Transcription

STATE FARM Code of Conduct2017Message from the ChairmanOur mission at State Farm is to help people manage risks of everyday life, recover fromthe unexpected and realize their dreams. We have thousands of opportunities to buildconfidence with customers and State Farm associates every day.We have built a trusted brand by living our values and keeping our promises. Ourcustomers expect us to do the right thing. We depend on each other to do the right thing.By holding ourselves to high standards, we can continue to be there for ourcustomers, helping more people in more ways.Michael L. Tipsord, Chairman, President & CEOState Farm Code of Conduct 2017p. 1

CONTENT OVERVIEWNon-RetaliationEthical and Legal ConductAnti-Money LaunderingCompeting and Dealing Fairly with Othersp4Report Information Accuratelyp4Acquiring and Using Sensitive Informationp5Privacyp5Antitrustp5Restrictions on Employmentp5Respecting the Intellectual Property Rights of Othersp6Licensing RequirementsRestrictions on EmploymentGifts, Gratuities and Improper Incentivesp6Improper Paymentsp6Gifts, Entertainment, and MealsProtection of State Farm's Informationp7Confidential and Proprietary Matterp7Electronic Information Resources and Data Securityp8Telephonic Systems Usagep8Physical Propertyp8Responsible Financial Managementp8Information RetentionWork Environmentp8Equal Employment Opportunityp9Drugs and Alcoholp9Workplace Safety and SecurityEnvironmental ProtectionConflicts of InterestClaim Litigation CounselAcknowledgement and DisclosureState Farm Code of Conduct 2017p. 2

In 1922, George Mecherle said, “Honesty isn't the best policy – it is the only policy.” This is as true todayas it was when State Farm was founded. Although State Farm and the insurance and financial servicesindustries have changed through the years, State Farm's commitment to maintaining high standards ofintegrity remains the same. We all have a responsibility to exercise good judgment, honesty andintegrity when performing our jobs.While the Code of Conduct cannot address every circumstance, it summarizes into one document manyexisting Company policies, rules and guidelines pertaining to business behavior. The Code provides youwith a common frame of reference and assists you in making the right choices. The Code underscoresour commitment to exercise sound business ethics for the benefit of our customers, fellow employeesand associates, the Company and the public.The policies, rules and guidelines referenced in the Code are easy to understand and many will alreadybe familiar to you. This Code is intended to guide employees on ethical and legal standards of businessconduct. The Code does not attempt to cover every situation. Specific policies can be found in otherState Farm resources which complement this Code. You should become familiar with the Code as well asall referenced policies, rules and guidelines because you are expected to adhere to them. Failure toadhere to them will result in disciplinary action as appropriate. Should you like to review the referencedpolicies, rules or guidelines in detail, they are available online or through Human Resources or yoursupervisor.Instances may occur when you know or suspect improper conduct or a breakdown of security orbusiness controls. In those cases, you have an obligation to talk to your supervisor, or another memberof management, a Human Resources Department representative or use the Open Door Policy. If you feelyou cannot use these avenues for whatever reason, you should call the Compliance & Ethics Hotline. Thetoll-free number is 1-800-355-2633. The Compliance & Ethics Hotline is intended to provide another wayof reporting in good faith, any known or suspected violations of the Code or Company policies, as well asany ethical and legal concerns. All reported concerns will be investigated promptly. Employees areexpected to cooperate fully with any investigative efforts.Calls to the Compliance & Ethics Hotline are answered by an independent company that specializes inthese services. The calls are summarized and then referred to Enterprise Compliance and Ethics, orothers as appropriate for investigation. Calls to the Compliance & Ethics Hotline will be kept confidentialto the extent possible.These standards will help continue State Farm's reputation for fair dealing and honesty.State Farm Code of Conduct 2017p. 3

NON-RETALIATIONState Farm will not tolerate retaliation against anyone who reports in good faith any known orsuspected improper conduct or a breakdown of security or business controls, nor will State Farmtolerate retaliation against anyone who participates in an investigation. If you believe you havebeen retaliated against or have witnessed retaliation, you have a responsibility to report it tomanagement or to use the other reporting avenues available to you.ETHICAL AND LEGAL CONDUCTState Farm and its employees must comply with this Code and all laws and policies applicable toState Farm's business. Each of us must be willing to raise ethical and legal concerns. State Farmexpects employees to conduct State Farm's business in an ethical and legal manner and torecognize that in all their transactions and at all times they have a duty of undivided loyalty toState Farm. These obligations demand positive action by all employees to protect the interestsof State Farm, and to avoid situations where their self-interests actually or apparently conflictwith the interests of State Farm.ANTI-MONEY LAUNDERINGEmployees must inform their management if they suspect money laundering or terroristfinancing related to State Farm products.COMPETING AND DEALING FAIRLY WITH OTHERSState Farm employees must treat others fairly and honestly.REPORT BUSINESS INFORMATION ACCURATELY:State Farm and those with whom State Farm does business rely on the accuracy of theinformation that they use to conduct business. Every communication of information to be usedfor business purposes by State Farm or others with whom State Farm conducts business must beaccurate to the best of your knowledge and belief.Responses to media contacts and public discussions on behalf of State Farm should beconducted through authorized spokespersons. Only respond to inquiries on behalf of State Farmif you have authority.State Farm competes by fairly and accurately emphasizing the merits of its products andservices, not by disparaging competitors or their products. Advertising and sales materials mustcomply with State Farm’s guidelines.ACQUIRING AND USING SENSITIVE INFORMATION:State Farm Code of Conduct 2017p. 4

State Farm's or another company's inside (non-public) information must be kept confidentialand may not be used for personal gain.Employees must not use any inside information for their own interest or that of others, orprovide any such information to others, in connection with the purchase or sale of any personalproperty, real estate, or securities that State Farm is actively considering buying or selling or hasdecided to buy or sell, or in connection with any other transaction or activity. These obligationswith respect to non-public information continue after employees leave State Farm.Improper means must not be used to acquire another company's sensitive or proprietaryinformation, including inducing or attempting to induce another company's present or formeremployees or third parties to disclose sensitive or proprietary information to us. An employeemust not reveal to State Farm any sensitive or proprietary information obtained from anothercompany before joining State Farm.PRIVACY:Employees are required to follow proper and secure procedures for the handling and retentionof customer and associate information. Employees must take appropriate measures to ensurethe accuracy of information. Access and distribution of information must be limited to thosewho have a need to know. Sharing information must comply with State Farm procedures andcustomer preference.ANTITRUST:Employees are required to avoid any conduct which violates or which might appear to violatethe antitrust laws. Any communications with competitors, and many communications withsuppliers, are especially subject to antitrust risk. Such communications and all other employeeactivities must be in accordance with antitrust compliance guidelines and advice from theCorporate Law Department.RESPECTING THE INTELLECTUAL PROPERTY RIGHTS OF OTHERS:State Farm employees may not reproduce, display, perform or distribute any materials that areowned by, licensed to, or subject to the copyright of others without first obtaining the owner'swritten permission or an appropriate license. For example, printed materials, photographs,graphics, software programs, diagrams, designs, logos, musical arrangements and any othermaterials, whether found on the Internet in other electronic formats, or in traditional media,that were not produced or developed by State Farm may require permission or license from theowner before they can be reproduced, displayed, performed or distributed. An exception to thisrule may apply for “fair use” situations as advised by the Corporate Law Department.LICENSING REQUIREMENTS:State Farm Code of Conduct 2017p. 5

Employees in positions for which professional, regulatory or government-issued licensure isrequired must keep their licenses current and in good standing. Employees must inform theirmanagement immediately if their licenses are revoked, suspended or otherwise restricted.RESTRICTIONS ON EMPLOYMENTWithout the prior written consent of the applicable regulatory authorities, federal law prohibitsState Farm from employing any person who has been convicted of a criminal offense involvingdishonesty, breach of trust, or money laundering, including offenses involving the illegalmanufacturing, sale, distribution of or trafficking in controlled substances, or who has agreed toenter a pretrial diversion or similar program in connection with the prosecution of such anoffense. Convictions for certain job-related offenses may also disqualify an individual fromemployment.Employees must inform their management or Human Resources if they are convicted of a felonyor agree to enter into a pretrial diversion or similar program in connection with a felony.Employees must also inform their management or Human Resources if they are convicted of amisdemeanor involving dishonesty, breach of trust, money laundering, or the illegalmanufacturing, sale, distribution of or trafficking in controlled substances, or agreed to enterinto a pretrial diversion or similar program in connection with such a misdemeanor.Employment of the above-mentioned individuals can subject the company and the individual tocriminal and civil liability.GIFTS, GRATUITIES AND IMPROPER INCENTIVESSupplies, materials and services must be selected objectively, free from personal biases or selfserving motives.IMPROPER PAYMENTS:State Farm prohibits offering or receiving, directly or indirectly, any bribes, kickbacks or otherpayments to influence business.GIFTS, ENTERTAINMENT AND MEALS:In the course of performing their jobs, employees may be offered gratuities which usually areintended as gestures of goodwill or appreciation. These include gifts, entertainment, meals andbeverages, tickets to sporting or cultural events, services or other similar favors.Employees, members of their families and persons with whom they have a close personalrelationship may not solicit, accept or give, directly or indirectly, gratuities that might influence,or might reasonably be deemed by others to influence their actions or decisions or those of theState Farm Code of Conduct 2017p. 6

recipient. Even nominal gifts can be inappropriate if used in a way which creates the impressionthat a certain vendor is endorsed.Employees may not accept, individually or as part of a group, anything that could reasonably bethought to have more than a nominal intrinsic value (nominal intrinsic value: e.g., promotionalor advertising pens, pencils, notepads, calendars or other similar gifts of limited value) that isbeing offered to employees individually or as part of a group. Gifts or gratuities exceedingnominal intrinsic value should be refused or returned unless the employee's managementapproves of acceptance, disposition or attendance based upon a business need.Transportation, hotel services and expense reimbursement are prohibited in conjunction withattendance at approved vendor-sponsored events unless the employee is a presenter at theprogram or part of a panel, and other participants are treated equally.Acceptance or participation in a business meal situation is appropriate when based on abusiness need and such dining occurs in conjunction with business discussions.These guidelines cannot cover every situation that may arise. Employees' Senior Vice Presidentsor Department Heads may have more restrictive guidelines.Employees are expected to use good judgment and exercise the highest degree of integrity inconducting State Farms business. Employees should discuss with their supervisor any situationthey are uncertain about.PROTECTION OF STATE FARM’S INFORMATIONState Farm employees must protect State Farm’s information from unauthorized or improperuse.CONFIDENTIAL AND PROPRIETARY MATTER:Information is an asset to State Farm. The nature of information ranges from trade secret,confidential, internal use only and privileged information. Each has varying requirements forprotection. Examples include intellectual property, such as patents, copyright and trade secrets,as well as customer lists, business models and marketing plans. Additional examples includeclaim information, contractual obligations and information developed for internal use. It is theexpectation of State Farm that any intellectual property developed while employed at StateFarm, belongs to State Farm.Employees must safeguard State Farm information from unauthorized disclosure or use, andmust not use State Farm information for their benefit or that of others. Employees must returnany information to State Farm when they leave State Farm. The obligation not to disclose or useState Farm information continues after employees leave State Farm.State Farm Code of Conduct 2017p. 7

To protect confidentiality and to preserve applicable legal privileges, the discussion of StateFarm legal matters should be restricted to those with a need to know.ELECTRONIC INFORMATION RESOURCES AND DATA SECURITY:Employees are responsible for preserving the confidentiality, integrity and availability of StateFarm's electronic information resources and data through the application of State Farm'sinformation security policies, standards and guidelines. Electronic information resources anddata must be protected from misuse, loss and unauthorized access and disclosure – regardlessof where the data resides (for example-test, development, or production). State Farm'selectronic information resources are property of the Company to be used primarily for Companypurposes, and not for personal benefit or that of others. Employees are expected to use StateFarm's electronic information resources primarily for State Farm purposes and have a duty notto waste such resources. Personal use must be reasonable and kept to a minimum.Electronic information resources include, but are not limited to: State Farm’s network,computers, workstations, software, hardware, Internet/intranet, modems, electronic messagingsystems (email) and fax machines. State Farm reserves the right to monitor, record, access andreview any information on its resources and systems. This review may include accessingCompany-furnished equipment and supplies.To protect against computer viruses and to comply with intellectual property laws, only StateFarm-issued or approved software may be used on State Farm's computers. Any reproduction ofsoftware and accompanying manuals must comply with intellectual property laws and withformal agreements between State Farm and the software supplier.TELEPHONIC SYSTEMS USAGE:State Farm's telephonic communication systems should be used primarily for business- relatedpurposes. Telephonic communication systems include but are not limited to: voice mail,telephones and cellular phones. State Farm reserves the right to monitor, record, access andreview any information on its resources and systems.This review may include accessing Company-furnished equipment and supplies.PHYSICAL PROPERTY:State Farm's physical property such as vehicles, supplies and office facilities must be protectedfrom loss, misuse or damage. The use and reproduction of articles, books and video recordingsmust be consistent with intellectual property laws.RESPONSIBLE FINANCIAL MANAGEMENT:State Farm Code of Conduct 2017p. 8

Employees must be cost-conscious when spending State Farm's funds and when incurringbusiness expenses. Business travel must be conducted and other reimbursable businessexpenses must be incurred consistent with applicable State Farm policy.INFORMATION RETENTION:Employees are responsible for managing State Farm information, whether paper or electronic,in accordance with information retention policies, procedures and guidelines.WORK ENVIRONMENTState Farm is committed to providing a safe, healthy, inclusive and productive workenvironment that values diversity.EQUAL EMPLOYMENT OPPORTUNITY:State Farm will not practice, tolerate nor condone discrimination by or against State Farmemployees on the basis of age, race, color, religion, sex, national origin, sexual orientation,gender identity, disability, genetic information, or any other basis prohibited by law. Nor willState Farm tolerate sexual or any other form of harassment which interferes with workperformance or creates a hostile or offensive work environment.DRUGS AND ALCOHOL:State Farm prohibits the sale, use or possession of illegal drugs and other unauthorizedcontrolled substances, including the unauthorized use of prescription drugs while on or usingCompany property or while on Company business. State Farm also prohibits the sale or use ofalcoholic beverages while on or using Company property. Employees may not report to work,remain at work or operate Company-provided vehicles while under the influence of alcohol ordrugs not medically authorized.WORKPLACE SAFETY AND SECURITY:State Farm employees must comply with all federal, state and local safety and health laws andregulations, including occupational health and safety standards.Threats and violent or intimidating behavior will not be tolerated. Employees must comply withState Farm's internal security policies and procedures.Except as allowed by law, employees are prohibited from carrying firearms or weapons while onor using State Farm's property or while on Company business.State Farm Code of Conduct 2017p. 9

ENVIRONMENTAL PROTECTIONState Farm will comply with all federal, state and local environmental protection laws, includinglaws pertaining to the transportation, storage and disposal of solid waste and hazardousmaterials and substances.CONFLICTS OF INTERESTEmployees must affirmatively protect the interests of State Farm and avoid conflicts of interestwith State Farm, both in appearance and in fact, and must not use their positions or knowledgeof State Farm's decisions or considerations in any manner that conflicts with or otherwiseprejudices State Farm's interests.Unless advance written approval is obtained from the appropriate Senior Vice President orDepartment Head, employees must not directly or indirectly have any position with orsubstantial interest in any business or property, or engage in any employment or other activity,which takes time and attention away from the performance of their job duties, conflicts orcompetes, or might reasonably be supposed to conflict or compete with State Farm's interests,or affects their independent judgment to act in State Farm's interests.State Farm's personnel decisions, as well as the selection of providers of goods and services,must not be influenced by personal interests. Unless advance written approval is obtained fromthe appropriate Senior Vice President or Department Head, or from appropriate leadership forsenior Leadership Level employees, persons with whom you have a close personal relationshipshould not be subject to your scope of supervision or influence in the terms, conditions orchanges in status in their employment. The same approval process applies to the selection ofproviders of goods and services.CLAIM LITIGATION COUNSELState Farm recognizes that those employees holding positions as Claim Litigation Counsel owean ethical duty of undivided loyalty to their individual clients. If the good faith discharge of theseduties and responsibilities by Claim Litigation Counsel conflicts with their duty of undividedloyalty to State Farm as an employee, the duty to their individual clients is preeminent.ACKNOWLEDGEMENT AND DISCLOSUREThe completion of your Code of Conduct Acknowledgement and Disclosure form requires you toprovide information in two sections. Section 1 requests information about convictions forcertain offenses or agreements to enter into pretrial diversion or similar programs in connectionwith such offenses. Section 2 requests information about other potential conflicts with theCode. You must complete both Sections of the Acknowledgement & Disclosure form.State Farm Code of Conduct 2017p. 10

State Farm Code of Conduct 2017 p. 6 Employees in positions for which professional, regulatory or government-issued licensure is required must keep their licenses current and in good standing. Employees must inform their management immediately if their licenses are revoked, suspended or otherwise restricted. .