Over 700 employees across the enterprise are involved in the management and oversight of ethics, regulatory and compliance initiatives. Allstate’s chief ethics and compliance officer (CECO) leads the ethics and regulatory compliance programs and oversees governance, enforcing the company’s code of conduct and ensuring appropriate resources for ethics and compliance. The CECO meets with the Board of Directors twice a year, including in executive session, and reports on the company’s performance and initiatives regarding ethics, regulatory compliance and privacy. The CECO is also involved in oversight of integrity investigations.
The CECO reports quarterly at the cross-functional Internal Compliance and Controls (ICC) meeting made up of executive leaders. ICC meets quarterly to discuss management topics related to audits, ethics, privacy and regulatory compliance, including performance, education, risk and culture.
Policies and practices
Global Code of Business Conduct
Allstate’s Global Code of Business Conduct, published in English and French-Canadian, outlines our core values and sets expectations for how we conduct our work. Our Global Code addresses the following topics, many of which have supporting policies and procedures that provide more detail:
- Confidential information
- Conflicts of interest
- Data privacy (consumers, customers, employees)
- Diversity/discrimination/equal employment opportunity
- Fair dealing (fair business practices)
- Gifts and entertainment
- Information security
- Insider trading
- Intellectual property
- Misconduct investigations
- 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
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, a 24/7 toll-free number
- Using the Allstate i-Report website
If an employee needs to report concerns that someone’s personal information may have been breached, misused, accessed or disclosed without proper authorization, they can email the privacy team directly to report their concerns. An email address and contact for the Board’s Audit Committee is provided on the Allstate Investor Relations website.
When reporting concerns, employees can choose to remain anonymous, where and when the law permits. In 2020, approximately 39% of employees who filed reports through the hotline did so anonymously. Our Speak Up Process details what is expected of Allstate managers if they receive a report from an employee, including encouraging employees to speak up, communicating expectations, responding to all concerns and thanking employees for bringing any concerns 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 an allegation is substantiated. If necessary, Human Resources and leadership determine the appropriate action or discipline. Reports regarding matters of integrity are immediately escalated to our investigative services team and are included in reports to the Board of Directors.
Under company policy, Allstate does not discuss details of cases or corrective actions with anyone other than the disciplined employee. A Human Resources representative follows up with the reporting individual to confirm that the case has been investigated, handled and closed. Our case management platform records and logs employee-submitted reports and related investigations. A report on key trends and concerns is shared with the Board of Directors semi-annually.
In 2018, we implemented a new case management platform that offers better metrics and stronger evaluation of trends. It was launched in several Allstate subsidiary companies.
Programs and performance
Board of Directors
Ethical behavior begins with Allstate’s most senior leaders and cascades down the organization through our required annual training. Our Board of Directors receives specialized ethics and decision-making training. They also receive education and training on topics such as insider trading, cybersecurity, conflicts of interest and regulatory developments.
Allstate managers undergo ethics and compliance training that includes a manager-specific annual compliance module. An Ethical Leadership Toolkit is available on the intranet, 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 managers feel comfortable handling reports, preventing retaliation and encouraging employees to speak 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 ethical culture
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 2020, 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. We use an upfront assessment that allows tenured employees to demonstrate knowledge of the content and complete related lessons.
In addition to Global Code of Business Conduct training, all employees are required to complete a sexual harassment course and fraud module. Additionally, select employees undergo risk-specific training related to their job function that addresses topics such as anti-corruption, conflicts of interest, data privacy, equal opportunity, insider trading, procurement, social media and money laundering.
In accordance with increased privacy regulation including the California Consumer Privacy Act, we’ve increased expectations of our suppliers with regard to privacy practices. All Allstate suppliers 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 complete background checks on our largest suppliers and any supplier handling Allstate data. Our Supplier Code of Conduct was last updated in December 2019 to include additional information on human rights, compensation, child labor, and diversity and inclusion.
Allstate regularly assesses regulatory compliance risk at the enterprise, business and area of responsibility level. A comprehensive risk assessment process looks at ethics, compliance and privacy to incorporate into a holistic view. We map over 60 potential risks across 30 business units and levels of operation to understand inherent and residual risk, document requirements and controls, create action plans and complete monitoring and testing to ensure ongoing compliance.
Regulatory compliance areas assessed include:
- Human resources
- Investments and disclosures
- Marketing and sales
- Products and pricing
These compliance areas cover fair labor and payroll laws, sexual harassment, bribery and corruption, environmental and workplace safety, false advertising, whistleblower protection, product terms and services, and many others. A new laws triage process helps identify and assess all new laws and regulations to determine applicability, impact and remediation for all business areas and departments.
The chief ethics and compliance officer 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.
Integrity Index Survey
Conducted by the Gartner Compliance and Ethics Leadership Council, the Integrity Index Survey provides employees an opportunity to offer feedback that may influence company strategy, as well as addressing important cultural issues. About 17,000 employees across The Allstate Corporation and its subsidiaries participated in the annual Integrity Index survey in 2020, an almost 50% increase from 2019.
Survey results are anonymous and confidential and 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.
The chief ethics and compliance officer presents results to all senior leaders. At this meeting, we identify areas of strength and opportunity, and business areas often develop their own customized solutions to address them.
|Tone at the Top||5.85||5.82||5.77||5.77|
|Direct Manager Leadership||6.28||6.26||6.25||6.22|
Inspire survey results
We believe trust is a significant driver of employee engagement, retention and satisfaction. We conduct the annual Inspire employee engagement survey and measure whether employees feel that their immediate managers create an environment of trust. With our transition to remote work over the past year, we credit our managers for keeping their direct reports engaged from afar, with only a slight dip in Inspire results for 2020.
|% favorable response to: “My immediate manager actively creates an environment of trust”||
May 2018: 87%
September 2018: 86%
In 2021, for the seventh 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. The assessment is performed by a third-party benchmarking organization that works to drive industry best practices. Companies are scored in five categories: ethics and compliance, environmental and societal impact, a culture of ethics, governance, and leadership and reputation. The award factored in Allstate’s response to some challenges specific to 2020, including the pandemic, environmental, social, and governance factors, and the topic of equity, inclusion, and social justice. Allstate is the only honoree in the property and casualty insurance category for 2021.