Global Code of Business Conduct

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Global Code of Business Conduct
The Allstate Family of Companies

The Allstate Family of Companies

The Allstate Corporation is the largest publicly held personal lines insurer in the United States. Allstate serves distinct customer segments with differentiated offerings in the United States and Canada by conducting business through Allstate Insurance Company and other subsidiaries.

Allstate brand auto, homeowners and other personal lines insurance products are sold primarily through Allstate-exclusive agencies, serving brand-sensitive customers who prefer local personalized advice and service.
Allstate Northern Ireland Limited is a technology company that provides core IT competencies, programming, operations support, integration services and risk analytics to Allstate and its subsidiaries.
Allstate Canada offers Allstate brand products through employee producers and differently branded products through brokers working in five provinces across the country (Ontario, Quebec, Alberta, New Brunswick and Nova Scotia).
Encompass brand auto, homeowners, umbrella and other insurance products are distributed through independent agencies that serve consumers who prefer personal advice and assistance from an independent adviser and are brand neutral.

Answer Financial serves self-directed, brand-neutral consumers who want a choice between insurance carriers, offering comparison quotes for auto and homeowners insurance from approximately 25 insurance companies through its website and over the phone.
Esurance sells auto, homeowners, and other personal lines insurance products to self-directed, brand-sensitive consumers primarily online and through contact centers.
Allstate Solutions Private Limited provides software development, software testing, business process offshoring and management, technology support, analytics and other IT-enabled services to Allstate and its subsidiaries.
Arity is a technology company that uses data science and predictive analytics to transform massive amounts of data into actionable insights. From data collection to risk scoring, Arity offers solutions to help keep drivers and customers safe, secure and on the road.
SquareTrade is a highly rated protection plan provider trusted by millions of customers for its fast and efficient service. SquareTrade protects mobile devices, laptops, tablets and other consumer electronics and appliances from malfunctions, accidental damage and life’s frequent mishaps.

Allstate and Encompass Northbrook, IL

Allstate Canada Markham, Ontario, Canada
Allstate Northern Ireland Belfast, Northern Ireland

A Global Force for Good
Allstate is a global corporation, with companies based in four countries on three continents.

Esurance and SquareTrade San Francisco, CA
Answer Financial Encino, CA

Arity Chicago, IL

Allstate Solutions Private Limited Bangalore, India

Being part of the Allstate Family of Companies carries a special significance. As one of America’s most iconic brands, we continue a proud legacy of innovation, caring and good work, which is redefining the way people think about corporations.
At the heart of this evolution, there remains one constant: our values. It is our commitment to our core values of honesty, caring and integrity, inclusive diversity, engagement, superior performance and accountability that defines who we are and how we act each and every day. These values represent our solemn responsibility to serve our customers and society—and we will not compromise them.
Our Shared Purpose defines Allstate’s strategic vision and the kind of culture we need to drive results—a culture where you’re not just empowered to help shape our future, you’re expected to lead the way. It’s an exciting time to be a part of the Allstate family, and with it comes great responsibility. It’s up to each and every one of us to ensure we stay true to our purpose and the values outlined in the Global Code of Business Conduct.
The Global Code is your guide; refer to it often. If you find yourself tested, challenge yourself to do that heroic act that will ask a little more of you—defy expectations. Measure yourself in how you do the right thing, the right way, at the right time. It’s how we let our customers and communities know that no matter how they come to us—or where we serve them—they can count on us. We joined this Company to make a difference. We are a force for good.
Thomas J. Wilson Chairman and Chief Executive Officer

The Allstate Family of Companies is changing in 2017 to operate under one Global Code of Business Conduct. What’s not changing is our commitment to operate with the highest degree of integrity and honesty. Our values and conduct define our collective culture and are essential to the kind of corporation we are and intend to remain.
In a rapidly changing world, we pride ourselves on being different—a difference built on a foundation of integrity and trust. How we respond when faced with a situation that doesn’t quite feel right says a lot about us, our culture and how we do business. The Global Code is meant to be a resource to help you make the right decisions as you carry out your duties every day. We all have a responsibility to integrate the principles of the Global Code into our work, to build on the trust bestowed upon us by our stakeholders and to protect our brand reputation.
The Global Code is one of many resources available to help us honor our values. Use the Global Code and refer to it often. It’s the perfect complement to guide your talent, passion and purpose.
Kelly Noll Senior Vice President Chief Ethics &
Compliance Officer Chief Privacy Officer

Table of Contents
Our Shared Purpose 6
Our Core Values 8 People with Purpose: Doing the Right Thing 8 Adoption and Disclosure of the Code 8 Waivers 8 Responsibility and Accountability 8 Special Responsibilities of Managers 9 Ethical Decision-Making 10 Speaking Up, Seeking Help and Resolving
Concerns 10 Anonymity and Confidentiality 11 Zero Tolerance for Retaliation 11 Investigations 11 Fair Process and Disciplinary Action 11

Our People Make Us a Different Kind of Company 12
Valuing Inclusive Diversity 13 Promoting Equal Opportunity 14 Fostering a Respectful Workplace 16 Keeping the Work Environment Safe and
Healthy 17 Respecting the Intellectual Property of Others 18 Using Social Media Responsibly 19
We’re a Winning Team for Our Customers, Our Communities and Each Other 20
Selling and Marketing with Integrity 21 Safeguarding Our Assets and Information 22 Using Information and Communications Systems
Responsibly 23 Preventing Insider Trading 24 Protecting Confidential and Restricted
Information 25 Protecting Personal Data 26 Competing Fairly 27 Gathering Competitive Intelligence Fairly 28
We Are a Force for Good for All of Our Stakeholders 30
Avoiding Conflicts of Interest 31 Relatives and Friends 31 Personal or Family Financial Interests 31 Gifts and Entertainment 32 Corporate Opportunities 32 Outside Employment and Other Activities 32
Following Internal Controls 33 Creating, Maintaining and Disclosing
Accurate Records and Accounts 34 Responding to Inquiries from Investors,
Analysts and the Media 35

Honesty, Caring and Integrity on a Global Scale 36
Doing Business Across Borders 37 Preventing Money Laundering 38 Preventing Bribery and Corruption 39 Respecting and Protecting Human Rights 40
A Force for Good in the Places We Live and Work 42
Protecting Our Environment 43 Contributing to Our Communities 44 Participating in the Political Process 45


Our Shared Purpose
As the Allstate Family of Companies,* our individual customer value propositions differentiate us, but the way in which we do business 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 a 22nd-Century Corporation can be. This Global Code of Business Conduct, which we refer to throughout this document as our Code, is built upon our 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.
*Throughout this document, the “Allstate Family of Companies” and “Company” are defined as The Allstate Corporation and its subsidiaries. 6


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.

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.

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 our Global Code of Business Conduct Waiver Process at www
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.
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

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

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 the resources listed at



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 on the right
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
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:
• Answer Financial, Esurance and Allstate U.S.: Call (800) 706-9855 or access the website at
• Allstate Canada: Call the ClearView Connects hotline at (866) 275-2138, access the website at or send a report by mail to the ClearView Connects post office box at P.O. Box 11017, Toronto, Ontario M1E 1N0
• Allstate Northern Ireland: Call the ANI i-Report line at (0800) 169-3658 or send an email to [email protected]
• ASPL: Call the ASPL i-Report line at (000-117) 855-645-5594 or access the website at
You may remain anonymous during this process.

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Global Code of Business Conduct