Delivering on Our Commitments

As Alliance Data has matured since its founding, our culture of caring and doing the right thing has deliberately evolved into a principled, stakeholder driven sustainability strategy. We hold ourselves accountable to our stakeholders and to the pillars of our strategy, while aligning with respected global frameworks. Reporting publicly on our progress keeps us on track and further demonstrates our commitment to transparency, accountability and good practice.

Our Strategy

Our approach is rooted in the understanding that to grow our business and prosper over time, we must meet the evolving needs and expectations of a broad range of stakeholders. We answer to our partners and their customers; our associates; stockholders and investors; regulators and policy makers; and our communities and neighbors around the globe. By engaging regularly with them, we gain valuable input and insights that inspire ideas and strategies for creating shared value.

Ethical Decision-Making

Driving global growth and long-term success through integrity, ethical decision-making and transparency.

28% Board diversity
(female representation)
97.7% Associates completing annual ethics training
93% Say on Pay Support – executive compensation score
$0 Significant fines or
monetary sanctions

Management Approach

Business Integrity and Ethics

Business integrity, ethics and compliance with all applicable laws and regulations governing our business are among the guiding principles that influence planning and decisions related to Alliance Data’s operations and success. Our leaders set the tone at the top and foster a culture of integrity and accountability.

We operate under a comprehensive Code of Ethics, which covers numerous aspects of conduct expected of our associates. We also maintain supplementary codes of ethics for our Board of Directors and senior financial officers, which address additional standards and guidance applicable to their roles.

We have a long tradition of good corporate governance, and our Board of Directors continues to develop, support and oversee the implementation of responsible, stakeholder-centric practices consistent with the evolving governance environment, our stakeholders’ expectations and the commitments we’ve made to them.



Lead in data-driven marketing and loyalty programs, ensure the secure and responsible use of data, adhere to responsible lending practices and display an unwavering commitment to service.

44.6M Active cardholder accounts
+4.26% Above industry average in customer satisfaction
47.7 Credit card complaints per million active accounts (low among credit card banking peers)
0 Data breaches

Management Approach

Information Security and Data Privacy

Respecting consumer privacy and safeguarding information are central to everyone’s role at Alliance Data. Our commitment to good data governance and protection in these critical areas is foundational to our ability to help our clients understand and build relationships with their customers, and for consumers to understand how data is governed.

Our attention to data security and privacy starts with policies and practices governing both enterprise-wide and specific lines-of-business controls and compliance procedures. These policies and practices address how we manage our privacy commitments, responsibilities, obligations and marketplace expectations, and privacy and security risks, and how we monitor threats, collaborate across the enterprise and report to the Board.

Dedicated cybersecurity and privacy teams across the company establish and monitor standards, protocols and management processes. Our clients also depend on us to stay on top of the most current developments in data security and privacy, and to provide insights and education to ensure adherence to strong consumer privacy and data protection expectations, controls and practices.

Fair and Responsible Banking

We are committed to building trust and providing outstanding service to our clients and cardmembers. Comenity Bank and Comenity Capital Bank are the banks behind Alliance Data’s branded consumer credit programs. We work with top companies and some of the best-known retailers to extend their brands with their customers through innovative private label, co-brand and commercial credit card programs.

Applying the industry’s most advanced analytics and data-driven consumer insights, we deliver meaningful customer experiences through tailored credit solutions that build relationships, drive brand affinity and enhance customer loyalty. Whether our cardmembers shop with our clients in-store, online or through a mobile device, we deliver consistent, seamless customer experiences across all consumer touchpoints.

Credit and lending

As a leading provider of branded credit programs, fair and responsible lending is core to our cardmembers’ journey with us. Our credit programs create a win-win for consumers and clients. Significant consideration and detail go into ensuring the consumer credit application and underwriting processes are administered fairly.

We adhere to a straightforward, transparent, impartial and equitable process for our lending practices. This is made possible through our fully automated proprietary process, which has been rigorously calibrated to accurately analyze and issue credit based on unbiased statistical modeling criteria. For further assurance, each year we employ an outside third party to conduct an extensive review of our credit portfolio and evaluation metrics, screening for any evidence of unintentional bias or discrimination to further ensure fair and responsible lending protocols.

Customer care

Delivering an exceptional customer experience is at the heart of our business practices, and our award-winning Care Centers are dedicated to creating that positive experience for our valued cardmembers throughout every interaction. Whether communicating approved credit, answering cardmember questions or collecting a payment, we recognize that every opportunity to connect with cardmembers counts. Advancing our customer-centric approach is an ongoing imperative.

Responsible Marketing

Across the entire enterprise, through our data-driven marketing services and across all channels, we work with clients to create marketing campaigns that result in relevant, meaningful communication for end-consumers.

We believe consumers should understand how information is provided and used for marketing purposes. The more informed consumers are about the use of data for marketing purposes, the more they can enjoy the many benefits provided by the responsible use of information.



Cultivate an inclusive, healthy workplace where we develop and reward associates – and empower them to contribute to our continued success.

8,500 Total number of associates
62% Total workforce diversity
(female representation)
41% Senior leadership diversity
(female representation)
18% Voluntary turnover

Management Approach

Attracting and Retaining Top Talent

The better we do at meeting our associates’ needs, the better we’ll do as a company. The same shifting of expectations among clients and consumers that is disrupting the marketplace is also impacting the workplace – and we’re innovating to keep pace.

Associate experience

Every associate’s workday is made up of scores of discrete tasks: training, performance and career planning, timekeeping, collaboration across teams and locations, and so on.

Training and development

We offer a variety of online and on-site structured training, coaching, tuition reimbursement for external courses and on-the-job learning opportunities.

In our Care Centers, virtual training sessions help minimize downtime and improve productivity. In one example, our customer care associates attended a virtual presentation on the topic of negotiation that saved approximately 30 hours of productivity by enabling us to run larger sessions than would typically fit into a classroom.

Physical and financial well-being

There’s a well-established connection between associate health and well-being and an associate’s ability to do his or her best work. Our data also tells us that associates who join one of our on-site fitness centers, undergo company-provided health checks or participate in our 401(k) plan are significantly more likely to stay with the company. For these reasons, we have long had programs to support associate physical, mental and financial well-being.

Diversity, Equality and Inclusion

As a company with clients, end-consumers and associates around the world, we work to reflect the diversity of the markets we serve and embrace different backgrounds, viewpoints, skills and talents.

Consistent with our values, our Code of Ethics states that we will not discriminate based on race, color, religion, religious dress and grooming, gender, pregnancy, age, national origin, disability, sexual orientation, marital status, citizenship, veteran status, gender identity, transgender status or any other protected status.

Beyond the Code, and basic protection of individual rights, we actively promote diversity, equality and inclusion (DE&I). Alliance Data has established Business Resource Groups that provide an opportunity for professional development, education, and social and community involvement for our associates from unique backgrounds.

At the Board and leadership levels, the focus has been on promoting gender and skills diversity. While demographics have been the focus of associate diversity efforts in the past, the Board of Directors adopted the Rooney Rule in 2019, which is a commitment to include women and underrepresented minority candidates in every pool from which Board nominees are chosen. Our Board is also regularly briefed on our diversity performance, including gender make-up, gender leadership, Board refreshment and pay equity.



Invest in the long-term vitality of our communities through programs and initiatives that make a measurable impact.

~$10M Community investment (donations)
26,500 hours Community investment (volunteerism)
8% Supplier diversity spending
93% of associates agree that Alliance Data encourages associates to participate in activities that benefit the community.

Management Approach

Community Investment

Our company is only as strong as the communities where we work and that we serve. Alliance Data directly supports people, associations and agencies in those communities by investing in an array of targeted initiatives.

We continue to grow our community investments commensurate with the growth of our business. Our four focus areas are based on what’s most important to our associates, where our communities need the most support and how we can promote a sustainable economic environment:

  • Education — helping students of all ages acquire the skills and knowledge they need to achieve their highest potential and become productive members of society
  • Children — promoting, protecting and improving the lives and health of children
  • Independence — maximizing individuals’ independence and self-determination
  • Environment — respecting the impact our operations have on the environment and striving to measurably reduce our carbon footprint

In addition, we prioritize investments that connect associates, align with our expertise, are geographically inclusive, provide measurable impact, and enhance our brand and reputation.

Community Reinvestment

Under the Community Reinvestment Act (CRA), passed in 1977 as a measure to expand access to credit, federally insured depository institutions like Comenity Bank and Comenity Capital Bank have an obligation to support the credit needs of the communities in which they are located.

Comenity and Comenity Capital are subject to regulatory supervision by the FDIC and the Consumer Financial Protection Bureau (CFPB), in addition to state supervision in Delaware and Utah, where the banks are respectively headquartered. In our most recent FDIC examination, we received the highest rating of “outstanding” for our activities under the CRA.

Comenity’s holistic approach to community reinvestment engages and connects local stakeholders and resources, as well as community development investments and services, to meet the greatest needs of the communities it serves. These programs are led by an officer appointed by the bank’s Board of Directors, with oversight from respective bank committees.



Respect our environment through sustainable operations and investments in global conservation efforts.

8% Electricity from renewable sources
120,005MT CO2e Greenhouse gas emissions (total)
8% reduction in CO2e emissions
79% of associates say that Alliance Data is environmentally responsible

Management Approach

Reducing Our Carbon Footprint

Alliance Data has an ongoing commitment to reducing our greenhouse gas (GHG) emissions to help combat climate change. Our efforts extend to all lines of business, stakeholder groups and our work in the community.

The starting point of our efforts to reduce our carbon footprint is capturing our GHG inventory, which details and quantifies our emissions. We completed our eighth inventory in 2019, and we are using the results to better understand and manage our impacts and to report to the CDP. The GHG inventory also provides the basis for ultimately setting science-based emissions reduction targets.

Using Resources Efficiently

Our GHG inventory indicates that some of our biggest environmental impacts are energy consumption, paper usage and associate commuting — so that’s where we focus our environmental efforts.

Energy conservation

Facility managers are responsible for conservation projects at their respective buildings. Improvements have been made by upgrading to energy-efficient LED lighting and removing desktop printers in existing buildings. However, the biggest gains come from new facilities that are designed for efficiency from the start: LoyaltyOne’s headquarters has received LEED Platinum certification and the Company has been recognized as one of Canada’s Greenest Employers.


The majority of our paper purchase is based on the needs of our clients. Paper is used in client-driven marketing materials and cardmember or collector statements, although many clients are shifting from print to digital formats. We’ve made strong gains internally by switching from individual desktop printers to multi-function devices (MFDs), which are shared by multiple users and discourage unnecessary printing. MFD defaults are set to double-sided black-and-white printing.


Efforts to minimize emissions from commuting include work-from-home programs, which are rare for the industry, electric car charging stations, and bike racks and on-site shower facilities to encourage cycling to work.


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