Responsibility to Our
PARTNERS AND CUSTOMERS
Trust is the foundation of every customer, partner and company relationship. To build long-lasting business relationships, we follow the law and treat our customers the way we would want to be treated ourselves — in an open, honest and respectful manner. We empower our customers and partners to make informed decisions about the products and services we offer and to select what best meets their needs and circumstances.
Business Partners
We value the trusted relationships we have with our business partners who share our commitment to ethics and compliance, diversity and inclusion, human rights, environmental sustainability, and fair dealing.
> Our Responsibilities
- We’re committed to maintaining our reputation and only work with suppliers, customers and other business partners committed to doing business ethically.
- We conduct each business relationship with honesty, fairness, mutual respect and nondiscrimination.
- We never take advantage of our business partners through manipulation, concealment, misuse of confidential information, misrepresentation of facts or any other unfair dealing or practice.
- We never collude with business partners to take advantage of others.
- We select business partners based on objective criteria and the value they bring to Assurant, not due to personal relationships or friendships. We also ensure that they understand our standards for high performance in ethics and compliance in addition to their contractual obligations.
- We’re alert to any signs that a business partner is violating applicable laws or regulations.
- We promptly disclose any situation that may appear to involve a conflict of interestA 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..
- We protect the confidential and proprietary information of our business partners.
- We complete applicable due diligence on prospective suppliers and customers before entering into contracts, and we follow our Procurement (MyBuy on Connect), Anti-Corruption, and Third Party policies.
- We seek to understand and follow all relevant conflict mineralsA 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. regulations in any country in which we do business.
Privacy and Data Protection
We’re successful when our customers trust us to protect their privacy and use their data in the ways that they permit us. We protect and respect the privacy of our employees, customers, clients, partners and other third parties who entrust us with their personal information.
> Our Responsibilities
- We follow applicable data protection and privacy laws.
- We properly secure personal data.
- We only collect and use personal data for legitimate business purposes and follow our Privacy policy.
- We only share personal data within Assurant on a need-to-know basis.
- We ensure our third parties follow Assurant’s data protection and security standards.
- We keep personal data according to our Global Records Retention Schedule and Information Management policy and then destroy it securely.
- We promptly report suspected privacy incidents and data breaches.
Money Laundering, Terrorist Financing and Economic Sanctions
We’re committed to preventing criminals from abusing our business systems and processes to further unlawful activities. Assurant employees must always follow appropriate due diligence procedures designed to prevent someone from using our company to disguise criminal transactions or engage in any type of money laundering activity. Further, Assurant screens third parties to ensure we don’t transact with individuals or entities on applicable sanctions and/or terrorist watchlists. If you’re concerned about the reputation of any third party seeking to do business or doing business with Assurant, contact Compliance or the Ethics Office.
We all have a role to play in helping to prevent criminals from using Assurant’s products and services. This includes an obligation to know our customers, identify and escalate suspicious activity, maintain required documentation throughout a business relationship, and escalate transactions with sanctioned countries, people or businesses.
Fair Competition and Antitrust
We seek competitive advantage through superior performance, never through illegal or unethical business practices. We comply with all applicable fair competition and antitrust 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. 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. everywhere we operate.
> Our Responsibilities
- We don’t suggest or engage in any actions, understandings or agreements that try to or could limit competition.
- We avoid any kind of contact or discussion with competitors that could create the appearance of impropriety and never share or discuss competitively sensitive information. If we come across these situations, we promptly end them and notify Legal immediately.
- We don’t take advantage of our market position.
- We only use, obtain, accept or receive information about competitors, customers and suppliers to which Assurant is entitled.
Frequently Asked Questions
Generally, competitive intelligence refers to the ability to gather, analyze and use information collected on competitors, customers and other market factors that contribute to a business’s competitive advantage. Please contact your Compliance Officer or Legal for assistance in determining whether the competitive intelligence you have is appropriate to use.
Anti-Bribery and Anti-Corruption
Assurant is committed to conducting its business fairly, honorably, with integrity and in compliance with the law in all jurisdictions where it operates, including all applicable anticorruption and anti-bribery laws.
Assurant has a zero-tolerance policy approach to any form of briberyThe 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. and corruption. Our success depends on the superiority of our products and services, and never as a result of bribery or other means of corruption. Our values don’t permit corrupt acts or payments as a means to gain or retain business for or on our behalf — even if that means losing or walking away from a business transaction.
> Our Responsibilities
- We never offer, promise to provide, or give anything of value to anyone in order to gain a business advantage as described in our Anti-Bribery and Corruption policy.
- We follow due diligence procedures before hiring a third party.
- We don’t ask a third party to do something that we, ourselves, are prohibited from doing.
- We keep thorough and complete records of all transactions with third parties according to our Records and Information Management Policy.
- We don’t enter into verbal contractual relationships with third parties unless in consultation with Legal.
- We don’t provide business courtesies, including gifts, travel and/or entertainment, to government officialsThis 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. or their families without complying with our Anti-Bribery and Corruption policy.
Frequently Asked Questions
Bribery and corruption risks are a concern worldwide and such risks can undermine the health and viability of Assurant and the environments where we operate can greatly damage our reputation and can result in severe fines and criminal proceedings.
Interacting with Government Officials
Assurant follows the highest ethical standards when conducting business with government officialsThis 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.. Assurant strictly prohibits any promise, offer or provision of anything of value to any government official for the purpose of improperly obtaining or retaining business, influencing action, or obtaining any form of improper benefit. We comply with federal, state and local laws when involved in public policy matters and when developing and maintaining relationships with government officials.
> Our Responsibilities
- We don’t offer, promise, make or authorize the giving of anything of value to a government official, directly or indirectly, through family members, close associates, brokers, agents, attorneys, contractors or other business partners that’s inconsistent with our Code and Anti-Bribery and Corruption policy.
- We prohibit even small facilitation paymentsPayments to government officials to expedite an administrative action, such as securing a permit. and, if requested by a government official to provide one, we immediately contact Compliance.
- We cooperate fully with all government and regulatory agency audits and investigations.
- Consistent with the company’s Political Activities Policy Statement, we each have the right to participate in the political process on our own time and at our own expense but may not use Assurant resources for political purposes or contributions without prior approval from Legal. Additional rules may apply to your line of business or role with Assurant.
Import, Export and Anti-Boycott Laws
As a global company, we’re committed to complying with laws and regulations governing the import and export of Assurant products, services, technologies and information everywhere we operate. To deliver on our commitments, we always know what we’re importing and exporting, the parties in the transaction and the origin/destination of our goods.
> Our Responsibilities
- We comply with all applicable laws, regulations and restrictions relating to import, export, boycotts, customs and embargoes.
- We ensure that all imports and exports comply with these requirements.
- Before we engage in these activities, we consult with local import/export support or the Corporate Compliance team.
- We only use Assurant-approved third parties, including customs brokers and logistics providers.
- We ensure information provided to any Customs official or to any agent hired to facilitate Assurant imports and exports is accurate and truthful.
- We report any concerns about customs payments that seem suspicious or out of the ordinary.
- We maintain records of all import and export transactions according to our Record and Information Management policy.
Frequently Asked Questions
Some products or technologies may require an export or an import license before shipment, and certain technical information may not be posted on the internet or attached to an email. Local law might prohibit a sale altogether. These obligations can’t be avoided by using a third party that would deliver the company’s products to a forbidden destination, person or entity.
Before purchasing parts, work with Procurement to get a contract in place. By engaging Procurement (MyBuy on Connect) early, we can screen the supplier to ensure it is legitimate and its parts comply with chain of custodyAll 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. and conflict mineralsA 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. regulations.
Every day, we strive to raise the bar on what it means to do business honestly and ethically, and it’s our commitment to do so with each other, our business partners and our customers.
When in Doubt - Speak Up
If you have questions or concerns, let your manager, the People Organization or the Ethics Office know.