01 Our sustainability approach 02 Sustainable investing 03 Active stewardship 04 Corporate sustainability 05 Appendix 04.3 Ensuring responsible business conduct Principles 3 5 04.3.2 Globally harmonised policies The Code of Ethics serves as a foundation In 2022, all AllianzGI employees risk in the portfolio via implicit or explicit and standards for our compliance culture and regulatory participated in Global Compliance performance promises. Investment risk Globally applicable policies include, but are expectations for all AllianzGI employees. Training covering (amongst other areas) also includes liquidity risk, which depends not limited to, the AllianzGI Code of Ethics, The code and the accompanying supporting Anti-Money Laundering, Anti-Fraud and on asset liquidity and flows on the liability Speak-Up policy and policies governing policies have been revised in 2022 to Economic Sanctions. side, as well as constraints imposed by Anti-Money Laundering, Anti-Fraud, provide consistent application of our policies regulators. For investment risk oversight, Anti-Trust, Anti-Bribery, Economic across jurisdictions worldwide, meet the 04.3.4 Managing risks effectively the Risk Management function defines Sanctions, Personal Account Dealing, expectations of various regulators, and The independent Risk Management which risk models and analytics are used Order Execution, Confidential Information/ reflect industry best practices. function is responsible for setting up a to ensure compliance with regulatory Insider Information, and Data Privacy. firm-wide auditable, documented risk requirements and, for selected topics 04.3.3 Ensuring compliance management system and risk policies or if contractually agreed, that further Employees are required to act in The Compliance function is responsible for that are consistent with AllianzGI’s independent risk analyses and supervision accordance with these policies at all times, implementing and maintaining an effective business strategy. We cluster risks is conducted beyond what is required whether dealing with clients, external third compliance programme. This includes into four risk categories: investment by regulation. parties or other Allianz employees. compliance risk analyses as well as the risk, operational risk, business risk, annual compliance self-assessment and and reputational risk. We consider Operational risk is defined as the risk of Our clients expect their personal control plan. Compliance also develops sustainability risk, concentration risk loss inherent in our internal organisation, information to be treated with and administers guidance for employees, and emerging risk as transversal risks processes and controls resulting from the utmost care and we take this regular compliance training sessions on the that may be realised in one or more of potential failure to deliver our products responsibility seriously. Employees must Code of Ethics and Anti-Money Laundering, these categories. Our robust processes or services in the required time and adhere to confidentiality in relation to and annual and ad-hoc training on and procedures ensure that we effectively quality, and in line with all regulations. client information and firm activities. matters related to other company policies monitor and manage risks within Each function is responsible for ensuring AllianzGI pursues an effective and procedures. these categories. an appropriate control framework to management and fair handling of the govern its key processes and mitigate potential conflicts of interests that may This involves the monitoring of proxy voting Investment risk includes the risk of operational risks. The Risk Management arise in the course of providing investment and investment guidelines, including those changes in the value of investment function has established an integrated services. We have embedded robust related to sustainability matters such portfolios that may be perceived as framework to oversee operational risk business policies and processes governing as exclusion lists. AllianzGI Compliance inconsistent with the risk profile of the management by the business. ethics and client confidentiality. These are monitors portfolios for compliance with respective portfolio as communicated to detailed in the AllianzGI Code of Ethics and investment guidelines, both pre- and the investor. This includes the risk that the echo Allianz Group’s overall standards. post-trade. company is exposed to market and credit Allianz Global Investors Sustainability and Stewardship Report 2022 111