Our responsible business practices touch every aspect of our business and provide a solid footing for all of our actions. They give us the framework to operate with consistency and purpose, from our governance, risk management and investment approaches to the way we manage customer information.
Integrity, respect and responsibility are not just guiding principles at Lincoln Financial; they unify and inspire us to help people take charge of their lives.
The Lincoln Financial Code of Conduct and Conflict of Interest Policy are the center of our ethical culture. The Code of Conduct is more than a set of policies or rules; it is a roadmap that ensures we remain on the path to accomplish our work responsibly.
Lincoln Financial’s legal department provides all 9,000+ employees with mandatory training throughout the year on the Code of Conduct and related policies. The training covers topics including anti-money laundering, anti-fraud, privacy, insider trading, the Code of Conduct and ethics, and conflicts of interest. Many of our employees also receive role-based training from other departments, such as Human Resources and Information Security.
We reiterate the tenets of our Code of Conduct along with our expectation that our employees and agents will behave in accordance with the shared values and principles set forth. We have also designed support systems to make it easy for employees to “do the right thing” every time. Lincoln Financial’s Enterprise Compliance group focuses on empowering employees with the information and tools they need to promote a culture of integrity at Lincoln Financial.
Our employees have access to all of our policies, including our Code of Conduct, through our intranet. Other notable policies include Lincoln Financial’s Conflict of Interest Policy, Political Contribution Policy, and policies related to improper payments and the Foreign Corrupt Practices Act.
An Ethics Helpline is available to employees and is staffed with live agents who answer employee questions and help them navigate difficult situations in a confidential manner.
Each year, a corporate compliance risk assessment is conducted to prioritize risk areas for the year. Matters related to bribery, anti-fraud, collusion, anti-kickback regulations, unfair practices, conflicts of interest and corruption are evaluated as part of this risk assessment.
To ensure colleagues are acting in accordance with internal guidelines, Lincoln Financial regularly collects information regarding compliance with the Code of Conduct and our policies. This information is analyzed and the matters raised are investigated and resolved through the Office of the General Counsel. The legal department meets quarterly with senior management to review significant issues or trends relating to compliance with the Code and our policies. Based on this analysis, we determine whether our policies or training should be revised. The Audit Committee receives quarterly reports on compliance matters. The Lincoln National Corporation Board of Directors (the “Board”) also participates in the oversight of the Code of Conduct and approves changes to the Code.
The Board has adopted a set of Corporate Governance Guidelines to promote the functioning of the board and our committees. The guidelines also set forth a common set of expectations as to how the board should perform its functions. Our board maintains independence standards, which are included in the guidelines. These independence standards require that a majority of our directors must be independent (as defined under the applicable SEC rules) and meet the criteria for independence as set forth in the New York Stock Exchange (NYSE) listing standards.Learn more about our corporate governance. >
The Corporate Governance Committee of the Board provides oversight of the company’s sustainability and corporate social responsibility (CSR) strategy. Lincoln Financial’s efforts focus on promoting sustainable communities and business practices in the areas of philanthropy, volunteerism and environmental impact. The Office of Corporate Responsibility is responsible for developing and implementing the company’s sustainability strategy, which includes the following:
Lincoln Financial recognizes the importance of regularly evaluating environmental, social and governance factors that may impact the business. To formalize this process, we developed and implemented an institutional Sustainability Management System (SMS). The SMS guides us in assessing and managing our environmental, social and economic performance with respect to identified areas of impact. The SMS framework serves as a guide for how to document our management processes and procedures, monitor their outcomes and continually evolve our performance over time. The system follows a plan-do-check-act (PDCA) framework and includes audit procedures for critical areas so that we can verify the accuracy of data and information we publish.
Enterprise risk management is an integral part of our business processes. Senior management is primarily responsible for establishing policies and procedures designed to assess and manage the Company’s significant risks. We also have a Corporate Enterprise Risk and Capital Committee, made up of members of senior management and the Chief Risk Officer, which provides oversight of our enterprise-wide risk structure and of our processes to identify, measure, monitor and manage significant risks, including credit, market and operating risk. The Board’s role is regular oversight of the overall risk management process, including reviews of operational, financial, legal and regulatory, cybersecurity, compensation, strategic and competitive risks.
For two years in a row, Lincoln Financial has received the “Insurance Risk Management Team of the Year” award from the EQDerivatives Editorial Board. Our market risk management program uses hedging strategies to reduce risk and volatility from variable annuity products. This recognition reinforces the strength of our risk management program and the quality of our investment guarantees.
Through Lincoln Financial’s risk assessment process, we have identified potential risks to business operations and profitability driven by physical climate change parameters, such as severe weather events. In Lincoln Financial’s SEC filings, including our Annual Report and Form 10-K, the results of certain weather-related catastrophic events typically associated with climate change are cited as a global risk factor that could potentially affect claim liabilities and the availability of reinsurance. Climate change and other environmental and social impact risks are identified and assessed through the company’s Risk Self-Assessment process and the Emerging Risk Task Force.
The Office of Corporate Responsibility oversees enterprise-wide integration of sustainability practices along with climate change risk and opportunity assessment. The office routinely gathers and assesses information relating to relevant business risks stemming from climate change that may impact the company. It is also responsible for the integration of enterprise-level processes for further evaluation of climate change risks and impacts on the business in general, including the management of environmental risks to physical assets.
Severe weather has the potential to impact Lincoln Financial’s facilities directly. To mitigate the impact of such events, business continuity and disaster recovery plans are in place for critical business units. Risk assessments are also conducted at specific sites with greater exposure to natural risks, such as severe winter weather and tornadoes.
As a financial services provider primarily engaged in the sale of products and services associated with life insurance, annuities, defined contribution, group life, disability and dental, our company is focused on a variety of risks associated with these businesses. The primary risks associated with these business lines are mortality, morbidity, longevity, policyholder behavior and capital markets risk. As a result, enterprise risk management is an integral part of our business processes.
The corporate Enterprise Risk Management team calculates capital requirements based on catastrophic and other extreme events, which would encompass climate-driven scenarios. Lincoln Financial’s risk management processes are designed to promote awareness of new, existing and potential risk factors to meet existing and evolving circumstances.
To mitigate financial and other risks identified in our 10-K report, Lincoln Financial reinsures a significant amount of the mortality risk on fully underwritten, newly issued, individual life insurance contracts. If Lincoln Financial were to experience adverse mortality or morbidity events, a significant portion of claims would be reimbursed by our reinsurers.
Lincoln Financial understands the importance of considering environmental, social and governance (ESG) factors in our investments. Our portfolio management professionals, as well as our internal and third-party asset managers, are guided by our ESG Investment Policy as they integrate ESG considerations into their due diligence, monitoring processes and investment decision-making. Climate change factors may also result in additional risk to our investment portfolio. These risks can include operational, market, liability, policy and regulatory risks.Read our ESG Investment Policy. >
We recognize that our customers are also thinking about environmental, social and governance factors in their investments. For this reason, we offer a variety of socially responsible investment options in a number of our products, including personal variable annuities, Lincoln DirectorSM group variable annuities and other retirement plan solutions.View a list of these funds. >
Lincoln Financial Group is committed to keeping the personal information collected about our potential, current and former customers confidential and secure. Lincoln Financial is subject to both federal and state legislation and regulation governing the protection of the nonpublic personal financial and health information we receive about our consumers and customers. Proper handling of confidential information, including nonpublic personal information, which consists of medical, financial and employment information, and strategic business and financial information, is important to Lincoln Financial. We have adopted policies and procedures that we believe are reasonably designed to comply with all applicable federal and state privacy legislation and regulations governing the protection of our customer nonpublic personal information.
Lincoln Financial has developed an information security program that addresses physical and logical security, user access management, network perimeter security, incident management, logging and monitoring, vulnerability management, data encryption, application controls, change management, security awareness, and other information risk management controls. Lincoln Financial has also adopted an incident response program.
The Chief Information Security Officer is in charge of security for Lincoln Financial. We also have a dedicated Privacy team that reports to the company’s Chief Privacy Officer. The Information Security and Privacy teams each report up to an executive officer.
We recognize that our employees play a key role in keeping information secure. Information security training is required for all employees and contractors annually. Additional privacy training is mandated annually for all employees.
The company has a business records retention program that mandates specific retention and destruction time frames for all records according to record type and use. Retention and destruction policies are reviewed annually and updated as needed to ensure compliance with said laws and regulations.
Multiple internal audits of the company’s information risk management practices are conducted each year, including an annual holistic audit covering the company’s information security processes. In addition, four external audits are conducted annually that cover (to varying degrees) the company’s information security practices surrounding various specific Lincoln Financial products and systems. Information security policies and standards are reviewed annually and are updated as necessary to appropriately manage information risk consistent with industry standards.Learn more about our policies and practices. >