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We secure your future – the common purpose that inspires and motivates all �鶹��ýapp Global Corporate & Specialty employees around the world to give our best to serve our customers, partners, shareholders, every day.

Introduced in 2006, our Code of Conduct has lived through some changes, the latest in 2020, but one thing has remained constant: Our commitment to running our business in an ethical and compliant way and with integrity. This is how we have earned and maintained the trust of our stakeholders.

At AGCS, we are stronger together. We lean on our strong values and principles. We treat each other with respect, we act with integrity, are transparent and tell the truth.

We give the highest priority to compliance with legal, regulatory and internal requirements. When violations are detected at an early stage, appropriate actions can be taken to prevent or mitigate damages to customers, employees, business partners and the company itself.

If you have information about an act of wrongdoing or violation of rules at AGCS, you can report your concern via our online reporting channel:

With the SpeakUp@�鶹��ýapp tool, we offer a simple way to report concerns. The tool fully protects your identity. We make sure that each reported incident is dealt with by our independent examiners in an impartial and effective way.

Based on your report, we can contribute to stopping any potential violations, help the people affected and improve our prevention measures. It also helps us to minimize the risks of future wrongdoings. 

You can use the SpeakUp@�鶹��ýapp tool, or any of the other reporting channels listed below, if you have information that AGCS or any of its suppliers violate any laws, regulations or internal rules. 

The incidents you can report include e.g.: 

• fraud, theft or corruption 
• antitrust violations and potential conflict of interest
• financial irregularities or breaches of accounting or tax provisions
• discrimination, harassment, harmful working conditions and other breaches of human rights
• severe environmental damage

Please note that this channel of communication is not intended for complaints that do not reflect an act of wrongdoing or a violation of external or internal requirements. For further information on how to submit a complaint, please see the section on complaints below.

Investigations

AGCS examines all submitted messages and ensures that they remain confidential and that all involved parties are treated equally.

Please be advised that your message can only be investigated if it contains sufficient information. As such, we ask you to provide as many details as possible. If you do not have access to detailed information, this does not prevent you from voicing your concerns.

It is useful for our investigations team if you provide your name and/or an e-mail address when submitting a report.  If you would prefer to remain anonymous, however, we will respect your decision and your concern will still be investigated.

When making a report, we encourage you to set up an electronic mailbox in the SpeakUp@�鶹��ýapp Tool. This will enable us to contact you and if necessary, request further information to support with our investigation.

Where we are able to contact you via e-mail or through the electronic mailbox in the SpeakUp@�鶹��ýapp Tool, we will confirm receipt of a report within 7 days.

Confidentiality and anonymity

Your information will be treated confidentially. We take appropriate steps to make careful use of all information received, and to safeguard the interests of all involved persons. Reports will only be disclosed to the extent necessary to investigate an allegation or where disclosure is required in connection with applicable legal or regulatory proceedings. All data provided is processed in accordance with applicable data privacy requirements.

Zero tolerance for retaliation

AGCS does not tolerate any form of actual, threatened or attempted retaliation against anyone who submits a report in good faith or anyone who assists with investigations arising from such reports. This remains the case even in cases where an investigation does not confirm the allegations made.

If you would prefer not to use our reporting tool, you may send your concerns:

• Via courier to the following address:

�鶹��ýapp Global Corporate & Specialty SE
Global Head of Compliance
Dieselstraße 8
85774 Unterföhring
Germany

• In-person directly to the Compliance Department

Concerns may also be reported externally to your relevant competent authority (i.e. local regulatory authority).

Reporting to external authorities

The German Government has defined the following authorities that accept reports on misconduct as external reporting channels:

• Federal Office of Justice (Bundesamt für Justiz)
• Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht)
• Federal Competition Authority (Bundeskartellamt)

Nous attirons votre attention sur un cas de fraude récent survenu en France qui nécessite une vigilance accrue. Les fraudeurs se font passer pour des employés, donnent une fausse image d'�鶹��ýapp et de ses produits et falsifient des documents commerciaux dans le cadre de leurs activités criminelles pour tenter d'escroquer de l'argent.

Si vous pensez avoir été victime de ces agissements, n'hésitez pas à vous rapprocher de votre interlocuteur �鶹��ýapp habituel, puis à informer immédiatement �鶹��ýapp Commercial en envoyant un message à l’adresse suivante : agcs.psm@allianz.com

Nous vous recommandons également, même en l’absence de préjudice, de contacter l’un des sites gouvernementaux en charge de recenser ces cas :

Les signalements sont utiles pour empêcher d’autres tentatives d’escroquerie.

We would like to draw your attention to a recent case of fraud in France that prompts increased vigilance. Fraudsters are impersonating employees, misrepresenting �鶹��ýapp and �鶹��ýapp products as well as forging commercial documents in their criminal activities to attempting to defraud people of their money.

If you believe that you have been a victim of this type of fraud, please contact your usual �鶹��ýapp representative and immediately inform �鶹��ýapp Commercial by sending a message to the following address: agcs.psm@allianz.com

We also recommend that, even if no harm has been done, you contact one of the government sites responsible for recording such cases:

Reporting cases is a useful way of preventing further attempts at fraud.