Allianz Receives Human Rights Grievance Over Venture Global Operations

Stakeholders in Louisiana and Germany filed a comprehensive human rights grievance against Allianz SE based on documented harms of Venture Global’s Calcasieu Pass 1 LNG and CP2 construction concerning pollution and economic loss. It alleges the German insurer (through its subsidiary, which held 7% of a $2.4 billion USD insurance policy for the CP1 methane terminal) violated its own policies and international human rights laws by providing coverage to Venture Global’s terminals and construction contractors in Louisiana. The grievance argues that Venture Global’s conduct and Allianz’s knowing complicity have led to an emergent ecological and human rights crisis and reflect a clear and ongoing disregard for legal and ethical obligations.

This complaint follows a similar grievance that was recently filed against Japanese insurer Tokio Marine, and after years-long attempts from stakeholders and representatives of the local communities, warning the major German insurer about reputational, human rights, and financial risks of fossil fuels and LNG underwriting. Allianz has a documented history of non-compliance with its own Human Rights Policy, Standard for Integration of Sustainability, Code of Conduct, and international human rights frameworks through its exposure to Venture Global. Allianz’s provision of insurance to Venture Global materially supports Venture Global’s operations in Louisiana by acting as a financial safety net against catastrophic losses and reducing associated risks. Allianz’s continued business relationship with Venture Global exposes the company to significant legal and reputational risks and undermines Allianz’s stated commitment to human rights.

The complaint, submitted through Allianz’s Whistleblowing Tool, argues Allianz violated multiple provisions of its own Human Rights Policy, which covers all impacts linked to its business activities and requires due diligence before engaging with clients, direct engagement with impacted communities, compliance with domestic and international laws, and employee compliance with human rights standards. Insurance coverage was provided despite findings that the facility was out of legal compliance with the Clean Air Act for over 50% of its operating time and is currently subject to multiple federal lawsuits challenging its Clean Air Act permits and state operational licenses.

Human Rights Impacts from CP2 Dredging Disaster

The grievance details economic harm regarding a catastrophic August 2025 disaster where a dredging project associated with Venture Global’s CP2 construction project spilled tons of sediment into fishing waters, smothering crucial oyster beds in thick sludge as shrimp season opened. Shrimpers shared on social media their empty, muddy nets and oysterfolk blame the disaster for killing their catch and destroying their income months after the disaster. This is a violation of rights enshrined in Article 25 of the Universal Declaration of Human Rights that specifically protects standard of living against loss of livelihood.

This accident is part of a pattern of environmental violations which are ending the livelihoods for those of us who live here. CP2 is shaping up to be a sacrifice zone: an industry project that sacrifices communities, health, climate, local economies and justice for short-term profit. But to speak plainly, Venture Global isn’t the only company making money off our suffering; they aren’t the only ones to blame…No insurance company should underwrite CP2…We need help. We are fighting to survive while watching the oyster beds get covered in silt, the crabs and shrimp choke and fisherfolk and our families get nosebleeds nightly from the pollution when working in the waters our parents and grandparents worked for decades. We want to thrive! Let the marshes stay wild, give us back our safety and economy and let our communities breathe,” said Captain Ray Mallet, a local shrimper and one of the complaint’s signatories with the Fisherfamily Advisory Council for Tradition & Stewardship (FACTS).

Additionally, Allianz has case specific exposure to human rights harms through its underwriting of aspects of the current CP2 LNG construction process. A public records request recently revealed an Allianz subsidiary currently holds a $1 million USD insurance policy with Venture Global CP2, LLC construction contractor, Callen Marine Ltd, the operator contracted to oversee important aspects of the dredging when the spill occurred.

Allianz’s sustainability integration policy identifies Oil & Gas as a “Sensitive Business Area” and applies screens to those client transactions that include impact mitigation measures to address air pollution, water and soil contamination from spills, biodiversity, and water management policy. It further stipulates its clients have a published commitment to human rights, due diligence process, community resettlement plan, and a Free Prior and Informed Consent (FPIC) policy. However, Venture Global does not appear to have any of these published, publicly available human rights policies.

Allianz Violates Human Rights Frameworks

The grievance outlines the violation of numerous international human rights frameworks that Allianz purports to uphold. Here are a few highlights:

• Right to Adequate Standard of Living (Resulting From Loss of Livelihood)
  • Article 25 of the Universal Declaration of Human Rights
  • Article 11 of the International Covenant on Economic, Social and Cultural Rights
• The Right to Safe and Dignified Working Conditions
  • Article 23 and 3 of the Universal Declaration of Human Rights
  • Article 6 and 25 of the International Covenant on Economic, Social and Cultural Rights
  • Principle 5 of the ILO Declaration on Fundamental Principles and Rights at Work
• Right to Cultural Heritage
  • Article 27 of the Universal Declaration of Human Rights
  • Article 15 of the International Covenant on Economic, Social and Cultural Rights
  • United Nations Declaration on the Rights of Indigenous Peoples
• Right to Health
  • Article 12 of the International Covenant on Economic, Social and Cultural Rights,
  • Article 26 of the International Covenant on Civil and Political Rights
• Right to a Healthy Environment
  • UN General Assembly
• Right to Remedy
  • Article 8 of the Universal Declaration of Human Rights,
  • Article 2 of the International Covenant on Civil and Political Rights
  • Principle 22 of the UN Guiding Principles on Business and Human Rights

The complaint warns that failure to act on these rights violations could result in additional complaints to the OECD German National Contact Point. There is also precedent for grievances like these to trigger investigations by UN Special Procedures. The grievance includes a detailed timeline showing Allianz was repeatedly warned about these risks in March of 2021 to most recently as April of 2026. Despite these warnings, Allianz continued providing coverage. Its insurance policy for the CP2 LNG construction contractor is set to renew October 1, 2026.

Impacted Community and Ally Demands for Allianz

The organizations – For A Better Bayou, Fisherfamily Advisory Council for Tradition & Stewardship (FACTS) of the Habitat Recovery Project, urgewald, and Rainforest Action Network are demanding that Allianz:

1. Deny coverage renewal for Venture Global’s Calcasieu Pass LNG when the policy expires March 14, 2027. Additionally, Allianz should deny coverage for all Venture Global CP2 construction contractors, like Callan Marine, before the policy renews on October 1, 2026.
2. Rule out any future coverage for Venture Global’s expansion projects (CP2, CP3, Plaquemines LNG Phase II)
3. Conduct full human rights due diligence, including in-person meetings between senior leadership and impacted communities
4. Provide monetary remedies to affected fishing families and communities
5. Launch internal investigation to hold accountable executives who approved non-compliant coverage

The situation in Louisiana demonstrates the manifold dangers to which the LNG sector exposes people and the environment. A glance at the latest climate data is enough to understand that not a single new LNG terminal should be allowed to go into operation. As a globally influential industrial insurer, Allianz plays a key role here. It must live up to its responsibility and consistently end its business with gas infrastructure.” – Regine Richter, Finance Campaigner at Urgewald.

Allianz has an obligation to work with impacted communities who have a right to remedy as enshrined in Article 8 of the Universal Declaration of Human Rights. Other major insurers of Venture Global—like SwissRe, Chubb, AXA, SCOR, Aviva, MunichRe, and Zurich—could risk similar human rights complaints if they fail to proactively adhere to their human rights due diligence processes.

Allianz reportedly received approximately $620 million from direct fossil fuel premiums in 2023- 2024. The company’s North America operations have outperformed other regions, suggesting Allianz facilitated and profited from these ongoing human rights harms. Academic research cited in the complaint demonstrates that when insurers adhere to their underwriting policies, it creates market conditions that directly constrain harmful operations more broadly. This means that Allianz SE’s compliance with its own policies could decrease its risk exposure, remedy the harm caused in this case, and help shift the entire industry away from projects that degrade human rights and the environment.

Grievance Outline

Below is an outline for the 28 page grievance which can be read here.

I. Infringements of Human Rights Policies and Laws

A. Allianz SE’s Infringements of its Own Human Rights Policy
B. Relevant International Human Rights Law and Frameworks

II. Human Rights Abuses Caused by Venture Global with Material Support from Allianz

A. Recent Case Study: Venture Global’s CP2 Construction Disaster
B. Loss of Livelihood and Standard of Living
C. The Right to Safe and Dignified Working Conditions
D. Right to Cultural Heritage
E. Right to Health
F. Right to a Healthy Environment

III. Allianz’s Culpability and Responsibility to Remedy Harm

A. Culpability: Allianz Facilitated and Profited From These Human Rights Harms
B. Disregard for Risks: Efforts to Raise Human Rights Concerns with Allianz
C. Right to Remedy
D. Allianz’s Responsibility and Consequences
E. Course of Action to Remedy Human Rights Harms

Appendix: A table from Allianz’s policies with additional analysis on how it applies to Venture Global