01 Our vision of 02 Sustainable 03 Active 04 Strengthening sustainability 05 Appendices sustainability investing stewardship in our operations 04.3 Ensuring responsible business conduct Principle 3 5 04.3.2 Globally harmonised The Code of Ethics serves as a foundation 04.3.4 Managing the Risk Management function de昀椀nes policies and standards for our compliance culture and regulatory risks e昀昀ectively which risk models and analytics are used Globally applicable policies include: expectations for all AllianzGI employees. The independent Risk Management to ensure compliance with regulatory the AllianzGI Code of Ethics and Speak- function is responsible for setting up a requirements and, for selected topics or 04.3.3 Ensuring compliance if contractually agreed, determines when Up policy, as well as policies governing The Compliance function is responsible 昀椀rm-wide auditable, documented risk further independent risk analyses and anti-money laundering, anti-fraud, for implementing and maintaining management system and risk policies that supervision should be conducted beyond anti-trust, anti-bribery, economic an e昀昀ective compliance programme. are consistent with AllianzGI’s business what is required by regulation. sanctions, personal account dealing, This includes compliance risk analyses, strategy. We cluster risks into four risk Operational risk is de昀椀ned as the risk of order execution, con昀椀dential information/ as well as the annual compliance categories: investment risk, operational loss inherent in our internal organisation insider information and data privacy. self-assessment and control plan. risk, business risk and reputational and the processes and controls resulting Employees are required to act in Compliance also develops and risk. We consider sustainability risk, from potential failure to deliver our accordance with these policies at all administers guidance for employees, concentration risk and emerging risk products or services in the required time times, whether dealing with clients, regular compliance training sessions as transversal risks that may be realised and quality and in line with all regulations. external third parties or other on the Code of Ethics and anti-money in one or more of these categories. Each function is responsible for ensuring Allianz employees. laundering, and annual and ad-hoc Our robust processes and procedures an appropriate control framework to Our clients expect their personal training on matters related to other ensure that we e昀昀ectively monitor and govern its key processes and mitigate information to be treated with company policies and procedures. manage risks within these categories. operational risks. The Risk Management the utmost care and we take this All employees attended mandatory Investment risk includes the risk of function has established an integrated responsibility seriously. Employees must compliance training in 2023, covering changes in the value of investment framework to oversee operational risk adhere to con昀椀dentiality in relation to topics including anti-money laundering, portfolios that may be perceived as management by the business. client information and 昀椀rm activities. anti-fraud and economic sanctions. inconsistent with the risk pro昀椀le of the AllianzGI pursues e昀昀ective management The Compliance function is involved respective portfolio as communicated to and fair handling of the potential in the monitoring of proxy voting and the investor. This includes the risk that the con昀氀icts of interests that may arise as investment guidelines, including those company is exposed to market and credit we provide investment services. We have related to sustainability matters, such as risk in the portfolio via implicit or explicit embedded robust business policies and exclusion lists. It also monitors portfolios performance promises. Investment risk processes governing ethics and client for compliance with investment also includes liquidity risk, which depends con昀椀dentiality. They are detailed in the guidelines, both pre- and post-trade. on asset liquidity and 昀氀ows on the liability AllianzGI Code of Ethics and echo Allianz side, as well as constraints imposed by Group’s overall standards. regulators. For investment risk oversight, Allianz Global Investors Sustainability and Stewardship Report 2023 83