Corporate Governance Awards 2016: Best compliance and ethics program (large cap) - The Allstate Corporation
The Allstate Corporation’s compliance and ethics program is built to influence all levels of the company and maintain a continuous dialogue about what it means to have an ethical culture.
With more than 40,000 employees at Allstate, Kelly Noll, senior vice president and chief ethics and compliance officer, acknowledges the challenge of finding communication channels that resonate with different communities. ‘We go from talking to millennials to long-service employees who have spent their entire career with us,’ he says. ‘We’ve learned that you need variety to communicate with different audiences.’
Allstate’s multimedia mix includes blog posts, video articles, quizzes, games and roleplaying scenarios, all hosted on the firm’s internal social network and intranet sites. It has recently experimented with clickbait headlines such as ‘They REALLY Did That?!?’ and ‘What Would You Do?’, based on topical issues.
It’s all intended to make employees feel they are actively engaged in the culture of ethics, culminating in an annual recommitment to Allstate’s code of ethics.
‘We make it a condition of employment,’ says Noll. ‘It helps to get leaders talking about why compliance is important.’ Leaders are given their own ethics toolkit, complete with talking points, presentations and calendars to distribute to employees.
In the last year Allstate has moved from ensuring employees are compliant to recognizing those who go above and beyond in demonstrating integrity and inclusive leadership.
Noll launched a Values in Action program, whereby employees can nominate their peers, which triggers a notification to the nominee’s manager. In some cases, these good news stories are then written up as role model stories, to be used in companywide communications.
Noll has spent his entire career with Allstate and was part of the HR function until 2012. He believes his experience and understanding of internal communications has helped him to shape a culture of ethics. ‘Compliance needs to work closely with HR,’ he says. ‘While I own the code of the ethics, HR owns the policies and procedures. We don’t want to send mixed messages.’
He reports on a quarterly basis into the control and compliance committee, chaired by CEO Tom Wilson. These are normally very involved meetings that go into some detail about Allstate’s compliance practices.
Twice a year Noll provides an update to the audit committee, where he discusses the company’s ethics, compliance and privacy programs. The current focus with this group is developing a global code of business conduct. ‘It was an interesting exercise,’ Noll says. ‘There has to be a little bit of flexibility, but when you get down to the behavior and values you expect, you can get alignment pretty easily.’