Amendments to the Code of Conduct and Business Ethics

Our Code of Business Conduct and Ethics (the "Code") was substantially revised and updated effective March 1, 2008. The new Code differs from the prior version most significantly in the way the material is organized and presented. Significant policy changes and additions include the following:

Commitment to Non-Retaliation. This policy is new only in that it is a stand-alone policy; in the prior Code, the non-retaliation commitment was included in the general Code violation reporting policy. This change is designed to highlight our non-retaliation commitment.
Sexual Harassment. Our detailed sexual harassment policy has been removed from the Code and included in a separate document for employees. The Code now provides a brief statement of our prohibition of sexual harassment and links employees to the full policy.
Gifts and Entertainment. The new Code modifies our former policy on this topic to prohibit Progressive people from offering or accepting gifts, entertainment or meals to or from anyone doing or seeking to do business with Progressive, unless one of the narrow exceptions applies.
Wage and Hour Compliance. This is a new stand-alone policy prohibiting Progressive employees from falsifying their timecards and requiring them to take affirmative steps to correct inaccurate time records.
Alcohol and Illegal Drugs. Previously, our substance abuse policy was published in a separate document for employees. The policy, among other matters, prohibits the use, possession, sale, purchase, solicitation, distribution or being under the influence of alcohol or any illegal drug during working time (including meal times), at any time on Progressive premises or inside a Progressive-supplied vehicle, and under certain other circumstances.
Diversity. This is a new statement of policy based on our current corporate diversity statement; it is not a change in policy on the subject. The policy is now included in the Code to highlight the importance of diversity to our organization.
Records Management. This is a new stand-alone policy summarizing records management responsibilities.
Public and Investor Communications. This is a new stand-alone policy requiring Progressive people to route media inquiries through our Integrated Marketing and Communications Group and to avoid attributing comments to Progressive when communicating publicly, whether live or via electronic communications media.
Addendum. The Addendum is a new feature of the Code. The Addendum collects special rules for Claims people and several technical exceptions to the Conflicts of Interest policy.