Governance

Ethics and integrity

Overview

Values-based leadership is in Allstate’s DNA. “Doing well by doing good” has not only been our corporate legacy in our communities for the past ninety years, but it also defines our approach to Allstate’s transformation from a traditional insurance company into a technologically enabled and consumer-focused organization that not only keeps pace with today’s rapid digital innovation but leads it.

For the eighth consecutive year, Allstate has been named one of the World’s Most Ethical Companies by Ethisphere, a global leader in defining and advancing the standards of ethical business practices. This designation recognizes organizations that foster a culture of ethics and transparency at every level, and it validates that Allstate’s values of integrity, inclusive diversity & equity, and collective success are embedded in everything we do

Accountability

Allstate’s Ethics and Compliance programs are chartered, independent functions overseen by the Chief Ethics & Compliance Officer (CECO) and supported by hundreds of employees. The CECO’s deep involvement across the enterprise ensures day-to-day senior executive engagement and drives the foundational connection of our programs to our business practices across the Allstate Family of Companies.

The CECO reports quarterly to executive leadership at the cross-functional Internal Compliance and Controls (ICC) meeting and semiannually to the Audit Committee and Board of Directors, including in executive session, to cover topics including trends, audits, ethics, privacy and regulatory compliance, performance, education, risk and culture. The CECO has broad, independent authority to enforce the company’s global Code of Business Conduct (Code), ensure appropriate resources for ethics and compliance, report on the company’s performance regarding ethics, regulatory compliance and privacy, and oversee integrity investigations.

As a condition of employment, all employees worldwide must complete annual ethics/compliance training and certification as allowed by law. Robust processes ensure misconduct allegations are promptly investigated without retaliation against those who report.

Policies and practices

Allstate’s policies help communicate our expectations for ethical behavior and provide guidance and resources to employees who are facing ethical dilemmas. Allstate’s policies, including those described below, form only a piece of our holistic approach to ethics and integrity. Allstate’s policy approach is to support and empower employees, and we expect our employees to do the right thing in all situations and to “speak up” when they need help.

Global Code of Business Conduct

Allstate’s Global Code of Business Conduct outlines Our Values and sets expectations for how we conduct our work. It addresses the following general topics:

  • Anti-bribery/corruption
  • Anti-money laundering
  • Antitrust/competition
  • Conflicts of interest
  • Cybersecurity, data and privacy
  • Diversity/discrimination/equal employment opportunity
  • Ethical decision-making, including digital ethics framework
  • Fair dealing (fair business practices)
  • 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

Digital ethics framework

Allstate’s approach to ethics and integrity adapts to stay on the cutting edge of changes in data, technology and digitization. In 2021, Allstate pioneered a digital ethics framework to provide actionable guidance across the enterprise on how to identify and address ethical concerns in the use of data and innovative technologies, like artificial intelligence.

Supplier Code of Conduct

With increased privacy regulation, including the California Consumer Privacy Act and the New York Department of Financial Security Cybersecurity Regulation, and Allstate’s desire to ensure doing the right thing for our customers happens in all aspects of our value chain, we’ve increased expectations of our suppliers.

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 suppliers handling Allstate data. Our Supplier Code of Conduct was last updated in July 2021 to include additional information on human rights, compensation, child labor and diversity and inclusion.

Reporting concerns

A healthy reporting environment is foundational to organizational ethical health, and Allstate’s Speak Up Process encourages and educates employees to report any activities that cause concern and seek guidance for situations that arise that fall outside of policy guardrails. Anyone at Allstate may report questions or concerns related to regulatory compliance or illegal, unethical conduct by:

  • Contacting any 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 is concerned about a security breach or that personal information may have been breached, misused, accessed or disclosed without proper authorization, they can email Allstate Information Security at Cyber@allstate.com or any suspected privacy incident to Enterprise Business Conduct by emailing PrivacyIncidentManagement@allstate.com or the local cybersecurity team.

We support and train employees and managers on a variety of reporting pathways to allow employees to choose one that feels comfortable. For example, when reporting concerns, employees can choose to remain anonymous, where and when the law permits. In 2021, nearly a third of employees who filed reports through the hotline did so anonymously, which is consistent with benchmarks indicating a healthy reporting environment. Our Speak Up Process also provides manager-specific guidance on what to do if they get a report directly from an employee: encourage employees to speak up, listen and communicate expectations, respond to all concerns and thank employees.

Allstate policy and the Global Code of Business Conduct prohibit any form of retaliation for reporting a workplace or ethical concern.

Investigations

Allstate investigates all reports and applies our consistent, Global Internal Investigations Standards, and the Allstate Agency Standards, which dictate that when acting on behalf of Allstate, agents and agency staff must act in compliance with the company’s ethical standards with respect to ethical business practices, and all applicable international, federal, state and local laws and regulations.

Allstate has a designated Investigative Services team responsible for investigating substantiated matters alleging unethical behavior or integrity-related misconduct and follows a “zero tolerance” approach to integrity-related violations of the Global Code of Business Conduct and the Agency Agreement. Once the investigation is concluded, a Human Resources representative follows up with the reporting individual to confirm that the case has been investigated, handled and closed.

Allstate rigorously records, logs, and reports employee-submitted complaints, related investigations, referrals and closures, and we use a digital case management platform to generate metrics used to update leadership and the Board of Directors on investigative services trends and the state of Allstate’s ethical environment.

Allstate’s case management platform offers metrics used to inform leadership and the Board of Directors regarding investigative services trends and the state of Allstate’s ethical environment.

Training and education

Board of Directors

Ethical behavior is expected at all levels, starting at the top. The Allstate Board of Directors receives training in ethics, decision-making, insider training, cybersecurity, conflicts of interest and regulatory developments. As a part of our Board of Directors annual compliance process, the board reviews our six policies: Anti-Bribery, Antitrust, Insider Trading, Inclusive Diversity, Sexual Harassment, Violent Crime and The Global Code of Business Conduct.

Managers

Allstate managers participate in ethics and compliance training that includes a manager-specific annual compliance module, supplemented by an Ethical Leadership Toolkit that includes additional resources for managers and content to share with their teams related to ethical decision making and our Speak Up Process.

Manager training at Allstate is focused on establishing, maintaining and encouraging an open and psychologically safe environment. It’s important for our managers to feel comfortable handling reports, preventing retaliation and encouraging employees to speak up about unethical behavior.

To measure the impact of our training, we:

  • Analyze training course metrics captured via our Ethics and Compliance Learning site
  • Document employee feedback
  • Track misconduct
  • Survey employees annually to measure Allstate’s ethics culture

Employees

We electronically distribute the Global Code of Business Conduct to all employees with accompanying training. Ethics and compliance training is conducted during onboarding and every year after, and we monitor its effectiveness through internal measures. In 2021, 100% of employees completed ethics and compliance training on our Global Code of Business Conduct – a condition of employment at Allstate as allowed by law.

All employees are also required to complete training related to sexual harassment and other risk areas as indicated by function. Risk-specific training addresses, for example, fraud, anti-corruption and bribery, conflicts of interest, data privacy, equal opportunity, insider trading, procurement, social media, anti-trust and money laundering.

As Allstate pivoted to a largely remote working environment in response to COVID-19, training pivoted as well from in-person classes and group discussions to virtual. Virtual training is now provided for yearly Annual Compliance training and other ethics and compliance topics and sessions on navigating change, energy for life, emotional intelligence and leading with compassion. New remote technologies were deployed to make it easier for employees to participate and provided increased assistance to make participation easier. We complete background checks on our largest suppliers and suppliers handling Allstate data. Our Supplier Code of Conduct was last updated in July 2021 to include additional information on human rights, compensation, child labor, and diversity and inclusion.

Business

Allstate regularly assesses regulatory compliance risk at the enterprise, business and area of responsibility level. A comprehensive risk assessment looks at ethics, compliance and privacy to incorporate into a holistic view. We have identified over 60 compliance risk categories and require regular monitoring to ensure ongoing compliance.

We assess regulatory compliance in the following areas:

  • Corporate
  • 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. We also identify and assess all new laws and regulations to determine applicability, impact and remediation.

The chief ethics and compliance officer and their staff work closely with business units to ensure they have resources and support to fulfill their ethics and compliance requirements.

Programs and performance

Enterprise Business Conduct & Strategic Resource Groups

Allstate’s Ethics and Compliance programs are supported by the Enterprise Business Conduct (EBC) team and the Compliance & Governance team, both led by the CECO. These teams provide deep subject matter expertise in areas including ethics, integrity, compliance, and conduct, and provide governance and oversight of the Ethics and Compliance programs.

In 2021, Allstate also launched the business-forward Strategic Resource Group, designed to operate on a consulting model and partner with business teams across the company to problem-solve in the ethics, compliance, and privacy space when new and high-risk areas arise during product development and launch, mergers or acquisitions, or other times of intense transformation.

These teams regularly assess ethics and compliance risk at the enterprise, business and area of responsibility level, looking at ethics, compliance and privacy to incorporate into a holistic view. We map over 60 potential risks—including 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—across 30 business units and levels of operation to understand inherent and residual risk, document requirements and controls, create plans, and complete monitoring and testing to ensure ongoing compliance.

If an assessment reveals an area for opportunity, the CECO and their staff work closely with business units to ensure they have resources and support to fulfill their ethics and compliance requirements.

EBC also leads robust responses to any ethics, compliance or privacy issues or incidents that may arise, including regulator inquiries, cross-functional leadership with legal, data, and information security partners to conduct root cause analysis and mitigate future risk. EBC partners closely in incident response with the aptly named Innovation Law group, a team founded by the CECO in 2018 to support Allstate in high-risk and emerging areas including in resolving ethics, integrity and compliance related issues.

To further ensure the enterprise has robust support during Allstate’s digital transformation and to best protect our customers, the CECO also created and leads Innovation Law – designed to provide cutting-edge legal support to evolving areas such as technology, intellectual property, data, ethics, privacy, regulatory compliance, cybersecurity, risk management, international and commercial matters.

Inspire Survey Results

Allstate has not only been recognized by external third-party benchmarking groups as an industry leader in ethics and integrity, but internal metrics also validate that Allstate practices what it preaches in this space. Trust is a significant driver of employee engagement, retention and satisfaction.

Through Allstate’s biannual Inspire employee engagement survey, we measure whether employees feel that senior leadership are role models for Allstate’s values and that their immediate managers create an environment of trust.

Metric 2020 2021
% favorable response to: “Senior Leadership in my business area are role models for the core values of [company].” Not available* 79%
% favorable response to: “My immediate manager actively creates an environment of trust” 84% 90.6%

*To improve and streamline the employee experience we integrated components of the Integrity Index into the Inspire Survey in April 2021.

Recognition

For the eighth consecutive year, Allstate has been named one of the World’s Most Ethical Companies by Ethisphere, a global leader in defining and advancing the standards of ethical business practices. This 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 the third-party benchmarking organization scoring companies 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 the COVID-19 pandemic, as well as other environmental, social and governance factors.

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