Anti-Boycott | Anti-Bribery | Anti-Corruption | Antitrust | Anti-Money Laundering
WHAT COULD IT LOOK LIKE?
Ethical Decisions
Acting Ethically and with Integrity
Guiding principle
We will conduct business ethically, with integrity and in compliance with applicable laws.
Why it matters?
Doing the right thing for our policyowners and customers, our company, and each other requires more than just complying with applicable laws and regulations. We are also committed to conducting business ethically, in order to provide our policyowners and customers with financial security and peace of mind. Unethical or illegal behavior is never justified.
How we do it?
- We are committed to conducting business ethically and in compliance with applicable laws.
- Unethical or illegal behavior is never justified.
- We compete vigorously, but fairly, and will gain business advantages only through appropriate behavior.
- Fraudulent behavior by anyone — policyowners, customers, employees, advisors, or third parties — will not be tolerated.
- We are all responsible for being familiar with and following the relevant laws, regulations, and company policies that govern how MassMutual does business.
COMPANY POLICIES
| What’s the issue? | What is it? | What could it look like? | What should I do? |
|---|---|---|---|
| Antitrust | Antitrust laws are designed to stop companies from making deals that remove competition from the marketplace. Violating antitrust laws hurts consumers and can result in higher prices and limited product choices. | While at an industry meeting, an employee from a competitor suggests that each company at the meeting charge the same price for its products. | Leave the discussion without participating. Topics like price fixing, market allocation, boycotting, and exchanging competitively sensitive information are off-limits for discussion with competitors. Review the Antitrust Policy for more information. |
| Bribery | Giving someone something of value because you expect them to do something that benefits you in return. | You provide an all-expenses paid trip to Disneyland to a foreign government official with whom MassMutual is interested in doing business. |
Before providing anything of value to a foreign government official, check with a member of the Law to see if it’s permitted. Review the Anti-Bribery and Anti-Corruption Policy for more information. |
| Money Laundering | A process by which an individual, corporation or other entity tries to create the appearance that illegally derived funds come from legitimate sources. | A few weeks after purchasing a whole life insurance policy, there are several loans taken and quickly repaid by third party payors not related to the policy. | This may be an attempt by the policyowner to use their life insurance policy to illegally launder money. If you observe a “red flag” you must immediately notify your manager, the Compliance & Ethics Department or MassMutual’s AML Compliance Officer. |
*Subsidiaries should refer to their own local policies if not applicable.