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

  1. 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;
  2. and/or

  3. 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.
General Counsel
Torchmark Corporation
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:

Treatment of Complaints

Reporting and Retention of Complaints and Investigations

Revised July 2010