AMERICAN FAMILY
CODE OF CONDUCT
& BUSINESS ETHICS
American Family Mutual Insurance Company and its Subsidiaries
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EthicsLine 1-877-772-6326
EthicsLine 1-877-772-6326
A MESSAGE FROM JACK SALZWEDEL
Dear Colleague:
Our vision is to be the most trusted and valued customer-driven insurance
company. Acting in the highest ethical manner is one of the critical steps in
achieving that vision, and reflects our brand promise to inspire, protect and
restore dreams. For more than 85 years, we have demonstrated an unwavering
commitment to performance with integrity and have built a reputation for
maintaining the highest ethical standards. As we expand our enterprise to
include new affiliates, new lines of business and new territories, we will continue
to work diligently to uphold both our high expectations for ethical conduct and
our excellent reputation.
Jack C. Salzwedel
If you ever encounter an ethical dilemma in your role at American Family, you
may be momentarily surprised. But it can happen. There are times when ethical
dilemmas can arise. At those moments, you should step back to decide whether a decision or action is
right – right for our company, customers, colleagues and communities – and consistent with our ethical
standards. If you face such a moment, it’s important that you do the right thing.
The Code of Conduct & Business Ethics is your guide to appropriate conduct and will help you in your
day-to-day responsibilities. The Code provides explanations of ethical requirements and sets forth the behavior expected of all of us. It further provides real life scenarios and values to assist in guiding our behavior. The Code will help to guide us and provide examples to ensure that we act with integrity and earn the
trust placed in us. While the Code cannot set forth every issue you might face, it does contain a summary
of shared expectations and references a number of company resources. It is extremely important that you
read and understand the Code and keep it handy as a reference.
Our company’s leaders are responsible for our actions and to build a culture in which compliance with the
Code and other company policies is at the core of our business activities.
We are proud of our long legacy of operating with integrity, honesty and professionalism. With your help,
American Family will continue to do the right thing and our reputation for integrity will endure. Thank you for
your personal commitment to good ethical behavior.
Jack C. Salzwedel
Chairman and Chief Executive Officer
EthicsLine 1-877-772-6326
INTRODUCTION
contingent workers, interns, and suppliers while
performing services on the company’s behalf. A
similar Code exists for agents and their staffs.
The American Family Code of Conduct & Business
Ethics helps us carry out our daily business activities within appropriate ethical and legal standards.
The Code also includes references to company
policies, laws and regulations that help us make
sound workplace decisions. It is important to stay
current with company policies as they may change
periodically.
The Code will be maintained online in the Company Policies section of the Compass home page,
on the Compliance Department intranet site, and
on People Place. Paper copies of the Code can
be obtained from the Warehouse and Distribution
Center.
The Code applies to all American Family officers
and employees. The Code also applies to
TABLE OF CONTENTS
Integrity: The Code’s Foundation..................... 4
The Basic Blueprint...................................... 4
Issues Beyond the Code.............................. 5
Reporting Violations ..................................... 5
Investigations................................................ 6
No Retaliation............................................... 6
Business Practices.......................................... 6
Recordkeeping............................................. 6
Use of Company Electronic Resources......... 7
Confidential Company Information................ 8
Confidential Customer Information................ 8
Confidential Employee Information................ 9
An Ethical Working Environment.................... 10
Inclusion and Diversity................................ 10
Discrimination and Harassment.................. 10
Workplace Safety....................................... 10
Disclosure of a Felony Conviction............... 11
Other Corporate Policies, Social Media &
Standards of Conduct................................ 11
Outside Interests........................................... 13
Conflict of Interest....................................... 13
Gifts, Meals and Entertainment................... 14
Political Activities and Contributions............ 16
Other Laws and Regulations.......................... 17
Insider Trading............................................ 17
Anti-Trust.................................................... 17
Terrorism and Money Laundering................ 18
Federal/State Laws and Regulations........... 18
American Family Resources........................... 19
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EthicsLine 1-877-772-6326
INTEGRITY: THE CODE’S FOUNDATION
If you’ve ever built a house or any other permanent
structure, you know the importance of starting with
a solid foundation. American Family’s Code of Conduct & Business Ethics is no different; our Code’s
foundation is integrity, which consists of honesty
and truthfulness. Integrity is important in every
decision, every action, every day.
Integrity is expected and required at every level of
the organization – in all dealings with employees,
agents and their staffs, contingent workers,
contractors, temporary workers, interns, suppliers,
and customers; in the accuracy of our advertising;
in the recording of our business transactions; and in
the quality of our products and performance of
our service.
Our Vision: To be the most trusted and valued
customer-driven insurance company.
American Family’s business is conducted following
both the law and the highest ethical standards.
Integrity starts with the example set by management and the character and good judgment of
every individual. Violations of all aspects of this
Code may result in disciplinary action up to and
including termination.
color, sexual orientation, gender identity/expression, national origin/ancestry, age, disability,
marital status, political affiliation, disabled veteran
status or other protected status.
• Promptly report any improper discriminatory behavior, sexual harassment, illegal activities or other
violations of this Code.
• Exercise independent judgment free from any
improper outside influence.
• Maintain the confidentiality of company and
customer information.
• Comply with all applicable federal, state and local
laws and regulations.
• Complete all mandatory training.
• Follow this Code’s standards.
The Basic Blueprint
American Family’s commitment to the highest level
of ethics is demonstrated by our mission statement
and values.
Ethical, compliant behavior should never be
compromised in the pursuit of business objectives.
You are expected to:
• Conduct yourself in a highly ethical manner.
• Perform your duties with honesty and integrity.
• Treat others with respect without regard to race,
creed, religion, physical appearance, gender,
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Reporting Violations
Company leaders and managers are expected to
follow all of the above requirements and set an example of good ethical behavior for all individuals. Company leaders and managers are also expected to:
American Family expects that we all operate with
the highest degree of ethics and integrity. Violations
of American Family’s Code of Conduct & Business
Ethics, any states or federal laws and regulations,
and other suspected ethical misconduct should be
reported to management, your divisional Compliance
Liaison, Corporate Compliance, Human Resources or
Corporate Legal. Reports may also be made confidentially to the EthicsLine. This resource is available:
• 24 hours a day, seven days a week;
• Via telephone at 1-877-77AMFAM (1-877-772-6326);
• Via an online submission form which can be found
on the Compliance Department’s website
(https://www.compliance-helpline.com/welcomeAmFam.jsp)
• Provide information all individuals need to remain
compliant with company policies, laws and regulations.
• Create a culture within American Family which
promotes the highest standards of ethics and
compliance.
• Take appropriate action when a violation of this
Code is brought to their attention.
• Support and enforce company policies concerning retaliation, harassment and other abuse.
Issues Beyond the Code
The Code cannot possibly cover all circumstances
you may encounter in your role with the company. If
you are faced with a situation not addressed by the
Code, consider the following questions and seek
help from others:
• Do I have all the facts?
• Am I confident that I have reviewed all applicable
policies and other available resources?
• Should I discuss the situation with my manager,
Corporate Compliance, Human Resources,
Corporate Legal or divisional Compliance Liaison,
before acting?
• Would I feel comfortable reading about my actions
in the newspaper?
Q
A
: What is the EthicsLine?
: The EthicsLine is a simple, risk-free way to report
any work-related incidents that may cause or
contribute to losses or problems. The EthicsLine is also
a source for seeking guidance on work-related incidents.
It’s a confidential resource to help you keep our workplace a safe, secure and ethical environment.
Q
: I’m concerned about reporting someone’s misconduct. What if I am wrong and it gets me in
trouble or I hurt their reputation?
A
: Action is not taken against individuals who make
reports in good faith even if the report turns out
to be false. Persons handling investigations are careful when looking into alleged wrongdoing to ensure that
individuals’ reputations are protected. Investigations are
conducted in an objective, fair and confidential way.
If you are still unsure what to do, seek guidance
from your manager.
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EthicsLine 1-877-772-6326
You may make your report anonymously or provide
your name if you wish. The purpose of any questions asked of you when calling the EthicsLine, is
to gather enough information to enable a full and
fair investigation. This information is gathered by
a trained communications specialist not affiliated
with American Family, and forwarded to Corporate
Compliance for initial handling.
Q
: I have files in my desk drawer from a project I
completed a few years ago. I plan on throwing the
outdated files in the recycle bin when I have some
free time.
A
: Before you throw out your records, it’s important to
review your division’s record retention schedule to
make sure you are discarding your records in an appropriate timeframe. Also make sure that the records are
not subject to any pending litigation holds. Make sure
confidential records ready for disposal (as shown on your
record retention schedule) are shredded or placed in
confidential recycling containers. You can obtain a copy
of your record retention schedule from your manager or
your divisional Compliance liaison.
Investigations
All employees are required to fully cooperate with
investigations conducted by authorized areas of the
company, such as Corporate Compliance, Human
Resources, Corporate Legal, Internal Audit or the
Special Investigations Unit.
EthicsLine. By raising concerns, you help to protect
yourself, coworkers and the company.
This cooperation extends to emails and other records pertaining to the investigation which should
be retained by individuals until the investigation
has been concluded and should be made available
upon request. Information about an investigation
should not be shared with anyone, especially the
subject of the investigation.
BUSINESS PRACTICES
Recordkeeping
American Family does not tolerate retaliation
against anyone who in good faith reports a suspected or violation of state law, insurance regulation
or this Code.
Business transactions must be recorded in a timely
manner, and reported accurately in the company’s
books and records. These transactions include
virtually all activities pertaining to the business of
insurance, such as applications taken, policies
issued, premium paid, claims incurred, paid, etc.,
and must be kept in accordance with your division’s
Records Retention and Destruction Policy.
The company treats claims of retaliation seriously,
and will take all necessary steps to investigate and
address allegations of retaliation. If you suspect
that you or someone you know has been retaliated
against for raising an ethics or compliance issue,
you can immediately contact Corporate Compliance, Human Resources, Corporate Legal or the
By following your division’s Records Retention and
Destruction Policy, you retain only business records
that are required, and properly dispose of records
and copies that no longer meet any compliance
or business requirements (and are not subject to
pending legal litigation hold requirements), including
drafts of documents that have become finalized.
No Retaliation
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Further information on recordkeeping can be found
in American Family’s Records Retention and Destruction Policy, which is located on the Compass
homepage under Company Policies. The policy
can also be found on the Compliance Department’s
site. Specific record retention schedules have been
developed for each business area, including a definition of what is considered to be a record.
• gambling sites
• auction sites (including eBay, unless you have a
business reason to do so)
Personal use of company electronic resources is
allowed, but limited to incidental use, and should not
interfere with your productivity or work performance.
For rules related to corporate liable cell phones and
other corporate liable devices, refer to the Corporate Cellular Device Policy found on the Sourcing
and Procurement intranet site. Do not use company
electronic resources to conduct personal business.
Further, do not use company electronic resources to
access or make changes to your personal information, such as billing records, underwriting information, and claim files, via any channel not available to
our customers. Equipment not issued by the company must not be connected to company electronic
resources without approved security controls.
Use of Company Electronic Resources
You should apply common sense and good
judgment when using company electronic resources. The term ”company electronic resources”
includes, but is not limited to, American Family
information systems, applications and programs,
computer equipment (laptop, tablet or smart
phone), cell phones, company-owned voice mail
systems, and the company’s network. This policy
applies to any access of company electronic resources.
Do not store, install or use unauthorized software
on company electronic resources. Illegal and/or
unauthorized downloading, uploading, copying or
distribution of copyrighted or trademarked materials
using company electronic resources is not allowed.
Your use of company electronic resources may be
monitored. Accessing, distributing or storing inappropriate information on company electronic resources is
not allowed.
The term “inappropriate information” refers to any
text, images, audio, video or other material that
could be considered discriminatory, harassing or
offensive. Examples of inappropriate information
include, but are not limited to:
• pornography or sexually explicit material
• racist material
• violent material
• electronic chain letters
• e-mail hoaxes
Q
: I’ve started my own business and do a lot of my
business over the Internet. I’ve been using my
American Family computer to access my personal
e-mail account and to update the website for my
personal business, but only on my lunch break and
after work. Is this OK?
A
: This is not OK. Using company electronic resources
for outside business interests is not acceptable.
You should review the Use of Company Electronic
Resources section as well as the American Family
Information Security Policy to better understand your
responsibilities with company electronic resources.
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EthicsLine 1-877-772-6326
Q
: A good friend experienced an insurance loss
with us. I do not work in Claims but he wants me
to see if I can find out anything about his claim from
company computer records and let him know if he’s
getting a fair deal. I know we’re supposed to focus
on good customer service but is it all right for me to
do this?
A
: No it is not all right. You should not review nor disclose information from his claim file. While the
customer’s interests are important, company policy states
only authorized individuals who need to know customer
information may access and use it. Customer information
may not be accessed or used for personal reasons.
It is important that you understand and follow
American Family’s Information Security Policy.
American Family’s Information Security Policy provides guidance for protecting company information.
The policy is located on the Compass homepage
under Company Policies.
Confidential Customer Information
State and federal privacy laws and American
Family’s privacy policy require all of us to protect
the security and confidentiality of customers’ personal information. This includes information such
as name, address, policy and account information,
medical information and status as an American
Family customer.
Confidential Information
American Family defines confidential information as
any non public information pertaining to the business of company or its affiliates (“company”). Non
public information is defined as information that is
not readily accessible by those without a need to
know, and if disclosed, may be prejudicial to the
company, its employees, its business partners,
and/or its customers. Examples include but are not
limited to customer, supplier, financial, pricing or
personnel data; merger and acquisition, product or
marketing plans; new product designs, proprietary
processes and systems and trade secrets.
Only authorized individuals who need to know a
customer’s personal information may access and
use it. Customer information may not be accessed
or used for personal purposes. Customer information may not be disclosed outside American Family for any purpose other than the underwriting or
administration of a customer’s policy or account,
unless the disclosure has been properly authorized
by the customer or is permitted or required by law.
Confidential Company Information
All individuals must be careful to maintain the confidentiality of company information and information
concerning customers, employees, agents and their
staff, contingent workers, contractors, temporary
workers, interns, suppliers, and other individuals
and entities in our business dealings.
In addition to understanding American Family’s
Information Security Policy, individuals must take
all mandatory privacy and security training including but not limited to Gramm-Leach-Bliley (GLB),
Protecting Customer Information, Health Insurance
Portability Accountability Act (HIPAA).
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Confidential Employee Information
• All requests for employment verification for
current or former employees, including requests
for personal and character references, must be
forwarded to Ask HR. The full Employment Verification Policy is located on People Place under
AmFam Policies.
American Family abides by the following principles
with regard to employee privacy rights:
• The company requests and retains only information that is required for business or legal purposes.
• The company protects the confidentiality of all
personal information in Human Resources records
and files.
• You have the right to correct inaccuracies or disagree in writing regarding your personal information located in company records.
• Access to personal information will be strictly limited
to individuals with a clear business “need to know.”
• American Family refuses to release information
to outside sources without an employee’s written
approval unless authorized or required by law.
Employee information will be released based on
subpoena or other court order.
Q
: I received a call from an individual working in
human resources for another company. She is
working on a research project for her company and
asked for my staffs’ hire dates, titles and base salaries. What should I do?
A
: Information about our workers is confidential and
should only be given to those who are authorized to
have the information. You should not provide the information to the individual. Instead, refer her to our Human
Resources Division.
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EthicsLine 1-877-772-6326
AN ETHICAL WORKING ENVIRONMENT
Inclusion and Diversity
dignity and respect. It is not acceptable to discriminate or harass others on the basis of race, creed,
physical appearance, gender, color, sexual orientation, gender identity/expression, national origin/
ancestry, age, disability, marital status, political
affiliation, religion, disabled veteran status or other
protected status.
American Family is dedicated to promoting a culture
that is welcoming, diverse and inclusive. The company strives to build the most talented workforce
possible that mirrors the communities we serve.
Our commitment to inclusion and diversity
positively affects our company. It helps create a
desirable working environment for individuals and
enhances our ability to be productive and serve
customers from all walks of life.
If you believe you have been discriminated against
or harassed, or if you witness these types of behaviors, promptly report the incident to your manager
or Ask HR at extension 33123. Managers must immediately communicate reports of discrimination or
harassment to Human Resources.
All employees are required to complete the following educational courses within one year of their
employment date: Respect in the Workplace and
Charting Your Course. If you have not completed
these courses, please go to the Learning Connection to enroll in the next available class.
American Family will conduct an impartial investigation of all reported incidents. If it is determined that
discrimination or harassment has occurred, the company will take immediate and appropriate action.
Discrimination and Harassment
If you feel a complaint was not resolved through
the company complaint procedure, a formal complaint can be filed with the appropriate city or state
agency or the Federal Equal Employment Opportunities Commission.
American Family provides equal employment
opportunities for all persons and has a strong belief
that all employees, agents, agents’ staff, contingent
workers, contractors, temporary workers, interns,
suppliers, and customers should be treated with
It is prohibited to retaliate against individuals who file
equal employment opportunity (EEO) complaints.
Q
: Some of my coworkers tell disgraceful off-color
jokes while sitting at their desks. Their conversations are loud enough for everyone to hear. Why
does the company allow this?
Workplace Safety
You must follow all federal, state and local
laws or policies related to health, safety, security
and the environment. The Protection and Safety
Department provides information about environmental, safety, and security policies and procedures
on its intranet site. The goal is to reduce accidents
and minimize the impact on individuals and the
A
: The company does not allow this conduct. This is
unacceptable behavior. What is kidding to some
may be offensive to others. This behavior could create an
unacceptable environment. Individuals should not take the
chance of insulting coworkers with comments or gestures
that may be unwelcome. Situations should be reported to
your manager, Human Resources, the EthicsLine or the
Compliance Department.
EthicsLine 1-877-772-6326
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Disclosure of a Felony Conviction
company. Ultimately, it is everyone’s responsibility to
maintain a safe work environment. Report all health,
safety and building security incidents to Protection
and Safety by either calling extension 31444 or going
to the Protection and Safety Department intranet site
found on the Compass home page under Company
Policies.
American Family has strong guidelines in place
about employing or contracting with individuals engaged in the business of insurance who have been
convicted of a felony involving a breach of trust
or dishonesty. You must immediately inform your
manager or Human Resources if you have any past
or current felony convictions.
All employees are expected to complete several mandatory safety/security courses, including
Workplace Violence Crisis Response Training, found
on The Learning Connection. Certain groups of
employees are also required to take specific safety
courses based on their job family or role. Managers,
for example, are required to complete the Manager
Workplace Violence Prevention Awareness Training,
also found on The Learning Connection. More information related to required employee safety/security
courses can be found in the Education Division intranet
site under Planning Your Education and then Required/
Mandated Training.
Violation of this law can subject the company and
the individual to criminal and/or civil liability.
Other Corporate Policies
Social Media
American Family believes in the importance of using
social media as a business medium to collaborate,
discuss issues and network with others. We support the responsible use of this technology and
expect our employees to use sound judgment and
common sense, and follow the established guidelines when accessing or participating in social media.
You are expected to:
• Understand and follow our Code of Conduct &
Business Ethics
• Adhere to our information security policies
• Respect American Family’s proprietary and confidential information, and not disclose such information
• Refrain from posting copyrighted material
• Clearly identify yourself as an American Family
employee if you comment or blog externally about
any aspect of our company, and include a disclaimer that the views you present are your own
and not those of American Family
• Recognize that we have individuals officially designated by American Family to speak on behalf of
the company, so do not communicate with
If you have been subjected to an act of violence while at
work or as a result of your employment, or if you observe
an act of violence against another individual, you should
promptly notify management, Human Resources or Protection and Safety (extension 31444). Violent situations
that present immediate danger should be reported to
911 and local security in offices where available.
Some examples of violent acts include: yelling, shoving,
biting, striking, scratching or kicking another person;
making threatening remarks or gestures, following or
stalking; threatening behavior that is intended to cause
fear or emotional distress; intentional damage to company or personal property; possession of a weapon on
company property; and behavior motivated by harassment, hate or domestic violence.
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• harassment or creating a hostile work environment
• disorderly conduct
• inappropriate voice or written communications
• insubordination
• intentionally wasting or destroying company property
• leaving the job without permission
• misrepresenting information on the job application; falsifying company records; lying about work
or conduct
• possession of firearms or other weapons in the
company’s buildings or pool cars
• reporting to work under the influence of drugs
or alcohol; or the possession or the use of illegal
drugs or alcohol on company property
• sleeping on the job
• theft or fraud
• unauthorized taping or recording of meetings,
conversations and company communications
ustomers, claimants, employees, agents and the
c
media as a representative of the company
• Treat others with respect; personal attacks, profanity, and abusive or offensive comments are not
acceptable
Employees who violate this Social Media Policy
may be subject to disciplinary action through our
Performance Improvement Process up to and
including termination of employment. If you witness
a violation or have a concern, please contact your
manager, HR, Corporate Compliance or the EthicsLine. The complete policy is located in the AmFam
Policies section of People Place (People Place/AmFam Policies/AmFam Policies Home/Social Media).
Personal use of company-owned or company-provided electronic resources or devices are allowed
but limited to incidental use and should not interfere
with your productivity or work performance.
If you witness a violation or have a concern, please
contact your manager, HR, Corporate Compliance
or the EthicsLine. The complete policy is located in
the AmFam Policies section of People Place (People Place/AmFam Policies/Standards of Conduct).
Standards of Conduct
Common sense will be your best guide to determining appropriate behavior on the job. However,
there are specific actions that are viewed as unacceptable. While the list is not all-inclusive, any of the
following acts could result in disciplinary action or
immediate termination of employment:
This Code provides an overview of ethical and
legal standards. In addition to the Social Media &
Standards of Conduct policies, detailed information about company policies is located in AmFam
Policies section of People Place. All employees are
required to review and understand these policies.
• damaging the company’s business reputation
• disregarding company rules and policies
• gambling on company property
• habitual carelessness or violating safety regulations
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Q
: My father owns a body repair shop and wants
to provide his services to American Family. Is
he allowed to approach American Family to pitch
his company?
A
: Your father may approach American Family to
pitch his company as long as you have no involvement in the selection process. His company will
need to go through the normal selection process and
meet American Family’s criteria. If your father’s company is chosen to provide services to American Family,
you should not be involved with any of his work unless
it is first disclosed to the company’s chief legal officer.
You should always disclose these types of situations to
your manager.
OUTSIDE INTERESTS
Conflict of Interest
You must exercise good judgment, independent
from any outside influence, avoiding activities and personal interests that create a potential conflict between
your interests and the interests of the company.
Q
: A supplier has asked me for a statement
describing our great experience with a
product. Can I provide this?
You should not receive any improper benefit from
your position with the company, nor should your
relatives. Conflicts may arise from a variety of situations, including ownership interests in other businesses, outside employment, contracting with relatives, and acceptance of gifts. The following rules
apply to potential conflict situations.
A
: No. This is a form of endorsement that helps the
supplier market their product.
• Reveal or use non-public customer or company
information to further personal interests.
• Have any position outside American Family, take
part in any activities or hold personal investments
which might conflict with the company’s best interest. You should not have outside board, officer
and/or employee positions, or take part in outside
activities which may make you unable to place the
company business interests first. You should avoid
personal investments in other companies which
conflict with, or compete with company operations.
• Have outside interests which influence your ability to perform your work. Outside work interests
should not compete with company operations.
• Provide or agree to provide a testimonial, endorsement or letter of recommendation relative
to supplier products or services utilized by the
company. For further information, refer to the
company’s Endorsement Policy (go to the Communications site on Compass, and then Media
Policies & Tips).
• Contract for the purchase of goods or services
for the company unless the contract terms are in
the best interest of the company. You may not
personally benefit from any involvement you have
The term “relative” used in this section includes
a spouse, parent or step-parent, child or stepchild,
sibling or step-sibling, grandparent or step-grandparent, grandchild or step-grandchild, uncle or
aunt, nephew or niece, in-law, domestic partner, or
legal guardian.
You may not:
• Receive any kind of payment, other than your
normal salary, company-issued bonus or gift card,
on any company business transaction. (An exception to this guideline may be made under the next
bullet point.)
• Participate in non-insurance business with American Family without notifying our chief legal officer
before the activity takes place. Business activity is
to be done on behalf of the company by someone
who has no interest in the activity.
• Participate in or influence American Family business transactions involving a relative. This is not
intended to prevent the company from transacting
business with an employee’s relative as long as the
transaction is handled by a disinterested third party.
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in the contracting process. Competitive bidding
should be used whenever possible.
• Solicit from our suppliers for charitable contributions on behalf of American Family.
where your personal interests or feelings may conflict
with American Family’s best interests.
Gifts
During the course of a calendar year, you may not
accept gifts having a total value of more than $50
from any one third party. “Gifts” includes anything of
value, whether goods or services, including prizes
from drawings and raffles. “Gifts” also include meals
or tickets to events where the third party does not attend with you. It is never acceptable to receive cash
or cash equivalent (such as a prepaid debit card or
gift cards) from a third party.
Inform your management if you face a situation
involving a potential or actual conflict of interest.
A manager who is unable to determine whether a
conflict exists should consult with Corporate Compliance. Matters that cannot be resolved by Corporate
Compliance will be reviewed by the chief legal officer.
You may also report your potential conflict
directly to Corporate Compliance or the EthicsLine.
The EthicsLine can be reached at 1-877-77AMFAM
(1-877-772-6326) or through an online submission
feature, which you can find on the Compliance
Department’s website.
If you receive a gift or gifts in excess of the $50 limit,
notify your manager and politely return the gift(s) with
an explanation of American Family’s policy. Gifts valued
above $50 may be accepted if declining the gift would
cause undue embarrassment by violating local custom
or tradition, if the gift is perishable and impractical to return, or if the gift is intended to be a donation to a nonprofit charitable organization. Gifts valued in excess of
$50 which are accepted as charitable donations must
be reported on the annual conflict of interest disclosure
form. Perishable gifts not donated to charity may be
shared with all persons in your department.
If a conflict of interest is found to exist, the company
may ask you to end the activity causing the conflict
and/or take the appropriate action regarding your
employment. If the conflict of interest is a blatant disregard of this Code, or damaging to the company’s
interest or reputation or the interests of policyholders,
it will be grounds for immediate termination. All employees are required to annually complete a conflict
of interest disclosure statement. Corporate Compliance reviews the disclosure statements and follows
up with managers when necessary.
Meals and Entertainment
“Meals” include both food and beverages.
“Entertainment” includes but is not limited to sporting
events, cultural events, concerts, golf outings, conferences, and seminars.You may accept a meal or
entertainment from a third party, so long as the cost
is reasonable, there is a legitimate business purpose,
and the third party accompanies you. If the thirdparty is not present, the item is a gift and you should
refer to the gift section of the code to determine if
accepting the meal or entertainment is appropriate.
Gifts, Meals and Entertainment
In the course of performing your job, you may be offered gifts, meals, and entertainment from third parties (potential or existing suppliers, service providers,
customers, claimants and agents) who have or hope
to have business dealings with American Family.
Accepting these items can cause conflicts of interest
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The term “reasonable” can vary depending on the circumstances and the level and/or corporate position of
the persons involved. Legitimate business purposes
include activities done to demonstrate a company’s
product or service, establish or strengthen valuable
business relationships, and enhance professional development. Accepting a meal or entertainment must
always have a legitimate business purpose. Whenever
possible, obtain your manager’s approval before accepting a meal or entertainment from a third party and
discuss what is reasonable under the circumstances.
If questions arise about whether to accept a meal or
entertainment, consider whether an option is to have
American Family pay for the expense.
ing a legitimate business purpose. You are required
to obtain your manager’s approval before attending
and American Family should pay all associated expenses including transportation, meals and lodging.
• These rules do not apply to gifts, meals, or entertainment that a trade association offers for services
you provide to the association, so long as the
cost is reasonable. For instance, it is acceptable
to receive reasonable meals, lodging, and travel
expenses in exchange for serving as an association
board or committee member or for speaking at an
association conference.
• It is never appropriate to solicit gifts, meals, or
entertainment from a third party. Solicitation includes
entering prize drawings and raffles at conferences,
seminars, and other events.
• You are responsible for using good judgment to
ensure that receipt of a gift, meal, or entertainment
is proper and could not be viewed as an attempt to
receive favorable treatment or obligate you or the
company in any way. To judge whether it is appropriate to accept a gift, meal, or entertainment, ask
yourself whether the item is appropriate and reasonable, and how it would appear to others if you
accepted it.
• Do not accept any gift, meal, or entertainment during contract negotiations if you are in a position to
influence supplier selection or contract negotiations.
You should not accept any gift, meal, or entertainment if it will impact your ability to impartially and
objectively handle future supplier selection or contract negotiations.
• Do not accept personal favors from third parties.
• Make third parties aware of our Code provisions if
they provide gifts, meals, or entertainment. Inform
them that you expect them to respect and abide by
our limitations.
If you have a legitimate business need to participate
in frequent meals or entertainment with a third party,
American Family should pay for the expense whenever possible, rather than the third party. Travel and
lodging expenses associated with meals or entertainment should always be paid by American Family. The
term “frequent” can vary depending on the circumstances, including what is reasonable and customary,
and the level and/or corporate position of the persons
involved.
General Guidelines
The following general guidelines apply to gifts, meals,
and entertainment:
•B
usiness units and managers may establish requirements for their employees that are stricter than
these rules. Communicate any such requirements in
writing to all covered employees.
•T
hese rules also apply to gifts, meals and entertainment received from an American Family agent.
•T
hese rules do not apply to registration fees for
continuing education courses and conferences hav-
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Q
A
: A supplier wants to take me out to a basketball game. Can I accept the invitation?
: If the supplier gives you the tickets, and does not
attend the game with you, the tickets are a gift
and are subject to the $50 limit. If the value of the
tickets is over $50, notify your manager and politely
return the tickets to the supplier with an explanation of
American Family’s policy.
If the supplier accompanies you to the event, this is
entertainment and is subject to a reasonableness
standard. Obtain your manager’s pre-approval, which
includes a discussion about whether there is a legitimate
business purpose in attending the game with the supplier. Always consider whether your attendance at the
event would influence or appear to influence a decision
you make about the supplier. Also, consider whether it
has a business purpose, how it might appear to others, and whether attendance benefits the company. Do
not accept the tickets during contract negotiations with
the supplier if you are in a position to influence supplier
selection or contract negotiations. Disclose all gifts and
entertainment you receive to your manager.
Considerations – Conflicts of Interest and Gifts,
Meals, and Entertainment
In evaluating any conflict of interest question, including the receipt of gifts, meals, or entertainment,
consider the impact on your ability to exercise good
judgment to act in American Family’s best interest. Use questions like these to help you evaluate
potential conflict of interest situations:
• Will your ability to make impartial, unbiased decisions be influenced?
• Will you feel a sense of obligation?
• Is someone hoping to receive something from you
or American Family in return?
If you answer “yes” to any of these questions, consider whether it is appropriate to be involved in the
situation. Other questions to consider in relation to
the receipt of meals and entertainment include:
• Is participation in the event valuable enough to
you and American Family that you would participate even if American Family must pay for it?
If the answer is “yes,” any potential conflict
concerns could be eliminated by having American
Family pay for the expense rather than participating on someone else’s tab. If the answer is “no,”
what does that say about the event?
• What message does it send to others if they learn
that you participated in the event? Would you be
comfortable with that information appearing in a
Compass story?
• For leaders, what kind of “Tone at the Top” will
you set by participating in the event?
Q
: My friend is running for political office and I
would like to help with the campaign. Is this
allowed?
A
: Yes. Your personal political activity is your business. Just make sure that you do not use company resources, including company time, e-mail or
American Family’s name, to advance the campaign.
activities and contribute personal resources to
candidates and political parties. It is not permissible
to use American Family resources to advance your
own personal political activities, and your personal activities should not in any way suggest that American
Family is involved with or supportive of a candidate
or issue. Participation in political activities must not
interfere with your productivity or work performance.
American Family has established political funding
programs (Political Action Committees (PACs) and
Conduits). If you wish, you may make voluntary contributions to these programs, which in turn, make contributions to candidates. The company does not pressure individuals to contribute personal funds, nor will a
decision on whether or how much to contribute factor
into the relationship between you and the company.
Political Activities and Contributions
American Family encourages you to participate in
the democratic process as private citizens by voting
and staying informed on pending public policy issues. You may personally volunteer in political
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16
Q
A
: What are “anti-trust laws” and do they apply to
me?
: Anti-trust laws are designed to promote fair
competition by making certain trust-related practices
illegal. Trusts are similar to monopolies and involve concentrations of economic power in the hands of a few. Trusts
and monopolies lead to anti-competitive practices, which
can then lead to price controls. While there are exceptions
to anti-trust laws that pertain to the business of insurance,
American Family is generally obligated to comply with antitrust laws.
American Family’s Government Affairs Department
is responsible for all lobbying efforts with government
officials on behalf of American Family. The law requires
registration and reporting of activities by employees
who communicate with government officials on behalf
of American Family (or who perform work in support
of the communication of others). If you are involved in
such activities, you must notify the Government Affairs
Department. You should not request reimbursement
for any expenses incurred for lobbying or political
activities on behalf of American Family without first
contacting the Government Affairs Department.
Federal law prohibits providing any item of monetary
value to Members of Congress and their employees.
American Family must biannually certify that it has
complied with this federal gift prohibition. Many of
American Family’s operating states have similar
laws. On behalf of the company, you should not
provide any gifts, entertainment, in-kind contributions (such as your time, office supplies or use of
office space), or travel to any government official
without first discussing it with the Government Affairs Department.
non-public information and (b) the disclosure of such
information to any other person except to the extent
necessary to carry out professional responsibilities.
The definition of material is information that would
be considered relevant to an investor who is considering investing in this stock or to a current shareholder wishing to sell.
OTHER LAWS AND REGULATIONS
Insider trading
Anti-trust
While working at American Family, you may learn
or have access to confidential non-public information about American Family and its business relationships. This includes not only American Family
information, but also information about its suppliers,
alliance partners, and customers. This Code and
federal law prohibit both (a) the buying or selling of
securities while in the possession of material
Federal and state anti-trust laws prohibit agreements and activities that unfairly restrain trade or
reduce competition. Prohibited activities generally
include price fixing, boycotting specific suppliers or
customers, allocating or dividing products, territories or markets and restricting the availability
of products.
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EthicsLine 1-877-772-6326
A number of topics are inappropriate to discuss
with competitors. Anti-trust implications are possible
when attending meetings (including trade association meetings) or participating in discussions with
competitors or representatives of competitors. If
you are in a meeting with competitors where any
of the following topics arise, you should leave the
meeting and report the incident to your manager or
Corporate Legal:
• Pricing information, rating methodologies, underwriting criteria, limits, deductibles and other
features of products or services.
• Allocation or division of products, services, markets or customers.
• Limitations or restrictions on products or services
that may be offered.
• Limitations or restrictions on the ability of competitors to do business with any person, entity or group.
• Marketing plans or strategies.
• Internal or external costs associated with supplier
products or services.
“specially designated nationals” (SDN), Reasons
for being in the OFAC database include links to terrorism, money laundering, drug trafficking, hostile
enemy countries and leaders of blocked countries.
The company is not to do business with people
whose names appear on the SDN list. American
Family has a system in place that automatically
checks customer, supplier, and claimant names
against the SDN list on a daily basis. The system will
automatically notify Corporate Compliance of any
possible match. Corporate Compliance will determine if the individual is an exact match against the
SDN list and will notify you on next steps.
You are required to inform Corporate Compliance
if you suspect money laundering related to American Family products. Money laundering is the act
of converting money gained from an illegal source
into money that appears legitimate so that its illegal
source cannot be traced.
Federal/State Laws and Regulations
Terrorism and Money Laundering
American Family requires compliance with all applicable state and federal laws. In addition to the laws
noted, each state has its own laws which regulate
the insurance and financial products industries.
The Office of Foreign Assets Control (OFAC) of the
U.S. Department of the Treasury administers and
enforces economic and trade sanctions based
on U.S. foreign policy and national security goals
against targeted foreign countries, regimes, terrorists, international drug traffickers, individuals involved in proliferation of weapons of mass destruction, and all other threats to national security, foreign
policy or the U.S. economy.
Q
A
: What is an example of money laundering?
: An individual may purchase a large life insurance
policy with money they received illegally (sale of
drugs, stolen property, etc.). They will pay cash for the
first premium payment. Then, within a few days they
decide to use their rights under the “free look” provision,
and ask for a refund. The cash received from the illegal
activity is now “clean”, in the form of a refund check from
American Family.
In order to comply with OFAC regulations, American
Family is required to check names and businesses
with whom we do business (insureds, claimants,
suppliers, etc,) against government databases of
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18
Q
A
: Who is the Compliance Liaison for my
division?
: Visit the Compliance Department’s website and
click on the Compliance Liaisons in the left side
navigation bar.
Both federal and state laws regulate the sale of securities products. If you are unsure of your legal obligations, contact your manager. You may also seek guidance from Corporate Compliance or Corporate Legal.
American Family Resources
Our company’s Code of Conduct & Business Ethics
requires us to meet challenges with integrity and in
ways that maintain our reputation for honesty and
fair dealing. If you are unsure of what to do, seek
clarification and guidance before you act. If you ever
feel pressured to act in a way that conflicts with the
Code or company policies, talk with your manager,
Human Resources, your division’s Compliance Liaison, Corporate Compliance, or Corporate Legal.
An online training module exists to assist you in
understanding the Code. Employees are required to
complete the module. If you have not already completed this module, you can do so by accessing
the module through The Learning Connection. The
module consists of a series of multiple-choice and
true/false questions reviewing the information found
in the Code. It will take you approximately 10-15
minutes to complete the module.
The Compliance Department’s intranet site has
additional information about this Code, mandatory
training, and other compliance matters. There are
also a number of company resources on Compass
that are available to assist you.
The Code of Conduct & Business Ethics applies to
all individuals associated with American Family –
officers, employees, agents and agents’ staff,
contingent workers, interns, and suppliers. Doing
the right thing requires understanding this Code
and the ethical implications of your choices. It can
sometimes be challenging, but ethical behavior
pays off. Take a stand when you see a problem,
and when in doubt, ask for help. For each of us,
ethics and compliance are calls to action.
Resource Name
Access Information
Corporate Compliance: Your information source for various
compliance policies and programs.
http://compass/govaffairs/compliance
American Family Information Security Policy: All information
about American Family’s Information Security Policy.
http://compass/corporateinformationsecurity/SecurityPolicy
Education: Click on The Learning Connection link to search the
http://education/employee
extensive collection of online/classroom learning opportunities.
EthicsLine: American Family’s 24/7, toll free, confidential compliance hotline.
1-877-77AMFAM (1-877-772-6326) or
http://compass/govaffairs/compliance
People Place: Information about American Family’s
company policies in one location.
https://peopleplace/peopleplace
Protection and Safety: Your resource for safety information.
http://sharepoint/support/safety/SitePages/home.aspx
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GAC-2E
Stock No. 25001 Rev. 3/15