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Our Shared Purpose

As the Allstate Family of Companies1, our individual customer value propositions differentiate us, but it's the way in which we do business that defines us. Adhering to the highest ethical standards is universal and a cornerstone of our culture. It's how we let our customers, stakeholders and communities know that no matter how or where we serve them, we'll continue to defy their expectations of what insurance can be.

This Global Code of Business Conduct, which we refer to throughout this document as our "Code," is built upon core values that drive us, guide us and point the way forward when our path seems or becomes unclear. By incorporating these values in everything we do, we build trust and strengthen relationships. Our core values are the bedrock of Our Shared Purpose: to help customers realize their hopes and dreams by providing the best products and services to protect them from life's uncertainties and prepare them for the future.

1Throughout this document, "The Allstate Family of Companies" and "Company" are defined as the Allstate Corporation and its subsidiaries.

Our Core Values

Our core values define our culture and what it means to be part of the Allstate Family of Companies. They are non-negotiable.

Honesty, Caring and Integrity — We are truthful. We put people ahead of policies and always do the right thing.

Inclusive Diversity — We gain strength and inspiration from our differences.

Engagement — We are fully present and connected in everything we do.

Superior Performance — We use every resource and opportunity available in our quest to be the best.

Accountability — We take personal ownership and refuse to look the other way.

women in conference room having a discussion

People with Purpose: Doing the Right Thing

Our Code declares who we are and what we stand for, integrating our policies with our principles and core values. It underscores our commitment to doing business legally and ethically, and provides both the foundation and the framework for the decisions we make and the actions we take every day, around the globe. It's also a practical tool to help us understand what is expected of us, how we live our core values and when we should seek help.

The Code applies to the entire Allstate Family of Companies. It's up to each and every one of us to lead from our seats and to stand firm in our commitment to understanding it, knowing how to use it and following it at all times. It contains references to relevant policies and insights into realistic scenarios we might face in a complex and demanding global marketplace. It also features specific guidance on how we can help Our Customers, Our Stakeholders, Our Communities and Our People to prosper without compromising our core values. This unyielding commitment to doing the right thing, in fact, strengthens and propels our business by making us more reliable, resilient and responsive to those we serve.

Adoption and Disclosure of the Code

The Code provides ethical guidelines for conducting business on behalf of the Allstate Family of Companies (The Allstate Corporation and its subsidiaries). It applies to every employee and officer, as well as outside directors, of the Allstate Family of Companies. This Code was adopted by the Audit Committee of the Board of Directors of The Allstate Corporation. The Audit Committee is responsible for periodic review and assessment and approval of changes to the Code.

The Code cannot address every issue that may be encountered, so we must be familiar with its principles and use it to guide our judgment and inform our actions. Additional information including relevant policies may be found in links throughout the document.

Waivers

We recognize that in exceptional cases, a strict application of the Code may result in serious hardship. In these rare circumstances, except for employees of Allstate Canada Group, a waiver of the Code to mitigate hardship may be sought. Any waiver of the Code for the CEO, CFO, Controller or other senior financial or executive officers, or outside directors, must be approved by the Audit Committee. For all other employees, any waiver must be approved according to procedures adopted by the Audit Committee.

For more information, see Resources.

Responsibility and Accountability

Fulfilling Our Shared Purpose means holding ourselves and each other accountable to the Code. Accountability is often confused with responsibility, but, in fact, it's more. Responsibility is something given to you, and accountability is something you must take upon yourself. It's about engagement, results and ownership. By being accountable to our Code, we honor our core values and the people we serve.

men in conference room lookina at laptop

We each need to understand and comply with the spirit and requirements of foreign and domestic laws, rules, regulations and company policies that apply to our jobs. This protects the customers who depend on us and the shareholders who have invested in us. That means we each have an obligation to ask questions, raise concerns and report violations regarding the Code. We are committed to fostering an environment that empowers us to lead from every seat and raise concerns without the threat of retaliation. Anyone who violates our core values, policies or Code through illegal or unethical behavior may face disciplinary action, up to and including termination of employment.

In addition, we're all expected to:

  • Act with honesty, caring and integrity in a manner that protects the Company's reputation
  • Respect our colleagues, customers, business partners and communities
  • Ask questions and seek help if we are unsure how to proceed, and nurture an environment that encourages everyone to come forward with concerns
  • Promptly report all known or suspected violations of the law, the Code or company policies
  • Cooperate with all company investigations
  • Never intimidate or retaliate against anyone who reports a concern or cooperates with an investigation
  • Promptly disclose any unpardoned felony, criminal offense, or other serious conviction of ourselves or a company colleague to Human Resources

industry

hiring regulations
industry hiring regulations

Certain insurance industry regulations include disclosure and other requirements relating to individuals convicted of felonies involving dishonesty or a breach of trust. Failure to comply with these regulations could result in civil or criminal penalties. For more information, see Resources.

Special Responsibilities of Managers

People leaders have a special responsibility to proactively promote the ethical culture we want to sustain and empower every employee to do the same. If we lead or supervise others, we should:

  • Provide personal leadership that demonstrates the highest quality and ethical standards every day
  • Achieve performance goals in ways that are consistent with our core values
  • Be aware of all laws, rules, regulations, policies, procedures and processes that relate to our responsibilities and direct employees accordingly
  • Remain engaged and consistent about regularly communicating the importance of our core values and policies and the consequences of failing to honor them
  • Ensure that team members have the knowledge, resources and training needed to follow the law and our Code and to develop their careers
  • Keep our core values and the Code in mind when making decisions about hiring, promoting and delegating
  • Identify and mitigate ethics, compliance and policy risks
  • Listen respectfully and respond in an appropriate and timely way to employees who seek advice or raise concerns
  • Address or escalate violations immediately
  • Stand firm against any form of intimidation or retaliation
woman standing infront of cube

Ethical Decision-Making

When faced with ethical issues where the right decision or course of action is unclear, we should first ask ourselves:

  • Is it legal?
  • Does it follow the spirit and intention of applicable laws and regulations?
  • Is it the right thing to do?
  • Does it conflict with our core values?
  • Is it consistent with our Code and company policies?
  • Could it adversely affect our Company or its stakeholders?
  • What are the consequences?
  • How would it be perceived by our family and friends?
  • Would we feel comfortable if our actions appeared in the news or social media?

If uncomfortable with or unsure of the answer to any of these questions, we must seek help before proceeding.

Speaking Up, Seeking Help and Resolving Concerns

We can rely on our honesty, caring and integrity to guide us, but when we are not sure how to proceed, we also have a duty to step forward, ask questions and seek help. And if we believe a violation of our policies, our Code or the law has happened or may be about to happen, we are obligated to report it.

To seek help, report violations and resolve concerns, you can follow the Speak Up Process by:

  • Contacting your manager
  • Contacting any manager
  • Contacting Human Resources
  • Emailing your local Compliance mailbox
  • Using the additional local reporting options as listed below

Often it is best to start with your manager when raising a concern, but sometimes this may not be feasible. The most important thing is that you lead the way, speak up and seek help when something doesn't feel right.

speak up

process

speak up process

The Speak Up Process is an important resource for providing fair, prompt and safe resolutions of concerns. It should be used to report legal, ethical, regulatory or compliance concerns regarding employees, agents, vendors, clients and customers of the Allstate Family of Companies. You can follow the Speak Up Process 24/7 in the following ways:

You may remain anonymous during this process.

Anonymity and Confidentiality

The Company will always strive to address concerns fairly and discreetly. Employees with concerns are strongly encouraged to identify themselves when seeking assistance. This is the best way to ensure that a thorough and complete investigation can be made and that an effective and lasting resolution can be reached.

However, we recognize that in some cases people may prefer to remain anonymous when raising concerns. Anonymous reports can be made through the Speak Up Process. An investigation will be conducted using the facts provided, while working to maintain your anonymity as far as permitted by law. When necessary, the Company may also consult with you confidentially if anonymity would hinder the investigation or resolution of the issue.

people having coffee in breakroom

Zero Tolerance for Retaliation

We do not tolerate intimidation or retaliation against anyone who raises a concern, makes a report or cooperates in an investigation.

Retaliation is not just malicious and contrary to our core values-it also undermines the culture of openness and trust we are determined to maintain. Any threat of retaliation can hinder investigations and prevent people from coming forward with concerns. Retaliation can take many forms and is sometimes subtle. It can also occur inside or outside of the workplace. In many instances, it is also illegal. Each of us has a role to play in making retaliation unacceptable and maintaining an environment in which we can all feel safe and comfortable raising an issue or reporting a violation.

We recognize speaking up isn't always easy, and we want to make the decision to speak up as simple as possible. Retaliation against anyone who raises a concern or reports a violation in good faith may result in disciplinary action, up to and including termination of employment.

Investigations

We are committed to thoroughly investigating all reports of violations and reaching fair resolutions. We will try to maintain the confidentiality of those involved, where this is allowed by law and does not hinder the investigation or resolution of the issue. Most investigations are handled internally, but, in rare cases, they may be referred to an outside agency.

Reports about a possible violation of the law or any questions about accounting, auditing, disclosure or other financial or reporting practices will be referred to the General Counsel for investigation. The General Counsel may refer these matters to the Audit Committee.

Fair Process and Disciplinary Action

When possible and where required, all parties involved in an investigation will get a fair chance to explain circumstances and present their side of the story. We make efforts to complete the process promptly, while still taking whatever time is needed to conduct a proper and thorough investigation.

Violations of the Code or the law, or retaliation by anyone against an employee for reporting a concern in good faith or cooperating with an investigation, may result in discipline, up to and including termination of employment.

ECC Monitor: OK