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S04371  03 / 2023
Authors
Dr. Mauricio Vargas 
Finance Expert Greenpeace Germany 
mvargas@greenpeace.org
Marie Kuhn 
Finance Expert Greenpeace Germany 
mkuhn@greenpeace.org
DWS: Big Bonuses  
for Greenwashing
How the remuneration system of Deutsche Bank subsidiary  
DWS undermines effective climate and sustainability goals

Executive Summary	
4
 Introduction	
5 
The remuneration system of Deutsche Bank subsidiary DWS	
6
Sustainability review of the 2020 DWS remuneration system	
6
	
Principle 1: Remuneration must be appropriate
	
Principle 2: Sustainability goals must be appropriately weighted to have an impact
	
Principle 3: Sustainability goals must be ambitious and offer no incentives 
	
for greenwashing
Adjustments to the DWS remuneration system as of 2021	
12
	
An admission of past misguided incentives?	
	
Picking up litter and planting trees instead of instituting effective investment guidelines
Conclusion	
14
Greenpeace demands	
14
	
DWS must implement a remuneration structure that complies with the Paris agreement
	
As the parent company of DWS, Deutsche Bank must assume responsibility

4
In the summer of 2021, whistleblower Desiree Fixler sparked 
a greenwashing scandal that rocked the financial industry 
and continues to make headlines today. Fixler, a former 
sustainability manager at DWS, revealed that the asset 
management firm was promoting its investment fund 
products as greener than they actually were. Since then, US 
and German regulators have been investigating DWS and  
its parent company Deutsche Bank for suspected investment 
fraud stemming from greenwashing – a first in the sector. 
Meanwhile, in several studies of the Deutsche Bank subsidi-
ary, Greenpeace has managed to identify additional instances 
of greenwashing. All of this suggests that the fraud with 
sustainability promises at DWS might be systematic.
In light of these revelations, the present report examines the 
role played by the DWS senior executive remuneration 
system in the greenwashing scandal and its ongoing impact 
today. It is based on publicly available data such as annual 
and remuneration reports. This analysis focuses on three 
recognized principles of sustainability that must be fulfilled 
to pave the way for effective operational implementation of a 
company-wide sustainability strategy – principles which 
DWS itself was involved in developing:
—	 Company remuneration structures must adhere to  
	
the principle of proportionality. 
—	 The achievement of sustainability targets must have a  
	
sizeable impact on executive remuneration. 
—	 The relevance and materiality of the sustainability  
	
targets must be assured.
The research conducted by Greenpeace has led to the  
following findings on the DWS remuneration system: 
	 A review of the proportionality of the DWS remuneration 
system has revealed that, given the size of the compa-
ny, the DWS CEO is by far Germany’s best-paid manag-
er of a listed company. A peer group comparison shows 
that the salary of the DWS CEO is significantly higher 
than what is paid for similar positions in the industry, 
and even exceeds the salary of most CEOs of DAX-list-
ed companies. Hence, the company fails to take an 
appropriate approach to top executive salaries as a 
key means of achieving sustainability goals.
	 When it comes to weighting sustainability targets in 
executive board remuneration, there is ample evidence 
that environmental, social and governance (ESG) 
criteria have had a substantial influence on the salaries 
received by top management and by the CEO in 
particular since 2020. The structuring of bonus-relat-
ed sustainability targets has proven to be highly 
problematic, though, because it gives top manage-
ment massive incentives to pursue systematic 
greenwashing. The relabeling of funds to meet 2020 
sustainability goals can be considered as manipula-
tion. This questionable approach enabled former CEO 
Asoka Wöhrmann to receive higher bonuses.
	 By all appearance, this massive perverse incentive has 
now been recognized. In the Compensation Report 
2021, the problematic goal of “ESG-specific assets 
under management” has been removed from the 
performance targets for the CEO. But the revised set 
of sustainability targets has been reduced to largely 
ineffective pseudo-sustainability indicators. For 
example, employee trash collection campaigns help  
to boost the bonuses paid to the CEO. Yet relevant 
indicators are missing, such as the inclusion of  
financed emissions from investments, which account 
for 99 percent of greenhouse gas emissions. The 
ineffectiveness of the new DWS sustainability 
targets constitutes a new form of greenwashing.
In light of these findings, Greenpeace is calling on DWS to 
adopt a remuneration structure that maintains a balanced  
approach to salaries and ensures the relevance and tangibili-
ty of environmental objectives, such as achieving the goals  
of the Paris Climate Agreement. As the parent company of 
DWS, Deutsche Bank bears a significant responsibility for 
these greenwashing scandals and has a duty to remedy these 
abuses as quickly as possible. 
Executive Summary

5
The business of sustainability is booming – and is becoming 
an increasingly important factor in the approach adopted by 
financial institutions. Companies generally start out by 
revamping their corporate image so they can present them-
selves to the general public as a pioneer of the green transi-
tion. But adding a coat of green paint to a firm’s image does 
not always go hand in hand with the appropriate revisions of 
its business practices. This discrepancy between words and 
deeds is called greenwashing. In the past, depending on the 
magnitude of the greenwashing, this has sparked a certain 
amount of negative press and aroused a certain degree of 
public indignation. As a rule, though, there have been no 
tangible consequences. The case of DWS, Germany’s largest 
asset manager and a subsidiary of Deutsche Bank, is an 
exception: For the first time, allegations of greenwash-
ing were not treated as a minor infraction, but as a 
potential criminal offence. Currently, US and German 
financial market regulatory authorities and law enforcement 
agencies are probing DWS for alleged investment fraud. 
An important starting point to ensure the credible and 
effective implementation of sustainability principles in 
companies is the inclusion of sustainability goals in the 
remuneration structure of top management. At any rate, this 
is the recommendation of a working group that put forward 
the “Guidelines for Sustainable Management Board Remuner-
ation Systems” for the implementation of environmental, 
social and governance (ESG) criteria. This white paper was 
jointly prepared by supervisory board chairpersons, repre-
sentatives of major institutional investors, academic repre-
sentatives and experts in corporate governance. As one of 
Germany’s largest institutional investors, DWS itself played  
a leading role in the development of these guidelines.1
1	
Available here (select “EN” for the English version): http://www.leitlinien-vorstandsverguetung.de 
2	
These principles are derived from the Guidelines for Sustainable Management Board Remuneration Systems and the German Corporate Governance Code (GCGC). Also see the PWC analysis (2023) Paying for net zero –  
Using incentives to create accountability for climate goals: https://www.pwc.co.uk/human-resource-services/pdf/paying-for-net-zero-using-incentives-to-create-accountability-for-climate-goals.pdf
3	
From the Guidelines for Sustainable Management Board Remuneration Systems: “[O]nly the improvement of material relevant targets will have a sustainably positive effect on corporate performance.”
4	
All Greenpeace publications can be found on the campaign website (website in German): https://www.greenpeace.de/klimaschutz/finanzwende/deutsche-bank-tochter-dws-greenwashing-betrug 
Generally speaking, the remuneration of senior management 
should be based on transparent, measurable and effec-
tive criteria. Furthermore, many experts in the field consider 
the following three key principles2 to be indispensable 
for a credible approach to sustainability: 
PRINCIPLE 1: The remuneration structure for the top 
management of a company must comply with certain 
principles of sustainability, such as the principle of propor-
tionality.
PRINCIPLE 2: The achievement of sustainability goals 
must have a sizeable impact on executive remuneration 
in order to anchor a corporate sustainability strategy in a 
credible manner. 
PRINCIPLE 3: When formulating remuneration targets, it is 
important to ensure that these goals lead to effective imple-
mentation of the planned sustainability strategy and do not 
provide incentives for greenwashing by top management. 
The relevance and materiality3 of the sustainability 
goals must be ensured.
In addition to the recently raised allegations of greenwash-
ing, in 2022 Greenpeace has published several research 
papers4 on the climate protection pledges made by DWS. 
These publications prove that, despite its claims, the Deut-
sche Bank subsidiary is systematically undermining the 
implementation of its sustainability objectives at both the 
organizational and product levels. This raises the question of 
the extent to which DWS may have violated standards of 
good governance through its remuneration structures and 
may even have created financial incentives for misconduct by 
management when it came to anchoring the company’s 
sustainability goals. 
The present analysis examines the compensation system that 
was in place under former CEO Asoka Wöhrmann and 
current practices at DWS with respect to the three sustain-
ability principles mentioned above. 
Introduction

The remuneration  
system of Deutsche 
Bank subsidiary DWS 
Sustainability review  
of the 2020 DWS  
remuneration system
The formal structure of DWS’s remuneration system is based 
on the requirements of Section 162 of the German Stock 
Corporation Act5 and the recommendations of the German 
Corporate Governance Code (GCGC)6, which is a standard for 
good corporate governance commissioned by the German 
government. The GCGC concretely states that “the remunera-
tion structure of listed companies is to be oriented towards the 
company’s sustainable and long-term development. The 
remuneration of Management Board members shall promote 
the corporate strategy and support the long-term development 
of the company.”
The GCGC specifically recommends that compensation 
should include a short-term and long-term component. This 
requirement is also reflected in the remuneration system for 
DWS executives, which essentially consists of two salary 
components:
First, there is a fixed, non-performance-related remuner-
ation component, which consists of a basic salary along 
with pension contributions and additional perks like the use 
of a company car.
Second, this remuneration is supplemented by a perfor-
mance-related variable component, commonly referred 
to as a bonus, which may not exceed twice the basic salary. 
This variable part of the compensation is divided into a 
portion that may be paid out as short-term incentives 
(short-term award, STA) and currently amounts to 40 percent 
of the bonuses, and a portion to be paid out as a long-term 
award (LTA), which is paid over a period of five years and 
accounts for 60 percent of the total variable remuneration. 
The aim of these staggered payments is to make it possible to 
withhold disbursement under malus and clawback contract 
clauses that provide for the subsequent reduction or complete 
forfeiture of variable remuneration in the event of serious 
compliance violations. Such a payment scheme is intended to 
ensure that management can also be held liable for decisions 
with ramifications that only become apparent over the long 
term. This means, for example, that DWS CEO Asoka 
Wöhrmann, who resigned in 2022, could still be held 
accountable for greenwashing at DWS by deducting from his 
as yet unpaid bonuses.
5	
English translation available here: https://www.gesetze-im-internet.de/englisch_aktg/ 
6	
English translation available here: https://www.ecgi.global/node/9896
7	
See “Das üppige Gehalt des neuen DWS-Chef”, an article published in the Süddeutsche Zeitung on June 27, 2022 (text in German): https://www.sueddeutsche.de/wirtschaft/dws-deutsche-bank-hoops-1.5610003 
8	
See: EY (2022): Mixed Compensation Barometer 2022, available here (text in German): https://assets.ey.com/content/dam/ey-sites/ey-com/de_de/news/2022/11/ey-mixed-compensation-2022.pdf.  
The remuneration of the DWS CEO was excluded from the mean value.
PRINCIPLE 1:  
Remuneration must  
be appropriate
The proportionality or “usual level” of remuneration consti-
tutes an important aspect of a company’s credible sustain-
ability strategy. This is explained in Section G.2 of the  
GCGC as follows: “The Supervisory Board shall establish the 
specific target total remuneration for each Management Board 
member [...] which shall [...] not exceed the usual level of 
remuneration without specific reasons.”
The code then specifies the process used to determine the 
appropriateness of the level of remuneration:
“In order to assess whether the specific total remuneration of 
Management Board members is in line with usual levels 
compared to other enterprises, the Supervisory Board shall use 
an appropriate peer group of other third-party entities, and 
shall disclose the composition of such group. The peer-group 
comparison shall be applied with a sense of perspective, in 
order to prevent an automatic upward trend.”
How well is DWS performing in terms of the proportionality 
of its remuneration? In the run-up to the 2021 Annual 
General Meeting, proxy advisory firm Glass Lewis criticized 
the proposed total remuneration of €6.9 million for 
then CEO Asoka Wöhrmann as “excessive” and recom-
mended that shareholders reject the pay package. The 
recent change in leadership at DWS has only further fueled 
allegations of excessively high salaries for the company’s top 
executive. According to news reports, the planned remuner-
ation of the new DWS CEO, Stefan Hoops, with a total 
salary of €7.2 million, significantly exceeds that of his 
predecessor.7 
But how do the salary levels of DWS executives compare with 
their peers in the industry? DWS Group is a stock corporation 
listed on Germany’s SDAX index, where the average total 
remuneration for CEOs in 2021 was €1.334 million8. That same 
year, the total remuneration of then DWS CEO Asoka Wöhr-
mann amounted to €6.945 million, or more than five times the 
average for SDAX-listed companies. Even compared with 
the MDAX (average total remuneration €2.748 million), the 
DWS CEO’s total remuneration is many times higher than the 
average for MDAX CEOs.

7
A comparison with Germany’s largest companies reveals  
that the DWS CEO receives a salary that favorably compares 
with that of large DAX-listed companies. In fact, the remu-
neration of the DWS CEO is significantly higher than 
the average for DAX CEOs of €5.961 million and roughly 
corresponds to the remuneration of the CEO of Allianz SE. 
The comparison with Allianz SE raises doubts about the 
appropriateness of the DWS pay structure. After all, Allianz 
is a global corporation with an annual profit of €13.4 billion 
(12 times that of DWS), a market capitalization of €89 billion 
(14 times that of DWS)9, annual sales of €148.5 billion  
(55 times that of DWS) and 152,840 employees worldwide  
(45 times that of DWS).10 
For a further verification of this impression of disproportion-
ately high levels of payment at DWS, it seems appropriate to 
draw a broad comparison with all 40 DAX companies. Such a 
comparison is only meaningful if the respective size of the 
companies is taken into account. Factoring in the size of a 
company to evaluate proportionality is warranted because 
the level of compensation paid to top management should 
clearly reflect the extent of their responsibilities. It only 
stands to reason that mistakes made at a large corporation 
with several hundred thousand employees, billions in sales 
9	
Reference date: January 27, 2023
10	
Data from the annual reports. Key figures for DWS for 2021: Sales 2.72 billion euros, profit 1.14 billion euros, 3422 employees.
and a comparably high market capitalization will have more 
far-reaching repercussions than what would normally be 
expected at smaller companies. 
Figure 1 shows the remuneration structures of the DAX 40 
corporations in relation to the size of the company, as  
measured by the size of the workforce and sales. The DWS 
compensation structure immediately stands out as an outlier 
compared with the German DAX companies, further under-
pinning the grave doubts about the proportionality of the 
salaries paid to top executives. This is especially true if we 
exclude the two newcomers to the DAX from the (bio)tech 
sector, whose key performance indicators, as major beneficia-
ries of the COVID pandemic, are subject to considerable  
fluctuations and are therefore not particularly representative. 
	 In summary, given the size of DWS, the remuneration 
structure and the amount of compensation awarded in 
2021, it would appear that the DWS CEO is by far 
Germany’s best-paid manager of a listed company. 
Consequently, the company fails to comply with the 
principle of proportionality, which is a key aspect of a 
pay structure that promotes an effective approach to 
sustainability. 
Figure 1  CEO remuneration relative to the size of the company in comparison to DAX listed companies 
Quelle: 
2.500 €/E
2.000 €/E
1.500 €/E
1.000 €/E
500 €/E
0 €/E
Total salary CEO: Per employee
Basic salary CEO: Share of sales
Puma
0.00%
0.05%
0.10%
0.15%
0.20%
0.25%
0.30%
0.35%
0.40%
0.45%
0.50%
Hannover-
Rück
Deutsche 
Börse
HelloFresh
Qiagen
Zalando
Deutsche 
Bank
10.000 €/E
1.000 €/E
100 €/E
10 €/E
1 €/E
Total salary CEO: Per employee (log)
Basic salary CEO: Share of sales (log)
DWS
0.00%
0.00%
0.01%
0.10%
1.00%
Deutsche Börse
Hannover 
Rück
Porsche
Daimler Truck
Deutsche Post
Siemens
Mercedes-
Benz
DWS
Puma

8
PRINCIPLE 2:  
Sustainability goals must  
be appropriately weighted  
to have an impact
The high salary paid to the DWS CEO raises further ques-
tions regarding the targets and goal achievement that are 
used to determine the performance-related component of the 
remuneration. Since this analysis primarily focuses on the 
implementation of sustainability aspects in the business 
strategy, particular attention is paid to the anchoring and 
assessment of sustainability objectives in the remuner-
ation of the Executive Board. 
The implementation of a sustainable business strategy plays 
a prominent role in DWS corporate communications. For 
example, whereas the term ESG “only” appeared 70 
times in the 2019 annual report, it crops up 728 times 
in the following year’s annual report.11 This vigorous 
DWS sustainability campaign was also accompanied by a 
corresponding anchoring of sustainability objectives in the 
compensation of the Executive Board. Accordingly, when 
reviewing the 2020 and 2021 compensation reports, readers 
are left with the distinct impression that sustainability has 
been widely incorporated into the remuneration structure of 
senior executives and, in particular, of the CEO. 
DWS also misses no opportunity in its annual reports to 
proudly proclaim its commitment to implementing sus-
tainability criteria in the management of the company. 
For instance, in the 2020 Annual Report, DWS writes (p. 10): 
“We [intend] to make sustainability a key strategic focus of 
both our fiduciary and corporate activities. [...] Our aim is to 
become a leading ESG asset manager, which requires sustain-
ability to be embedded in everything we do. To achieve our 
ambitions, we developed a Sustainability Strategy, which relies 
on 4 focus areas: making sustainability the highest 
management priority, integrating ESG in the investment 
process, developing market leading products, and leading and 
engaging to promote sustainability practices.”
DWS then uses this as a basis for specifying its objectives 
and emphasizing the importance of sustainability aspects  
in the formulation of its compensation structure. Sustain-
ability is explicitly named as one of five principles for 
determining the amount of remuneration:
11	
The aforementioned annual reports are available here: https://group.dws.com/ir/reports-and-events/annual-report/ Numbers refer to the German version.
12	
Compensation system for the Managing Directors of the General Partner. Published in the run-up to the 2021 AGM, downloadable at:  
https://download.dws.com/download?elib-assetguid=04a356d46c0b407ebd88ff8e3361fb6e&publishLocationGuid=eacbc9cf4b8e4d2189eb69cd09e2ff4f 
13	
Ibid. 
14	
These are our own estimates based on the 2020 Compensation Report and the assumption that 25 percent of the short term performance component was linked to ESG topics. The basis for this assumption is that within the 
DWS Executive Board the responsibility for implementing the sustainability strategy lies primarily with the CEO. Indeed, the DWS officially announced in 2019: “Dr. Asoka Woehrmann is the CEO and Chairman of the Executive 
Board. [...] Dr. Woehrmann has [...] assumed the responsibility for setting the overall DWS Group ESG and Sustainability strategy.” See DWS 2019 Annual Report, p. 155
“Responsible and sustainable action are of paramount strate-
gic importance. For that reason, the performance parame-
ters of the compensation system are closely linked with 
DWS’s ESG/sustainability strategy. […] DWS aims at 
shaping the future of investing. [...] Against this backdrop, 
responsible investing and a clear focus on sustainability 
concepts such as environmental, social and governance (ESG) 
underpin DWS’s fiduciary credo.” 12
The high priority accorded to sustainability is reflected in  
its high weighting in the variable component of the  
remuneration: 
“Overall, the ESG objectives account for at least 20% of the 
total reference variable compensation.” 13
Hence, the weighting of at least 20 percent specified for 2021 
is to be understood as the mean value of the weighting of 
sustainability in short- and long-term objective achievement. 
Indeed, ESG implementation is predominantly achieved for 
short-term objectives with 27 percent and trails among 
long-term objectives with 15 percent.  
In the previous year, i.e. 2020, the weighting of ESG imple-
mentation in determining the amount of remuneration was 
less clearly defined, but nevertheless still substantial. Thus, 
in addition to a personal balance score card, which was 
designed to include ESG targets and represent 50 percent of 
short-term compensation, individual goals with a weighting 
of 33 percent were used to determine short-term compensa-
tion. Likewise, when it came to long-term compensation, the 
company-wide implementation of sustainability was an-
chored with a weighting of 10 percent.  
 
Despite the ambiguities regarding the exact weighting, an 
overall assessment of these specifications indicates that ESG 
criteria were already accorded a substantial weighting in the 
remuneration of top management and, in particular, the CEO 
on the order of between 15 and 20 percent in 2020.14 
	 In summary, the sustainability goals are weighted  
sufficiently high to have an effective impact. However, 
the concrete definition of the goals is decisive for the 
overall effectiveness.

9
PRINCIPLE 3:  
Sustainability goals must be  
ambitious and offer no  
incentives for greenwashing
The implementation of sustainability in management board 
compensation is given a correspondingly high weighting in line 
with the recommendations that were made. However, it goes 
without saying that establishing a policy like this is not an end 
in itself. Anchoring sustainability criteria in top management 
remuneration must ultimately specify relevant and effective 
sustainability criteria as measurable performance targets that 
are used to determine the amount of remuneration, in accor-
dance with the white paper of the working group “Guidelines 
for Sustainable Management Board Remuneration Systems,” 
which, as previously described, DWS itself helped to compile.
15	
The question of whether all of these objectives are effective will remain unanswered here for the time being. However, there are legitimate doubts as to whether, for example, the CSR activities of DWS employees, such as 
planting trees, actually have a relevant ecological impact or are primarily intended for PR purposes. It is also perplexing that, at first glance, the key Scope 3 emissions are to be reduced, but this does not include the significant 
“financed emissions” that represent >99% of Scope 3 emissions. To gain a better understanding of the importance of Scope 3 emissions, DWS could have consulted the in-house research department of its parent company 
Deutsche Bank: What are Scope 3 emissions and why are they important? 
https://www.dbresearch.com/PROD/RPS_EN-PROD/What_are_Scope_3_emissions_and_why_are_they_import/RPS_EN_DOC_VIEW.calias?rwnode=PROD0000000000517071&ProdCollection=PROD0000000000518185
16	
The concrete objectives were referenced in the Compensation Report (p. 114) of the DWS Annual Report 2020 as follows: “Detailed information on the Key Performance Indicators and successes in the area of ESG can be found 
in the chapter ‘Operating and Financial Review – DWS Performance’ and in the chapter ‘Operating and Financial Review – Overview of 2020’. 
To implement its company-wide sustainability strategy, DWS 
also developed transparent and measurable performance 
indicators for its objectives, which it describes in its compensa-
tion reports while, in some cases, also reporting on the con-
crete extent of target achievement.15 
In 2020, the Compensation Report addressed the ESG targets 
with reference to the following key performance indicators 
(KPIs) as a means of identifying sustainability performance, 
and this was included in the 2020 Annual Report.16
As shown in Figure 2, the increase in dedicated ESG assets 
under management is a key indicator of the achievement of 
sustainability objectives. It is worth noting that the conver-
sion of non-sustainable funds into ESG products is also 
Figure 2  ESG KPIs defined by DWS to identify sustainability performance
KPI
Near-term ambition
2019 Result
2020 Result
Dedicated ESG AuM  
(assets under management)
Grow our ESG AuM through a combination of flows  
into existing products, flows into new products and 
enabling the transfer of existing client assets from 
non-ESG products into ESG dedicated products
9.7 bn
93.6 bn
PRI rating for Strategy &  
Governancea
Maintain 2019 result of A+
A+
A+
Global emissions –  
Scope 1, 2 and 3b
Reduce Scope 1 and Scope 2 as well as our Scope 3 
emissions at which we have influence on such as  
business travel
11,982
6,822
Sustainability rating
Achieve a CDP rating in 2020
N/A
C
Gender diversity
Progress towards our 2021 target of 26% of positions 
at the first management level below the Executive 
Board held by female executives and 29% at the  
second management level below the Executive Board 
21.5 % – 1st level 
26.8 % – 2nd level
27.0 % – 1st level
28.2 % – 2nd level
Corporate engagements
Increase the number of corporate engagements
250
454
Proxy voting
Increase the number of companies whose shareholder 
meetings we vote at, for portfolios domiciled in Europe 
and Asiac
1,722
1,859
 
a 	
Due to methodology change in PRI ratings we will not be disclosing an updated ambition in this report 
b 	
In t/CO2e. Includes Scope 3 emissions from Real Estate, Air Travel and Car Fleet/Leased Vehicles. DWS Real Estate emissions for 2020 are determined on a pro-rata average FTE basis from DB Group emissions  
	
(natural gas, liquid fossil fuels, renewable and grid electricity, district heating, cooling and steam) and relate to the period October 1, 2019 to September 30, 2020. Q4 2019 is used as a proxy for activity in Q4 2020.  
	
2020 Air Travel and Leased vehicles based on January 1, 2020 to December 31, 2020 DWS data. All 2019 emissions results based upon the calendar year. Air travel derived from actual DWS flight data and leased vehicles  
	
from driven kilometers with diesel or gasoline cars. The most appropriate emission factors have been used for each activity data type from internationally recognized sources e.g. DEFRA (2018 and 2019), GHG Protocol,  
	
eGRID (2018) and IEA (2019), RE-DISS (2018) or, if more relevant, from country or contract specific sources. The factors include all GHGs where possible and the gases’ Global Warming Potential as per the IPCC AR5 assessments 
c 	
Ambition restated to reflect number of companies whose meetings we vote at instead of number of meetings voted disclosed in 2019 NFR

10
attributed to the increase. It follows, then, that there is a 
tangible incentive for top management to increase the 
volume of ESG funds, which can also be accomplished by 
reclassifying funds that were originally considered unsus-
tainable. In fact, the “hard” numbers show that the propor-
tion of “sustainable” fund assets soared from 2019 to 
2020. 
Figure 3 shows the changes in the proportion of “sustainably” 
managed fund assets, as disclosed by DWS in its annual 
reports since 2019. It should be noted that there was no 
17	
See: Annual Report 2021, p. 37: “A comparison of the ESG AuM figures for 2020 and 2021 is not feasible, as the framework for determining the figure has been revised [...].”
consistent classification of sustainability throughout the period 
under review, as DWS itself admits.17 In its Annual Report 
2020, for instance, DWS distinguishes between “ESG-integrat-
ed” and “dedicated ESG” investments. Furthermore, the 
German version of the report refers to a third category, namely 
so-called “ESG-specific” (ESG-spezifische) assets, although this 
was translated in the English version of the text as “dedicated 
ESG AuM” or simply “ESG AuM”. 
The amount of “specific” sustainable assets under 
management grew rapidly by 34 percent in 2020 com-
Figure 3  “Sustainable” assets under management, as reported by DWS  
source: annual and semi-annual reports, 2019 to 2022
In bn euro
600
500
400
300
200
100
0
In % of AuM
12 %
10 %
8 %
6 %
4 %
2 %
0 %
Total 2019
Total 2020
H1 2021
Total 2021
H1 2022
/ 1 / Percentage of “ESG specific” assets in AuM
/ 2 / “Dedicated” sustainable assets (Active and Passive)
/ 3 / “Dedicated” sustainable assets (impact, real estate, infrastructure)
/4 / “ESG integrated” assets
/ 5 / ESG assets under management in the Active segment
/ 6 / ESG assets under management in the Passive segment
/ 7 / Total sustainable
/ 8 / ESG assets under management in the Alternatives segment
(Value too small to be visible )
Published  
retrospectively
/ 1 /
/ 4 /
/ 3 /
/ 3 /
/ 6 /
/ 2/
/ 2/
/ 5 /
/ 7 /

11
pared to the volume reported (retroactively) in 2019, 
which was 10 times faster than the growth rate for the total 
amount of assets under management. Total assets designated 
as “sustainable” – or in DWS’s wording, “ESG-integrated” – 
grew to an aggregate volume of €552 billion, or 70 percent of 
assets under management, according to the 2020 annual 
report. While this ballooning in the number of “ESG-inte-
grated” assets under management was heavily criticized in 
public due to the allegations of manipulation brought by 
former DWS Group Sustainability Officer Desiree Fixler18 , 
which also sparked investigations by the financial superviso-
ry authorities, the explosive growth in “dedicated ESG”19 
assets under management went largely unnoticed. 
However, in view of the fact that bonuses were linked to 
these parameters, this development is highly problematic. It 
creates a tremendous incentive to label existing funds 
as sustainable and thus achieve the sustainability 
objectives without making the necessary changes to 
the basic underlying concepts of the funds. This devel-
opment has also been observed in recent years. For example, 
numerous funds were awarded a so-called Article 8 sustain-
ability classification20 and in some cases also given an ESG 
label in the fund name, without any substantial changes 
being made in the asset management. 
This approach has sparked considerable consternation 
among the general public. For example, DWS’s flagship 
product, DWS Top Dividende, was changed to a so-called 
Article 8 sustainability fund with “ESG integration,” al-
though the de facto orientation of the fund remained un-
changed, according to news reports.21 Numerous existing 
funds were given a makeover and even had an ESG sustain-
ability label added to their names, such as the fund heavy-
weight DWS ESG Akkumula. Paradoxically, however, this 
ESG fund is currently no longer marketed by DWS as a 
“sustainable” fund investment, despite the inclusion of “ESG” 
in the fund name.22 
18	
For example, see here (text in German): https://www.handelsblatt.com/finanzen/anlagestrategie/trends/greenwashing-verdacht-wie-schwammige-esg-kriterien-vermoegensverwalter-in-misskredit-bringen/27619212.html 
19	
DWS uses diverse ESG categories in its annual reports in a highly inconsistent, confusing and downright questionable manner: It refers to “ESG-integrated,” “dedicated ESG,” and “ESG-specific” assets along with “ESG assets” 
and “sustainably” managed assets. Aggregate reporting was based on estimates that only appeared plausible due to a lack of clarity in the DWS reports. 
20	
According to the EU Sustainable Finance Disclosure Regulation (SFDR), DWS is required to classify its funds in one of three sustainability categories:  
Article 6, Article 8 or Article 9. Article 8 funds promote environmental or social characteristics, while Article 9 funds pursue sustainable investments and have explicit sustainability objectives.
21	
See the the article “Schöner grüner Schein,” published in the Süddeutsche Zeitung on August 31, 2021 (text in German):  
https://www.sueddeutsche.de/wirtschaft/dws-greenwashing-top-dividende-deutsche-bank-fonds-1.5397374
22	
A search of the funds listed on the DWS website, made on Feb. 10, 2023, failed to reveal the fund listed among the sustainable products. Nevertheless, in test purchases commissioned by Greenpeace in September 2022,  
the fund was explicitly recommended as sustainable during advisory talks with the parent company. The results of the test purchases can be found here (text in German):  
https://www.greenpeace.de/publikationen/schwache-performance-klimavertraegliche-dws-fonds-beratungs-check 
	 The facts add up to a highly disturbing overall picture 
for the year 2020. To successfully achieve their objec-
tives, management had to increase the volume of 
“sustainably” managed funds, with simple relabeling of 
the funds as an apparently widely accepted practice. 
From an empirical perspective, we have determined 
that the fund volume in question did indeed surge that 
same year and there was consequently a correspond-
ingly high level of target achievement for the payment 
of bonuses.

12
An admission of past misguided incentives?
The following year, 2021, changes were made to the corre-
sponding compensation report and the ESG objectives to be 
achieved were adapted and specified:
Evidently, a significant modification is that, in contrast to 
2020, the increase in “sustainably” managed assets has been 
dispensed with and now only the net cash inflow is taken 
into account in achieving the target of sustainable financing.  
It is unclear whether this correction can be considered an 
implicit admission of previous perverse incentives. What is 
clear, however, is that the new sustainability targets have 
corrected a glaring weakness in the previous bonus system, 
which raises the question of whether, with these changes, the 
revised DWS remuneration system now provides the right 
incentives for top management to implement an effective 
sustainability strategy. 
23	
Scope 1 and 2 describe emissions that result directly from a company’s own business operations, while Scope 3 also includes indirect emissions along the entire value chain, such as emissions generated by DWS’s financial 
investments. See the aforementioned definition by Deutsche Bank’s in-house research department: What are Scope 3 emissions and why are they important?
24	
For example, the emissions financed via the loan book at the parent company Deutsche Bank exceed the emissions of its own business operations by a factor of 385, according to its own information.  
https://www.db.com/news/detail/20220304-deutsche-bank-veroeffentlicht-details-zum-co2-fussabdruck-ihrer-unternehmenskredite?language_id=3=
25	
 See the research conducted by the Guardian on the limitations of the CDP rating: https://www.theguardian.com/environment/2022/apr/09/why-eco-conscious-fashion-brands-can-continue-to-increase-emissions
Picking up litter and planting trees instead of 
instituting effective investment guidelines
It is conspicuously obvious that the focus of the sustainabili-
ty goals has shifted markedly toward the company itself, 
with some goals that are extremely feeble or irrelevant 
from the point of view of sustainability. For example, in 
the interest of protecting the climate, the primary focus of  
a financial services provider such as DWS should clearly not 
be on Scope 1 or Scope 2 emissions23 but rather on the 
financed emissions (that fall under Scope 3).24 The level of 
ambition of the modified targets is thus highly questionable, 
especially since it also relies on a very narrowly defined 
climate rating that aims to disclose climate metrics and again 
places a strong focus on the reduction of Scope 1 and Scope 2 
emissions. For the reasons cited above, this fails to make the 
grade for a financial institution.25 By the same token, it is 
questionable whether CSR activities that involve the compa-
ny’s workforce, like planting trees and collecting waste, 
which DWS showcases on its social media channels, should 
be considered key sustainability goals when, for example, 
the firm lacks binding investment guidelines aimed at 
complying with international environmental agree-
ments. Last but not least, the governance goal “ethical 
conduct, integrity and speak-up culture” is bewildering 
because no key figures are provided for this in the ESG key 
performance indicators that are used in the annual report to 
Adjustments to the 
DWS remuneration  
system as of 2021
Figure 4  The ESG objectives of top management for the year 2021  
and their respective weighting within the long-term remuneration components.a 
Environmental, Social and Governance (ESG) footprint
Share of long-term 
remuneration (25%) 
Environment
Sustainable finance and  
investment
ESG net flows
5 %
Sustainability rating
5 %
Reduce own CO2  
emissions
Energy consumption
0.8 % 
Travel emissions
4.2 %
Social
Corporate social responsibility activities  
of DWS employees 
5 %
Governance
Ethical conduct, integrity and speak-up culture
5 %
a 	
source: Own calculations based on the DWS Annual Report 2021, p. 104

13
determine progress in sustainability26 At any rate, the high 
level of achievement of this target area stands in stark 
contrast to the recent allegations made by whistleblower 
Desiree Fixler about DWS’s poor handling of internal 
criticism.27 
One has the distinct impression that the most glaring flaws 
in the 2020 remuneration system – which led to the misman-
agement of the sustainability strategy and the systematic 
greenwashing of investment funds – were initially addressed 
with the new bonus structure. However, this was accom-
plished by introducing largely toothless environmental 
targets. It is hard to imagine how top management, and 
especially the Chairman of the Executive Board who explicit-
ly cites “driving sustainability as a core principle for DWS”28 
among his performance targets, can expect to make any 
substantive progress on enhancing the company’s sustain-
ability based on these unambitious goals. 
One thing seems certain, though: the company has lowered 
the hurdle for achieving high targets in implementing 
the sustainability strategy, making it that much easier 
for the head of DWS to secure record salaries. So it 
comes as no surprise that the company exceeded its targets 
for ESG in 2021 by 134 percent, which is close to the maxi-
mum possible target achievement level (150%):29
26	
Elsewhere in the text (Annual Report 2021, p. 93), reference is made to positive feedback from employee surveys and the 140% target achievement is attributed to a nuanced improvement in the corporate feedback culture. It is 
not clear why this target was mentioned, even though it did not appear in the ESG performance indicators, while the earlier target of a gender quota aimed at increasing the number of women in the first two management levels 
below the Executive Board, for example, was omitted from the report for apparently arbitrary reasons. 
27	
For more on this criticism, see the webinar “Greenwashing – An inside perspective,” with Desiree Fixler, hosted by Finanzwende e.V. Available at https://www.youtube.com/watch?v=P8JCLzm-HAA
28	
DWS Compensation Report 2021, p. 92. 
29	
Performance is based on a success factor, which is expressed as a 100% achievement grade if the target is met, but can climb to 150% if the target is surpassed. The success factor is multiplied by the agreed target figure for 
the variable component of the remuneration to determine the final bonus. 
This high level of ESG target achievement was what drove 
the record total salary of €6.945 million for DWS CEO Asoka 
Wöhrmann in 2021. However, the greenwashing scandal and 
allegations of fraud have cast considerable doubt on the 
validity of this result. 
	 Although the revised 2021 bonus system no longer 
features the appalling incentive to inflate the number of 
“ESG-labeled” funds, it remains an equally flagrant 
form of greenwashing. While sustainability aspects 
figure prominently in the remuneration requirements 
for top executives, in keeping with the recommenda-
tions for implementing a credible sustainability strate-
gy, the company’s environmental goals still lack 
relevance and effectiveness, rendering it impossible 
for the objectives to have a substantial impact. This 
makes it very easy for company officials to achieve 
their goals and secure large bonuses without much 
effort – an approach that essentially reduces the DWS 
sustainability strategy to nothing more than an exer-
cise in smoke and mirrors. 
Figure 5  Achievement of objectives for  
sustainability KPIs in 2021a
ESG-KPIs
Achievement of  
objectives
ESG net flows
150 %
Sustainability rating
140 %
Reduction of own CO2 emissions  
(air & rail)
142 %
CSR of employees
100 %
Corporate & speak-up culture
140 %
Total ESG achievement of objectives
134 %
 
 
a 	
Source: DWS Compensation Report 2021, p. 93.

14
The present research of the remuneration system of Germa-
ny’s largest asset management company has revealed that 
DWS is violating the fundamental principles of a 
sustainability bonus scheme.
Indeed, in light of the size of the company, it is fair to say 
that the CEO of DWS is by far best-paid chief executive of a 
German stock corporation. The amount of money paid to 
the CEO thus far exceeds what is permissible according 
to the principle of proportionality. 
Furthermore, it has become clear that DWS has been pursu-
ing a highly aggressive PR campaign since 2020 to promote 
its sustainability strategy and that, as recommended by the 
company, this strategy has been incorporated into the bonus 
scheme for top management with a correspondingly high 
degree of weighting. This means that sustainability is 
ostensibly accorded an appropriate degree of importance in 
the remuneration of DWS executives, which at first glance 
lends credibility to DWS’s efforts to promote sustainability. 
However, our analysis of the established sustainability 
objectives has revealed that these targets were fraught with 
significant perverse incentives in 2020. Specifically, the 
option of converting existing non-sustainable funds into 
investments that bear the coveted ESG label has made it 
possible to meet sustainability targets without enacting any 
major changes to DWS investment strategies. This is a 
significant conflict of interest for top executives, who 
were able to personally benefit from this greenwashing 
of the funds. In keeping with these perverse incentives, the 
proportion of “sustainably” labeled funds soared, which in 
turn justified correspondingly high bonus payments. 
The following year, 2021, DWS apparently recognized the 
misguided nature of its incentives – and the resulting 
conflict of interest – and removed the highly problematic 
parameter of “ESG-specific” assets under management from 
its performance targets. Nevertheless, the revised catalog of 
sustainability targets was also reduced to now largely 
ineffective indicators that, although they addressed the 
conflicts of interest, narrowed the focus of environmental 
targets to irrelevant corporate metrics. The toothlessness 
of the new DWS sustainability targets ultimately 
amounts to a new form of greenwashing.
30	
 See the blueprint for investment guidelines for dealing with coal, oil and gas companies in line with the goals of the Paris agreement (text in German): https://www.greenpeace.de/publikationen/blaupause-dws
	 DWS must implement a remuneration  
	 structure that complies with the Paris  
	 agreement
In order to be truly credible and consistent, DWS 
needs to adopt a compensation structure that 
maintains the proportionality of salaries and ensures 
the relevance and materiality of environmental objec-
tives. When it comes to implementing climate pro-
tection policies, this would require science based 
and ambitious targets that are not restricted to 
internal company parameters. These targets should 
stipulate a reduction of all financed emissions in line 
with the Paris climate agreement, and they should 
reward the implementation of credible investment 
guidelines that regulate aspects such as ways of 
dealing with companies that are considered particu-
larly detrimental to the climate. For effective invest-
ment guidelines on climate protection, Greenpeace 
has drawn up concrete proposals in the form of a 
blueprint that DWS can immediately put into practice.30  
	 As the parent company of DWS,  
	 Deutsche Bank  must assume  
	 responsibility
In view of what has come to light, it is clear that the 
multitude of greenwashing allegations at DWS can 
be traced to structural deficits and explained by the 
misguided incentive schemes of the bonus system. 
As the parent company of DWS, Deutsche Bank 
bears a major share of the responsibility for these 
glaring lapses. It is thus called upon to rectify this 
misconduct as quickly as possible and to put a stop 
to excessive bonus payments for greenwashing.
Conclusion
Greenpeace  
demands