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Avoiding Conflicts of Interest

People with Purpose

Win together with integrity, never allowing personal interests or activities to interfere with what is best for our Company.

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

Our commitment to honesty, caring and 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 sustain and grow our business over the long term.

women in a meeting room

Purpose in Practice

Avoiding conflicts of interest means we:

  • Are alert to situations where personal and company interests are or might be in conflict or where someone could reasonably think there is a conflict
  • 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, especially when we are unsure whether a conflict of interest exists
  • Disclose actual or potential conflicts honestly and promptly
  • Remove ourselves from the decision-making process if we have a conflict of interest and support whatever decision is made

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

There are several potential risk areas regarding conflicts of interest. Some of the most common include:

Relatives and Friends

We do not allow close personal or family relationships to 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 fully aware of any overlapping close personal or family relationships and clarify that the decision process should 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 in an email to Human Resources any significant personal or family financial interests in any member of 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 percent of a company's stock
  • Do not make personal loans to executive officers or members of the Board of Directors

All disclosures will be reviewed to determine whether a conflict exists and what actions, if any, ought to be taken.

Good Example

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.

man wearing glasses looking into camera

Gifts and Entertainment

We look for opportunities to build business relationships but 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, it is important that our partners and customers understand we will never sacrifice our integrity. This means we:

  • Never offer or accept gifts, entertainment or anything else of value if it appears to obligate someone to act or reciprocate in a certain way
  • Never offer or accept anything of value if it appears to violate the policies or core values of the Company or the other partyli
  • 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.

Good Example

If you were invited to an insurance trade show and the registration fee was waived, you could accept if the primary reason for attending would be to discuss business or develop business relationships. You would need to get your manager's approval first, and the Company would have to pay all associated travel expenses, if applicable.

Corporate Opportunities

We never take for ourselves any opportunity in which our Company could have an interest. This means we:

  • Share knowledge of opportunities we uncover and discoveries we make in the course of our work so that we can better pursue our goals as a company and serve those who count on us
  • Avoid using company property, information or resources for personal gain
  • Never compete with a member of the Allstate Family of Companies, directly or indirectly, as a representative of a non-Allstate company

Good Example

If you were to start a personal side business, it would not be appropriate for that business to involve any segment of insurance 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.

Outside Employment and Other Activities

We give our best effort every day, never allowing 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 approval before accepting a board membership at any for-profit company

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.

conflicts of

interest checklist

conflicts 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 core 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 it could give the appearance of a conflict of interest in the eyes of others?

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).

ECC Monitor: OK