AllianzGI Stewardship Statement Regulatory framework and conflicts of Training - AllianzGI has implemented global and local interest policy policies, including Codes of Ethics and Business Conduct, which are designed to ensure employees always put first the Our policies and procedures governing conflicts of interest interests of our clients and take care to avoid even the are designed to ensure that our conduct is in line with all appearance of impropriety. Such policies require our applicable regulatory requirements. The legal entities that employees to disclose all potential conflicts and, if together form AllianzGI are registered with and supervised applicable, recuse from voting decisions in cases in which by the relevant regulatory authorities in jurisdictions in which there is a potential conflict or even a potential perceived we operate around the world. conflict of interest. Specifically, portfolio managers or Proxy Committee members with a personal conflict of interest Global oversight - AllianzGI has established a Global Proxy regarding a particular proxy vote must recuse themselves Voting Committee to provide oversight of the proxy voting and not participate in the voting decisions with respect to process. The Committee reviews and discusses any proxy that proxy. We review and train all employees on such voting issues that may raise material conflicts of interest policies at least annually. between AllianzGI and its clients. It approves proxy voting decisions where a conflict of interest has been identified, Management - To manage potential conflicts in our and based on internal analysis, where the proposed vote engagement activities, AllianzGI has developed a clear and direction departs from AllianzGI’s policy recommendation. transparent internal escalation guidance. The guidance The decision making is based on AllianzGI’s Global distinguishes between non-public and public engagement Corporate Governance Guidelines summarising our position activities and assigns decision-making authority for on specific issues, including issues of corporate governance proposed engagements with clients, major suppliers, non- and corporate actions, and gives a general indication as to governmental organizations, policymakers, media and how we will vote in such instances. other parties. Our approach to managing potential conflicts in engagement activities, including collective engagement Conflict management - There are instances when we may initiatives and public policy engagements, is set out below: not wish to undertake proxy voting in strict adherence to the guidelines. Where a potential material conflict of interest – Affiliated companies: We normally refrain from formal arises between the company’s interest and those of a client engagement with affiliated companies. However, we are with respect to proxy voting, the Global Proxy Voting willing to provide informal feedback to the boards and Committee will convene to evaluate the issue, taking into management of affiliated companies, including account information from all relevant sources, including the explanation of any votes against management or our portfolio management team, the stewardship analyst, position on issues and concerns raised by other investors. management of a company presenting a proposal, shareholder groups and independent proxy research – Directors and employees: In instances where directors services. or employees of AllianzGI or our affiliated companies hold directorships or advisory roles at a company we are Other potential conflicts of interest in voting clients’ proxies engaging, those persons will be excluded from are addressed through the application of the Global engagement or voting. Corporate Governance Guidelines and Proxy Voting Policy, which is implemented through an unaffiliated third-party – Clients and significant suppliers: We do not change proxy voting service provider. our general approach to engagement with clients and significant suppliers. All deviations from the guidelines are documented and reviewed by our Compliance function to ensure AllianzGI employees comply fully with relevant policies and procedures. Functional separation - A separation of processes and management within AllianzGI helps ensure that individuals who are clients or have business relationships with the firm are not able to exercise improper influence over our proxy voting decisions. Proxy voting rests entirely with the investment platform. We have robust policies and procedures in place designed to ensure that our investment professionals’ proxy voting decisions are not subject to improper influence and that individuals who work in client service, sales and marketing or other non-investment functions are not in a position to influence the voting process. 7
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