Steve Koslow, Chief Ethics and Compliance Officer, Allianz Life

Allianz Life is going through a period of significant change against the backdrop of a number internal and external factors. As a leading provider of retirement solutions, the markets in which we operate are evolving rapidly. Digitization of our business continues to drive us toward scalable technology and solutions at an accelerated pace. And like other companies, we have a workforce that is just beginning to embrace our new ways of working. Anchoring our interactions in the value of integrity is more critical than ever to support our continued success, and our Ethics & Compliance team has a unique responsibility in advancing the company’s strategic priorities by championing integrity.

For the last three years, Allianz Life has been named one of Ethisphere’s World’s Most Ethical Companies®, which reflects the degree to which our Ethics & Compliance team has worked with senior leadership, employees, and external stakeholders to build a strong ethics program and further enhance our company’s “speak up/listen up” culture. Throughout the build of our ethics program, we have executed on various action plans and tactics including updating policies and training, producing internal blogs, developing manager toolkits, and offering culture surveys, all while deepening our connections throughout the company and industry.

As our team began planning for 2022, however, it became clear that the baseline was changing: the environment around us, the messaging, and actions plans of the past were not going to be enough to sustain and enhance our culture moving ahead. Thus, we embarked on an effort to reframe our approach to ethics with an emphasis on highlighting integrity through a culture of accountability, a culture that embraces a high level of personal accountability in all that we do.

Our updated ethics strategy, which we have rebranded as “Integrity in Action”, focuses on fostering a culture of accountability. It is grounded in the notion that an ethical culture is the responsibility of all of us, it is present in our day-to-day interactions, and it is an integral part of everything that we do. The idea is to enhance the way we think about ethics within our company beyond traditional messages such as doing the right thing or navigating an ethical dilemma, and toward emphasizing employee behaviors that will allow the company and our employees to be trusted to act with integrity and uphold the principles in our Code of Conduct during a period of immense change. These behaviors include:

  • Honesty. We are truthful and trusted to provide all information to the right parties needed to make informed decisions.
  • Transparency. We are open and transparent in communicating in a timely manner on what is working and what isn’t.
  • Ownership. We know our roles and take responsibility in owning outcomes for individual, team, and company goals and efforts.
  • Courage. We speak up when there is misalignment to our company values without fear of retribution from others.

When individuals or a team embody these behaviors, great things happen. And, they can quickly become a catalyst for high-quality project outcomes and success. We recently saw this come to life with a project team tasked with establishing a standard electronic document filing and retention system for the company. This multi-year project was not perhaps the most exciting of tasks, but it was a necessary and important effort to reduce costs and risks and increase efficiencies in the company.

Brad Quast, AVP, Privacy & Information Compliance, Allianz Life

The team experienced a number of technical, budgetary, and interpersonal challenges early on in the project. However, they managed to turn potential failures into successes by leveraging the qualities of a culture of accountability, especially ownership and transparency.

Throughout the course of the project, the team dedicated time to aligning on a defined set of individual roles and responsibilities. While these grew and shifted over the lifetime of the project, every team member knew what was expected and could take personal ownership for delivery. Importantly, the team viewed success and progress collectively. When challenges arose, rather than point fingers, they rallied by each other’s side to help out. For example, the team initially determined that each business areas would develop their own archiving structure based on their network folders, but the task was too overwhelming for those areas and the project got behind schedule and went yellow. The team owned this undesirable outcome and identified the need for outside consulting expertise to help build a standardized archiving structure that would be broadly applicable to all business areas. This ultimately allowed the project to get back to green much faster.

On more than one occasion, the team experienced technical setbacks. For example, the vendor responsible for technical execution of quarantining stale documents was underperforming, and the project schedule was negatively impacted. When this happened, the team immediately changed the status to yellow and promptly informed senior leaders and executive sponsors. The team owned this setback and were transparent in the project being in a yellow status. The team openly shared what was needed to get back to green—a new vendor and in-house technical ownership—and received the support necessary. The team lived a “no surprises” approach and, in turn, had the respect and trust of company leadership.

Despite the risks to its timeline, this project successfully achieved its key objective of creating an important new protection process company-wide through a culture of accountability. The Ethics and Compliance team has leveraged lessons from teams like this in developing our Integrity in Action strategy.

Lindsey King, Ethics & Compliance Training & Communications Lead, Allianz Life

Ethics 2022: An Expanded View of Compliance Support 
Thinking, planning, and moving beyond the fundamentals and foundational elements is essential to the next phase of our Ethics program. We’ve identified four main areas of focus for 2022, which are essential in ensuring continuous engagement and buy-in with and from our stakeholders on a culture of accountability: providing employee training and awareness; leveraging tone at the top; driving ethics into Allianz Life’s operating model; and optimizing compliance requirements.

Providing Employee Training & Awareness. As we maintain our strong foundational training program, we are now in the space where we’re able to engage our employees on the topic of ethics in new and exciting ways. This year, we are launching an updated Code of Conduct training that is required for all employees and new hires. Here, we worked with our Human Resources and Learning & Development partners to update scenarios that one might encounter at Allianz Life and how those scenarios should be handled, who to contact, and how to think about our own role within the company. We are working to emphasize the concept that we are all responsible for owning the ethical culture at Allianz Life, and part of that is making sure we understand the Code of Conduct Policy and understanding where to report when we have concerns or if something isn’t quite right.

We are also excited to launch our Integrity in Action: Leader’s Conversation Guide to all people leaders and managers in second quarter of this year. The development of this guide was based on feedback from Ethisphere’s Culture of Compliance survey conducted in 2020, specifically the data reporting that when employees and leaders talk about ethics and doing the right thing, good things happen: employees are more likely to report misconduct; employees are more than twice as likely to approach their supervisor with an issue; and three times as many employees believe that the rules apply to everyone (organization justice). Having piloted a number of different versions of this guide, the feedback we collected allowed us to pivot towards an individualized approach, where each leader will focus their conversations on the behaviors of a culture of accountability as best fit their teams, their business units, and their own experiences.

Leveraging Tone at the Top. Like so many companies, Allianz Life continues to embrace change while driving growth. We have also welcomed a number of new executives to our company over the last year. Part of our new strategy is to partner with our new members to publish a series of quarterly conversations with Steve Koslow, touching upon the importance of speaking up, safe failure, transparency, and open communications. Our first publication was with Susan Sachatello, Chief Growth Officer, on her first impressions of Allianz Life, our ambitious growth strategy, and the importance of ownership and transparency in project teams, and how we can be better communicators overall. Response to this first interview was overwhelmingly positive—not only do we get the opportunity to talk about these important topics, but the company as a whole gets to learn more about our leadership and how human they are.

Driving Ethics into Allianz Life’s Operating Model. Creating and maintaining a strong ethical culture requires making and maintaining deep partnerships across the company. Because ethics does not exist in silos, we are finding ways to work with our Human Resources, Diversity, Equity & Inclusion, and Learning & Development partners on how to best stay connected as we push critical yet related actions and messages through company-wide processes and initiatives. We are also finding ways to partner with other stakeholders on critical company change initiatives: Allianz Life currently has a significant program for accelerating and optimizing our business model, which involved rethinking decision-making and ownership at all levels. Our Ethics and Compliance team has a critical seat at the table in this effort and we are working on embedding ethics into these new models.

Optimizing Compliance Requirements. A lot of what we do in the compliance space is data-driven, reporting, and task-based efforts. For 2022, we’ll be working with technology and third-party vendors to optimize the compliance “must-dos,” especially the required Conflict of Interest and 1033 certification data collection process. This will allow us free up time to focus on efforts influencing and guiding our corporate culture. We are also looking into how other systems and processes can provide us new information on ethics and measurements on our ethical culture, like our internal employee recognition system.

While many challenges remain ahead for our Company, we are excited about our new strategy and through these main focus areas. Our Ethics and Compliance team continues to drive our company toward embracing the qualities of a culture of accountability will help ensure our ethical compasses points us and Allianz Life in the right direction.


About the Authors

Steve Koslow is Chief Ethics and Compliance Officer for Alliance Life Insurance Company of North America. With more than 20 years of experience in the financial services industry, Steve has broad knowledge in the development of ethics and compliance programs for insurance companies. He has experience leading large, complex ethics and compliance organizations and is an industry innovator in the area of ethics, analytics, and risk management.

 Brad Quast is Assistant Vice President, Privacy & Information Compliance for Allianz Life. He is an experienced data protection officer with particular expertise within the financial services and insurance industry, and whose skills include business process improvement, information security, and IT strategy. In his role at Allianz Life, Brad is responsible for a number of enterprise compliance functions including Data Privacy, Cybersecurity, Data Analytics, Third Party Risk Management, Training and Communications, and Ethics.

 Lindsey King is the Ethics & Compliance Training & Communications lead for Allianz Life. She has over 15 years of communications and project management experience in insurance and financial services, education, fine art, and technology. In her role at Allianz, she is responsible for leading the design, strategy, and delivery of ethics and compliance training and communications.