Sustainability Report 2021 GRI GRI 205 GRI 206 GRI 102-16 03.4 Compliance GRI 205-2 01 Introduction Our success is built on the trust Allianz Group Code of Conduct The new CoC was rolled out across the Group in Anti-money laundering of our customers, investors, The Allianz Group Code of Conduct (CoC) is 2021 along with training for operating entities to In accordance with applicable legal requirements, 02 Measuring and at the core of our corporate culture. It outlines raise awareness about the principles established Allianz Group operating entities establish risk- managing sustainability employees and the public the basic principles and values that guide the by the CoC, namely mutual respect, integrity, based policies and procedures to prevent the have in our performance and everyday decisions and conduct of all employees. transparency and responsibility. Operating entities risk of money laundering and terrorism financing 03 Strengthening Every new joiner to Allianz is informed of their are in the early stages of planning and delivering based on customer identification, verification and our foundation integrity. This depends on obligation to adhere to the CoC during their this training. monitoring, as well as suspicious activity reporting. 03.1 Corporate citizenship the personal ethical conduct welcome presentation. As part of a project led by Zero tolerance of fraud and corruption We employ screening and monitoring systems and 03.2 Cybersecurity Group Compliance, the CoC was fundamentally Allianz takes a zero-tolerance approach to fraud processes to manage risks and ensure compliance 03.3 Regulatory and public affairs and capability of all Allianz renewed in 2020 and approved by the Board and corruption. We are committed to complying with anti-money laundering requirements and 03.4 Compliance management and employees, of Management to replace the previous version fully with local and international anti-corruption economic sanctions restrictions. 03.5 Tax transparency from 2006. The updated CoC considers feedback and anti-bribery laws. Our aim is to go beyond Respecting economic sanctions 03.6 Sustainable procurement and their desire to create value collected from global employees on value complying with the minimum standards of the for all stakeholders. perception and includes an introductory message law, such that the Allianz Anti-Corruption Program and embargoes 04 Climate-related from the Group’s CEO, a clear link to the new We have global policies and procedures in place financial disclosure company purpose and relevant topics beyond sets standards for a consistent and comprehensive to ensure compliance with trade and financial Compliance mission traditional compliance including feedback culture, group-wide approach in every jurisdiction. sanctions. These include requirements for the 05 Our universal principles Our Compliance function fosters a corporate diversity, inclusion and sustainability. The program requires that employees and certain screening of customer and counterparty names culture of individual and collective responsibility The CoC expresses Allianz’s commitment to third parties with whom Allianz does business against the sanctions lists provided by the U.N., for ethical conduct and adherence to the rules by: respecting a wide range of international human are prohibited from offering, accepting, paying E.U. and the U.S. Office of Foreign Assets Control • enabling our employees to understand and rights standards including: or authorizing any bribe or any other form of (OFAC). Allianz’s global requirements also include live by the rules and oversee that adequate corruption, be it with the private sector or with an enhanced review requirement for high-risk and effective processes are in place to • the Universal Declaration of Human Rights; government officials. transactions related to countries, sectors or parties ensure adherence; • the U.N. Covenants on Human Rights; Anti-Corruption training is compulsory for all subject to sanctions restrictions. • supporting the business to identify, assess and • The Core Labor Standards of the employees with online and classroom training Due to the nature of our clients’ underlying mitigate compliance risks; International Labor Organization (ILO); delivered in multiple languages. To ensure business transactions, some of Allianz’s insurance online trainings achieve acceptable levels of coverage and other business can relate to • maintaining a confidential channel to report • OECD Guidelines for understanding and awareness, they include concerns, act on them and protect those who Multinational Enterprises; a mandatory test component that must be countries, sectors or parties subject to sanctions speak up in good faith; and • Guiding Principles for Business and Human completed and passed for the training to restrictions. For example, where permitted, Rights of the U.N.; and be deemed to have been completed by the we may issue insurance for humanitarian services • interacting transparently and truthfully employee. In 2022, we will introduce Anti- provided by our clients in sanctioned countries. with regulators. • The Ten Principles of the U.N. Corruption training KPIs in line with the World The Allianz Sanctions Compliance Program aims Global Compact. Economic Forum (WEF) requirements. to ensure we respect all applicable restrictions F or further information about our commitment and that these high-risk transactions undergo to human rights, see section 05.6. No material violations of corruption laws enhanced scrutiny. or corresponding official proceedings were reported to Group in 2021 which would have been required to be disclosed to Allianz Group’s Audit Committee. 62