A Summary of Allstate's Ethics and Governance Practices and Policies

Company
Ethics & Integrity

Integrity is central to our business. We believe doing what’s best for our customers begins and ends with operating with the highest ethical standards. We are proud of our reputation, which we have built on the sturdy foundation of our values: integrity, honesty, caring, inclusive diversity, accountability and superior performance.

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Conducting business with integrity doesn’t just attract new customers and benefit our bottom line—it engages our workforce.

We received an 89 percent favorable score (considered “exceptional” performance) on our 2016 VOICE survey for our environment of trust, as measured by employees’ experience with their immediate manager. Allstate’s environment of trust is one of the nine most significant drivers of engagement, retention and satisfaction, according to the survey.

VOICE Survey Responses

Definition

Maintaining governance practices that prevent unethical behavior, including anti-competitive behaviors, anticorruption, and compliance with regulatory and voluntary codes.

Trust

We received an 89 percent favorable score (considered “exceptional” performance) on our 2016 VOICE survey for our environment of trust, as measured by employees’ experience with their immediate manager.

HIGHLIGHT STORY

One Family, One Global Code

One Code, One Family. That’s the idea behind the Global Code of Business Conduct, a new roadmap for acting ethically when confronted with any number of situations at any of the Allstate family of companies. The Global Code of Business Conduct was launched to employees in May 2017.

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Global Code of Business Conduct

Allstate’s Global Code of Business Conduct (formerly the Code of Ethics), published in both English and French, outlines the values that are core to who we are and what we do. Our values define our culture and our beliefs, and set forth expectations for how we conduct our work. In addition to our Global Code of Business Conduct, we have policies for:

  • Anticorruption / bribery
  • Antitrust / competition
  • Confidential information
  • Conflicts of interest
  • Data privacy (e.g., employees, customers, consumers)
  • Diversity / discrimination / equal employment opportunity
  • Fair dealing (fair business practices)
  • Fair employment
  • Financial integrity and fraud
  • Gifts and entertainment
  • Information technology security
  • Insider trading
  • Intellectual property
  • Misconduct investigations
  • Money laundering
  • Non-retaliation
  • Political contributions, activities and lobbying
  • Procurement integrity / dealing with suppliers / supply chain oversight
  • Protecting company assets
  • Records management and retention
  • Social media
  • Workplace harassment
  • Workplace health and safety

Governance

Allstate has a robust governance structure for ethics and compliance.

In 2016, we had approximately 400 Allstaters across the enterprise focusing on ethics and compliance initiatives.

Of these, our chief ethics and compliance officer is the most senior individual overseeing our ethics and compliance program. In this role, our CECO is responsible for the company’s code of conduct; ethics and compliance budgeting; hiring of related positions and, to a lesser extent, procurement practices. The CECO meets with the board of directors twice per year and reports on the company’s performance and initiatives.

We also have a cross-functional Internal Controls committee that includes managers and executives. The committee convenes quarterly to discuss a wide variety of management topics related to ethics and compliance including performance, education, risk and culture.

Ethics and Compliance Risk Assessment

Annually, we conduct a highly collaborative risk assessment to assess risks related to:

  • Anticorruption / bribery
  • Antitrust / competition
  • Conflicts of interest
  • Data privacy laws and regulations relevant to employee, customer, or consumer data
  • Financial integrity and fraud
  • Gifts and entertainment
  • Information technology security
  • Insider trading
  • Money laundering
  • Political contributions, activities and lobbying
  • Procurement integrity / dealing with suppliers / supply chain oversight

Training and Communication

Board of Directors

Allstate’s culture of integrity begins with our most senior leaders. Our board of directors receives specialized ethics and decision-making education. In addition, we provide them with training on topics such as insider trading, cybersecurity, conflicts of interest and regulatory developments.

Employees

We distribute our Global Code of Business Conduct to all of our employees with accompanying training. We conduct ethics and compliance training as a standard part of the onboarding process and on an annual basis, and we monitor its effectiveness through a variety of internal measures.

In addition to Global Code of Business Conduct training, select employees undergo risk-specific training that addresses topics such as anticorruption, conflicts of interest, data privacy, equal opportunity, insider trading, procurement, social media, workplace harassment and money laundering as appropriate for their roles.

Managers

All managers undergo targeted training with respect to their individual responsibilities for compliance and ethics. We focus our manager training on creating an environment where employees feel comfortable speaking up when they observe unethical behavior, handling reports and preventing retaliation. To measure the impact of our training, we:

  • Document manager feedback
  • Track misconduct
  • Record the frequency with which the Global Code of Business Conduct is downloaded
  • Conduct an annual employee survey to measure Allstate’s culture of ethics

Our ethics culture survey is one of the primary drivers of feedback within our ethics and compliance initiatives. The CECO presents results to each senior leader in face-to-face meetings. At this meeting, we identify areas of strength and of opportunity, and many of our business areas develop their own customized solutions to address them.

Suppliers

All suppliers doing business with Allstate must adhere to our Supplier Code of Conduct, which outlines our expectations for human rights, environmental stewardship, diversity and inclusion, child labor and more. We comply with the United Kingdom’s Modern Slavery Act 2015 and post our Slavery and Human Trafficking Statement on the Allstate Northern Ireland and Allstate external websites. We execute background checks on all of our largest suppliers, and on any supplier handling Allstate data.

100%

In 2016, 100 percent of our employees had completed ethics and compliance training—a condition of employment at Allstate—on our Code of Ethics.

Recognition

Allstate’s rally cry to be a force for good is central to the way employees view their work and their roles in the community.

Allstate was named as a 2015, 2016 and 2017 World’s Most Ethical Company® by the Ethisphere Institute, a global leader in defining and advancing the standards of ethical business practices. The “World’s Most Ethical Companies” designation recognizes those organizations that significantly influence the way business is conducted by fostering a culture of ethics and transparency at every level of the company. To qualify, companies are scored in five categories, including ethics and compliance, corporate citizenship and responsibility, a culture of ethics, governance and leadership, and innovation and reputation.

Allstate also received the Best Compliance and Ethics Program (large cap) Corporate Governance award from Corporate Secretary in 2016. This award looks at coordination of governance, compliance, ethics and risk management process across the entire corporation. Judges consider the level of understanding and integration of good governance principles across all disciplines. Corporate Secretary found Allstate’s compliance and ethics program is built to influence all levels of the company and maintain a continuous dialogue about what it means to have an ethical culture.

Reporting Concerns

We encourage our employees to report any activity they observe or experience that causes concern. Should an employee decide to report a concern, they can contact their manager, another manager, or a Human Resources representative. Additionally, they can utilize our companywide reporting process, available 24/7, via phone or web. Employees can choose to remain anonymous where the law permits. In 2016, approximately 48 percent of our employees who filed reports chose to do so anonymously.

The Allstate Speak Up Process is designed to allow employees and non-employees to report any violations of laws, rules or regulations, as well as violations of our Global Code of Business Conduct or Company policies.

Employees may report any illegal, unethical conduct or regulatory compliance concerns by:

  • Contacting their manager, another manager, or a Human Resources representative
  • Calling the Allstate i-Report Line: 1-800-706-9855 which is a 24/7 toll-free number
  • Utilizing the Allstate i-Report website: www.allstatei-report.alertline.com

Allstate investigates all reports to determine whether the allegation is substantiated or unsubstantiated. If necessary, Human Resources and local leadership will determine action or discipline. Allstate will not discuss case specifics / disciplinary actions with anyone other than the disciplined employee. A Human Resource representative follows up with the reporter to confirm that the case has been investigated, handled and closed.

We track employee-submitted reports in our case management system. The system records and logs reports and related investigations regardless of how the report was originally made. Allstate policy and the Global Code of Business Conduct prohibit any form of retaliation for reporting a workplace or ethical concern.