3 Corporate Governance / Ethics and Conduct

Ethics and Conduct (G4-DMA, G4-57, G4-58, G4-SO3, G4-SO5, G4-SO7)

Allianz Seguros conducts its internal processes and relationships with all stakeholders based on solid ethical principles. The Code of Ethics and Conduct was inspired in the policy practiced by the Allianz Group. To ensure its efficiency, awareness campaigns and training are constantly carried out for employees.

Fighting corruption is one of the main programs of the Allianz Group. In Brazil, Allianz has formally adopted, since 2011, the Anti-Corruption Program, based on the guidelines of the Group. This program sets out the minimum prevention standards against any acts of corruption and bribery, regardless of whether they occurred in the private or public sector, by persons linked to local and foreign governments. The company also requires transparency and integrity in all its activities, whether internal or with third parties.

Annually, on December 9, when the International Anti-Corruption Day is celebrated, a series of events are carried out to keep employees alert to compliance issues. In addition, Risk Assessment Studies for Corruption, Fraud and Money Laundering are conducted once a year and are organized by the Compliance Department to further assess actions that are inherent to preventing these risks.

In 2015, the actions of the Antitrust Program were expanded in Brazil, following Allianz's global guidelines. In 2014, the company conducted classroom training for managerial positions and online training for all employees. In addition, an access channel was made available in the area of Compliance and in the Legal Department for consultations on the subject.

In 2015, the efforts in publicizing the Program were increased and the issue began to be more strategically addressed throughout the organization, emphasizing the areas with greater exposure and encouraging all employees to access the company guidelines. Standard 304, concerning the Antitrust Code Standard, and 305, which provides the Antitrust Policy, were posted on the intranet to better inform employees. During this period, there were no public corruption-related lawsuits filed against Allianz or its employees. Also, there were no lawsuits filed for unfair competition, anti-trust and monopoly practices in 2015.