WE ARE THE GOOD HANDS
ETHICS & INTEGRITY
Integrity is central to our business, and we’re proud of our reputation as one of the World’s Most Ethical Companies®; Ethisphere has recognized Allstate each of the last four years for high ethical standards in our business practices and values-based leadership. We have built this legacy on the sturdy foundation of our core values: integrity, honesty, caring, inclusive diversity, engagement, superior performance and accountability.

What Ethics & Integrity Mean at Allstate

Doing what’s right for our customers begins and ends with operating to the highest ethical standards. Allstate maintains governance practices that prevent unethical behavior — including anti-competitive behaviors and anti-corruption — and requires compliance with regulatory and voluntary codes.

GLOBAL CODE OF BUSINESS CONDUCT

Operating with integrity is critical to fostering lasting relationships with our customers, attracting new ones, making sure Allstate is a great place to work and enhancing our bottom line.

Allstate’s Global Code of Business Conduct (updated in 2017), published in English and French, outlines the values that are core to who we are and what we do. They 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:

  • Anti-corruption/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
  • Gifts and entertainment
  • Information security
  • Insider trading
  • Intellectual property
  • Misconduct investigations
  • 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

TRAINING AND COMMUNICATION

Ethical behavior begins with our most senior leaders and cascades down the organization through annual training, which is a condition of employment.

Board of Directors

Our Board of Directors receives specialized ethics and decision-making education. In addition, we provide them with education on topics such as insider trading, cybersecurity, conflicts of interest and regulatory developments.

Managers

All managers undergo training on ethics and compliance. Allstate launched an ethics training course for new leaders in 2017 as part of the New Leader Development Studio (NLDS). Additionally, an Ethical Leadership Toolkit is available on the company intranet site, including monthly Ethical Dilemmas for managers to discuss with their teams and resources for ethical decision-making. We focus manager training on creating an environment where employees feel comfortable handling reports, preventing retaliation and speaking up when they observe unethical behavior.

To measure the impact of our training, we:

  • Document manager feedback
  • Track misconduct
  • Survey employees annually to measure Allstate’s culture of ethics
Our Integrity Index survey is one of the primary drivers of feedback within our ethics and compliance initiatives. The Chief Ethics and Compliance Officer (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.

Employees

We distribute our Global Code of Business Conduct to all our employees and subsidiaries with accompanying training. We conduct ethics and compliance training as a standard part of onboarding and on an annual basis, and we monitor its effectiveness through internal measures. In 2017, 100% of our employees completed ethics and compliance training on our Global Code of Business Conduct – a condition of employment at Allstate — through our Annual Compliance Confirmation process.

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

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 UK Modern Slavery Act and post our Slavery and Human Trafficking Statement on the Allstate Northern Ireland and Allstate external websites. We do background checks on our largest suppliers and on any supplier handling Allstate data.

Integrity Index Survey

The Integrity Index Survey, conducted by the CEB Compliance and Ethics Leadership Council, gives employees a chance to provide feedback that influences company strategy as well as to address important cultural issues. CEB administers the annual survey to roughly 16,000 randomly selected employees. The survey is anonymous and confidential, and results are used to compare year-over-year effectiveness of Allstate’s ethics and compliance program.

The survey evaluates employee perceptions of the honesty, integrity and ethical actions of both senior leadership (“Tone at the Top”) and their direct managers (“Direct Manager Leadership”).

Employee Perception of Senior Leader and Direct Manager Ethics

Inspire Survey Results

Allstate’s environment of trust is one of the nine most significant drivers of engagement, retention and satisfaction; that’s why we conduct the annual Inspire employee engagement survey measuring what percent of employees feel that senior leadership and their immediate managers create an environment of trust. We received an 86% favorable score (considered “exceptional” performance) on our 2017 Inspire survey for our environment of trust, as measured by employees’ experience with their immediate manager.

Employee Perception of Environment of Trust

REPORTING CONCERNS

The Allstate Speak Up Process strongly encourages employees to report any activity that causes concern.

Anyone 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, a 24/7 toll-free number
  • Using the Allstate i-Report website: allstatei-report.alertline.com
If an employee wishes to report concerns that someone’s personal information may have been breached, misused, accessed or disclosed without proper authorization, they can email privacyincidentmanagement@allstate.com, or contact AIS-CSIRT@allstate.com to report Allstate information security concerns. An email to contact the audit committee is also available in our investor resources.
When reporting concerns, employees can choose to remain anonymous where the law permits. In 2017, approximately 38% of our employees who filed reports through our hotline did so anonymously. Our Speak Up Process details our expectations of managers at Allstate, who may receive a report from another employee. These expectations include encouraging employees to “speak up,” responding to every allegation promptly and respectfully thanking the employee for bringing the concern to their attention. Allstate policy and the Global Code of Business Conduct prohibit any form of retaliation for reporting a workplace or ethical concern.
Allstate investigates all reports to determine whether the allegation is substantiated. If necessary, Human Resources and local leadership will determine the appropriate action or discipline. Reports regarding matters of integrity are immediately escalated to our investigative team and are included in reports to the Board of Directors.
Allstate will not discuss the case or disciplinary actions with anyone other than the disciplined employee. A Human Resources 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, which records and logs reports and related investigations. The Board of Directors is made aware of substantiated concerns.

GOVERNANCE

Allstate has a robust management structure and oversight for our ethics and regulatory compliance teams.

In 2017, we had over 400 Allstaters across the enterprise involved in ethics, regulatory and compliance initiatives, with the Chief Ethics and Compliance Officer (CECO) overseeing our program. Our CECO is responsible for the company’s code of conduct, ensuring appropriate ethics and compliance budgeting and integrity investigations. The CECO meets with the Board of Directors or the Audit Committee of the Board twice per year and reports on the company’s performance and initiatives. The CECO is also involved in procurement oversight.
We also have a cross-functional Internal Controls and Compliance Committee comprised of executives. The committee convenes quarterly to discuss management topics related to audits, ethics, privacy and regulatory compliance including performance, education, risk and culture.

Risk Assessments

Allstate conducts risk assessments at the enterprise and business unit level. We assess risks related to:

  • Anti-corruption/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
The CECO and their staff partner with each business unit to ensure they have appropriate resources and support to fulfill their ethics and compliance requirements and complete any role-specific needs.

RECOGNITION

In 2018, Allstate was again named as one of the World’s Most Ethical Companies® by the Ethisphere Institute, a global leader in defining and advancing the standards of ethical business practices.

2018 marked our fourth consecutive year of recognition. The “World’s Most Ethical Companies” designation recognizes organizations that significantly influence the way business is conducted by fostering a culture of ethics and transparency at every level. To qualify, companies are scored in five categories: ethics and compliance, corporate citizenship and responsibility, a culture of ethics, governance and leadership, and innovation and reputation.
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