Sustainability Report 2021 GRI GRI 206-1 03.4 Compliance 01 Introduction Fair competition compliance with global programs in addition to additional opportunities to monitor, guide We believe fair competition and access to the local specificities. The changes also reinforce a and, if necessary, enforce remedial activities. 02 Measuring and market drives innovation, stimulates growth compliance-by-default and by-design mindset An additional benefit is the ability to learn from managing sustainability and benefits the consumer. As a global player through an evaluation of the status (e.g. standing) local and group best practices, further bolstering and a leading provider in our sector, we have of a compliance function within the enterprise our overall Compliance Culture. 03 Strengthening a responsibility to act in compliance with (e.g. the compliance function has a role/voice in As a matter of course, the development in the our foundation competition law. major strategic and operational considerations). ongoing proceedings in connection with the 03.1 Corporate citizenship To meet this responsibility, the global Allianz This holistic approach was rolled out in the second Allianz GI U.S. LLC Structured Alpha funds would 03.2 Cybersecurity Antitrust Program consists of the Allianz Antitrust half of 2021 through the Compliance Assurance also be monitored by the compliance function and 03.3 Regulatory and public affairs Standard and the Antitrust Code. The Standard of Risks and Effectiveness (CARE) program. considered as part of the regular reassessment of 03.4 Compliance lays out core principles and measures to be While CARE is primarily a self-assessment compliance risks. Major findings will be reflected 03.5 Tax transparency adopted across the Group in order to ensure exercise, it is reinforced with compliance reviews in the continuous improvement of our Compliance 03.6 Sustainable procurement compliance with antitrust law. The Code provides of operating entities, completed and coordinated Management System and compliance processes. a set of core behavioral rules that employees by Group Compliance. Compliance reviews are Voicing concerns 04 Climate-related must observe when dealing with competitors, completed on a risk-based, five-yearly cycle. financial disclosure customers and business partners. We provide This program is aligned to the CARE program Allianz offers employees multiple channels for 05 Our universal principles regular classroom and online trainings to top so that operating entities are encouraged raising concerns. Employees are encouraged management and exposed employees to refresh to exercise better rigor in the assessment of to report breaches and misconduct and and develop their understanding of antitrust control effectiveness against the background given information on where and how to do rules and how they affect their daily business. of anticipated confirmation activities. Group so. These include via management, speaking Questions and feedback received on the Compliance is itself subject to external, directly with Group Compliance, by e-mail, application of training content show the positive independent evaluation by one of the ‘Big 4’ and anonymously via the inhouse SpeakUp@ impact and efficacy of the training. companies. It is evaluated based upon CARE Allianz service found on our Group Intranet. elaborated criteria which have been certified as Some operating entities provide employees Managing compliance being compliant with regulations which define with a dedicated telephone hotline. All reported In 2021, the Compliance Function underwent requirements for compliance organizations. incidents are assessed, documented and a transformation in the way it assesses Group Compliance Reviews are supplemented managed according to internal guidelines and local Compliance Departments. In the past, by Targeted Reviews. These assess the and confidentiality is strictly adhered to. Group the focus was primarily on local implementation implementation status and effectiveness Compliance runs an annual awareness campaign of global programs (e.g. Sanctions, Anti-Fraud, of individual programs such as Anti-Trust, to remind employees of the avenues for reporting. Anti-Corruption, Anti-Money Laundering, etc.) Sales Compliance, etc. The benefit of this to ascertain the Compliance Culture of our multi-faceted review and confirmation strategy Operating Entities. Review procedures have been is that operating entities are monitored more expanded to confirm adequate compliance frequently and are engaged in more holistic scope, assure adequate skills to ensure complete assurance activities. Additionally, the frequent and effective scope coverage and confirm interactions with operating entities provide 63