Travelers established and maintains a Code of Business Conduct and Ethics, which applies to all our employees, officers and directors and provides a framework for sound ethical business decisions. The Code, which is also available in French and Portuguese for our employees located in Canada and Brazil, 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 additional Legal, Compliance and Human Resources personnel to help our employees reach the right decision, regardless of the circumstances.
We expect our suppliers to conduct themselves with the same level of honesty and integrity as our employees. 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. We also proudly commit to the protection of human rights everywhere we do business, as described in our Human Rights Statement.
Our ability to achieve our goals of being the undeniable choice for the customer and an indispensable partner for our agents and brokers depends upon 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 company-wide communications. Here’s an excerpt from one of his recent messages:
"Intellectual integrity, a culture of transparency and the duty to call it like we see it are necessary conditions for long-term success. We should hold ourselves and each other to that standard. One of the many things that makes this company great is the expertise, experience, grit and determination of Travelers employees. We have the skill and creativity to solve any problem and meet any challenge. But we can only solve problems and meet challenges if we’re honest with ourselves and each other about what those problems and challenges are.
I’m not sending this message because I think we have a problem. In fact, quite the contrary. I’m sending this message because our culture of collaboration, camaraderie and shared responsibility is a treasure that we should never take for granted."
This approach remains critical to maintaining our culture of candor and continuing to deliver sustained value to our stakeholders.
All employees must complete our annual Ethics and Compliance Training and Certification program, which includes:
- Code of Business Conduct and Ethics Training and Certification: We require all employees to complete annual ethics training, which includes training modules on a variety of important topics, such as anti-bribery and anti-corruption. Additionally, all 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 certify to their compliance with, applicable company policies. These include:
- Anti-Bribery and Anti-Corruption Policy
- Code of Conduct for Travelers System Users
- Equal Employment Opportunity Policy
- Gifts to Government Officials
- Harassment-Free Workplace Policy
- Internal Dispute Resolution Policy
- Nepotism, Favoritism and Personal Conflict of Interest Policy
- Non-Solitication and Non-Distribution Policy
- Respectful Workplace Policy
- Security Trading for Employees Policy
- Security Trading for Executives Policy
- Social Media Policy
- Supplier Management Policy
- Whistleblowing and Non-Retaliation Policy
Bribery and corruption are wholly inconsistent with Travelers core values, and we have instituted policies, procedures and internal controls for complying with anti-bribery and anti-corruption laws. Travelers strictly prohibits any promise, 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 additional information regarding our expectations for employees 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. To learn more about our employee practices and programs, see our Human Capital Management and Diversity & Inclusion sections. Our specific policies on equal employment opportunity and non-discrimination illustrate our commitment to maintaining a harassment-free and respectful workplace, and as outlined in our Supplier Code of Conduct, we expect the same from our suppliers. We regularly reinforce the principles embodied in these policies through additional education, which includes discrimination-free workplace training and harassment awareness training. We provide employees with multiple channels, including the Human Resources, Employee Relations and Compliance departments and the Travelers Ethics Helpline, to raise concerns about discrimination or harassment — or any other workplace concerns — and prohibit retaliation against employees who raise concerns in good faith. Each concern is investigated by trained professionals and, where appropriate, escalated internally. In addition, Travelers has an impartial Internal Dispute Resolution Policy that allows employees to seek review of employment-related issues, concerns, actions and decisions, including those relating to compensation.
Travelers has an independently administered Ethics Helpline, which is available to employees 24/7 to report issues or seek guidance confidentially and anonymously.
Once an Ethics Helpline report is filed, the Ethics and Compliance Office investigates the matter and addresses any ethical or compliance-related issues. It 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 all matters reported to the Chief Ethics and Compliance Officer that involve accounting, internal control or audit matters, or any fraud involving persons with a significant role in our internal controls.
We maintain a formal non-retaliation policy that prohibits retaliation against, or discipline of, an employee who raises an ethical concern in good faith.