparency requirements on directors: CVs and board meeting attendance should be disclosed on the website
- Over 50% of the board members should be independent
- tenure is considered as a critical factor for independence (max. 10 years)
- mandatory age limit set by the company is supported as to ensure a regular board refreshment
- separation of CEO and Chairman roles is supported for an appropriate balance of power and impartiality
- a direct and clear responsibility on ESG matters should be assigned to a director in the board
- The ESG performance assessment by external rating agencies influences DWS’s voting decisions on re-elections and the discharge of the Board of directors
Board members need to spend sufficient time and have an appropriate degree of ‘independence in mind’ in fulfilling their responsibilities as directors:
- maximum 3 board seats for executive directors
- maximum 5 board seats for non-executive directors

Executive Compensation

Transparency and comprehensibility on qualitative and quantitative performance indicators are necessary to allow sufficient oversight of remuneration systems
Balance between fix and variable pay and appropriateness of total pay need to be ensured
Integration of material ESG linked performance indicators into the remuneration of board members
Regular say-on-pay should take place as an important shareholder right
Relevant and adequate bonus-malus and claw-back mechanisms and reasonable deferral periods for executives need to be in place as key elements of a sustainable long-term oriented compensation structure

Shareholder Rights

We support the ‘one-share-one-vote’ principle and do not support voting caps
Interests of minority shareholders should be properly considered and necessary measures should be put in place
We support improved reporting practices on shareholder relevant information

Auditors

Key elements of appropriate disclosure as the term of appointment of the lead audit partner as to demonstrate his/her independence and objectivity: max. 5 year rotation for the audit partner
Disclosure of the non-auditing services and the appropriateness of the related fees to validate the independence of the external auditors
The audit firm has to be rotated after 10 years to ensure independence and objectivity

Corporate Governance and Proxy Voting Policy (2025)

Corporate Governance and Proxy Voting Policy (2024)

Corporate Governance and Proxy Voting Policy (2023)

DWS Stewardship Report (2023)

Active Ownership: Engagement & Proxy Voting Report (2022)

Active Ownership: Engagement & Proxy Voting Report (2021)

Active Ownership: Engagement & Proxy Voting Report (2020)

The DWS commitment to stewardship is demonstrated by the official recognition of DWS Investments UK Limited as a UK stewardship code signatory.

In order to ensure effective and efficient fulfillment of the associated obligations, the relevant processes and facilities are organized centrally and carried out by the affiliates within the DWS Group or made available to them.

UK Stewardship Code Report DWS Investment UK Limited
(nur in Englisch verfügbar)

Governance Expertise and Content Development

Reporting and Communication

Proxy Voting Advisory

Voting results

Corporate Engagement Process

We follow a stringent step-by-step approach in order to engage with our portfolio companies

*Notice:

Corporate Governance is conducted for DWS Investment GmbH, DWS Investment S.A. and for specific portfolio management mandates of DWS International GmbH.

The primary responsibility for the engagements and the exercise of voting rights outlined on this website lies with DWS Investment GmbH. To ensure an effective, efficient and consistent process, the following DWS legal entities have delegated the voting rights of their funds (in case of DWS Investment S.A.) respectively their institutional mandates (in case of DWS International GmbH) to DWS Investment GmbH:

- DWS International GmbH (applicable to mandates where the voting rights have been delegated by the institutional client)

- DWS Investment S.A

Reflecting our fiduciary duty to our clients, the exercise of our voting rights is made fully independent from any views or interests of our principal shareholder Deutsche Bank AG and other DWS legal entities.

Corporate Governance

Letters to Investee Companies

Thematic engagement: Net-Zero by 2050

Thematic engagement: Net-Zero by 2050

Thematic engagement: DWS Coal Policy

Thematic engagement: Net-Zero by 2050

Thematic engagement: Net-Zero by 2050

Thematic engagement: Human rights situation in Myanmar and Belarus

DWS ESG engagements and proxy voting activities 2022

Our involvement in annual general meetings

Corporate Governance Services

DWS Corporate Governance and Proxy Voting Policy - Core Values

Boards of Directors

Executive Compensation

Shareholder Rights

Auditors

Governance Expertise and Content Development

Reporting and Communication

Fulfilling our fiduciary duty

Proxy Voting Advisory

Best Practice Principles for Shareholder Voting Research

In the context of proxy voting advisory, DWS Investment GmbH complies with the requirements of the Best Practice Principles for Shareholder Voting Research.

All relevant policies and reports can be found here.

Voting results

Germany

Germany

Luxembourg

Luxembourg

U.S.

U.S.

Corporate Engagement Process

We follow a stringent step-by-step approach in order to engage with our portfolio companies

CIO View