Employee Complaint Procedures
for Accounting and Auditing Matters
Any employee of Torchmark or its subsidiaries may submit a good faith complaint regarding accounting or auditing matters to the management of the Company without fear of dismissal or retaliation of any kind. The Company is committed to achieving compliance with all applicable securities laws and regulations, accounting standards, accounting controls and audit practices. Torchmark's Audit Committee will oversee treatment of employee concerns in this area.
In order to facilitate the reporting of employee complaints, the Company's Audit Committee has established the following procedures for (1) the receipt, retention and treatment of complaints regarding accounting, internal accounting controls, or auditing matters ("Accounting Matters") and (2) the confidential, anonymous submission by employees of complaints or concerns regarding questionable accounting or auditing matters.
Receipt of Employee Complaints
- Employees may submit complaints or concerns regarding Accounting Matters on a confidential, anonymous basis to the Audit Committee by telephoning a toll-free number (1-877-854-0033) that is monitored by an independent, third party reporting service;
- Employees with concerns regarding Accounting Matters may also report their concerns or complaints to the General Counsel of the Company if confidentiality is not required or sought. The General Counsel shall forward a copy of the same to the Chairman of the Audit Committee.
P. O. Box 8080
McKinney, Texas 75070
Scope of Matters Covered by These Procedures
These procedures relate to employee complaints relating to any questionable accounting or auditing matters, including, without limitation, the following:
- Fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement of the Company;
- Fraud or deliberate error in the recording and maintaining of financial records of the Company;
- Deficiencies in or noncompliance with the Company's internal accounting controls;
- Misrepresentation or false statement to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports or audit reports of the Company; or
- Deviation from full and fair reporting of the Company's financial condition.
Treatment of Complaints
- Upon receipt of a complaint, the Chairman of the Audit Committee will direct General Counsel to (i) determine whether the complaint actually pertains to Accounting Matters and (ii) when possible, acknowledge receipt of the complaint to the sender.
- Complaints relating to Accounting Matters will be reviewed under Audit Committee direction and oversight by the General Counsel, Internal Audit or such other persons as the Audit Committee determines to be appropriate. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review.
- Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee.
- The Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment based upon any lawful actions of such employee with respect to good faith reporting of complaints regarding Accounting Matters or otherwise as specified in Section 806 of the Sarbanes-Oxley Act of 2002.
Reporting and Retention of Complaints and Investigations
- At the direction of the Audit Committee, a log of all complaints, tracking their receipt, investigation and resolution shall be maintained and periodic summary reports thereof shall be prepared for the Audit Committee. Upon their ultimate resolution, copies of complaints and such log will be maintained in the Office of the Corporate Secretary in accordance with the Company's document retention policy.
Revised July 2010