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.
Codes 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. Since the merger with Express Scripts in late 2018, the compliance and ethics teams worked to prepare an updated and refreshed Code, applicable to all employees, officers and directors, as well as consultants, suppliers, volunteers, interns and trainees, and those who work with us under collective bargaining agreements.
Cigna’s updated Code was approved by Cigna’s Board of Directors in 2019, it became effective in 2020 and it reflects Cigna’s updated values and mission.
Similar to the legacy Cigna Code, the refreshed Code addresses key topics, including conflicts of interest; full, fair and accurate reporting; protection of private, sensitive or confidential information; insider trading; and adherence 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 updated Code also incorporates language for Express Scripts business lines, including expanded language for Government Business lines and reporting fraud, waste, and abuse. 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, Thai, and Turkish. Although our Code covers suppliers, Cigna also has a Supplier Code of Ethics, which we include in our standard supplier contracts. Both of these codes sets forth four 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 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. It is Cigna’s policy to avoid any conduct that creates even the appearance of improper interaction with a government official or commercial business. Indeed, Cigna’s policy prohibits the use of business gifts, meals, and entertainment which improperly influence or create the appearance of improperly influencing employees, customers, suppliers, or others doing business with Cigna.
Cigna also maintains an anti-corruption policy, which covers specific topics related to anti-corruption. 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.
Cigna strictly prohibits facilitation payments. 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. Examples of such routine governmental functions include issuing licenses, granting permits, and installing telephone lines.
Cigna recognizes that its personnel may confront situations where payment is demanded to avoid physical harm. In these very limited circumstances, “Personal Safety Payments” may be made. Only where there is an imminent threat to the health or safety of Cigna personnel, may a Personal Safety Payment be made without prior approval. After a Personal Safety Payment has been made, it should be reported immediately to an International Compliance Officer as we report any such payments in our books and records.
Cigna is also a member of TRACE International, a globally recognized anti-bribery business organization.
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. We 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. 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.
Since 2018, Cigna has maintained a dedicated Chief Ethics Officer role, who reports directly to our Chief Compliance Officer. Additionally, as part of the integration we made enhancements to our core compliance controls and our risk reporting processes. The compliance organization continues to engage with their business partners 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 Audit Committee of the Board of Directors to inform them of key compliance topics.
In 2019, the Board of Directors established a Compliance Committee that 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, at least once annually, the Chief Ethics Officer presents, In addition, at least once annually, 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, in order to identify potential risk areas and evaluate any training and awareness needs.
This reporting occurs at the enterprise level, at the legacy company level (Cigna, Express Scripts, and eviCore), and at the level of Cigna's four primary business lines: Health Services, U.S. Commercial, Government Business and International Markets. Among other things, our operational reporting tracks:
- Overall Ethics Help Line volume, broken down by category (i.e., the volume of reports relating to compliance concerns; ethics inquiries; employee relations/human resources issues; data privacy concerns, etc.);
- The type of allegation raised (e.g., concerns regarding potential fraud; waste and abuse; conflicts of interest; disclosure of confidential information; misuse of resources; etc.);
- The volume of matters that were substantiated and unsubstantiated;
- Any disciplinary actions taken (i.e., the volume of verbal warnings, written warnings, and terminations);
- The number and type of matters referred to Legal/Litigation;
- Anonymity rates (i.e., the number of matters submitted anonymously vs. the number submitted by an identified reporting individual); and
- Average time to close data.
Ethics Training and Employee Engagement
We train all new employees on our Code and all employees affirm their adherence to the Code on an annual basis. We have also continued to design training courses that provide a more role-based approach to learning and include engaging and interactive content for learners. We also train our Board of Directors on their obligations under the Director Code of Conduct and the Code.
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. 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.
Cigna continues to develop new training models and content to ensure that educational initiatives resonate with and are understood by its employees.
In 2019, a Compliance Training Council was established to review and develop new compliance training for all employees in 2020. 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
All Cigna employees, as well as our Board of Directors, are trained on anti-corruption and compliance policies and their implementation during the onboarding process. 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. 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 our Compliance Organization. Third parties outside of the U.S. are assessed on a risk-based basis. All parties agree to anti-corruption contract language and higher-risk parties are subjected to additional due diligence.
As a large global enterprise operating in more than 30 countries and employing a multi-lingual 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. For instance, we continuously scope emerging FCPA risks in new markets, like Africa and the Middle East. In 2019, our European compliance team responded to the likelihood of Brexit by rolling out a new suite of policies, including a new anti-corruption policy that complies with the UK Bribery Act. We also work diligently to promote a culture of compliance across the enterprise and are continually raising awareness of risks related to corruption, specifically as it relates to Cigna's lines of business and geographies. This is typified by the monthly anti-corruption and compliance section in our International Markets newsletter.
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 meets five times per year and receives quarterly reports from the Global Compliance Officer, including an annual report on Cigna's 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 Labor Organization’s Declaration on Fundamental Principles and Rights at Work
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, non-discrimination, and harassment prevention.
In 2019, we reviewed and harmonized over 100 Express Scripts and Cigna policies related to protecting employees’ human rights. 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 provide manager trainings on topics, such as respecting employees’ rights and organized labor through our Cigna University curriculum. Additionally, we post notices informing employees about their rights to unionize and enter into collective bargaining agreements. At present, we have eight collective bargaining agreements with four unions located in the U.S. and Belgium. Our unionized employees comprise 2% of our workforce.
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, 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, health care professional 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. To that end, in 2019, Cigna, Express Scripts, and eviCore integrated their whistleblower hotlines so that all employees can report ethics and compliance concerns through one centralized location. 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.
Reports of potential misconduct are taken very seriously and promptly vetted, analyzed, responded to, and handled to resolution by attorneys, investigators and/or appropriate subject matter experts.