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Our stakeholders

Global Code of Business Conduct

We create value for our stakeholders

Our business is about more than money. It's about people.

Whether it's our customers, communities, shareholders or each other, we are committed to doing the right thing, the right way, at the right time. Each of us has the opportunity to drive change and make meaningful contributions through even seemingly small acts of good, like keeping accurate records and avoiding conficts of interest. Together, in ways large and small, we create value for all our stakeholders.

Avoiding conflicts of interest

We succeed with integrity, never allowing personal interests or activities to interfere with what is best for our Company. Our collective success arises from placing Company outcomes ahead of ourselves.

A "conflict of interest" occurs when an individual's private interest interferes (or appears to interfere) with the interests of the Company. We rely on teamwork and transparency to best serve our customers. Making bold decisions and taking calculated risks requires trust — in our information, our intentions and each other.

Our commitment to integrity compels us to do what is right for the people who are relying on us. We are all accountable for recognizing actual or potential conflicts of interest and avoiding even the appearance of them. By doing so, we protect the Company's reputation, build trust with our customers and communities and position ourselves to create the best path forward.

Avoiding conflicts of interest means we:

  • Disclose actual or potential conflicts honestly and promptly.
  • Recognize that conflicts of interest can be avoided or addressed if promptly disclosed and properly managed.
  • Consult with a manager or Human Resources for advice when we are unsure whether a conflict of interest exists.
  • Remove ourselves from the decision-making process if we have a conflict of interest.

For more details on how to disclose a potential conflict, see our Conflict of Interest Policy found under Resources.

There are several potential risk areas regarding conflicts of interest that should be avoided.

Relatives and friends

We do not allow close personal or family relationships to financial interests improperly influence our decisions at work. This means we:

  • Do not participate in the selection or hiring of job candidates who have a close personal or family relationship with us.
  • Ensure those involved in business decisions are aware of any overlapping close personal or family relationships and clarify that the decision process will not be influenced by those relationships.
  • Do not place family members or close personal friends in a reporting relationship within our organization.
  • Remove ourselves from decisions about current or prospective business partners that employ our close friends or family members.

Personal or family financial interests

We do not let our personal investments, or those of close family members, affect our work decisions. This means we:

  • Disclose any significant personal or family financial interests in the Allstate family of companies, or in a competitor or business partner.
  • Understand that a "significant" financial interest could include being an owner, partner, officer or director or a shareholder owning at least 5% of a company's stock.
  • Do not make personal loans to executive officers or members of the board of directors.

All disclosures, which may be sent via email to Human Resources or disclosed during the Annual Compliance attestation process, will be reviewed to determine whether a conflict exists and what actions, if any, ought to be taken.

Integrity insights

It is not necessary to disclose ownership of a limited number of shares in a publicly traded company or shares owned through a mutual fund or similar diversified investment vehicle.

Family reading book.

Gifts and entertainment

We never offer or accept inappropriate gifts or anything else of value to influence business outcomes.

Business courtesies, like nominal gifts and modest meals, can promote goodwill and strengthen business relationships. However, our partners and customers need to understand that we always act with integrity. This means we:

  • Never offer or accept gifts, entertainment or anything else of value if it appears to obligate someone to reciprocate in a certain way.
  • Never offer or accept anything of value if it appears to violate the policies or values of the Company or the other party.
  • Never offer or accept cash or cash equivalents, except for specific incentives of nominal value offered through an approved Company program.
  • Offer or accept meals only when they serve a legitimate business purpose and are not considered extravagant by local custom.
  • Accept gifts only if they are of nominal value.
  • Never accept gifts of any value from customers or current or potential suppliers if we are involved in claim handling or procurement.

Remember, laws and cultural norms on giving gifts and entertainment differ around the world. For further guidance, see our Conflict of Interest Policy found under Resources.

Integrity insights

You may be invited to an industry trade show, and the organizers may waive the registration fee. If the primary reason for attending is to discuss business or develop business relationships, you may accept. However, you would need to get your manager's approval first, and the Company would have to pay all associated travel expenses.

Man in kitchen.

Corporate opportunities

If our Company could have an interest in an opportunity, we never take it for ourselves. This means we:

  • Share knowledge of opportunities and discoveries we make so that we can better pursue our goals as a company.
  • Never use Company property, information or resources for personal gain.
  • Never compete with a member of the Allstate family of companies, directly or indirectly.
  • Promptly disclose and assign intellectual property developed in the course of our work for Allstate.

Outside employment and other activities

To achieve collective success as a company, we give our best effort every day. We never allow outside activities to interfere with our contributions to our Company or customers. This means we:

  • Ensure that outside jobs, personal businesses and volunteer work do not hinder our work for the Company.
  • Do not engage in activities that compete with the Company or could damage its reputation.
  • Never use Company resources, including other employees' time, for outside activities unless approved in advance.
  • Seek and gain approval from Human Resources before accepting a board service role at any for-profit company. Review our board service guidelines found under Resources.

Conflict of interest checklist

If you're concerned that you might have or appear to have a conflict of interest, ask yourself these questions before taking action:

  • Will I feel obligated or make someone else feel obligated to do something?
  • Am I failing to honor Our Values?
  • Is this an action that will benefit me but not the Company?
  • Is there any chance my judgment might be compromised?
  • Is there any way this action could give the appearance of a conflict of interest?

If you answer yes to any of these questions or aren't sure how to answer any of them, contact your manager or Human Resources, or email your Compliance mailbox (see our Conflict of Interest Policy found under Resources).

Integrity insights

If you were to start a personal side business, it would not be appropriate for that business to involve either insurance or non-insurance segments covered by the Allstate family of companies. Even if the business is unrelated, you should not use any contacts gained as an employee of the Allstate family of companies to build your clientele.

If you are unsure about whether a business courtesy, relationship or activity involves a potential conflict of interest, do not hesitate to seek help. Contact your manager or Human Resources, or follow the Speak Up Process.

For more information, see our Conflict of Interest Policy found under Resources.

Following internal controls

Our Behaviors of collaborating early and providing clarity ensure that our processes for developing internal controls involve all of us.

A "conflict of interest" occurs when an individual's private interest interferes (or appears to interfere) with the interests of the Company. We rely on teamwork and transparency to best serve our customers. Making bold decisions and taking calculated risks requires trust — in our information, our intentions and each other.

Together, we facilitate and follow our system of internal controls, knowing it helps us achieve our objectives, protects our assets and correctly accounts for them.

Following internal controls means we:

  • Design, employ and constantly improve robust controls to protect our assets and ensure accurate financial reporting.
  • Maintain a comprehensive and consistent records management system.
  • Fully comply with the Sarbanes-Oxley Act, the Foreign Corrupt Practices Act and any other insurance, financial, anti-corruption or other regulations that apply where we do business.
  • Empower management to implement controls transparently and thoroughly.

Responding to inquiries from investors, analysts and the media

We deliver consistent, accurate, clear information about our Company.

To ensure we provide clarity and comply with the law, only specifically designated employees should represent the Company to the public or the media. If you are contacted by an investor, analyst or media representative:

  • Forward all media inquiries, bloggers and other members of the media to our media relations department at
  • Never speak for the Company unless given specific authorization to do so.

Additional information may be found under Resources.

Creating, maintaining and disclosing accurate records and accounts

We manage all business records with accuracy and integrity, according to accepted accounting principles and legal requirements.

We generate millions of records every year. Making sure they are accurate and properly maintained is essential to our business. It increases efficiency and improves our ability to develop winning strategies. It also provides crucial information to investors, who rely on information that is timely and correct, and it enables us to meet strict regulatory standards and avoid investigations and legal action.

Creating, altering or destroying records for anything other than a legitimate business reason is unacceptable. Doing so to impede the efforts of any governmental or regulatory agency may also be a criminal offense. Every one of us plays a role in accurate record-keeping, and we must approach that role with Our Values of Integrity and Collective Success top of mind.

Keeping accurate records means we:

  • Reflect all transactions honestly, accurately and on time, and in the proper account, department and accounting period.
  • Record all assets, liabilities, revenues and expenses according to the law, generally accepted accounting principles and Company policy.
  • Ensure all reports, disclosures and communications to government authorities and investors are full, fair, accurate, timely and clear.
  • Create, store and dispose of all business records according to records management procedures and retention schedules.
  • Cooperate with all audits, market conduct exams and investigations, and safeguard any records that may relate to legal proceedings.

If you have questions or suspect inaccurate record-keeping, contact your manager or Human Resources. You can also follow the Speak Up Process.

Integrity insights

The term "records" means more than just invoices and quarterly reports. It also includes timesheets, expense reports, emails, voicemails, databases, submissions, drawings and photos. Anything that records a piece of business-related information, whether digitally or in hard-copy form, can be a record.

ECC Monitor: OK