We must ensure that we carefully handle all confidential information regarding the Company’s business, workforce members, customers, clients and business partners.
Many workforce members routinely come into contact with the personal health information or personal financial information of patients or fellow Company workforce members. Our customers, workforce members and clients expect us to diligently protect personal information.
Accordingly, our obligations necessitate that we safeguard confidential and personal information from unauthorized access – only providing information to authorized persons on a need-toknow basis – and to use information responsibly and with integrity, in conformance with federal, state and international laws. Our obligations also require that we ensure our use of algorithms and artificial intelligence, including new technology, such as generative artificial intelligence, is at all times consistent with our model and data governance framework, policies and applicable law. We are committed to maintaining trust by using or disclosing information as described in our privacy notices and policies. It goes hand in hand with who we are at The Cigna Group.
For our Company, an example of a primary privacy law is the Health Insurance Portability and Accountability Act (HIPAA), which is designed to protect the privacy of “protected health information” (PHI). PHI includes information that identifies an individual, such as their name, member and plan IDs, and account numbers, as well as information about their physical or mental condition and the provision of, or payment for, health care.
In addition to HIPAA, there are state laws that establish data protection requirements. Outside the United States, many countries maintain and enforce their own privacy laws, which can be stricter or have a broader application than U.S. law. Protections for personal information or business data might differ by country, state or municipality. You must know and comply with all information protection and privacy policies and laws that apply to your role at The Cigna Group.
Laws regarding personal information and PHI are complex and ever changing, reflecting evolving business and customer expectations. That’s why speaking up, asking questions and quickly reporting any concerns or potential data breaches are part of everyone’s job at The Cigna Group.
We do the right thing. Always. We never offer, solicit or accept improper inducements (bribes) – whether cash or anything of value or otherwise – from anyone to obtain or retain business or gain an unfair business advantage.
This includes interactions with commercial business representatives, government officials and intermediaries. Bribes also may not be paid indirectly through consultants or agents working on behalf of The Cigna Group.
A “government official” can be anyone who is employed by a government entity or employed by an organization controlled by any government, including federal, state, local, county and municipal offices, governments and boards (e.g., a physician working for a government-run hospital or an employee of a public university or school district).
“Anything of value” can include monetary payments but also includes anything useful or valuable to the recipient. Examples include:
Cash equivalents (e.g., gift cards, gift checks) or loans
Gifts, meals, entertainment, transportation or travel
Favors, including job offers or internships
Sponsorships
Donations to a charity affiliated with or sponsored by someone with whom we hope to do business or gain a competitive advantage
Political contributions
We must avoid any conduct that creates even the appearance of improper interaction with a government official or commercial business. Indeed, we prohibit the provision or reimbursement of business gifts, meals and entertainment that improperly influence or create the appearance of improperly influencing employees, customers, suppliers or others doing business with The Cigna Group.
Please review our Anti-Corruption Compliance Policy, our Business Gifts & Entertainment Policies, our Corporate Integrity Agreement Policy, our Small or Diverse Supplier Subcontracting for Government Clients Policy, our Lobbyist Retention Policy, and our Lobbying Activities and Mandatory Disclosure Requirements Policy. You may also contact our Compliance or Legal Department for assistance.
Facilitation payments, also known as “expediting payments” or “grease payments,” are small, unofficial payments made to “government officials” in order to secure or expedite the performance of a routine or necessary action to which the payer has a legal or other entitlement. In other words, it is a payment to an official to get them to do something they should have done anyway. Examples of such routine governmental functions include issuing licenses or permits and installing telephone lines and other basic services. Where a government agency publicly posts price lists for expediting services that are available to the general public, these payments are permitted. For example, the U.S. government has a fee schedule for standard passport processing and an increased cost for expedited processing. This increased payment is permissible because it is published, available to anyone and not based on the discretion of any one government employee.
When working on a bid for a new client, is it appropriate to accept a recommendation to hire a specific consultant or agent at the request of the potential new client? No. We will:
Never accept bribes.
Always consult with the Legal or Compliance Department about a potential client’s suggestion to engage a certain agent or consultant.
The Cigna Group 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. Examples of such circumstances include:
Being stopped by persons claiming to be police, military or paramilitary personnel who demand payment as a condition of passage of persons; or
Being threatened with imprisonment for a routine traffic, visa or other similar minor violation or for no reason at all, unless a payment is made.
Only under these or similar circumstances, and only where there is an imminent threat to the health or safety of our workforce members, may a personal safety payment be made without prior approval. Where a personal safety payment has been made, it should be immediately reported to the International Compliance Officer. You must accurately reflect any such payments in the Company’s books and records.
We collaborate and work closely with our business partners. Building strong relationships can include giving and receiving gifts and providing entertainment. However, we must carefully follow all our policies and procedures and never engage in any gift or entertainment activity with a business partner where it appears we are trying to gain an unfair business advantage, where our business judgment is compromised or where a conflict of interest could arise. In addition, meals, gifts or entertainment to or from a government official, union official, pharmaceutical manufacturer or any health care professional must be in strict accordance with our policies.
Pre-approval is required for an employee to speak or present at an event as a representative of the Company or on behalf of The Cigna Group or where the remarks or content may be attributed to the Company or make it appear that the employee is representing The Cigna Group. Before you accept any such invitations and speak externally, you must contact your supervisor and the Ethics Office and have your participation reviewed by Corporate Communications, consistent with The Cigna Group Communications and Social Media Policy. Pre-approval requests for external speaking engagements may be made through The Cigna Group Conflict of Interest and Outside Activity Disclosures Form.
We use sound judgment before offering or accepting any gifts or entertainment – and we ask questions and report any concerns.
Consult our Business Gifts & Entertainment Policies for additional guidance on giving and accepting gifts and entertainment. If you have any questions or see or suspect improper conduct regarding gifts or entertainment, make a report immediately to the Enterprise Compliance Department. You can also contact the Ethics Help Line.
Keeping our promises to each other and to our company includes partnering and collaborating fairly with all stakeholders.
When engaging in a gift or entertainment activity with a business partner, does it appear that one of us is trying to gain an unfair business advantage? We:
Never seek or solicit gifts or entertainment from any business partners or competitors.
Never accept cash or cash equivalents (e.g., gift cards) and will report any such offer to our compliance officer.
Never accept or give any gift above The Cigna Group gift limits.
Never offer any gifts or entertainment to, nor accept any from, health care professionals or pharmaceutical manufacturers that would be in violation of a company policy.
Never offer gifts or entertainment to or accept them from patients.
Accept only modest forms of entertainment that are reasonable and appropriate for the occasion (where accompanied by a business partner).
Follow company guidelines before offering any gifts, meals or entertainment to government officials, including adhering to monetary limits and preapproval requirements and obtaining pre-approval for providing invitations to events hosted or sponsored by The Cigna Group.
We expect our suppliers and contractors to conduct activities on behalf of The Cigna Group in a manner that is consistent with our Code and in accordance with their contracts with the Company. The Cigna Group Supplier Code of Ethics, which we include in our standard supplier contracts, sets forth several ethical principles, including complying with all applicable laws, rules and regulations; avoiding conflicts of interest; protecting customer, employee and client privacy; respecting human rights and labor; protecting the environment; and acting ethically and with integrity in business conduct. We work to make sure that suppliers and contractors live up to their obligations.
We may be exposed to material, nonpublic information about our Company and others. We never use any material, nonpublic information we have learned about any company to buy or sell the stock of that company. Doing so is known as “insider trading.” “Material nonpublic information,” or “inside information,” includes any information that has not been made public that a reasonable investor would consider important in making a trading decision. Therefore, we must never buy, sell or trade The Cigna Group securities – or the securities of other companies – until the Company releases that material information (for example, by means of a press release) and enough time has elapsed to permit the investment market to absorb and evaluate the information.
Common examples of inside information include financial information, new product or business growth plans, major contracts, business plans (including acquisitions and divestitures), major organizational changes, and major litigation, investigations or regulatory actions.
Handle inside information just as you would handle other confidential Company information.
Don’t discuss it with family, friends or anyone else.
Don’t talk about it in public places.
Don’t email it to unverified email addresses.
Don’t tell others at The Cigna Group unless they must know for business reasons to perform their duties.
Please refer to the Securities Transactions and Insider Trading Policy for additional information.
We are committed to maintaining the confidentiality of competitively sensitive information belonging to any third party with whom we have a business relationship (including our clients, vendors and partners). To support this commitment, The Cigna Group has established safeguards, or “firewalls,” that dictate which company workforce members may access and use such competitively sensitive information. Please refer to the Company’s Firewall Policies for additional information.
Regulators and our stakeholders expect The Cigna Group to maintain robust controls over Company assets and accounting practices to ensure that books and records are transparent and accurate. Our commitment to integrity is reflected in our dedication to accurate recordkeeping and complete and timely reporting, including with respect to the financial condition and results of The Cigna Group and its operations. Additionally, internal and external reports and communications must be full, fair, timely, accurate and understandable.
Each of us is responsible for creating, retaining and disposing of Company records in accordance with regulatory and business requirements and Company policies. You are required to follow the appropriate retention period for Company records, as governed by the Company’s records retention schedules, and, if applicable, any legal hold. If you know of or suspect a violation, you must report it promptly to your compliance officer. Please refer to the Control, Accounting and Reporting Policy and Global Records Management Policy for additional information.
As we focus on meeting the needs of our customers and business partners, we must also be aware of the signs of money laundering when dealing with third parties. Money laundering occurs when a party attempts to hide the source of illicit income or assets through otherwise legal transactions to make that income or asset appear legitimate.
You should contact the Legal or Compliance Department immediately when a third party:
Does not provide complete information or requested financial details.
Proposes an unusual transaction that does not seem to have a business purpose.
Changes the source or destination for payment for no clear reason.
Otherwise acts in a suspicious manner.
Please refer to The Cigna Group Anti-Money Laundering and Counter Terrorist Financing Policy for further details and a list of red flag behaviors.
The Cigna Group provides charitable donations, sponsorships and contributions to nonprofit organizations whose work supports the health and vitality of individuals and communities around the globe. All charitable contributions must be transparent and paid to nonprofit organizations whose charitable goals are compatible with The Cigna Group policies. Business area contributions to nonprofits must follow the Corporate Charitable Contributions process. Please refer to our Corporate Charitable Contributions Policy for further details.
The Cigna Group Foundation is a separate entity that makes charitable grants primarily to healthrelated nonprofit projects. Requests for funding of any kind from The Cigna Group Foundation should follow the Foundation’s application process. All interested parties should be directed to the public website for more information.
The Cigna Group encourages its workforce members, officers and directors to participate in the political process as private citizens. However, when you make political contributions or engage in political activities, you must clearly distinguish any personal political views from those of the Company.
Any use of The Cigna Group equipment, supplies, time, facilities, phones or administrative support in connection with any sort of political activity is strictly prohibited and could also be considered a “political contribution” in violation of the law and The Cigna Group policies. In some cases, even personal giving by workforce members or their immediate family may be prohibited. Please see our Political Activity Policy and our Political Contribution Pre-Clearance Policy for additional information. Where pre-clearance for a political contribution is required, the affected employee should complete The Cigna Group Political Contribution Request Form.
The Cigna Group is committed to the highest standards of ethical and legal business conduct and compliance with all applicable laws, regulations and policies that govern our business, including state and federal laws pertaining to fraud, waste and abuse. Individuals, including patients, health care providers and payers, are prohibited from making decisions based on illegal inducements rather than legitimate health-related reasons.
It is also against the law and our policies to submit false, fraudulent or misleading information to any government agency or third-party payer to obtain payment for a service or to gain or retain participation in a program.
Like anti-kickback laws, various other state and federal fraud, waste and abuse laws are in place to promote safety and efficiency in our health care system. Please refer to the False Claims Policy and the Payment Return (Federal Healthcare Program) Policy for additional information.
Are you putting The Cigna Group and yourself at risk by preparing invoices with false dates, even if it is at the request of your manager? Yes. We will:
Only put complete and accurate information in all records.
Not compromise or violate the Code, our policies or the law, even if a manager asks us to do so.
Report any suspicions of false records, or requests to keep false records, to the Ethics Help Line or to the Legal or Compliance Department.
National, state and local governments are significant customers for The Cigna Group around the world. In the United States, this includes the U.S. Department of Defense and federal and state health care programs, such as Medicare and Medicaid. The Cigna Group and Company workforce members can be held liable for any false information provided to the U.S. government, so we take particular care to be accurate when submitting claims or records to these customers. We promptly report any suspected misconduct, fraud or abuse.
The Cigna Group entered into a Corporate Integrity Agreement (CIA) with the U.S. Department of Health and Human Services, Office of Inspector General (HHS-OIG), in September 2023. The CIA promotes compliance with the statutes, regulations and written directives of Medicare, Medicaid and all other Federal Health Care Programs. It is the policy of The Cigna Group that our workforce comply with the terms of the CIA.
When a government is our customer, we may have additional contractual requirements that include, for example, rules prohibiting any requests for compensation (including free or below-cost services) in return for recommending or arranging for the purchase of goods, items or services reimbursable by the government. Please refer to the Anti-Kickback Policy for additional information.
The Cigna Group also has subsidiary companies that operate health and prescription drug benefit plans in Medicare Part D and Medicare Advantage programs, as well as clients that operate their own Medicare Part D, Medicare Advantage and managed Medicaid plans or offer such plans to their workforce members. In addition, certain Company subsidiaries function as health care providers through home delivery and specialty pharmacies that bill Medicare and state Medicaid agencies directly.
If your role is related to government programs business, you must be familiar with current program requirements, including the CIA, and carefully follow all applicable laws and regulations. This includes fraud and abuse laws as well as any other applicable national, state and local laws (e.g., pharmacy practice laws).
Laws and regulations regarding U.S. government health care programs, such as Medicare and Medicaid, can be complex and change frequently, so The Cigna Group has processes in place to prevent, detect and promptly correct instances of fraud, waste or abuse.
As a contractor for the U.S. Department of Defense, we must comply with the terms of our contracts and with all regulatory and statutory requirements that apply. If you work on the U.S. Department of Defense program, you’re responsible for knowing and complying with those requirements, including the U.S. government’s zero tolerance policy on human trafficking during the performance of government contracts and related subcontracts. Complying with these mandates may require additional actions from you, such as time tracking, that would not be required for work with other clients. If you have questions about the program requirements, contact the Compliance Department.
Please review the Corporate Integrity Agreement Policy, our Payment Return Policy (Federal Healthcare Programs), and our Chief Compliance and Risk Officer Policy. If you have questions about legal requirements for these policies, contact Enterprise Compliance, Federal Programs Compliance or the Legal Department.
We fully cooperate with any government audits or investigations as required by law. As The Cigna Group workforce members, we also cooperate fully with the Company’s Legal, Human Resources and Compliance personnel, who may be responding to or facilitating a government audit or investigation. You should promptly notify the Enterprise Compliance or Legal Department about any request for information or any unscheduled government inspection or investigation. Workforce members are not required to provide any such notice or cooperate with The Cigna Group lawyers in any investigations involving charges filed with the U.S. National Labor Relations Board.
When we communicate with government officials or regulators, we provide complete, factual and accurate information. We are allowed contact with government officials or regulators when our work for The Cigna Group requires it.
All other contact with government officials or workforce members, such as seeking new business from a government agency or seeking to influence the development of laws, regulations or policy, must be initiated through:
The Cigna Group Public Policy and Government Affairs Department for contact with the U.S. Congress or federal agencies.
The Regulatory and State Government Affairs Department for contact with states or state agencies.
Your local legal department for contact with governments or agencies outside the United States.
If you’re asked to complete a survey or questionnaire administered by, or participate in a study conducted by, a government agency or program, such as an insurance regulator, a health agency, the U.S. Office of Inspector General, the U.S. Centers for Medicare & Medicaid Services, or a U.S. state Medicaid program, you must obtain pre-approval from the Compliance Department.
Complex rules govern the recruitment and employment of former or current government officials and employees. Before approaching or considering current or former government officials and employees for employment or for a consulting or contracting role, seek guidance from Human Resources and the Legal Department.
If you are involved with government contracting, you must not accept solicitation information about a state or federal procurement from any source other than the procuring agency, such as a consultant or contractor. The attorney in the Legal Department responsible for government contracts must be involved in all government contracting initiatives.
Acting ethically, maintaining high standards of integrity and respecting the law are fundamental to our identity as a company. If you have been excluded from participation in a U.S. federal health care program or have been convicted of a criminal offense but have not yet been excluded from participation in any federal health care program, you must notify Human Resources, your manager, and the Chief Compliance and Risk Officer immediately, as required by The Cigna Group CIA and our Workforce Exclusion Screening Policy.
Further, if you have been found guilty or pled guilty or no contest to a criminal violation, you must notify your manager or Human Resources immediately (within three days). In addition, if you are arrested for an alcohol- or drug-related offense in the workplace or while conducting The Cigna Group business, you must notify your manager within five days of the arrest. Disclosure is not required if the criminal records have been expunged or are sealed juvenile offenses.
Certain employees are required to obtain and keep current a license or certification in the jurisdictions in which they work, such as a license to practice law, a pharmacist or an insurance agent’s license or registration, or a doctor’s or nurse’s license. It is your responsibility to obtain and maintain these requirements to continue performing your job. If you are disciplined, censured, suspended or disbarred from any licensed profession, you must notify your supervisor or Human Resources immediately.
When communicating with a regulator regarding an audit, is it responsible to engage in a conversation about seeking new business when the regulator mentions his agency is bidding for a new provider? No. We will:
Always follow our policy with regard to contact with government officials and regulators.
Not seek new business from a government agency unless authorized to do so.
Contact the Legal Department, the Compliance Department or the Ethics Help Line to report any concerns pertaining to communicating with government officials.
