Corporate Policies

Corporate Governance Statement for Allstate Northern Ireland Limited
For the year ended 31st December 2019

The Allstate Northern Ireland Limited Board of Directors (the "Board") is committed to sound corporate governance policies and practices. At Allstate, we want our customers to understand our governance structure; and therefore, we have highlighted key information below.

For the year ending 31st December 2019, under The Companies (Miscellaneous Reporting) Regulations 2018, Allstate Northern Ireland Limited (the "Company") is required to state which corporate governance code, if any, it applied in the financial year and how it was applied. If the Company departed from such a code, it must report the respects in which it did so, and its reasons for so departing. For the year ending 31st December 2019, the Company has applied the Wates Corporate Governance Principles for Large Private Companies (the "Principles"), published by the Financial Reporting Council ("FRC") in December 2018 and available on the FRC's website.

We set out below how the Principles have been applied over the past year. The information in this statement will be reviewed annually.

Principle 1 — Purpose and Leadership

The Company's principal activity is to deliver information technology and business process solutions for its ultimate parent Company in the United States, The Allstate Corporation, and its subsidiaries.

The focus of the Board in 2019 has been the implementation of the Company's Operating Strategy, supported by our corporate goals and underpinned by Allstate's values and leadership principles. The Company's Operating Strategy and corporate goals ensure that the Company's business model provides long-term sustainable value to The Allstate Corporation. As the Company's shareholders are fellow Allstate group companies, the goals of the Company align with our shareholder's goals. Shareholders are represented on the Board.

The Company issued a number of employee surveys throughout the year to gauge employee engagement levels and enable employee feedback to the senior leadership team and the Board. This employee engagement work links directly to our corporate goals. These results are added to operational data such as attrition, absence levels, and exit interview content and forms part of the material examined by the Board at each of its meetings.

In 2019, the results of employee surveys revealed that employees wanted closer insight and connection to the Company's overall strategy. Accordingly, this will be a focus area in 2020 and going forward, with the production of the Company's 2020 — 2023 strategic plan providing a framework for all employees to have visibility into the Company's strategy and plan for the next three years.

Employee consultation is addressed in the Directors' report — see section on "Employee Engagement". Information about relationships with other stakeholders such as business partners, suppliers, community and government can be found in the Strategic Report on pages 4 — 7, in the section "Engaging with stakeholders — s172 statement".

Allstate's Global Code of Business Conduct summarizes core values and principles that guide our business conduct and includes a Code of Ethics. Allstate's Code of Ethics applies to all board members, employees and officers of The Allstate Corporation and its subsidiaries. The Company is committed to operating its business with honesty, integrity, and the highest level of ethical conduct. Upon hire and annually thereafter, all board members, employees and officers of the Company must provide a documented acknowledgement that they have read and understood the Code of Ethics.

Consistent with our Code of Ethics, all directors must avoid conflicts of interest and act in the best interest of the Company. Annually, directors must complete a detailed questionnaire about their individual circumstances.

The Company follows the global Allstate "Speak Up!" program which encourages employees to report any illegal or unethical conduct, regulatory compliance matters, or Human Resource ("HR") concerns through a number of methods including a reporting hotline. The Company takes part in the annual global Allstate Integrity Index survey which measures the ethical strength of the organization.

The Company has a risk and compliance team which is augmented by the risk and compliance and internal audit functions of its ultimate parent Company.

Principle 2 — Board Composition

The Board is currently comprised of six members — the Chair of the Board and Managing Director positions are held by different Board members, and the remaining Board members are individuals chosen from the Allstate group of companies. The Board considers its size and composition appropriate for the size and nature of the Company.

In 2019, Eric Huls joined the Board bringing experience in data analytics as well as business acumen, vision and strategic thinking. Mr. Huls' experience complements the strategic direction of the Company, moving into data analytics, artificial intelligence and machine learning.

The diversity of the Board is positive in terms of gender with two women and four men, and this is aligned with the Company's commitment to diversity and inclusion. Nominees are selected based on their diverse skills and experiences with an intention that each is well-versed in certain core competencies including strategic oversight, corporate governance and leadership. This diversity of experience and expertise facilitates robust and thoughtful decision-making by the Board.

Board members bring specific competencies based on their areas of expertise and roles within the Allstate Corporation. Ongoing professional development occurs within those business roles. In addition, specific training is provided for the Board in relation to Board duties and understanding of the UK Corporate Governance framework and environment. At a minimum, evaluation of board effectiveness and composition occurs when individuals rotate from the Board and new members are sought. This may occur more frequently as circumstances require.

Principle 3 — Director Responsibilities

The primary responsibility of the Board is to oversee the affairs of the Company and to provide counsel and direction to the executive leadership of the Company and monitor Company performance. Its responsibilities include, but are not limited to, oversight of the Company's strategy, business performance and compensation programs.The Board also regularly reviews the Company's significant risk exposures and how those exposures are managed and mitigated.

The Board meets a minimum of three times each year. Notice of a meeting, which includes the agenda and advance review materials, is sent to the Board within a prescribed period prior to the meeting. The Managing Director reviews the content prior to the board meeting to ensure quality and integrity levels. Standing agenda items include review of all key aspects of the Company's business including financial performance, operational matters, stakeholder engagement feedback, risks and opportunities and regulatory matters. Attendance record is maintained for each meeting. The Company is subject to annual external audit and triennial internal audits to ensure that systems and controls are operating effectively. Results or findings are reported to the Board. Allstate legal representatives, the internal compliance team and external legal counsel engage with the Company on legal processes for the Board meetings. This ensures the governance processes are fit for purpose and comply with laws and regulations.

The Board does not have any sub-committees, and it delegates operational leadership to the Managing Director and his leadership team which includes representatives from HR, Finance and senior leadership.

Principle 4 — Opportunity and Risk

The Board seeks out opportunity whilst mitigating risk. Principal risks and uncertainties including in relation to financial risk management are addressed in the Strategic and Directors' reports on pages 4 to 7 and pages 8 to 10 of the Company's annual report (and are denoted as principal risks below).

In addition, the Managing Director considers further risks as part of the day to day management of the business, reporting to the Board as part of the materials provided for each board meeting in the form of the ANI Risk Register:

  • Cash flow (Principal risk)
  • Credit (Principal risk)
  • Liquidity (Principal risk)
  • Appointing and retaining talent
  • Systems, data protection and cybersecurity
  • Brexit

Senior leadership assess the content of the Board materials in advance and include the status of significant risks and opportunities, Senior leaders bring awareness of opportunities for innovation and value-creation in their specific business areas to the management meetings, which flow to the Board based on relevance and significance.

The Company's group uses a principle-based approach to enterprise risk and resource management focusing on measurement, transparency and dialogue. This measures, monitors and reports on the major categories of enterprise risk across the group, including insurance, financial, investment, operational (including reputational) and strategic. These risk-return principles define how the Company and the Board operates and guides decision-making around risk and return. These principles state that our priority is to protect solvency, comply with laws, maintain a supportive political and regulatory environment, act with integrity, and protect information assets and technology. Building upon this foundation, we strive to build strategic value and optimize risk and return.

Principle 5 — Remuneration

The Company's compensation strategy is delegated by the Board to the HR and Finance groups who use external benchmarking programs to assist with this work. It is designed to recognize and reward contribution to successful achievement of the wider group's goals and objectives. The executive compensation program delivers pay in accordance with corporate, business unit and individual performance. The key components of our compensation philosophy are consistency, competitiveness, performance and transparency. An Annual Compensation Report is issued to all employees setting out information regarding the strategy.

Principle 6 — Stakeholder Relationships & Engagement

The Board understands that good governance and effective communication are essential on a day-to-day basis to deliver our purpose, and to protect the Company's brand, reputation and relationships with our various stakeholders including employees, suppliers and the local communities in which we work.

Senior leadership communicates to the Company's employees through Town Hall meetings, presentations, internal emails, newsletters, social media channels and intranet posts. Regular employee engagement surveys are conducted to highlight areas of improvement.

The Board considers the results of all employee engagement surveys to be a good indicator of the Company's strategic direction, optimism in the future and career opportunities; they also facilitate Board discussion of future strategy and proposals for change.

Our success is driven by invested engagement from our leaders and our workforce, fostering Inclusive Diversity, one of Allstate's core values. Actively seeking out and leveraging the collective mixture of individual differences and similarities improves business outcomes for our workforce, the marketplace and our communities. The Company's diversity and inclusion program has successfully integrated diversity into the organizational culture. It is an ongoing, integrated corporate initiative that enhances the Company's ability to attract, motivate and retain a diverse pool of high performing employees. Employee Resource Groups are an intrinsic part of the Company's approach to inclusion and diversity. The Company is certified to Silver level by the Diversity Charter Mark NI, an important external validation of the Company's policies and performance in diversity and inclusion. The Company has a number of other stakeholder engagements in the areas of business networks, government, schools and universities and communities, environment and charities.

The Company follows the Allstate group auditing process, using the same external auditors as The Allstate Corporation and Allstate Insurance Company, currently Deloitte. The Board, the senior leadership team and the external auditors are committed to a positive working relationship that enhances the effective and efficient execution of the audit process.

Download the Corporate Governance Statement PDF

Allstate Global Holdings Limited

Tax Strategy

This policy has been published in compliance with paragraph 16(2) of Schedule 19 to the Finance Act 2016 and is in relation to the accounting period ended December 31, 2020. It will remain in force until it is next updated.

1. Introduction

The Allstate Global Holdings Group ("AGHL") is a UK Sub-Group of The Allstate Corporation. The companies in this group are all registered in Northern Ireland and the primary trading companies are Allstate Northern Ireland Limited and Arity International Limited.

At Allstate Global Holdings, our approach to tax is essential to ensuring tax compliance with all applicable laws and in fulfilling our fiduciary responsibility to the Allstate Corporation. We aim to achieve sustainable participation in local communities for the long term as a business and as a global corporate citizen.

2. Tax in our UK Statutory Accounts

The financial statements of Allstate Global Holdings companies are prepared in accordance with United Kingdom Generally Accepted Accounting Principles. The financial statements are audited by a professional accounting firm and filed publicly in the UK.

Our business activities incur a variety of taxes, which are primarily corporate taxes and employment taxes. In addition, we collect and pay employee taxes and indirect taxes such as value added tax. The taxes we pay and collect represent a significant part of our economic contribution to the economy in which we operate.

There are various reasons why the corporate tax cash payments in a particular year may be different from the corporate tax expense in the financial statements, including timing differences and deferred taxes.

We provide information on taxes in our annual statutory accounts which are filed with UK Companies Registry. The tax disclosures in our statutory accounts summarize in aggregate the significant components of corporate income tax expense for the periods presented.

3. Tax Responsibilities and Organisation

The Senior Vice President of Tax for The Allstate Corporation is responsible for managing the Company's Tax function globally and leads a senior team with specific geographic and technical responsibilities. UK finance personnel manage the routine tax processes relevant to their jurisdiction and collaborate with Corporate Tax as required.

In addition to working closely with the Corporate Tax department, AGHL group companies utilise professional tax experts routinely to give advice on tax matters and to prepare tax computations. We seek advice from external advisors on material transactions and whenever the necessary expertise is not available in-house.

The Board of Directors of each legal entity in the Group have overall responsibility for the financial reporting which includes tax, and updates on any significant tax matters are reported to the Board as required.

4. Tax Governance and Risk Management

The Allstate Code of Business Conduct addresses our responsibilities to the Company and its investors, customers, suppliers, consumers, and governments and defines how employees should conduct themselves as representatives and ambassadors of the Company. All employees are expected to understand the Code of Business Conduct and are expected to comply with the Code in addition to all applicable government laws, rules and regulations. Our approach to taxation is grounded in these values, which are reflected in our Code of Business Conduct.

The Allstate Global Holdings group maintains robust internal policies and procedures to support its tax control framework and manage risk. The governance structure in place ensures that tax decisions are taken at the appropriate level and ensures that there is alignment across our business. Each company in the group has specific Board of Directors and management approval requirements and approval process for both material, and non-material, commitments made on behalf of the relevant company. These processes include the Corporate Tax department being involved in changes in corporate structure, all business acquisitions and divestitures and business transactions.

5. Tax Planning and Level of Risk

Allstate Global Holdings group complies with applicable tax rules and regulations, including relevant transfer pricing guidelines. In the event that a company in the Group undertakes transactions, the Corporate Tax department advises the business on the tax consequences so that the business may structure its affairs in the manner that supports the business' commercial and economic activity. AGHL does not engage in artificial tax arrangements and seeks to minimise the risk of uncertainty or disputes. If a significant transaction occurs that may give rise to different interpretations, we tend to proactively seek advice from expert advisors in order to determine the best interpretation.

We adhere to the arm's length standard and apply it to ensure the parties to intercompany transactions are appropriately remunerated, as if they were unrelated parties.

6. Relationship with Taxing Authorities

Allstate Global Holdings seeks to develop open and mutually respectful relationships with government and fiscal authorities based on transparency and trust. We work collaboratively wherever, and whenever, possible with fiscal authorities to resolve disputes and to achieve early agreement.

In the UK, Allstate Global Holdings adopts an open, professional and transparent relationship with Her Majesty's Revenue and Customs ("HMRC"). We engage in open dialogue in relation to compliance and risk and are committed to making full and accurate disclosures in tax returns and in correspondence with HMRC. We seek to co-operate with HMRC at all times and to deal with issues in a timely and collaborative manner. Should genuine differences of opinion occur, we will always seek to resolve such an issue with reference to the relevant legislation and tax law.

This policy applies to the three companies in the AGHL group, being Allstate Global Holdings Limited, Allstate Northern Ireland Limited and Arity International Limited.

Download the UK Tax Strategy PDF

Terms & Conditions

These Terms & Conditions apply to https://www.allstateni.com (known as "this website" or "our website").

Conditions of use

By using this website and all others owned and maintained by Allstate Northern Ireland Limited ("Allstate Northern Ireland Limited", "our" or "we"), you agree to the following terms and conditions. Please read them carefully before you start to use our website. These terms and conditions may be revised at any time by our updating this notice and posting it on our website. You are bound by any such revisions if you continue to use the website after we have posted the changes; and we suggest that you periodically visit this page to review the most recent Terms & Conditions.

Restrictions on use of materials

This website is owned and operated by Allstate Northern Ireland Limited. Except as otherwise expressly permitted in writing by Allstate Northern Ireland Limited, no materials from this website or any website owned, operated, licensed or controlled by Allstate Northern Ireland Limited may be copied, reproduced, republished, uploaded, posted, transmitted, hyperlinked, or distributed in any way. You may download material displayed on this website for your personal use only and provided you do not remove any copyright and other proprietary notices contained on the materials. You may not distribute, modify, transmit, reuse, repost, link or use the content of this website for public or commercial purposes, including the text, images, audio, and video without written permission from Allstate Northern Ireland Limited.

Trademarks & copyright

All trademarks, services marks, trade names, logos, icons and domain names located on this website are the property of Allstate Northern Ireland Limited. Nothing contained on the website should be construed as granting, by implication or otherwise, any license or right to use any trademark, service mark, trade name, logo, icon and domain name displayed on this website without the written permission of Allstate Northern Ireland Limited or third party that may own such marks or names displayed on this website. Your use of the trademarks, service marks, trade names, logos, icons and domain names displayed on this website, or any other content on this website, except as provided herein, is strictly prohibited. Images displayed on this website are either the property of, or used with permission by, Allstate Northern Ireland Limited. The use of these images by you, or anyone else authorized by you, is prohibited unless specifically permitted in writing by Allstate Northern Ireland Limited. Any unauthorized use of the images may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes.

Links to other websites

This website may hyperlink to other websites which are not maintained or controlled by Allstate Northern Ireland Limited. Allstate Northern Ireland Limited is not responsible for the content of those websites. The inclusion of any hyperlinks to such websites does not imply approval of or endorsement by Allstate Northern Ireland Limited of those websites, their content or their products and services.

Disclaimer

The information and descriptions contained on our website are not intended to be complete descriptions of all terms, exclusions and conditions applicable to every product, scenario or service offered by Allstate Northern Ireland Limited, but are provided 'as is' and for general informational purposes only. Allstate Northern Ireland Limited makes no representations or warranties that the materials are suitable for your needs, are complete, timely, reliable, or are free from errors, inaccuracies or typographical mistakes. Allstate Northern Ireland Limited does not warrant that our website will operate error free or is free from viruses, worms, Trojan horses or other destructive or harmful code. Allstate Northern Ireland Limited also assumes no responsibility, and shall not be liable for, any damages to your computer equipment or other property as a result of your access to, use of, or browsing in our website or your downloading of any materials, data, text, images, video, or audio from this website or arising in connection with any failure of performance, error, omission, interruption, defect, computer virus, delay in operation or transmission, or line or system failure.

TO THE EXTENT PERMITTED BY LAW, ALLSTATE NORTHERN IRELAND LIMITED DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT.

Limitation of liability

To the maximum extent allowed by law, Allstate Northern Ireland Limited shall not be liable to you for damages of any kind whatsoever including, but not limited to, direct, indirect, consequential, special, incidental, including without limitation, lost profits or damages resulting from lost data or business interruption, or punitive damages of any kind whatsoever that may result from your use of or inability to use this website or the materials or services provided on this website or the products or services received from this website.

The clause above or any clause in these Terms & Conditions does not exclude or limit the liability of Allstate Northern Ireland Limited for anything for which liability cannot be excluded or limited by law or excludes or limits liability for personal injury or death caused by negligence, fraudulent misrepresentation or affect any statutory or other rights you may have under the applicable law.

Software licenses

You acknowledge that any software available or provided to you on this website may contain technology that is subject to strict controls by various agencies in the country from which the website is accessed. Allstate Northern Ireland Limited does not authorize the downloading or exportation of any software or technical data from this website to any jurisdiction prohibited by United Kingdom export controls laws and regulations.

Privacy

Please read our Privacy Policy. The Privacy Policy explains what information Allstate Northern Ireland Limited may collect from you on our website and how we will use and protect your information.

Cookies

Please read our Cookies Policy which sets out information about the cookies on our website.

Applicable Law

These Terms & Conditions, its subject matter and its formation (and any non-contractual disputes or claims) are governed by the laws of the United Kingdom. All users agree to the exclusive jurisdiction of the courts of Northern Ireland..

Contact information

Allstate Northern Ireland Limited

10 Mays Meadow
Belfast
Northern Ireland
BT1 3PH
Tel. +44 (0) 28 9067 8000

ANIPrivacyQueries@allstate.com

Registered in Northern Ireland NI034636


Download the Terms of Use Statement PDF

ANI Environmental Policy At Allstate Northern Ireland, we aim to be a responsible and socially conscious business, implementing practices and initiatives that benefit our people, our community and our environment.

In all aspects of our business we strive for continuous improvement and our environmental performance is no different; we recognize the ways our operations impact on the environment and seek to minimize those impacts.

This policy provides the basis for our environmental position and our commitment to operating in an environmentally responsible manner.

Our Commitments;

  • As a minimum, complying with all environmental legislation and regulations relevant to our business, and seeking to go beyond our basic obligations
  • Measuring and acting to reduce our carbon footprint, incorporating environmental management best practice to do so
  • Maximising the efficient use of energy, water and resources
  • Minimising and managing waste produced by our offices through a reuse, reduce, recycle strategy
  • Reducing our transport and travel requirements by promoting video conferencing, sustainable travel to work options and flexible working
  • Educating and training our employees on environmental issues and their own environmental impact
  • Including environmental considerations as part of any office space acquisition, design or refurbishment
  • Expecting our suppliers and service providers to uphold our ethos of sustainable environmental practices and incorporating environmental criteria into the procurement of goods and services
  • Offsetting our environmental impacts through a range of green initiatives, involvement in community conservation projects, investment and volunteering

As part of these commitments we will;

  • Communicate this policy to all employees and make it publicly available on our website
  • Monitor and review environmental performance against targets and objectives on a regular basis (at least annually)
  • Provide Senior Leadership oversight and direction through the Steering Committee for Charities, Community and Environment
  • Promote environmental awareness and initiatives through the employees’ AllGreen Environmental Committee

This policy will be reviewed annually to ensure continual improvement.

SIGNED BY: John Healy (Managing Director) DATE: 5/8/220


Download the ANI Environmental Policy PDF

Allstate Northern Ireland Limited Data Privacy Notice

1. Introduction

Allstate Northern Ireland Limited (also referred to in this notice as "ANI" or "we/us") provides this data privacy notice to tell you how we use your personal data that we gather from your use of the recruitment pages of our website, and during the course of the recruitment process.

ANI is a controller in relation to use of this information, meaning that it determines the way in which your data is used.

We have a Data Protection Compliance Officer, who is responsible for overseeing use of personal data by ANI. You may contact our Data Protection Compliance Officer with any queries about our use of your data. Contact details are provided at the end of this notice.

2. Sites covered by this notice

This notice applies to the recruitment pages at https://www.allstateni.com. If you are visiting other sections of our website, please refer to: https://www.allstateni.com/privacy-and-security.aspx

This notice does not apply to any third party websites which are linked to from our website as we have no control over those third party websites or how they may collect or use your personal data. You should contact such third parties for information about this.

In relation to our use of cookies, please see information about cookies in our general website Privacy Notice.

What information we collect.

We collect personal data in connection with our recruitment activities as described below.

Most of the personal data we collect as part of our recruitment process is provided by you:

  • Contact details (name, email, telephone number);
  • Areas of interest;
  • Username and password to apply for a role;
  • CV, experience, education, academic and professional qualifications;
  • Information provided as part of interviews and assessments;
  • Diversity and equal opportunities data;
  • Pre-employment screening information if your application is successful.

We create personal data in connection with our recruitment activities such as:

  • Interview and assessment results and feedback; and
  • Offer details.

We obtain personal data from third party sources such as:

  • References from your named referees;
  • Information from your referrer (where applicable);
  • Results of screening checks, including criminal records checks, drug and alcohol checks (this will depend on the role applied for);
  • Verification of information provided during the recruitment process by contacting relevant third parties (for example, previous employers); and
  • Information from professional social media sites that you are a member of (for example, LinkedIn).

4. Legal basis for use of your information

We process personal data for our legitimate interests to attract and secure the best talent to work with us as follows:

  • To identify and source talent including by searching our talent pool and publicly available sources (such as professional networking and job websites of which you are a member);
  • To process and manage applications for roles at ANI, evaluate you for open positions that match your interests and experience, manage your candidate profile, send you email notifications and other announcements, request additional information or otherwise contact you about your candidacy;
  • To screen and select talent by evaluating your suitability for employment with ANI, including through interviews and assessments;
  • To hire and onboard talent by making an offer to successful applicants and carrying out pre-employment screening checks;
  • To establish whether an applicant has committed an unlawful act or been involved in dishonesty, malpractice or other improper conduct;
  • To conduct statistical analyses and create reports including for example regarding use of our career's websites, demographic analysis of candidates, reports on ANI recruitment activities, and analysis of candidate sourcing channels;
  • To administer and manage our careers websites and communicate with you about careers at ANI; and
  • Any other purposes stated when you provide the information to ANI.

Where we are required to do so by law:

  • We carry out eligibility checks to ensure an individual has the right to work in the UK;
  • We collect and use information about gender and religious and philosophical beliefs for equality monitoring; and
  • We collect health related data for health and social care purposes, including to comply with our legal obligation to make reasonable adjustments.

5. Automated decision making

Certain stages of our recruitment process include algorithms that have been designed to automate some recruitment assessment decisions.

For certain roles you may be required to complete a series of online assessments which involve solely automated decision-making. The online assessments you are asked to complete have pre-defined responses which relate to requirements needed for the role. The predefined responses are based on data that indicates what good job performance at ANI looks like (informed by job analysis conducted with ANI and our partners) in relation to these assessments. Your responses to the online assessment questions and overall assessment score will be compared to the predefined responses and scores set for the relevant roles. Applicants with an overall assessment score that exceeds that required for the relevant role will progress automatically to the next stage of the recruitment process.

ANI carry out the automated decision-making as it is necessary for entering into a contract (i.e. the potential contractual relationship between ANI and you as employer and employee). Using automated decision-making supports ANI to maintain a fair and objective selection process, while managing the significant volume of applications received for specific roles.

You can ask for us to review the outcome of any automated decisions by emailing ANIPrivacy.

6. How long do we keep your information?

We will retain records during and after the end of the application process, for the purposes set out in section 4 above. For unsuccessful applicants, our retention period is 4 years. For successful applicants, your details are transferred across into personnel files and retained for the purposes of managing the employment relationship (in accordance with our employee data privacy notice). This applies to all recruitment data, with the exception of any personal data relating to criminal offences, which we will delete after a decision has been made about your recruitment, and in any case, no later than 30 days.

7. Security of your information

We take measures to help ensure that your personal data is secure, accurate, up to date and kept only for so long as is necessary for the purposes for which it is collected (see also section 3 above).

To help ensure the security of your personal data that you submit to our website (other than via an email message), we use security software to encrypt the information before and during its transmission through the Internet. We only allow information to be submitted for transmission if your browser is compatible with our security software. If your browser is not compatible, you will receive a message indicating your transaction can be completed but at a lower level of security.

No method of transmission over the Internet or email, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee absolute security. Please contact us using the details at section 12 below if you would like to discuss alternative communication methods.

8. Disclosure of your information

We may share your personal data with other members of the Allstate group (including Allstate Insurance Company in the US and Allstate Solutions Private Limited ("ASPL") in India) to support the recruitment process, to manage our IT systems, in compliance with legal or regulatory requirements and for other activities relating to management of the Allstate group.

We have entered into a data transfer agreement with Allstate Insurance Company and ASPL in relation to these activities — see section 9 below.

We (and our group entities) may disclose your personal data to other third parties, as follows:

  • In support of the ANI network where services are required to run and manage our IT systems. This may include storage of data on cloud-based systems. We will take steps to ensure that any such service providers are required to keep it confidential and secure;
  • We may use the products and services of third party organisations as part of the recruitment processes. The products and services we use differ depending on the role you apply for;
  • As required by law, such as to comply with a legal process or regulatory obligation;
  • In connection with the sale or proposed sale of our company or our business or assets. If ANI, or its parent company, or substantially all of its assets are acquired by a third party, your personal data will be one of the transferred assets; and
  • For any other purposes permitted by applicable data protection law.

Third party providers may use their own third party subcontractors that have access to personal data. It is our policy to use only third party providers that are bound to maintain appropriate levels of security and confidentiality and to process personal information only as permitted by ANI.

9. Transfer of information outside the UK

Certain data may be transferred to, and stored at, a destination outside the UK, where the data protection laws may not provide the same level of protection as within the UK. Whenever we transfer information to countries outside of the UK we will take steps which seek to ensure that your personal data is treated securely and in accordance with this notice. In particular:

  • We have entered into an agreement with Allstate Insurance Company (in the US) and Allstate Solutions Private Limited (in India) in order to provide safeguards relating to the transfer of your personal data outside the UK.

10. Your rights and updating your details

You have certain rights in relation to your personal data, including the right:

  • to access a copy of the personal data which we hold about you, together with other information about how we process it;
  • to request correction of inaccurate personal data and, in some circumstances, to request us to erase or restrict our use of your data, or otherwise to object to our use of your data for reasons relating to your situation;
  • not to be subject to a decision based solely on automated processing, which significantly affects you;
  • to receive a copy (in a machine-readable format) of personal data which you have provided to us, where we process it electronically based on your consent (see section 6 above);
  • to make a complaint about how we handle your data to the UK Information Commissioner's Office. Please visit www.ico.org.uk for more information about how to do this; and
  • to withdraw any consent which you have given relating to use of your data, at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis).

Note that there are certain limitations and exemptions to these rights which we may apply depending on the circumstances.

Please contact ANIPrivacyQueries@allstate.com to send us requests to exercise these rights (specifying what you are requesting), or for more information about them. Please also contact us if anything changes in your personal details so we can ensure we have up to date records.

11. Updates to this notice

We may change this notice and will post the most up to date data privacy notice on this page. You should check our website for updates or changes to this notice. This notice was last updated in November 2020.

12. Contact information

You may contact the Data Protection Compliance Officer with any queries relating to the processing of your data by us, to update your details, and to exercise your rights as described above.

Contact details are as follows.

The Data Protection Compliance Officer
Allstate Northern Ireland Limited
10 Mays Meadow
Belfast
BT1 3PH
Tel: +44 28 90 678000
ANIPrivacyQueries@allstate.com
Registered in Northern Ireland NI034636


Download the Applicant Data Protection Statement PDF

Allstate Northern Ireland Supplier Code of Ethics

Allstate Northern Ireland needs good partners.

At Allstate Northern Ireland (ANI), we're committed to operating with absolute integrity. We believe in always doing the right thing in the right way for the right reason. We demonstrate our values through our behaviors, decisions and interactions each and every day and expect our business partners to do the same.

That's why we deal only with suppliers who follow the Code of Ethics outlined in this brochure. Working with good business partners makes good business sense.

Supplier Code of Ethics

All Suppliers doing business with ANI must adhere to the following expectations:

  • Compliance - ANI is committed to compliance with all laws and regulations, both foreign and domestic, and we require the same of our suppliers.
  • Reciprocity - ANI believes in providing any supplier with a fair opportunity to conduct business with us. We do not require or expect any supplier to purchase or lease ANI products or services to compete for our business.
  • Conflicts of Interest - ANI employees agree not to be influenced by what best serves their personal interests over those of our customers and shareholders. Therefore, suppliers may not offer any ANI employee anything that may create the risk or perception of undue influence or call ANI's objectivity into question.
  • Personal Conflicts of Interest - ANI's decision making and actions will not be influenced by close personal or family relationships. Close personal relationships with ANI employees should be disclosed and will not be a basis of consideration in the competition for business.
  • Gifts and Gratuities - ANI employees will not be influenced or obligated by the offer of business courtesies. Current or potential suppliers should not accept or offer any gift, entertainment, benefit, favor or service.
  • Illegal/Improper Payments - ANI is committed to conducting business with unquestioned integrity and in full compliance with the law. Bribes, kickbacks and other similar payments are strictly prohibited.
  • Discrimination - ANI supports diversity and equal opportunity in employment. We expect our suppliers to uphold the same commitment by complying with all applicable laws, rules and regulations concerning discrimination.
  • Harassment and Abuse - ANI's commitment to a workplace free from harassment and abuse applies to all people, regardless of whether or not they are ANI employees. Unwanted and unwelcome verbal, visual, written, physical or sexual behavior that creates an offensive, hostile or intimidating work environment is not tolerated. We expect our suppliers to provide a similar work environment.
  • Health and Safety - ANI is committed to a safe and healthy work environment. We expect our suppliers to comply with all applicable safety and heath laws and regulations in the countries in which they operate. To ensure that a safe environment is maintained, suppliers are prohibited from:
    • Possessing, consuming or acting under the influence of unauthorized intoxicants or any controlled substance not prescribed by a licensed physician while conducting ANI business or while on ANI premises.
    • Bringing firearms or other weapons onto ANI premises, except as permitted under applicable laws and regulations.
    • Assigning ANI insurance-related work to any personnel whom a supplier knows, or should have reasonably known, to have been convicted of a felony involving dishonesty or breach of trust.
    • Bringing any personnel onto ANI premises whom a supplier knows, or should have reasonably known, may pose a significant risk to the health or safety of others.
  • Environmental Stewardship - ANI is committed to operating responsibly to support solutions that improve sustainability and protect our natural environment. We expect suppliers to conduct their operations in a similar manner.
  • Confidentiality - ANI respects the privacy of all individuals. We are committed to complying with applicable laws concerning proprietary, confidential and personal information.
  • Asset Protection - ANI's assets are critical to its success. Suppliers engaged in business with ANI agree to protect and preserve ANI's assets, whether tangible or intangible.
  • Human Rights - ANI believes in the appropriate treatment of its workforce. Suppliers are expected to provide safe and sanitary work environments, including rest and eating facilities. No business partner should permit any form of forced or involuntary labor.
  • Compensation - ANI provides competitive pay to its employees. Suppliers must comply with all applicable laws, rules and regulations concerning compensation.
  • Child Labor - ANI does not engage in the use of child labor and expects its suppliers to employ only workers who meet minimum age requirements in any location.
  • Brand Name Usage - ANI's branding reflects our position as a trusted and respected company. Use of the ANI name, slogan, logos and other trademarks and service marks is prohibited without prior written consent.
  • Professionalism - ANI supports an environment of professionalism. Suppliers are expected to conduct business in a professional manner and adhere to dress code expectations.
  • Diversity and Inclusion - ANI values and leverages diversity in a manner that enriches perspectives and creates a strong and inclusive organization. ANI believes in providing opportunities for many types of businesses, including those owned by minorities, women, people with disabilities, veterans and those who are lesbian, gay, bisexual or transgender. Suppliers are expected to hire, develop and retain a diverse workforce.
  • Fair Competition and Antitrust - ANI seeks to outperform competitors fairly and honestly, achieving competitive advantages through superior performance. Suppliers are expected to foster fair competition without restraining or inhibiting competitors or abusing a dominant market position.
  • Insider Trading - Suppliers are prohibited from purchasing, selling or trading ANI securities while in possession of material non-public information. Never directly or indirectly share non-public information acquired by conducting business with ANI.

Need to Report a Concern?

ANI expects our business partners to report any illegal, unethical conduct or regulatory compliance concerns. This may be done by:

  • Calling the Allstate Northern Ireland Alertline. This is a free phone number which you can call 24/7 at 0800 169 3658. You may provide your name or report your concern anonymously.

Download the ANI Supplier Code of Ethics Statement PDF

S172 Statement

Engaging with stakeholders

In accordance with s172 of the Companies Act 2006, the directors of the company act in ways that they consider, in good faith, to be most likely to promote the success of the company for the benefits of its members as a whole. In doing so, the directors have regard, amongst other matters, to:

  • the likely consequences of any decision in the long term,
  • the interests of the company's employees,
  • the need to foster the company's business relationships with suppliers, customers and other key stakeholders,
  • the impact of the company's operations on the community and the environment,
  • the desirability of the company maintaining a reputation for high standards of business conduct, and
  • the need to act fairly as between members of the company.

Operational decisions are made with stakeholders in mind, in a structured set of monthly meetings which include the senior leadership of the company. Key topics and decisions from these operational meetings are then brought to the Board Meetings which occur three to four times per year. The company's values and Code of Ethics empower employees to make the best decisions in the interest of the company and its stakeholders.

Allstate business partners and shareholders
The company provides services to business partners in other Allstate group companies. Engagement with our business partners is critical to the success of the company and to the successful delivery of products and services. Engagement is primarily through the managers who are responsible for individual workstreams and with senior leadership. Our shareholders are fellow Allstate group companies, and the goals of the company therefore align with our shareholder's goals.

Employees
As a service business, our people are fundamental and key to our success. We engage with employees via engagement surveys, forums, events, meetings, internal communities, our intranet, Allstate TV, Town Halls, video blogs and other multi-media channels. Key areas of focus include health and well-being, development opportunities, compensation and benefits. We encourage employees to own their own careers and provide training opportunities via multiple platforms.

Suppliers
The company builds strong relationships with key suppliers to develop mutually beneficial partnerships. The local procurement team is integrated with global procurement and seeks to implement high standards in supplier determination, onboarding, ongoing engagement and renewal. Our Supplier Payment Practices reports show healthy payment turnaround times. Our suppliers are an important part of the long-term success of the company.

Local communities
The company engages with the communities in which we operate to build trust and provide support. A series of strategic groups are in place to encourage local engagement. These include the Charities Committee, the Government and Business Network Engagement group and the Schools and University Engagement group. They work with local bodies to ensure the company can contribute to local dialogue and support the communities in which we live and work.

Government and regulators
The company actively engages with local Councils, the Northern Ireland Assembly and national government, to ensure we can contribute to local and national issues, such as Brexit or the response to Covid-19. We take part directly, representing the company specifically and indirectly, through local industry bodies and forums. The Risk and Compliance team inform relevant personnel of new laws or regulations and ensure the right groups are aware and informed. We engage frequently with external consultants who specialise in areas of regulatory change and participate in training sessions as required. The Board is updated on legal and regulatory developments and takes these into account when considering future actions.

Further information on our engagement with stakeholders can be found in the Statement of Corporate Governance Arrangements in the Directors' report.

John Healy
Director

10 Mays Meadow, Belfast, BT1 3PH

25 August 2020