People want to interact with companies they trust. At Cigna, we focus on earning, building, and maintaining the trust of our customers, clients, employees, business partners, and regulators. The more personal the topic, the more important trustworthiness becomes—and health care is a very personal topic. Conducting business ethically is critical to Cigna's continued success. To us, that means more than just obeying laws and regulations. It means meeting consistent standards of integrity in everything we do at Cigna.
Codes of Ethics and Principles of Conduct
Our Code of Ethics and Principles of Conduct (the “Code”) is the foundation for our unwavering commitment to integrity, compliance, and ethical conduct. The Code is a “real-world guide” to the behaviors and principles of conduct we embody as a team committed to making life better for millions of people in all corners of the world.
In our Code, we pledge to honor integrity in protecting company assets, reputation, and goodwill (including the avoidance of conflict of interests). We also emphasize Cigna's commitment to integrity in the marketplace, public sector, and workplace; and our role as a socially responsible corporate citizen. Cigna’s Code applies to directors, employees, and officers; and is published in Arabic, Chinese, English, Flemish, French, Indonesian (Bahasa Indonesia), Korean, Spanish, Thai, and Turkish. We also maintain a separate Director Code of Conduct that addresses obligations specific to directors of Cigna. In addition, Cigna has a Supplier Code of Conduct, which we include in our standard supplier contracts. Each of our codes sets forth 4 basic ethical principles, including compliance with all applicable laws, rules, and regulations; avoidance of conflicts of interest; protection of company assets; and a commitment to behave ethically.
A Strict Stance Against Bribery and Corruption
Due to Cigna's emphasis on doing business ethically and with integrity, we take anti-corruption compliance very seriously. Moreover, the legal requirements in just about all parts of the world in which Cigna does business prohibit improper payments to government officials. In many cases, government officials include obvious parties like the regulators who oversee Cigna's business, but also less obvious parties like employees of public hospitals with whom we work on a regular basis.
As part of our Code, it is Cigna's policy to conduct business ethically and to prohibit bribery of government officials in connection with the conduct of its business throughout the world. Cigna also maintains an anti-corruption policy, which covers specific topics related to anti-corruption, including facilitation payments. Bribery of government officials is illegal under the United States Foreign Corrupt Practices Act ("FCPA"), the U.K. Bribery Act, the Chinese Anti-Unfair Competition law, and the laws of many other countries in which we conduct business (collectively, the "Anti-Corruption Laws"). Violation of these laws subjects Cigna and its employees to potential criminal and civil liability, as well as reputational harm. It is the Company's policy that it and all of its wholly owned or controlled subsidiaries, directors, officers, employees, agents, and representatives comply with the spirit and the letter of the Anti-Corruption Laws at all times. Cigna is also a member of TRACE International, a globally recognized anti-bribery business organization.
Small payments given to a government official to expedite a routine, non-discretionary administrative action (sometimes referred to as facilitating payments) are not permitted under Cigna's anti-corruption policy, except (1) in exceptional circumstances and where permitted under local law; and (2) only with prior, written approval of the International Compliance Officer. If, in an emergency, an employee is compelled to make a payment to ensure personal health or safety, the payment must be reported to the International Compliance Officer at the earliest opportunity.
Enterprise Compliance and Ethics Oversight
In 2018, Cigna’s Enterprise Compliance organization continued to focus on reinforcing our organizational approach and culture of compliance with our business partners and customers. We continue to stress the duty to report instances of non-compliance and Cigna’s strong stance on no retaliation. As part of this initiative, we launched a communication strategy to help the organization understand the role of the Ethics Office and the investigation process. Videos discussing Cigna’s anti-retaliation policy were created and shared to further emphasize our strict policy against retaliation when someone reports something in good faith. We want employees to feel comfortable reporting what they perceive to be wrong-doings without the fear of retaliation.
In 2018, we created the Chief Ethics Officer role, reporting directly to the Global Chief Compliance Officer. Additionally, we made enhancements to our core compliance controls and our risk reporting processes. The compliance organization continues to engage with their business partners to discuss compliance requirements and conduct compliance risk reviews. These reviews are reported to the Enterprise Compliance Risk Officer and shared with Enterprise Risk Management for reporting purposes. Reporting and oversight at the highest level of the organization are achieved through regular meetings of the Global Chief Compliance Officer and General Counsel with the Audit Committee of the Board of Directors to inform them of key compliance topics. In late 2018, the Board of Directors established a Compliance Committee to oversee our key compliance and ethics programs, including compliance with the laws and regulations that apply to our business operations, such as data privacy and U.S. federal and state health care program requirements.
Ethics Training and Employee Engagement
We train all new employees on our Code and all employees affirm their adherence annually to the Code. In 2018, we continued our approach to design courses that include engaging and interactive content for learners and provide a more role-based approach to learning. We also train our Board of Directors on their obligations under the Director Code of Conduct and the Code. We inform the highest levels of the organization of ethics issues, including information regarding reported ethics violations concerns and actions taken, through reports to the Compliance Committee, which, in turn, informs the Board of Directors and the Audit Committee.
Cigna maintained a robust compliance and ethics communications calendar to emphasize the critical part that compliance and ethics play in Cigna's business operations, as well as, to inform employees about the resources available to them. To convey Cigna leaders’ commitment to the program and to our core value of acting with integrity, Cigna business leaders and the Enterprise Compliance organization communicate directly with employees throughout the year using emails, articles, and videos. The content emphasizes the importance of ethics and compliance, with a particular focus on how a strong ethical culture helps Cigna succeed as a business.
In 2019, we are focused on: building upon our ethical culture as we integrate our business and compliance functions with Express Scripts, reviewing and refreshing our Code of Ethics to create an interactive and dynamic tool for workforce members, delivering an enterprise-wide Compliance Ethical Culture Survey, and creating engaging compliance training that focuses on expected behaviors through role-based content.
Global Anti-Corruption Reporting, Training, and Risk Management
As a large global enterprise operating in approximately 30 countries and employing a multi-lingual workforce, there are a variety of challenges to address. One challenge we are addressing is scoping emerging FCPA risks in new markets, like Africa and the Middle East. Also, we continue to identify risk areas that would benefit from focused in-person training. For example, in the Middle East, where we are focusing on our Business to Government segment, additional anti-corruption training has been provided to client-facing employees. We work diligently to promote a culture of compliance so that employees report misconduct without fear of retaliation. We are continually raising awareness of risks related to corruption, specifically as they relate to Cigna's lines of business and geographies, in our focus on doing the right things for our customers, clients, partners, and communities around the world.
Employees are required to report any request for an improper payment by a government official to the Compliance Organization and have an affirmative duty to report actual or potential violations of Cigna's anti-corruption policy or the Anti-Corruption Laws, whether by employees or third parties, to the Compliance department. Certain employees are identified to receive training on anti-corruption principles and on Cigna's anti-corruption policy based on their role. In 2018, we rolled out an online anti-corruption training for our Board of Directors. Employees working in higher risk business units receive in-person anti-corruption training. Third parties outside the United States are assessed on a risk-based basis and higher risk parties are required to agree to anti-corruption contract language.
In 2018, Cigna's Enterprise Compliance and Internal Audit teams completed a data-driven FCPA Advisory Audit of our joint venture in China, one of the higher risk countries for anti-corruption where Cigna does business. In 2018, we expanded our Enterprise Compliance International team to provide dedicated support for anti-corruption and economic sanctions issues.
As we acquire new businesses, we work to integrate them into our global compliance program and our anti-corruption management process. As noted above, in late 2018, the Board of Directors established a Compliance Committee to oversee our key compliance and ethics programs. The Committee receives quarterly reports from the Global Compliance Officer, including an annual report on Cigna's anti-corruption program.
Integrity in Human Rights and Labor
Cigna supports fundamental human rights. While national governments bear the primary responsibility for upholding human rights, our company practices and policies, including policies addressing equal employment, harassment avoidance, charitable contributions, anti-corruption, and workplace safety, work to promote and protect human rights.
We strive to conduct our business in a manner consistent with the United Nations Universal Declaration of Human Rights and the International Labor Organization’s Fundamental Conventions.
We actively monitor employee complaints and grievances and produce quarterly trend reports to identify potential issues or locations where additional actions may be required. We also emphasize the importance of respecting employees’ rights in our manager training and through our Cigna University curriculum. Additionally, we post notices informing employees about their rights to unionize and enter into collective bargaining agreements.
Cigna has published a Human Rights Statement, which addresses human rights within the context of:
Through a focus on health equity, which is the pursuit of the elimination of health disparities, we strive to give individuals the best opportunity to achieve a healthier life and overcome health disparity barriers related to factors such as ethnicity, race, gender, age, geography, or economics.
We take an active, affirmative approach to ensure an appreciation of our individual and collective experiences, different ways of thinking and diverse communication styles. Cigna is committed to treating every employee with respect and protecting their human rights. Cigna does not discriminate in hiring, promotions, salary, or any other terms or conditions of employment, nor do we tolerate any form of harassment, whether verbal or physical.
Our Supplier Code of Ethics addresses integrity in human rights and labor and describes our expectations in the areas of: community, prohibition of child labor and forced labor, wages and working hours, health and safety, freedom of association, and non-discrimination and harassment prevention.
Whistleblower Protection and Addressing Reports of Potential Misconduct
Cigna maintains and communicates its policy of no retaliation when reporting is made, in good faith, regarding Cigna’s Code, principles or other compliance concerns. Additionally, if employees participate in an investigation of related matters, they will not be subject to retaliation. Furthermore, Cigna employees who engage in retaliation are subject to disciplinary action up to, and including, termination of employment.
Cigna also provides access to our 24-hour, toll-free Ethics Help Line and dedicated websites to assist employees around the world with any questions, or to enable them to report concerns and/or instances of potential misconduct.
Reports of potential misconduct are taken very seriously, and are systematically reviewed, investigated, and monitored by our Enterprise Compliance and Employee Relations teams.
Disclaimer: The report covers calendar year 2018 and unless otherwise noted, excludes the combination with Express Scripts, which closed on December 20, 2018.