01 Introduction and strategy 02 Measuring and managing sustainability 03 Climate change related disclosure 04 Strengthening our foundation 05 Our universal principles This holistic approach was initiated in 2021 through the Compliance Assurance of Risks and Effectiveness (CARE) program. While CARE is primarily a self- assessment exercise, it is reinforced with compliance reviews of operating entities, completed and coordinated by Group Compliance. Compliance reviews are completed on a risk-based, five-yearly cycle. From 2023, this review cycle will be reduced to a three-yearly cycle. The program is aligned to the CARE program so that operating entities are encouraged to exercise more rigor in the assessment of control effectiveness against the background of anticipated confirmation activities. Group Compliance is itself subject to external, independent evaluation by one of the four largest accounting firms. It is evaluated based upon CARE elaborated criteria which have been certified as being compliant with regulations which define requirements for compliance organizations. Compliance Reviews are supplemented by Targeted Reviews. These assess the implementation status and effectiveness of individual programs such as Anti-Trust, Sales Compliance, etc. The benefit of this multi-faceted review and confirmation strategy is that operating entities are monitored more frequently and are engaged in more holistic assurance activities. Additionally, frequent interactions with operating entities provide additional opportunities to monitor, guide and, if necessary, enforce remedial activities. An additional benefit is the ability to learn from local and group best practices, further bolstering our overall Compliance Culture. An online tool for compliance issues management provides an overview of issues detected in the course of the above activities. It requires reporting on mitigating activities as well as on follow- up procedures, including a review of actions undertaken and documented in the tool. 04.3 Compliance Allianz Group Sustainability Report 2022 128