Ethics & Values

Travelers established and maintains a Code of Business Conduct and Ethics, which applies to all of our employees, officers and directors and provides a comprehensive framework for sound ethical business decisions. The Code, which is also available in French for our employees located in Canada, provides principles for each employee to follow when acting on behalf of Travelers and sets forth our expectations on a number of topics, including conflicts of interest, compliance with laws, business ethics and use of corporate assets. Our Chief Ethics and Compliance Officer oversees communication, education and compliance with the Code. We also employ and train Legal, Compliance and Human Resources professionals to help our employees reach the right decision, regardless of the circumstances.

Our ability to achieve our goals of being the undeniable choice for the customer and an indispensable partner for our agents and brokers depends on our culture of honesty, integrity and accountability. Our commitment to transparency and integrity starts with our senior leadership. Our Chairman and CEO, Alan Schnitzer, sets the tone, including through regular companywide communications. Here’s an excerpt from one of his messages:

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This approach remains critical to maintaining our culture of candor and continuing to deliver sustained value to our stakeholders.

We expect our suppliers to conduct themselves with the same level of honesty and integrity as our employees. The Travelers Supplier Code of Conduct documents our expectation that all contractors, consultants, suppliers and vendors demonstrate their commitment to ethical, humane, socially responsible and legally compliant business practices, including by maintaining a harassment-free and respectful workplace. We also proudly commit to the protection of human rights everywhere we do business, as described in our Human Rights Statement.

To learn how our ethical culture drives our ability to attract and retain talented, diverse and qualified employees, see our Human Capital Management and Diversity & Inclusion sections.

Board Oversight

The Nominating and Governance Committee of the Board of Directors periodically reviews the Code of Business Conduct and Ethics and recommends changes to the Board, as appropriate. The Audit Committee, which has oversight responsibility for regulatory and compliance matters, receives a quarterly report on compliance matters, including Ethics Helpline activity. In addition, the Audit Committee meets in executive session with the Chief Ethics and Compliance Officer each quarter.

Upholding a culture of honesty, integrity and accountability is critical to the long-term success of our organization. To support this culture, we promote ethics and compliance awareness across our operations. On an annual basis, our employees are required to complete our Ethics and Compliance Training and Certification program, which includes:

• Code of Business Conduct and Ethics Training and Certification. We require our employees to complete annual ethics training, which includes training modules on a variety of important topics, such as anti-bribery and anti-corruption. Additionally, our employees and directors must certify annually that they have reviewed, understand and agree to comply with the principles set forth in the Code.
• Policy Certification. We expect all employees to familiarize themselves with, and confirm their compliance with, applicable company policies. These policies include:
  • Anti-Bribery and Anti-Corruption
  • Information and System Use
  • Equal Employment Opportunity
  • Gifts to Government Officials
  • Harassment-Free Workplace
  • Internal Dispute Resolution
  • Nepotism, Favoritism and Personal Conflict of Interest
  • Respectful Workplace
  • Security Trading for Employees
  • Security Trading for Executives
  • Social Media
  • Supplier Management
  • Whistleblowing and Non-Retaliation

Bribery and corruption are wholly inconsistent with our company’s core values of honesty, integrity and accountability, and we have instituted policies, procedures and internal controls for complying with anti-bribery and anti-corruption laws. Travelers strictly prohibits any promise, any offer or the provision of anything of value to any government official or any other person for the purpose of improperly obtaining or retaining business, influencing action or obtaining any form of improper benefit. We provide our employees with additional information regarding our expectations in our internal Anti-Bribery and Anti-Corruption Policy.

Additionally, we are committed to providing a fair and inclusive workplace where all employees are treated with dignity and feel valued, respected and supported. Among other things, we require our employees to complete harassment awareness training, and our Internal Dispute Resolution Policy allows employees to seek review of employment-related issues, concerns, actions and decisions. To learn more about our employee practices and programs, see our Human Capital Management and Diversity & Inclusion sections.

In our continuing efforts to raise awareness and educate employees regarding compliance and ethics issues, Travelers publishes a periodic “Dear Ethics” column on the company’s intranet site. We base the topics of the “Dear Ethics” column on real situations that the Travelers Ethics and Compliance Office has addressed and anonymize them for publication. The column’s goal is to address situations in a relatable fashion and offer concrete suggestions for how employees should act in various circumstances.

We provide employees with multiple channels to raise concerns, including the Human Resources, Employee Relations and Compliance functions and the Travelers Ethics Helpline. Our independently administered Ethics Helpline is available to employees and others 24/7 to report issues or seek guidance confidentially and anonymously. Trained professionals investigate each concern and, where appropriate, escalate it internally.

Once an Ethics Helpline report is filed, a review is conducted, if appropriate. Any ethics- or compliance-related issues are addressed by the Ethics and Compliance Office. Our Chief Ethics and Compliance Officer provides the Audit Committee with quarterly summaries of matters reported through the Ethics Helpline and more frequent compliance updates, as appropriate. Additionally, the Audit Committee receives reports on matters reported to the Chief Ethics and Compliance Officer that involve accounting, internal control or audit matters or that relate to any fraud involving persons with a significant role in our internal controls.

We also maintain a formal Whistleblowing and Non-Retaliation Policy that prohibits retaliation against, or discipline of, an employee who raises a concern in good faith.