Allstate’s Global Code of Business Conduct, published in English and French-Canadian, outlines the values that are core to who we are and what we do. They define our culture and beliefs, and set forth expectations for how we conduct our work. The Global Code was updated in 2017.
In addition to our Global Code of Business Conduct, we have policies for:
Ethical behavior begins with our most senior leaders and cascades down the organization through annual training, which is a condition of employment.
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.
All managers undergo training in 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 our Ethical Dilemma Spotlight series, which features a new ethical dilemma every month in the Leadership at Allstate newsletter. Each scenario is accompanied by a guide that facilitates ethical discussions within teams. Topics cover a variety of ethical issues, including accepting gifts, reporting inaccurate numbers, sexual harassment and retaliation.
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:
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 opportunity, and many of our business areas develop their own customized solutions to address them.
We distribute the Global Code of Business Conduct to all 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 2018, 100% of our employees completed ethics and compliance training on our Global Code of Business Conduct – a condition of employment at Allstate — through the annual compliance confirmation process. For the first time in 2018, we used an upfront assessment that allowed tenured employees to demonstrate their knowledge of the content and pass related lessons. We continued this approach to annual compliance confirmation in 2019.
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.
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 any supplier handling Allstate data.
The Integrity Index Survey, conducted by the Gartner Compliance and Ethics Leadership Council, gives employees a chance to provide feedback that influences company strategy as well as to address important cultural issues. Gartner administers the annual survey to roughly 16,000 randomly selected employees. The survey is anonymous and confidential, and results are used to compare the 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 direct managers (“Direct Manager Leadership”) on a seven point scale.
Allstate’s environment of trust is a significant driver of engagement, retention and satisfaction; that’s why we conduct the annual Inspire employee engagement survey measuring whether employees feel that their immediate managers create an environment of trust.
The Allstate Speak Up Process strongly encourages employees to report any activity that causes concern.
Allstate employees may report any illegal, unethical conduct or regulatory compliance concerns by:
If an employee needs to report concerns that personal information may have been breached, misused, accessed or disclosed without proper authorization, they can report Allstate information security concerns directly to the privacy team via a dedicated email. A contact for the Board’s Audit Committee is provided on the Allstate Investors Relations website.
When reporting concerns, employees can choose to remain anonymous when the law permits. In 2018, approximately 40% of employees who filed reports through the hotline did so anonymously. Our Speak Up Process details what’s expected of managers at Allstate if they receive a report from an employee. These expectations include encouraging employees to speak up, responding to allegations promptly and thanking employees 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.
In 2018, we launched an anti-retaliation campaign across the company to help employees think about what workplace retaliation might look like and affirm our zero-tolerance stance on any form of retaliation. This campaign included posters with four scenarios asking employees, “Is this retaliation or something else?” We also dealt with the issue of workplace retaliation through articles on Allstate NOW, Allstate’s internal newspaper, and leadership messaging.
Allstate investigates all reports to determine whether an 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.
Under company policy, Allstate does not discuss cases or disciplinary actions with anyone other than the disciplined employee. A Human Resources representative follows up with the reporting person 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.
In 2018, we implemented a new case management tool that offers better metrics and stronger evaluation of trends. Over the next two years, we will work across the Allstate family of companies to bring this tool to all our locations.
Allstate has a robust management structure and oversight for our ethics and regulatory compliance teams. We have over 400 Allstaters across the enterprise who are involved in ethics, regulatory and compliance initiatives, with the Chief Ethics and Compliance Officer (CECO) overseeing the program. The CECO is responsible for the company’s code of conduct, ensuring appropriate ethics and compliance budgeting and integrity investigations. The CECO meets with the full Board of Directors or the Audit Committee twice a 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 made up of executives. The committee convenes quarterly to discuss management topics related to audits, ethics, privacy and regulatory compliance, including performance, education, risk and culture.
In 2018, Ethisphere evaluated our Ethics and Compliance Program, which helped us determine the scope of compliance activities throughout the organization, the effectiveness of our compliance program and whether the company’s culture is conducive to compliance activities.
Allstate assesses regulatory compliance risk at the enterprise, business and area of responsibility level. We map more than 60 potential risks across 30 business units and levels to understand inherent and residual risk, document requirements and controls, create action plans, and complete monitoring and testing to ensure ongoing compliance.
The regulatory compliance areas we assess include:
These areas cover categories such as fair labor and payroll laws, sexual harassment, bribery and corruption, environmental and workplace safety, tax, false advertising, whistleblower protection, product terms and services, and many others.
The CECO and their staff partner with business units to ensure they have appropriate resources and support to fulfill their ethics and compliance requirements and complete any role-specific needs.
In 2019, for the fifth consecutive year, Allstate was named one of the World’s Most Ethical Companies® by Ethisphere, a global leader in defining and advancing the standards of ethical business practices.
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. Companies are scored in five categories: ethics and compliance, corporate citizenship and responsibility, a culture of ethics, governance and leadership, and innovation and reputation.