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People want to interact with companies that 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 trust is – and we recognize that health care is a very personal topic. Conducting business ethically is critical to Cigna's continued success as a business.
To us, that means more than just obeying laws and regulations. It means meeting consistent standards of integrity in everything that we do. Our ethics, compliance, and employee relations teams play a critical role in driving ethical behavior and values throughout the company by creating a culture that is designed to help employees meet their responsibilities to be ethical corporate citizens and support the dignity of workers across our value chain.
Code of Ethics and Principles of Conduct
Our Code of Ethics and Principles of Conduct is the foundation for our unwavering commitment to integrity, compliance, and ethical conduct. The compliance and ethics teams oversee the annual review and update to the Code, which is applicable to all employees, officers and directors, consultants, suppliers, volunteers, interns and trainees, and those who work with us under collective bargaining agreements.
In 2020, Cigna updated its Code as part of an annual refresh process. The subsequent Code was approved by Cigna’s Board of Directors. The Code continues to address key topics, including avoiding conflicts of interest; promoting a respectful and safe workplace; engaging in full, fair, and accurate reporting; protecting private, sensitive, or confidential information; refraining from insider trading; preventing money laundering; honoring economic sanctions and trade restrictions; engaging in fair business practices and competition; respecting the environment; and adhering to laws and regulations affecting the conduct of Cigna’s business, as well as Cigna’s prohibition on retaliation against any individual who, in good faith, reports violations of company policy or unlawful conduct. The latest updates to the Code further strengthen our commitment to compliance, ethical conduct and integrity, and our core values, including by providing examples of acts that could constitute a bribe. In addition, the Code satisfies the listing requirements of the New York Stock Exchange, which mandate that a code of conduct address at minimum conflicts of interest; corporate opportunities; confidentiality; fair dealing; protection and use of company assets; compliance with laws; rules and regulations; and reporting of illegal or unethical behavior.
Cigna’s Code is published in Arabic, Chinese (Simplified and Traditional), Dutch, English, French, French Canadian, Indonesian, Italian, Korean, Spanish, and Thai. While we expect our suppliers and contractors to conduct activities on behalf of Cigna in a manner that is consistent with our Code, Cigna also has a Supplier Code of Ethics, which we include in our standard supplier contracts. Both of these codes set forth several 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
Cigna’s emphasis on doing business ethically and with integrity means we take anti-corruption compliance very seriously. Moreover, the legal requirements in the vast majority of the countries in which Cigna does business prohibit improper payments to government officials. In many cases, government officials include not only the regulators who oversee Cigna’s business but also 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 our business throughout the world. It is also Cigna’s policy to avoid any conduct that creates even the appearance of improper interaction with a government official or commercial business, as required by the U.K. Bribery Act. Cigna also maintains an Anti-Corruption Policy, which was reviewed and refreshed in 2020. The policy covers specific topics related to anti-corruption, such as bribery and facilitation payments. It covers several areas that have been the subject of prosecutions in recent years including charitable contributions, hiring at the request of government officials, and interacting with government officials using third parties. Bribery of government officials is illegal under the United States (U.S.) 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”). Violations of these laws subject Cigna and its employees to potential criminal and civil liability, as well as reputational harm. As such, it is the Company’s policy that Cigna and all of its wholly owned or controlled subsidiaries, joint ventures, directors, officers, employees, agents, and representatives must comply with the spirit and letter of all Anti-Corruption Laws at all times. Facilitation payments, which Cigna strictly prohibits, are also covered in the policy. Facilitation payments, also known as “expediting payments” or “grease payments,” are payments made to induce foreign officials or political parties to perform routine functions that they are otherwise obligated to perform.
In 2020, Cigna conducted an anti-corruption and economic sanctions risk assessment focused on business units outside the U.S. We leveraged the results of the risk assessment to provide enhanced training and testing in higher-risk countries.
Cigna is proactive about staying abreast of anti-corruption best practices. To this end, we are a member of TRACE International, a globally recognized anti-bribery business association, and Gartner, a general resource for compliance, ethics and anti-corruption.
Enterprise Compliance and Ethics Oversight
Cigna’s Enterprise Compliance organization and the Ethics Office continues to reinforce our culture of integrity and compliance with our business partners. A key element of Cigna’s culture of compliance is the company’s maintenance of a dedicated Chief Ethics Officer. The role reports directly to our Chief Compliance Officer and has visibility across the enterprise.
We also continue to stress both the duty that employees have to report actual or suspected misconduct as well as Cigna’s strong prohibition against retaliation. As part of these efforts, we launched a communication strategy to help the organization understand the role of the Ethics Office and the investigation process.
In 2020, we have also continued to make enhancements to our core compliance controls and our risk-reporting processes. The compliance organization continues to engage with business partners across the organization to review 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 Chief Compliance Officer and General Counsel with the Compliance Committee of the Board of Directors to inform them of key compliance topics. The Compliance Committee of the Board of Directors oversees 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. The Compliance Committee is advised of any significant investigative matters. In addition, the Chief Ethics Officer presents, to the Compliance Committee of the Board, an overview of ethics-related milestones and priorities as well as an overview of ethics and compliance concerns reported to the Ethics Office and the Ethics Help Line.
In addition, on a quarterly basis, the Ethics Office prepares operational reporting regarding ethics and compliance concerns reported to the Ethics Office and the Ethics Help Line to compare it to both internal historical data and external benchmarking data, to identify potential or emerging risk areas or trends, and to evaluate any training and awareness needs.
This reporting occurs at the enterprise level and at the level of Cigna’s three primary business lines: Evernorth, U.S. Medical, and International Markets. Among other things, our operational reporting tracks overall Ethics Help Line volume; the types of guidance sought or allegations raised; the volume of investigative matters that were substantiated or unsubstantiated; any disciplinary actions taken; the number and type of matters referred to Legal/Litigation; anonymity rates; and average time to close data.
In 2020, Cigna also conducted an Ethics Survey to canvas our employees on our ethics and compliance program and gain insight and benchmarking regarding the ethical culture. Cigna partnered with Ethisphere, a global leader in advancing ethical business standards and practices, to conduct the survey and:
- Confidentially and anonymously canvas our employees;
- Get an objective measurement of our ethical culture and compliance program globally;
- Obtain critical external benchmarking to help measure the effectiveness of our program against corporate peers; and
- Identify potential risk areas and evaluate training and awareness needs to help guide future program development.
The results of Cigna’s Ethics Survey were strong and reflective of a culture that emphasizes integrity and ethical behavior.
Ethics Training and Employee Engagement
We train new employees, including part-time workers and contractors, on our Code. Additionally, employees affirm their adherence to the Code annually. Similarly, our Board of Directors is also trained on their obligations under the Code and the Director Code of Conduct.
Cigna maintains a robust compliance and ethics communications calendar to emphasize the critical part that compliance and ethics play in Cigna's business operations and to inform employees about the resources available to them. To convey our leadership’s 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. We also design training courses that provide a more role-based approach to learning and include engaging and interactive content for learners. 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, a Compliance Training Council was established to review and develop new compliance training for all employees in 2020. In 2020, Cigna created a new Required Compliance Training Policy, which covers the tracking and monitoring of training; responsibility for training completion; training schedule; timing; and delivery method. Additionally, Cigna continues to develop new training models and content to ensure that educational initiatives resonate with and are understood by its employees.
Cigna regularly updates and tailors its trainings, communications, and awareness campaigns with a combination of virtual, live, and other formats to ensure that its ethics and compliance training has broad reach and appeal.
Global Anti-Corruption Reporting, Training, and Risk Management
Cigna employees, including part-time employees and contractors, as well as our Board of Directors, are trained on anti-corruption and compliance policies and their implementation during the onboarding process and then annually thereafter. In addition, certain employees are designated to receive further training on anti-corruption principles and on Cigna's anti-corruption policy based on their roles. Similarly, employees working in higher-risk business units or geographies receive in-person anti-corruption training prior to COVID-19. During the COVID-19 pandemic, employees in high-risk geographies are being trained via Webex, which still allows for more personalized and interactive training. Cigna plans to return to in-person trainings for these employees once we can do so safely.
Per the Ethics Policy, 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 their business unit compliance officer, their manager, or the Ethics Help Line.
Third parties outside of the U.S. are assessed on a risk-based basis. Contract templates include anti-corruption language, and higher-risk parties are subjected to additional due diligence.
As a large global enterprise operating in more than 30 countries and jurisdictions and employing a multilingual workforce, there are inherent challenges that we face around corruption. As a result, we take a proactive stance, anticipating and addressing challenges before they become emergent and monitor emerging FCPA risks in new markets, such as Africa and the Middle East. In 2020, our European compliance team responded to Brexit by rolling out a new suite of policies, including a new anti-corruption policy that complies with the U.K. Bribery Act. We also work diligently to promote a culture of compliance across the enterprise and raise awareness of risks related to corruption, specifically as they relate to Cigna’s lines of business and geographies.
As we acquire new businesses, we work to integrate them into our global compliance program and our anti-corruption management process. We work with the onsite compliance teams to ensure compliance with Cigna's policies, including anti-corruption, economic sanctions, and data privacy. The Compliance Committee receives reports from members of senior management, including the Chief Compliance Officer and General Counsel – International Markets, including with respect to anti-corruption program and compliance risks.
Integrity in Human Rights and Labor
Cigna supports fundamental human rights for all. While national governments bear the primary responsibility for upholding human rights, we strive to protect human rights through our practices and policies and by complying with the laws of the countries in which we do business. Our commitment to human rights is guided by the laws of the U.S. governing human rights as well as the following international documents:
- United Nations Guiding Principles on Business and Human Rights
- International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and Its Follow-Up
Cigna’s Human Rights Statement, which has been reviewed by the Corporate Governance Committee of the Board of Directors, reflects our expanded understanding of Human Rights.
Our company’s Human Rights Statement addresses human rights within the context of:
We expect our employees to act lawfully toward colleagues, vendors, suppliers, customers, and business partners as outlined in our Code of Ethics and Principles of Conduct. Our respect for human rights is reflected in our labor practices, diversity and inclusion, comprehensive discrimination and harassment policies, workplace health and safety, and strict prohibition of child labor, forced labor, and human trafficking. 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.
Vendors, Suppliers, and Business Partners
Our Supplier Code of Ethics addresses integrity in human rights and labor and describes our expectations in the areas of community, child labor, human trafficking, forced labor, wages and working hours, health and safety, freedom of association, nondiscrimination, and harassment prevention.
Measures to Protect Employee Rights
In 2020, Cigna created and deployed a new employee dispute resolution process known as the Be HEARD (Helping Employees and Resolving Disputes) program. The Be HEARD program is designed to foster open communication between employees and management and includes an open door policy, anonymous reporting options, and a process to review disputes regarding disciplinary action and other workplace issues. As part of the Be HEARD process, in 2020 Cigna moved away from a mandatory arbitration policy and issued new arbitration agreements to its employees that included a process by which employees could opt-out of the agreement for a period of time following execution.
We actively monitor employee complaints and grievances to identify potential issues or locations where additional actions may be required. Cigna also conducts annual employee engagement surveys to gauge employee satisfaction. Additionally, Cigna created a focused Climate Assessment/Work Environment Review Team in 2020 to work directly with specific departments and locations. The team gives employees the ability to engage in collaborative discussion about what is working, what may not be working, and how the business can improve overall employee morale and engagement. The climate review team conducts reviews quarterly in areas with identified concerns.
In 2020, Cigna created the Navigating Social Issues Advisory Team to focus on reviewing social issue complaints and updating the company’s policies and processes using a social justice lens. As part of their review, the employee “dress for your day” policy was updated to permit certain apparel that identifies social injustice, such as Black Lives Matter.
Cigna posts notices informing employees about their rights to unionize and enter into collective bargaining agreements. At present, we have eight collective bargaining agreements in the United States. We have less than 1,000 unionized employees, which comprise less than 2 percent of our United States domestic workforce. We provide relevant manager trainings, such as respecting employees’ rights and organized labor, through our Cigna University curriculum.
In 2020, Cigna revamped its Employee Health Advisory Team (EHAT) to manage the COVID-19 Response process. The EHAT team quickly created a new governance structure, and new COVID-19 policies/processes, and monitored the day-to-day protocols to ensure ongoing employee health and safety. Cigna, under the guidance of the EHAT, initiated a massive move to virtual working for non-worksite-dependent roles, ensured safety protocols were being followed for worksite-dependent employees, and worked to offer benefit and time off programs that exceeded new government requirements. The EHAT also created an online microsite as a real-time resource for managers and employees during this difficult time. The microsite features a portal where employees can submit COVID-19 questions and issues and get timely responses and guidance.
Ensuring Whistleblower Protection and Addressing Reports of Potential Misconduct
Cigna maintains and communicates its policy that strictly prohibits retaliation against anyone who reports, in good faith, suspected violations of Cigna's Code or principles or other compliance concerns. Additionally, if employees participate in an investigation of related matters, they will not be subject to retaliation. Cigna employees who engage in retaliation are subject to disciplinary action up to, and including, termination of employment.
Each and every day, we strive to do the right thing for our customers, patients, clients, co-workers, partners, communities, and shareholders. All employees are encouraged and have a duty to speak up, in good faith, when they encounter or identify an ethics or compliance concern. The Ethics Help Line is confidential, anonymous (where permitted by law), and available 24 hours a day, seven days a week, from anywhere. The Help Line can be reached inside or outside of the U.S. and is available in multiple languages. We also have a dedicated Ethics Help Line website to assist employees around the world with questions they might have, and to facilitate their ability to report concerns or instances of potential misconduct.
In 2020, the Ethics organization issued a Compliance Investigations Policy that sets forth Cigna's consistent approach and best practices for conducting compliance investigations.
Promoting Ethical Conduct through Communication and Awareness Campaigns
We created comprehensive programming in 2020, while a large contingent of our global workforce worked at home, to continue to inspire our “speak up” culture of ethics, compliance, and integrity. As part of these efforts, the following communication and awareness campaigns were executed:
- The “Ask Yourself” Series: A monthly enterprise intranet series featuring digestible misconduct scenarios in an “ask yourself” format, based on actual matters and “lessons learned” from the Ethics and Privacy Offices and other priority risk areas. The series showcased the right actions to take, along with helpful resources.
- “Lunch and Learn” Sessions: The Ethics Office hosted “lunch and learns” for the Legal and Compliance departments.
- “Ask the Experts” Podcast: The Chief Ethics Officer and the Chief Privacy Officer conducted an internal podcast on key ethics and privacy risks and resources.
- Enterprise Leadership Team (ELT) Communications: We also partnered with the ELT and their communications teams to send out emails and campaigns to foster additional awareness of and adherence to the Code, key policies, and risk mitigation.
- Ethics Videos: Videos discussing Cigna’s anti-retaliation policy were created and shared to further emphasize our strict policy against retaliation when someone reports an ethics or compliance concern in good faith.