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