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In My Good Hands.SMTHE ALLSTATE CODE OF ETHICS1
opportunityethicsperspective
IN MY GOOD HANDSSMTable of ContentsA Message from Thomas J. Wilson.2A Message from Kelly Noll .3About the Code. 4Our Values in Action. 4Using the Code.5Our Responsibilities.5Compliance with the Law.5Special Responsibilities of Leaders and Managers.6Asking Questions and Reporting Concerns.7Making Ethical Decisions .7Resources for Getting Answers or Raising Concerns.7Non-retaliation. 8Administration of the Code. 8Annual Compliance Confirmation. 8Investigations . 8Disciplinary Action. 8Adoption and Disclosure of the Code. 8Waivers of the Code .9Our Employees In My Good HandsSM.11Valuing Diversity and Inclusion.12Preventing Harassment .14Promoting a Safe and Healthy Workplace. 15Our Investors In My Good HandsSM. 27Avoiding Conflicts of Interest. 28Personal Conflicts of Interest. 28Outside Employment or Self-Employment. 28External Board Service. 29Political Activity. 29Outside Financial Activities or Investments.30Business Courtesies.30Improper Personal Benefits. 31Corporate Opportunities. 31Creating and Maintaining Accurate Records. 32Protecting Our Assets. 32Corporate Reputation. 34Confidential and Proprietary Information. 34Information and Communications Systems. 36Avoiding Insider Trading. 37Our Communities In My Good HandsSM. 39Giving Back to Our Communities.40Protecting the Environment.41Speaking to News Media and the Public.42Using Social Media Responsibly. 43Our Customers In My Good HandsSM. . 17Selling and Marketing with Integrity.18Promoting Fair Competition.18Gathering Competitive Intelligence.20Preventing Bribery and Corruption.21Protecting Personal Data. 221
THE ALLSTATE CODE OF ETHICSAllstate’s values and principles are the foundation for Our Shared Purpose. They form thefoundation for everything we do and every interaction with more than 16 million households.Our commitment to doing the right thing has been at the core of this company throughoutour history. We do the right thing, the right way at the right time.The Allstate Code of Ethics guides both our overall purpose as a company and the things wedo every day. This Code provides a roadmap for making decisions and ensuring we make theright choices.Allstate stands apart because of our people. You are the key to our success. This Code reflectsthe values and principles you embody and ensure Allstate has the highest ethical standards.The Allstate Codeof Ethics guides bothour overall purposeas a company andthe things we doevery day.2Thomas J. WilsonAllstate Chairman and Chief Executive Officer
IN MY GOOD HANDSSMMaking a good decision often appears easier than it is in reality. Our decisions are a reflection ofwho we are both individually and collectively. They say a great deal about our values, beliefs andexperiences. At work, our decisions also reflect Allstate’s integrity, which is why doing the right thingis critical to our company and our reputation.The choices we face in challenging circumstances can be among the most difficult to make and oftencarry significant risks. So when you’re faced with a tough situation, especially one that doesn’t feelright, explore it more. Even seemingly familiar topics can have subtle differences, competing valuesand broad implications. By stepping back, we gain appropriate insight, a clearer perspective and theability to act with confidence.Our values and principles provide us with the parameters within which we work and serveour customers, and the Code of Ethics guides our decisions. Use the Code of Ethics to youradvantage — to learn to access resources and to enhance your problem-solving skills. The Codewill help you to sort out the gray in situations and improve your ability to make the best decisionsfor our customers and our company.As a company built on integrity and trust, we must work continuously to refine our decisionmaking skills.Kelly NollSenior Vice PresidentChief Ethics, Compliance and Privacy OfficerLaw & RegulationAt work, our decisionsalso reflect Allstate’sintegrity, which iswhy doing the rightthing is critical toour company andour reputation.3
THE ALLSTATE CODE OF ETHICSOur Values in ActionAt Allstate, we’re committed to operating withabsolute integrity. Always doing the right thingin the right way for the right reason is importantto our business and our reputation. It buildstrust, making Allstate a stronger, more cohesiveorganization, and it strengthens the bonds withour customers and other stakeholders andprepares us for the future.Our path to sustainable success is mapped outin Our Shared Purpose. Making our purpose areality is all about aligning Allstate’s purpose,strategy and execution with behaviors. Thebehaviors, which are exemplified in this Code,should be guided by the values that are at thecore of who we are and what we do. Our valuesdefine our culture and core beliefs and set forthexpectations for how we conduct our work.visiondiversityhonesty4OUR SHARED PURPOSEWHYHOWOur strategicvision & ourcorporate goalOur operating& leadershipprinciplesWHATOur operatingpriorities &corporate goalThey are: Honesty, Caring and Integrity Inclusive Diversity Engagement Accountability Superior PerformanceWe put our values into action by demonstratingthem through our behaviors, decisions andinteractions each and every day. When facedwith decisions, sometimes the answer isclear and the right decision is easy. Othertimes, decisions can be complex and guidanceis needed.All of our choices matter. This Code is one ofmany resources available to help us make theright choices and honor our values. Read theCode carefully, and consider how it appliesto you and your job. It is a business resourceas well as a symbol of Allstate’s commitmentto doing the right thing and delivering on the
IN MY GOOD HANDSGood Hands promise. Read the Code in itsentirety, seek guidance whenever needed andbe comfortable speaking up when you havequestions or concerns.By understanding the Code and seeking help inunclear situations, you’re in the best positionto promote the values of Allstate, which arereflected in its You’re In Good Hands WithAllstate slogan.Using the CodeWe know that situations involving businessconduct and ethics can be complex. As acornerstone of our commitment to operatingwith integrity, this Code includes informationand resources, links to relevant Companypolicies (when connected to the Companyintranet) and realistic question-and-answerscenarios to help guide us in making decisions.The Code topics are organized under fourmajor headings representing expectationsof key stakeholder groups. They are: Our Employees Our Customers Our Investors Our CommunitiesThe categories are not exclusive; the obligationslaid out within them may overlap. We mustnever assume based on our job responsibilitiesor interactions that any part of the Code does notapply to us as individuals. In fact, while specificdetails may be more relevant to some of us thanothers, we are all responsible and accountablefor upholding the Code in its entirety.The interpretation of this Code is subject toapplicable laws. If you have questions about theCode or its content, speak with your manager,another manager, your local Human Resourcesconsultant, or send an e-mail to HRComply.Our ResponsibilitiesCOMPLIANCE WITH THE LAWWe share the responsibility for ensuring thatAllstate achieves its goals in the right way. Itis important to be proactive in regard to thematters covered in the Code so that we cananticipate and avoid problems that could disruptour business or harm Allstate’s reputationand relationships. We also need to be able toaddress issues that do occur in an appropriateway and as quickly as possible.Each of us has a personal obligation toask questions, raise concerns and reportmisconduct. Allstate is committed to fosteringan environment in which everyone feelscomfortable and well supported in doingthese things.SMEach of us needs to understand and complywith the laws, rules and regulations applicableto our jobs.Compliance with laws, rules and regulations,both foreign and domestic, protects thecustomers who depend on us and theshareholders who have invested in ourCompany. In addition to not engaging in anyillegal or unethical activity, we all must reportobserved or suspected noncompliance.At Allstate, we: Act with honesty, caring and integrity in amanner that protects Allstate’s reputation Follow the law and Allstate policies whenconducting Company business Respect colleagues and those with whom wedo business Ask questions and seek help if we are unsureabout making the right choices Promptly report all known or suspectedviolations of the law, this Code or Companypolicies Encourage an environment of comfortspeaking up about concerns Cooperate with all Company investigations5
THE ALLSTATE CODE OF ETHICS Never intimidate or retaliate against colleagueswho report an ethics or compliance concern orparticipate in any investigation Achieve performance goals in a mannerconsistent with the values and principles ofour CompanyAdditionally, the Violent Crime Control and LawEnforcement Act is a federal insurance fraudlaw regulating the involvement in the insurancebusiness of individuals convicted of feloniesthat involve dishonesty or breach of trust. Youmust inform Allstate of any felony convictioninvolving dishonesty or breach of trust bysending an e-mail to HRComply. Be aware of laws, rules, regulations, policies,procedures and processes pertinent to yourresponsibilitiesFailure to report a conviction is a serious legalconcern that may subject you to civil andcriminal penalties.For more information, see the Violent CrimeControl and Law Enforcement Act Policy.standardsempowerethics6SPECIAL RESPONSIBILITIES OF LEADERSAND MANAGERSManagers have the added responsibilityof exemplifying the behaviors we expectof everyone at Allstate and promoting theethical culture we want to sustain.In particular, if you are a leader or manager,you should: Promote a culture of ethics and legalcompliance through personal leadership thatdemonstrates the highest ethical standardsand quality in your work every day Guide and empower your teams by ensuringthat they have the knowledge, training andresources necessary to follow the law andthe Code Be visibly engaged and proactive in relationto ethics and compliance matters Supervise employees by ensuring theyfollow the law, this Code and Allstate policiesand procedures Respond quickly to ethics and compliancequestions (with assistance, if required,from others including Human Resources orEnterprise Business Conduct) Ensure that any actual or potential breachof the Code is dealt with or escalatedimmediately Listen respectfully Stand against any form of intimidationor retaliation
IN MY GOOD HANDSAsking Questions andReporting ConcernsMAKING ETHICAL DECISIONSEvery decision we make is a reflectionof our Company.No code of ethics can cover every situation.When faced with ethical issues where theright decision or course of action is unclear,we should ask ourselves: Is it legal? Is it the right thing to do? Does it conflict with our values? Is it consistent with the Code andCompany policies? Could it adversely affect ourCompany or its stakeholders? What are the consequences? How would it be perceived by yourfamily and friends?If you are still uncertain about the ethics orlegality of an issue, seek additional guidancebefore proceeding.RESOURCES FOR GETTING ANSWERS ORRAISING CONCERNSEach of us plays an important role in ensuringthat Allstate achieves the highest levels ofethical conduct.Part of doing the right thing in the right wayfor the right reason is speaking up if somethingdoes not feel right. If you see or suspectmisconduct, report it immediately. If the Code orpolicies and procedures do not provide enoughdirection, seek help.Below are many resources available to helpyou when you have a question, need additionalguidance about the topics discussed in thisCode or want to raise an issue or report aconcern: For assistance with Code-related ethics andcompliance concerns, or questions aboutAllstate’s company policies, send an e-mailto HRComply.SM To report a potential violation of laws, rulesor regulations or a potential violation of theCode, speak with your manager, anothermanager or your local Human Resourcesconsultant. You may also use the Allstatei-Report process.Allstate i-Report is Allstate’s commitment to afair, prompt and safe resolution of your concern.It should be used to report ethical, legal,regulatory or compliance concerns regardingAllstate employees, agents, vendors, clientsand customers. You can use the Allstatei-Report Process by calling the Allstate i-ReportLine at 1-800-706-9855, which is a 24/7toll-free number, or accessing the website athttps://allstatei-report.alertline.com.Anonymous reports cannot be submittedusing the Allstate i-Report website. To remainanonymous, please use the Allstate i-ReportLine. We would prefer that people identifythemselves since this always helps us conductthorough and efficient investigations andnecessary follow-up. If you choose to remainanonymous, we will conduct an investigationusing the facts provided while working tomaintain your anonymity as far as permittedby law. Would you feel comfortable readingabout your action in the news?7
THE ALLSTATE CODE OF ETHICSNON-RETALIATIONINVESTIGATIONSWe do not tolerate intimidation or retaliationagainst anyone who raises a concern, reportsa violation or participates in an investigation.We are committed to thoroughly investigatingreports of potential violations. Mostinvestigations are handled internally. In rarecircumstances, an investigation may bereferred to an outside agency.We understand that it isn’t always easy to speakup regarding a concern and that doing so takescourage and may not feel comfortable.No matter what our position within theCompany, we report all instances of retaliationif we see or are aware of them. Retaliation byanyone against an employee for raising an issueor reporting a concern may result in discipline,up to and including termination of employment.Administrationof the CodeANNUAL COMPLIANCE CONFIRMATIONintegrityconducthonesty8 88Allstate’s compliance standards and proceduresare designed to ensure prompt and consistentaction against violations of the Code. As acondition of employment, each of us is requiredannually to read and certify to our understandingof the Code and, where applicable, individualbusiness unit professional conduct requirements.Failure to complete Annual ComplianceConfirmation may result in discipline, up toand including termination of employment.Reports that concern a possible violation of thelaw or the Code, or any complaints or concernsabout accounting, auditing, disclosure or otherfinancial or reporting practices will be referredto the General Counsel for investigation. TheGeneral Counsel may refer these matters tothe Audit Committee.DISCIPLINARY ACTIONViolations of the Code or the law, or retaliationby anyone against an employee for raisingan issue or reporting a concern, may result indiscipline, up to and including termination ofemployment.ADOPTION AND DISCLOSURE OF THE CODEThe Allstate Code of Ethics, in its entirety,applies to every Allstate employee and officer,as well as Allstate’s outside directors. This Codewas adopted by the Audit Committee of theBoard of Directors of The Allstate Corporation.The Audit Committee is responsible for periodicreview and assessment and approval of changesto the Code.
IN MY GOOD HANDSSMWAIVERS OF THE CODEWe recognize that in rare circumstances a strictapplication of the Code may result in a serioushardship. In these exceptional cases, a waiver ofthe Code in order to mitigate a serious hardshipmay be sought.Any waiver of the Code of Ethics for the ChiefExecutive Officer, Chief Financial Officer,Controller, other senior financial or executiveofficers, or members of the board of directorsmust be approved by the Audit Committee. Forall other employees, any waiver of the Code ofEthics must be approved in accordance withprocedures adopted by the Audit Committee.For more information, see the Code of EthicsWaiver Process.We are committed to thoroughly investigatingthe report of a potential violation.understandingpridevalues9
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IN MY GOOD HANDSSMOur EmployeesA positive and dynamic work environment with a robust ethical culture is essentialto Allstate’s success. It defines and enriches our interactions with each other andIN THIS SECTION:VALUING DIVERSITY ANDINCLUSIONPREVENTING HARASSMENTPROMOTING A SAFE ANDHEALTHY WORKPLACEour customers; it also helps to foster the mutual respect and trust that enables usto collaborate effectively and serve those who count on Allstate. This environmentdoesn’t happen by accident. We create and sustain it when we treat each otherwith fairness and respect, support our colleagues and work in harmony withAllstate’s values. Our workplace and businesses are enhanced when we valuethe individual differences, unique perspectives and contributions that each ofus brings to Allstate.11
Our EmployeesInclusive Diversity is a key business strategyand competitive advantage for Allstate. It’sabout creating a work environment whereindividual diversity is valued, so that allemployees can reach their potential whilemaximizing their contributions to ourcustomers and shareholders.CHRISTY HARRIS, VICE PRESIDENTTALENT ACQUISITON AND INCLUSIVEDIVERSITYINTEGRITY IN ACTIONQ: I’m considering an applicant who cameto the interview in a wheelchair for a jobin which she’d be working in the fieldwith our customers. I believe that shecan satisfy the expectations of the job,but I’m afraid that some customers maybe uncomfortable with her disability.Assuming that she can perform therequirements of the job, is this alegitimate reason not to hire her?A: No. To deny an applicant or employeea job based on the reaction of others toa disability or other protected status isunlawful discrimination. If the applicant isthe best qualified person for the job, weshould hire her. At Allstate, we appreciatewhat makes each of us different. Ourcustomers expect nothing less.1212Valuing Diversityand InclusionAt Allstate, we value and leverage the fullbreadth of our differences, which enrich ourperspectives in the service of customers andmake us a strong and inclusive organization.Everyone counts and has a voice at Allstate,regardless of role or length of service. Our abilityto outperform competitors in serving customersdepends on attracting, developing and retaininga rich mix of talented, committed people basedon merit. Treating people inside and outside ourorganization fairly and respectfully honors ourvalues of honesty, caring and integrity and helpsto protect and enhance our reputation. It alsobuilds the trust upon which collaboration andlong-term mutual benefit are based.We Value Diversity and PreventDiscrimination By: Treating each other with dignity, respectand courtesy Strictly prohibiting discrimination on thebasis of:- Race; color; age; sex; sexual orientation;gender identity/gender expression; nationalorigin; religion; disability; citizenship; statusas a veteran; military service or any otherstatus protected by applicable law Making reasonable accommodations asappropriate for others’ disabilities andreligious beliefs Committing to equal opportunity for allemployees and applicants Complying with all applicable employmentlaws, rules and regulations Making employment-related decisions onthe basis of job performance Reporting instances of unfair treatment ordiscrimination to your manager, anothermanager, your local Human Resourcesconsultant or by contacting Allstate i-Report Not retaliating against anyone whoreports discrimination or participatesin an investigation of these reportsTo learn more, see our Managing DiversityPolicy, Positive Workplace Policy andEmployee Relations Policy.
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Our EmployeesFeeling safe and secure at work isabsolutely critical for Allstate employees,and is foundational to employee satisfaction.Additionally, Allstate wants even morefor its employees – to feel empoweredand experience meaningful work throughan environment of trust, transparencyand integrity.HARRIET HARTY,EXECUTIVE VICE PRESIDENT,HUMAN RESOURCESINTEGRITY IN ACTIONQ: One of my coworkers asked me to goon a date with him after our teammeeting last week. I politely declinedthe offer because I’m already datingsomeone else. Since then, he has askedme out two more times. The offers areunwanted. I’m beginning to feel reallyuncomfortable. Is this consideredharassment?A: Yes. Persistent requests for dates canbe considered sexual harassment.Harassment has no place at Allstate.We are committed to maintaining apositive, productive and safe workenvironment. You should alert yourmanager, another manager, your localHuman Resources consultant or contactAllstate i-Report about this concern.1414Preventing HarassmentAt Allstate, we believe that everyone has boththe right to work in an environment free fromharassment as well as the duty to helpprevent it.Our commitment to a workplace free fromharassment applies to all people, regardless ofwhether they’re Allstate employees. Everyone isentitled to be treated with dignity and respect.We don’t tolerate any form of verbal or physicalharassment, intimidation or bullying. Rememberthat harassment isn’t always obvious ordeliberate and that unintentional or seeminglyinnocent behavior could be interpreted asharassment.We Respect Each Other and PreventHarassment By: Conducting ourselves appropriately in alldealings with others in the workplace Being conscientious as to how our actionsand comments might be perceived ormisunderstood by others Avoiding behavior that creates a hostile,intimidating or offensive work environment,such as:- Unwanted verbal or physical conduct ordegrading/disparaging jokes relating to race;color; age; sex; sexual orientation; genderidentity/gender expression; national origin;religion; disability; citizenship; status as aveteran; military service or any other statusprotected by applicable law- Persistent or unwelcome flirting, sexualadvances, sexual comments, touching,pressure for dates or other sexuallysuggestive behavior Being vigilant for signs that others may beexperiencing harassment Reporting instances of harassment to yourmanager, another manager, your local HumanResources consultant or by contacting Allstatei-Report about the concern Not retaliating against anyone who reportsharassment or participates in an investigationof these reportsTo learn more, see our EmployeeRelations Policy.
INTEGRITY IN ACTIONPromoting a Safe andHealthy WorkplaceAt Allstate, we care about the health andsafety of our employees, visitors and othercompanies’ employees working at ourfacilities. We take reasonable and legallyrequired precautions to provide safe andsecure workplaces.A safe and healthy workplace provides aproductive work environment where all peoplehave the ability to achieve their goals. Theworking conditions at Allstate are intended toprotect the health and safety of employees,visitors and business partners. It is importantfor all of us to comply with all applicable healthand safety policies and procedures at ourwork locations, including relevant standards,instructions and processes.A drug- and alcohol-free workplace supportsour health and safety goals and is vital to ourintegrity, reputation and business performance.We cannot allow our judgment to be impairedat any time. No one may be under the influenceof intoxicants or any controlled substance thathas not been prescribed by a licensed physicianwhile conducting Allstate business or while onCompany premises.Acts of violence, threats or physical intimidationhave no place at Allstate, and we all have aresponsibility to help ensure they do not occur.We Support a Safe and Healthy WorkEnvironment By: Reporting to management any accident, injury,illness, or unsafe or unhealthy condition ofwhich we become aware Knowing what to do in an emergency and cooperating during the practice of emergency drills Maintaining a drug- and alcohol-free workplace Not saying or doing anything that could createfear or threaten the safety or security of others Not bringing firearms or other weaponsonto Company premises or while travelingon Company business (except to the extentwe are required to permit this activity underapplicable laws)Q: My coworker talks about consumingalcohol after leaving work when he isbusy or stressed and frequently saysthat he needs a drink. I think that hemay have an alcohol dependency, andit could be affecting his health, workingrelationships and business judgment.If I report this to my manager, will mycoworker lose his job?A: N o. Your coworker would not beterminated simply for having an alcoholdependency. We understand thataddiction occurs and can be overcome.And our Employee Assistance Program(EAP) may be able to provide resourcesto help employees conquer addiction.In addition, to the extent that yourcoworker requires additional assistanceto help him perform his job, yourmanager can talk to and work with himto provide appropriate assistance.However, we do expect that no employeewill conduct business while under theinfluence. Employees under the influenceat work may be subject to discipline. Reporting instances of unsafe or violent behavioror unsafe working conditions to your manager,another manager, your local Human Resourcesconsultant or by contacting Allstate i-Report Not retaliating against anyone who reportsunsafe or violent behavior or unsafe workplaceconditions or participates in an investigationof these reportsTo learn more, see our Employee Health andSafety Policy and Employee Relations Policy.For additional information on our Companypolicies, talk to your manager, anothermanager, your local Human Resourcesconsultant or send an e-mail to HRComply.1515
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IN MY GOOD HANDSSMOur CustomersEverything we do at Allstate should be driven by our purpose of protecting ourcustomers from life’s uncertainties and helping them prepare for the future. InIN THIS SECTION:SELLING AND MARKETINGWITH INTEGRITYPROMOTING FAIR COMPETITIONallowing us to serve them, our customers place confidence and trust in us to dothe right thing. We must demonstrate that we’re worthy of this trust and assureGATHERING COMPETITIVEINTELLIGENCEour customers that Allstate lives into its Good Hands promise. This is both aPREVENTING BRIBERYAND CORRUPTIONshared responsibility and an individual responsibility. Living up to it every dayPROTECTING PERSONAL DATAincreases customer loyalty, enhances Allstate’s reputation and strengthens ourability to grow and thrive in a competitive market.1717
Our CustomersLeading with integrity is consistently doingthe right thing, at the right time, for the rightreasons. It’s table stakes in building neededtrust and confidence with all of ourstakeholders.ALICE BYRNE, RETIRED FIELD SENIORVICE PRESIDENT, MIDWEST REGIONINTEGRITY IN ACTIONQ: I work at the Customer Contact Center.I’ve nearly closed the sale of an autoproduct to one of our current homeowner policyholders. She wants tocompare o
Allstate stands apart because of our people. You are the key to our success. This Code reflects the values and principles you embody and ensure Allstate has the highest ethical standards. Thomas J. Wilson Allstate Chairman and Chief Executive Officer The Allstate Code of Ethics guides both our overall purpose as a company and the things we do
