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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 with
concerns regarding Accounting Matters may report their
concerns or complaints to the General Counsel of the
Company.
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 75070-8080
and/or
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| 2. |
Employees may
forward complaints or concerns regarding Accounting Matters
on a confidential, anonymous basis to the Audit Committee
through regular mail marked CONFIDENTIAL and addressed as
follows:
Chairman of Audit Committee
Torchmark Corporation
P. O. Box 8080
McKinney, Texas 75070-8080 |
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. |
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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, the Corporate Secretary will
maintain a log of all complaints, tracking their receipt,
investigation and resolution and shall prepare a periodic
summary report thereof for the Audit Committee. Copies
of complaints and such log will be maintained in accordance
with the Company's document retention policy. |
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