Key Definitions

Antitrust and Competition Laws:

Antitrust and competition laws serve to prevent anticompetitive business practices, such as price fixing or impairing the ability of others to compete in the market.

Anything of Value:

A broad concept that includes, without limitation, financial or other advantages, such as cash payments, loans, inappropriate gifts, travel, lodging, services, amenities, employment opportunities and internships, charitable donations, and tickets to sporting and other events.

Breach of Trust:

A criminal offense involving dishonesty, breach of trust or money laundering. Some examples include, but are not limited to, theft, misappropriation, embezzlement, forgery, false identification, false report to law enforcement, tax evasion, drug possession with intent to distribute and writing of a bad check.

Bribery:

The intentional offer, promise or giving of anything of value, directly or indirectly, to or from any person to improperly influence that person as an inducement for that person to act improperly or refrain from acting properly, including in accordance with official or fiduciary duties or contractual or other obligations, or to gain any other improper advantage.

Bullying:

Typically a form of repeated, unreasonable, persistent and aggressive behavior directed at an individual or individuals that’s intended to cause fear, intimidation, humiliation and distress or harm to another person’s body, feelings, self-esteem or reputation.

Chain of Custody:

All steps in a supply chain that take possession of the product, including miners, transporters, exporters, processors and manufacturers. It provides record of the sequence of entities that have custody of minerals as they move through a supply chain that traces a material back to its origin. Some examples of a chain of custody regulation are verifying that slave labor wasn’t used in any manufacturing process and that no parts used in production were obtained from sanctioned countries.

Company Record:

A record is any documented information (in any media like paper or digital) that’s necessary to satisfy the needs of Assurant’s business operations, legal and regulatory requirements, fiscal responsibilities and historical needs.

Confidential Information:

Information that you acquire, receive, learn, create, develop or have access to because of your employment at Assurant and that’s not made readily available to the public. Please refer to the Assurant Information Classification Guide for more information.

Conflict Minerals:

A natural resource in the global supply chain extracted from a geographical region of conflict and used to finance civil wars and perpetrate human rights violations in that region.

Conflict of Interest:

A conflict of interest may occur when your personal interests or the activities you perform on behalf of Assurant interfere (or appear to interfere) with the company’s, a shareholder’s or a client’s best interest. A conflict can arise when you take action or have interests that make it difficult to perform your company work objectively.

Discrimination:

In alignment with the International Labour Organization (ILO), any distinction, exclusion, or preference, especially in a worse way from the way in which you treat other people on the basis of actual or perceived race, color, religion, national origin, ancestry, physical or mental disability, medical condition, genetic information, marital status (including registered domestic partnership status), sex and gender (including pregnancy, childbirth, lactation and related medical conditions), gender identity and expression, age, sexual orientation, past or present military service, immigration status or any other status protected by the laws or regulations in the locations where Assurant operates.

Diversity, Equity and Inclusion (DEI):

Diversity: It’s who we are. Diversity encompasses the range of similarities and differences everyone brings to the workplace.
Equity: It’s how we’re treated. Equity is the guarantee of fair treatment, access, opportunity and advancement for everyone while striving to identify and eliminate barriers that have prevented the full participation of some groups.
Inclusion: It’s how we feel. An inclusive workplace recognizes, appreciates and effectively utilizes the talents, skills and perspectives of everyone.

Economic Sanctions:

Economic sanctions are foreign policy tools that impose strict limits on a range of activities, including providing financial services or conducting transactions. They’re imposed by governments or international bodies to try to isolate or impede a specified individual, entity or jurisdiction for some specified purpose or activity.

Facilitation Payments:

Payments to government officials to expedite an administrative action, such as securing a permit.

Fraud:

The use of deception with the intention of obtaining an advantage, avoiding an obligation or causing loss to another party. Internal fraud includes any effort by an employee to deprive Assurant or its customers and partners of any assets by theft, deception or other corrupt means.

Government Officials:

This term is defined broadly to include employees of government-controlled entities and public-international organizations, as well as elected officials and candidates for public office.

Harassment:

Unwelcome words, actions or behaviors that denigrate, disrespect or belittle an individual or create a hostile, offensive or intimidating work environment because of a protected category. Sometimes, a person’s conduct may be considered harassment even if it wasn’t intended to be offensive.

Human Trafficking:

Human Trafficking includes, without limitation, recruiting, harboring, transporting, providing, or obtaining a person for labor or services through the use of force, coercion, fraud or deception, the abuse of power or of a position of vulnerability, or the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation. Exploitation includes, without limitation, involuntary, servitude, peonage, debt bondage or slavery, the removal of organs, and sex trafficking, or other forms of exploitation.

Inside Information:

Information about a business organization that isn’t generally available to or known by the public (also called “nonpublic information”).

Insider Trading:

Insider trading involves trading in a public company’s stock by someone who has material, nonpublic information about that stock. Insider trading can be either illegal or legal depending on when the insider makes the trade. Generally, it’s illegal when the material information is still nonpublic.

Intellectual Property (IP):

Knowledge, ideas, discoveries, formulas, inventions, and other intangible assets that have commercial value and are protected under copyright, patent, service mark and trademark laws. Additional examples of intellectual property include technical inventories, brands and logos, software code, presentations, databases, customer lists, process documents and product designs and roadmaps.

Legal Hold:

A legal hold suspends all document destruction procedures to preserve appropriate records or information under special circumstances, such as anticipated or actual litigation or government investigations. Legal identifies what types of records, information or documents are required to be placed under a legal hold.

Material Nonpublic Information:

Information that a reasonable investor likely would consider important in deciding whether to buy, hold or sell securities of a company.

Money Laundering:

Making money derived from unlawful activities “clean” by making it appear that the money came from legitimate sources or transactions..

Protected Activities:

Protected activities include reporting harassing conduct, discrimination or retaliation; filing a claim of harassment; providing evidence in any investigation; or intervening to protect others who may have suffered harassing conduct, discrimination or retaliation.

Protected Characteristics:

Protected characteristics are defined as age, ancestry, citizenship, color, creed, ethnicity, gender identity and expression, genetic information, marital status, mental or physical disability, national origin, pregnancy, race, religion, sex, sexual orientation, veteran status or other categories defined by federal, state or local law.

People (HR)/Work-Related Concerns:

Questions or concerns about benefits, conflict with a coworker or manager, workplace conduct, discrimination, performance, compensation, theft or harassment.

Retaliation:

Taking adverse action against an employee in response to that employee’s good faith report of an actual or suspected violation of our Code, company policies or legal requirements. It’s against company policy to retaliate against any Assurant employee or representative who, in good faith, reported a violation or suspected violation of law, this Code, or other company policies. Additionally, retaliation against those who assist in an investigation into a reported violation is also prohibited. Any Assurant employee who retaliates against anyone who made a good faith complaint may be subject to disciplinary action by the company up to and including termination of employment.

Sexual Harassment:

Sexual harassment is unwelcome verbal or physical behavior based upon a person’s gender/sex and includes unwanted verbal or physical sexual advances, requests for sexual favors or visual, verbal or physical conduct of a sexual nature.

Terrorist Financing:

Terrorist financing provides funds for terrorist activity. It may involve funds raised from legitimate sources, such as personal donations and profits from businesses and charitable organizations, as well as from criminal sources, such as the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion.

Weapon:

The term weapon includes firearms, explosives, knives and other weapons that might be considered dangerous or that could cause harm.

The Workplace:

The workplace includes actual worksites, any setting in which work-related business is being conducted (whether during or after normal business hours), online and electronic interactions with company employees and third parties involved in our operations, company sponsored events, and company-owned/ controlled property.

Speak Up

When in Doubt - Speak Up
If you have questions or concerns, let your manager, the People Organization or the Ethics Office know.

Speak Up