01 04.4 Business conduct and operational risk management Principles 3 5 Introduction 02 Sustainable investing Our success is built on the trust our The responsibility to perform tasks concerning anti- laws as well as to the Allianz Privacy Standard (APS), 03 money laundering and to implement procedures to which – together with the Allianz Binding Corporate Active stewardship clients, employees and the public have prevent money laundering and terrorist financing Rules – ensures a common understanding of, and 04 in our performance and integrity. They (following the “three lines of defence” model) lies within adherence to, global privacy standards. AllianzGI as a sustainable business expect their personal information to be the business and Compliance and Audit functions. We As part of the Legal and Compliance function, 04.1 B uilding our approach to treated with the utmost care and we take document all procedures and measures regarding the AllianzGI has established a Global Data Privacy function sustainable investing this responsibility extremely seriously. prevention of money laundering and terrorist financing. with regional Data Privacy Officers and one Global 04.2 Developing a shared vision for Key responsibilities of the Compliance Data Privacy Officer. This function informs, advises and inclusion and diversity Code of Ethics function include: issues recommendations regarding compliance with 04.3 P romoting employee health We have embedded robust business policies and applicable data privacy laws and regulations, the APS, and wellbeing in a hybrid • Implementation of regulatory requirements into the and other internal and legal standards and guidelines. work environment processes governing ethics and client confidentiality. business processes of AllianzGI It works in close co-operation with the respective 04.4 Business conduct and These are detailed in the AllianzGI Code of Ethics and Information Security Officers to ensure that adequate operational risk management echo Allianz’s overall group standards. • Management of conflicts of interest 04.5 Managing the environmental • Anti-money laundering and anti-bribery/fraud data protection-related technical and organisational impact of our operations Employees are required to act in accordance with measures are in place. 04.6 Corporate citizenship these policies at all times whether dealing with clients, monitoring other external third parties or other Allianz employees. • Setting up information barriers to prevent confidential Risk management along the value chain 05 They must adhere to confidentiality in relation to client information from being passed on We consider risk management to be an integral part of Appendix information and firm activities. Additionally, employees our business processes throughout the value chain, from must not engage in any activities that would result in • Monitoring of personal account dealings client onboarding and portfolio risk management to either a direct or indirect conflict of interest. • Prevention of insider trading and market abuse monitoring operational risks. Risks are addressed as part The Compliance function oversees the effective of an overarching reporting and controlling framework implementation of all regulations stipulated in the • Monitoring trading activities to ensure best execution covering both qualitative and quantitative risks for each Code of Ethics regarding acceptable business practices, to all clients of our functions along three lines of defence: conflicts of interest policies and expected standards • Investment guideline coding and monitoring: • The first line of defence is where each function of ethical behaviour. Every employee participates AllianzGI checks portfolios for compliance with is responsible for designing and implementing in regular compliance training. Personal account investment guidelines, both pre- and post-trade adequate controls related to its processes. dealing is an important topic of compliance with • Employee regulatory training • The second line of defence provides independent the Code of Ethics and is monitored via the online oversight and challenge of the day-to-day risk controls StarCompliance system. • Implementation and maintenance of an effective and risk-taking by the first line. This second line of Our Anti-Money Laundering (AML) policy and Global compliance programme (including the execution of defence is performed by the Legal and Compliance Client Due Diligence (CDD) procedures reflect the a compliance risk analysis and an annual compliance function and the Risk Management function. current requirements of the fifth EU AML Directive, the self-assessment). recommendations of the Financial Action Task Force Data privacy • The third line of defence provides independent on Money Laundering (FATF), the German Anti-Money assurance across the first and second lines of defence. Laundering Act and other European AML laws. We have We are committed to protecting the privacy rights of The third line of defence is performed by the Internal implemented procedures and controls to prevent money our clients, employees, business partners and other Audit function. laundering and terrorist financing. third parties when processing personal data. Personal data includes any information related to an identified or identifiable individual. We adhere to strict data privacy