Conflicts of Interest

Avoiding Conflicts of Interest

Guiding principle

We will avoid conflicts of interest between ourselves and MassMutual.

Why it matters?

Making business decisions based on what is in the best interest for the company, and not our personal gain or benefit, will allow us to maintain our reputation and the trust people place in us.

How we do it?

  • A conflict of interest occurs when our personal interests, activities, or relationships interfere with our ability to objectively and fairly make decisions or perform our responsibilities on behalf of MassMutual.
  • We will avoid conflicts of interest and, to the extent possible, even the appearance of conflicts of interest.
  • If we cannot avoid a conflict of interest, we must disclose it to MassMutual so it can be properly managed.
  • Examples of situations that may involve conflicts of interest:
    • Taking personal advantage of a business or investment opportunity that we learn about through MassMutual.
    • Acquiring a significant interest or investment in a MassMutual competitor or supplier.
    • Giving or accepting business gifts or entertainment.
    • Having a personal relationship with third parties that do or are trying to do business with MassMutual.
    • Family and personal relationships between employees.

COMPANY POLICIES

Anti-Nepotism | Business Gifts and Entertainment | Conflicts of Interest | Participation on Board of Directors

WHAT COULD IT LOOK LIKE?

What’s the issue? What is it? What could it look like? What should I do?
Business Gifts Any item of value provided to or accepted from a business partner at no charge. Accepting an expensive watch from a potential supplier during the contract negotiation process. Gifts that are greater than the applicable policy limits are generally not allowed. You should also avoid accepting the gift if you think the supplier will expect favorable treatment in return. For more information, refer to the Business Gifts and Entertainment Policy.
Outside Business Activities Business activities outside of your MassMutual job that may conflict with your duties to MassMutual. Taking a second job at one of MassMutual’s suppliers. Before you take the job, check with your manager. Your manager will work with the Compliance & Ethics Department to address any potential conflict. For more information, refer to the Conflicts of Interest Policy.
Participation on a Board of Directors Serving on a board of directors, board of trustees, advisory or other board in a personal capacity or as a representative of MassMutual. A charitable entity asks you to serve on its board of directors. In general, serving on the board of directors of a charitable entity in a personal capacity (not as a representative of MassMutual) is not a conflict of interest, so you don’t need to disclose the directorship or obtain approval. For more information, refer to the Participation on Board of Directors Policy.

*Subsidiaries should refer to their own local policies if not applicable.

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