MassMutual Code of Conduct for Temporary Personnel The Winning Way
MassMutual Code of Conduct for Temporary Personnel Contents 1 Introduction 2 Principles of Conduct 4 Speaking Up 5 Seeking Guidance Last Updated January 2013 Focus on the Customer Act with Integrity Value People Work Collaboratively Achieve Results
Introduction For over 160 years, MassMutual has helped its customers build a financially secure future. MassMutual has also built strong relationships and a tradition of trust with its customers and employees. At the core of these relationships is a commitment to act ethically and with integrity. This Code of Conduct for Temporary Personnel applies to individuals providing services to MassMutual who are contractors or temporary workers ( temporary personnel ). There are certain core principles and values that MassMutual expects of all individuals who conduct business on its behalf, whether they are MassMutual employees or temporary personnel. This Code of Conduct for Temporary Personnel explains these expectations. In addition, certain MassMutual policies applicable to temporary personnel provide further details regarding these expectations. These policies can be found on myhr. Focus on the Customer Act with Integrity Value People Work Collaboratively Achieve Results 1
Principles of Conduct We are expected to familiarize ourselves with and follow these Principles of Conduct, in addition to applicable company policies, while associated with MassMutual. We will conduct business ethically, with integrity and in compliance with applicable laws and regulations. Wherever MassMutual does business, it competes vigorously, but fairly. MassMutual is committed to conducting business ethically and in compliance with applicable laws and regulations. Unethical or illegal behavior is not justified in any circumstance. There are a number of laws and regulations that govern how companies do business, including antitrust and competition laws, anti-corruption laws and money laundering laws. In addition to the laws that apply to most companies, a number of additional laws and regulations apply to insurance companies, such as MassMutual. We should work with our MassMutual relationship managers to understand the laws, regulations and related policies and procedures that apply to our work with or on behalf of MassMutual. We will be respectful to others and welcome and encourage diverse opinions, attitudes, attributes and feelings. MassMutual is committed to maintaining a diverse, respectful and productive workplace where individuals work together and value and learn from each other. Certain behavior, including illegal harassment or discrimination, has no place in a respectful workplace and will not be tolerated. Violent or threatening behavior will also not be tolerated. We will protect confidential information related to MassMutual, its customers and employees against unauthorized access, use or improper disclosure. We are responsible for properly handling and using any confidential information that we may have access to. Confidential information includes non-public information that might be of use to MassMutual s competitors or harmful to MassMutual, its customers or employees if improperly accessed, used or disclosed. Confidential information may be verbal, written or electronic and includes records and information received on a confidential basis from other individuals or companies. If we have access to confidential information, we must take steps to safeguard that information to protect against unauthorized access, use or improper disclosure. While we are associated with MassMutual, we are expected to conduct ourselves professionally, ethically, with integrity, and in compliance with applicable company policies. We will use MassMutual property for business purposes and protect it from misuse, theft or damage. MassMutual may provide us with property, such as facilities, equipment, technology, information and trade secrets, to use for authorized business purposes. It is important to properly use and protect company property from misuse, theft or damage. This includes making sure that MassMutual property or other services are used for business, not personal, purposes. 2 Focus on the Customer Act with Integrity Value People Work Collaboratively Achieve Results
Principles of Conduct (continued) We will create and maintain documents and records, including financial information, that are timely, accurate and comprehensive. MassMutual s documents and records, including financial information, reflect how the company does business. It is important that these documents and records are authentic, accurate, complete, unaltered, and readily accessible and understandable. The work we do and the documents we create at MassMutual may be included in or become a record, including the company s financial statements, so it is important to make sure that the information we provide to others is timely, accurate and comprehensive. We will avoid conflicts of interest between ourselves and MassMutual. A conflict of interest occurs when our personal interests, activities or relationships interfere with or even appear to interfere with our ability to objectively and fairly make decisions or otherwise perform our responsibilities on behalf of MassMutual. For example, if we discover a business opportunity because of our use of MassMutual s property or information or our positions at MassMutual, we may not use that information for personal gain at the expense of MassMutual. Conflicts of interest can cause significant reputational or other harm, so it is important to identify up front and disclose situations that are, appear to be or could potentially lead to a conflict of interest. Focus on the Customer Act with Integrity Value People Work Collaboratively Achieve Results 3
Speaking Up During our association with MassMutual, we may find ourselves in a situation in which we believe someone s conduct does not comply with the Code of Conduct for Temporary Personnel, applicable laws, regulations, company policies or ethical standards. If that happens, or if we suspect illegal or unethical conduct, we should speak up and report our concerns. When we speak up and report compliance or ethics issues or concerns, we help ourselves, our colleagues and MassMutual address issues promptly and appropriately. Reporting channels include: our MassMutual relationship managers the HR Business Partner supporting our assigned business area MassMutual s Chief Compliance Officer the business or corporate unit compliance officer in our assigned business area Law Department counsel The Hotline provides a reporting channel in cases where we may not be comfortable discussing the issue or concern with an individual or where we prefer to raise the issue or concern anonymously. The Hotline is administered by an independent third party vendor. The Hotline can be reached 24 hours a day, seven days a week, by calling 1-800-422-1381 or via the web at www.massmutual.com/ethicspoint. Reports of unethical or illegal behavior will be handled promptly. MassMutual makes every effort to keep reports confidential, but information may need to be shared with individuals who are involved in investigating the report so they can investigate and follow-up appropriately. If we become involved in a company investigation, we are expected to cooperate fully and provide complete and honest answers to all questions. MassMutual values reports of compliance or ethics issues or concerns and will support us for coming forward to raise an issue or concern in good faith. Retaliation is illegal and contrary to MassMutual s values. Anyone who engages in retaliatory conduct against a person who has in good faith raised a compliance or ethics issue or concern will face disciplinary action, up to and including termination of employment or cessation of the contract or business relationship with MassMutual. The MassMutual Compliance and Ethics Reporting Hotline 4 Focus on the Customer Act with Integrity Value People Work Collaboratively Achieve Results
Seeking Guidance We may face a situation where the right decision is not clear or easy. To help us make the right decision, we should consider the questions in the Ethical Decision-Making Framework. We should also contact our MassMutual relationship managers or any of the resources listed in the Speaking Up section for guidance. Our Ethical Decision- Making Framework When we are unsure how to handle a situation or question whether it is the right thing to do, we should consider the following questions: Is my decision or action consistent with the standards in the Code of Conduct for Temporary Personnel, company policies or legal requirements? Is my decision or action consistent with MassMutual s values the Winning Ways? Does something feel wrong about the situation? How will my decision or action impact others? Would I feel comfortable explaining my decision or action to others? Would I feel comfortable if my decision or action appeared in a newspaper or otherwise became public? Should I ask for advice before acting? Please keep these principles, values and expectations of behavior in mind every day and help uphold MassMutual s reputation for ethics and integrity. Focus on the Customer Act with Integrity Value People Work Collaboratively Achieve Results 5
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