Allstate leverages a robust management structure and oversight for our ethics and regulatory compliance teams. More than 700 Allstaters across the enterprise are involved in 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 is responsible for oversight and governance, enforcing the company’s code of conduct, and ensuring appropriate resources for ethics and compliance functions. The CECO meets with the Board of Directors twice a year 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 also 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 Procedures
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. The Global Code was updated in 2017. The 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 (employees, customers, consumers)
- 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 firstname.lastname@example.org, or contact AIS-CSIRT@allstate.com to report Allstate information security concerns. An email address for the Board’s Audit Committee is provided on the Allstate Investor Relations website. 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 2019, approximately 38% 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. These expectations include encouraging employees to speak up, communicating expectations, responding to all concerns, 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.
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 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. We track employee-submitted reports in our case management platform, which records and logs 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. Since 2018, this new platform has been implemented in several of the seven Allstate subsidiary companies.
Programs and Performance
Training and Communication
Ethical behavior begins with our most senior leaders and cascades down the organization through our required annual training.
Board of Directors
Our Board of Directors receives specialized ethics and decision-making education. 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. An Ethical Leadership Toolkit is also 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 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 2019, 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 their knowledge of the content and pass related lessons.
In addition to Global Code of Business Conduct training, all employees are required to complete a sexual harassment course. Additionally, 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, 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. In December 2019, we updated our Supplier Code of Conduct to include additional information on human rights, compensation, child labor, and diversity and inclusion.
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:
- Human Resources
- Investments and disclosures
- Marketing and sales
- Product and pricing
These areas cover categories such as 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.
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 gives employees a chance to provide feedback that influences company strategy as well as to address important cultural issues. About 11,500 employees across The Allstate Corporation and its subsidiaries participated in the annual Integrity Index survey in 2019.
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.
The Chief Ethics and Compliance Officer 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.
Employee Perception of Senior Leader and Direct Manager Ethics
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. Remarkably, our results have remained at or above 86 for the last four years.
Employee Perception of Environment of Trust
In 2020, for the sixth 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.