Anti-Bribery and Anti-Corruption | Business Gifts and Entertainment | Communications with the Media and Other External Parties
Political Contributions and Solicitation | Solicitation and Distribution
WHAT COULD IT LOOK LIKE?
Government & Third Parties
Working with the Government and Third Parties
Guiding principle
We will be honest and forthright in our dealings with the government and third parties. We will comply with applicable laws when participating in the political process or when interacting with the government. We prohibit bribery and corruption in all forms.
Why it matters?
Building strong partnerships with the government and third parties and preventing unfair influence helps us keep our promises and do business as a trusted partner.
How we do it?
MassMutual encourages employees to participate in the political process as private citizens.
- Our political activities could impact MassMutual’s ability to do business with state or local governments. We must pre-clear any political activities or contributions we make to a political official, a candidate for a state or local political office, or a current state or local official running for federal office.
- We must make sure we understand applicable laws before interacting with the government.
- We must obtain approval before using MassMutual resources for political activities, lobbying on behalf of MassMutual, or interacting with or hiring a current or former government employee.
- We should contact Law if we receive an inquiry from a regulator, government agency, or law enforcement; a complaint, subpoena, notice of audit, or other legal document related to MassMutual; or if we are contacted about litigation against MassMutual or its employees.
COMPANY POLICIES
| What’s the issue? | What is it? | What could it look like? | What should I do? |
|---|---|---|---|
| Communications with Regulators | Only certain employees are authorized to communicate with regulators, government agencies, or law enforcement on behalf of MassMutual. | You receive a letter from a state insurance department requesting corporate records. | Forward the letter to Law. For more information, refer to the Communications with the Media and Other External Parties Policy. |
| Giving Gifts to Government Officials and Employees | Some laws limit the government representative’s ability to accept gifts (including meals and beverages). | You are trying to develop business leads at a conference. During a break you offer to buy the person next to you a cup of coffee. | If the person is a government official or works for a government agency, don’t buy anything for them unless you check with the Compliance & Ethics Department first. For more information, refer to the Anti-Bribery and Anti-Corruption Policy and the Business Gifts and Entertainment Policy. |
| Solicitation | Your time and activities in obtaining or arranging a political contribution. | Your friend is running for local office and wants you to ask other MassMutual employees for campaign contributions. | Using MassMutual’s equipment for political activities like soliciting campaign contributions is generally not allowed. Before forwarding any requests or making any contributions, contact the Compliance & Ethics Department. For more information, refer to the Political Contributions and Solicitation and Distribution Policy. |
| Facilitation Payments | A facilitation payment is a small payment made to a government official to expedite or secure the performance of a routine, non-discretionary governmental action that the official is required to provide. | You are traveling to a MassMutual location in another country and you make a small payment to a Customs official to speed up your customs clearance. | MassMutual prohibits facilitation payments under all circumstances and therefore you may not make them. |
*Subsidiaries should refer to their own local policies if not applicable.