Prudential 2021 ESG Report Anti-Money Laundering and Anti-Bribery/Anti-Corruption Oversight Prudential is committed to a comprehensive global anti-money and regulations. In the United States, covered 昀椀nancial institutions laundering (AML) and anti-bribery and corruption program (ABC). pursuant to the USA Patriot Act have policies and procedures to The Company recognizes the importance of protecting the integrity comply with the record keeping, reporting and audit requirements of of the global 昀椀nancial system from money laundering, terrorist the Act. 昀椀nancing, and other 昀椀nancial crimes. The Company complies with The Global Financial Crimes Unit (“GFCU”) is responsible for all applicable governmental requirements that have been designed enterprise compliance of Prudential’s ABC policies, procedures, and to prohibit and prevent both actual and potential money laundering, processes. The GFCU partners with personnel across the enterprise as well as other activities that facilitate money laundering and the to provide compliance oversight as well as an escalation path for funding of terrorists and/or other criminal activity. 昀椀nancial crime matters requiring attention. The GFCU proactively Prudential has policies that expressly de昀椀ne and prohibit practices manages the development and coordination of Prudential’s ABC associated with money laundering, bribery and corruption. Such Policy and Standards (including compliance with the Foreign Corrupt policies apply to all companies, branches, subsidiaries, af昀椀liates, Practices Act), provides oversight of the Gifts and Entertainment joint venture and private equity investments, where Prudential has system (which maintains documentation of gifts, entertainment, and management control. Prudential reviews and updates these policies items of value given to government of昀椀cials), identi昀椀es emerging to align with industry best practices as well as applicable regulations. bribery and corruption risks across the Prudential enterprise, All Prudential employees, including management and executives, conducts investigations into allegations of bribery and corruption are trained on these policies and their implementation during the under the direction of the Law Department, assists in due diligence onboarding process, and periodic refresher training is also provided. for mergers and acquisitions, and escalates concerns or potential In addition, business-level training is provided, which is tailored to the issues to Senior Leadership, which may include the Board of business and customized to the business units’ risks. Directors as necessary. Prudential developed a global 昀椀nancial crime training course, including anti-money laundering, sanctions and anti-bribery, for launch in 2022. Prudential has a rigorous customer due diligence program (Know Your Customer). Each business unit reviews current and prospective clients and their transactions for potential money laundering and terrorist 昀椀nancing activities. Prudential and its global businesses implement anti-money laundering programs in accordance with applicable laws Home Introduction Governance Sustainable Investing People Community Environment About this Report Appendix 11
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