Allianz SE

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Allianz SE provides an extensive and precise map of its climate-policy engagement. It names multiple identifiable measures it has worked on, including the Hong Kong SFC consultation on “Management and Disclosure of Climate-related Risks by Fund Managers,” the US SEC’s climate-disclosure rulemaking, support for the G20 “InsuResilience” initiative, endorsement and national implementation of the Task Force on Climate-related Financial Disclosures (TCFD) recommendations, and participation in the EU Green Recovery Alliance and other EU sustainable-finance rule-makings. The company is equally explicit about how it lobbies: it submits consultation responses (“In our consultation feedback we provided our views and recommendations on multiple topics”), encourages other stakeholders to do the same, signs joint calls to action, co-authors policy papers, sits on government advisory bodies such as the European Commission’s Platform on Sustainable Finance and Germany’s Sustainable-Finance-Beirat, and its CEO and Board members advocate at high-profile fora including the World Economic Forum, the Biden Climate Summit and the Petersberg Climate Dialogue. Allianz also sets out the concrete results it is pursuing, from establishing “net-zero aligned carbon pricing instruments” with a hybrid floor-and-ceiling design, to embedding the TCFD framework in mandatory national reporting, creating “standardized and mandatory sector-specific Key Performance Indicators,” increasing the share of pandemic recovery spending that is green, and expanding climate-risk insurance to hundreds of millions of vulnerable people. By detailing the policies, the channels and targets of engagement, and the specific regulatory and market outcomes it seeks, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Allianz SE demonstrates a moderate level of governance in its climate lobbying processes, with some clear mechanisms and oversight structures in place. The company states that "the AIM Sustainable Investing team oversees the engagement program and its implementation across our global operations," indicating a defined oversight body. Additionally, the Chief Sustainability Officer and Chief Investment Officer are involved in initiating engagements, as evidenced by their signatures on letters outlining concerns and inquiries, which suggests a structured process for addressing lobbying alignment. Allianz SE also reports that "AIM’s engagement activities are reported annually in the Sustainability Statement of the Allianz Group Annual Report," which is audited with reasonable assurance, providing a level of transparency. Furthermore, Allianz SE expects "companies and asset managers that have public commitments ensure that their policy engagement activities are congruent with those commitments," and uses the NZAOA paper as a basis for assessments, indicating a method for alignment. However, while the company mentions ensuring that "any relevant direct and indirect policy advocacy we undertake supports achieving global net zero emissions by 2050 or sooner," there is no detailed description of how this alignment is monitored or managed, nor evidence of active steps taken to align indirect lobbying through trade associations. Additionally, while oversight roles are mentioned, there is no explicit disclosure of a formal group or committee that reviews lobbying alignment. This indicates a governance process that is moderately developed but lacks comprehensive monitoring and alignment mechanisms for both direct and indirect lobbying activities.	2