Our Code of Ethics and Principles of Conduct (our Code) applies to everyone, no matter their role, at The Cigna Group and its controlled subsidiaries (collectively “Company”). This means our Code applies to the Company’s Board of Directors and all of our workforce members, a group that includes full- and part-time employees, contract workers, temporary employees, and interns. Certain Company business partners working on our behalf, such as agents, affiliates, contractors and consultants, are also expected to adhere to our Code in addition to any contractual provisions that apply to their engagement with The Cigna Group.
If a workforce member is bound by a collective bargaining agreement and that agreement is not consistent with the Code, the collective bargaining agreement will govern. Nothing in this Code should be construed as limiting employee rights under section 7 of the National Labor Relations Act.
At The Cigna Group, we do more than just obey laws and regulations; we operate with integrity, transparency, and accountability. We must be respectful, truthful, transparent and genuine in our interactions with our many stakeholders. Our individual actions always reflect the values of The Cigna Group and must always follow our Code, our policies and all applicable laws and regulations. We should know the policies and regulations that are applicable to our role and must complete all required compliance training.
We do not look the other way if we see or suspect, in good faith, any action or inaction that seems illegal or unethical. We report it so it can be addressed. No concern is too minor to report.
We share our concerns promptly and cooperate fully in any internal review, audit or investigation by providing complete, factual and accurate information and preserving and producing, in a timely manner, relevant documentation in response to internal requests. Anyone who violates our Code, our policies or applicable law; impedes or improperly influences a review, an audit or an investigation; or engages in conduct that is detrimental to the Company’s interests will face corrective actions, up to and including termination of employment, consistent with our Principles of Conduct – Disciplinary Action Policy.
Our Code and policies cannot address every situation that we may face. In most cases, common sense and good judgment are the best guides. In the absence of specific guidance, there are questions you should ask yourself when facing a dilemma.
Before you act, ask yourself:
Are my actions consistent with the values of The Cigna Group?
Am I the right person to make this decision?
Does this adhere to The Cigna Group Code and policies as well as the law?
Would I want this decision to be public?
If you answer “no” to any of these questions, you should contact your manager, a Compliance representative, a Human Resources representative, or a member of the Legal Department or the Ethics Office.
The Cigna Group has established and maintains a Disclosure Program so that when we have questions or concerns about whether something is ethical or compliant, we may always seek guidance through our Ethics Help Line. Our Ethics Help Line is available 24 hours a day, seven days a week by calling 800.472.8348 in the United States or by calling our international Ethics Help Line numbers available here; the Ethics Help Line is also accessible online at Cigna.ethicspoint.com. When reporting a concern through the Ethics Help Line, you are encouraged to identify yourself to facilitate future communication. You may request to remain anonymous when permitted by law.
Be HEARD is the employment dispute resolution program for The Cigna Group U.S. employee population. It is designed to encourage open and honest conversations between employees and management, foster strong working relationships, and maintain a rewarding, inclusive and engaging workplace. The Cigna Group believes that the resolution of employment-related disputes is best accomplished when we bring together the people involved to discuss the issues, share concerns and partner in finding a solution that works for everyone. Please refer to the Be HEARD site for additional information.
Regardless of the mechanism you may use to raise a concern or issue, know that you are protected. The Cigna Group Protection Against Retaliation Policy prohibits retaliation against any individual who, in good faith, reports violations of company policy, unlawful conduct or inappropriate activity, including allegations of violations of our Code of Ethics and Principles of Conduct.
All workforce members must report ethics and compliance concerns. Our expectation of each workforce member is to report, in a timely manner, any event, incident, situation or conduct that he or she believes, in good faith, violates, or potentially will violate, an applicable law or regulation, our Code of Ethics and Principles of Conduct, or any other policies or procedures, including those devised to prevent fraud, waste and abuse. Please refer to the Duty to Report Policy for additional information.
Workforce members who observe or receive a report of an ethics or compliance concern should refrain from conducting their own investigation and should instead promptly report the matter. In keeping with The Cigna Group Open Door Policy, compliance concerns may be reported initially to an immediate supervisor or manager or to a workforce member who works in Enterprise Compliance, Legal or Human Resources/Employee Relations.
While the first point of contact may be a workforce member, that person – no matter their position within the Company – must then report the compliance concern to the Ethics Help Line or to the Ethics Office. Violations of the Duty to Report Policy may result in disciplinary action, including termination of employment and, depending on the jurisdiction and the nature of the matter, criminal and/or civil penalties.
All reports are treated confidentially, with information shared only on a need-to-know basis. The Cigna Group conducts thorough and fair reviews and assessments. As warranted, the Ethics Office, Enterprise Investigations, Employee Relations, the General Auditor, General Counsel, the Chief Compliance and Risk Officer, and/or their designees investigate alleged violations of our Code. Investigations related to Federal Health Care Programs are conducted at the direction of the Chief Compliance and Risk Officer. Workforce members may also report violations to public officials for investigation and/or prosecution. If you are asked to participate in an investigation, you must fully cooperate, including by participating in interviews, providing truthful and complete answers and information and producing, in a timely manner, emails and other documents when requested.
If an investigation determines that a violation of the Code or Company policies has occurred, The Cigna Group will take corrective steps, which may include disciplinary action against those involved up to and including termination of employment.
When a colleague shares details about a compliance violation occurring outside of your department, how do you fulfill your duty to report it? We will:
Speak up and report any concerns in good faith, even without knowing all the facts.
Refrain from conducting an individual investigation.
Come forward in a timely manner to a manager or other resource listed in the Code.
If you manage people, you have additional compliance responsibilities. Managers lead by example. Managers also create a workplace that encourages workforce members to come forward with questions and concerns.
When our colleagues have an ethics or compliance concern, they will often raise it with a people leader first. Managers, compliance officers, human resources representatives and members of the Corporate Audit Department must promptly forward reports of known or suspected compliance concerns to the Ethics Help Line. Managers should also engage the Ethics Office and Human Resources when misconduct is reported. Please refer to the People Leader Action Guide for more information.
Managers must never retaliate against anyone for sharing concerns in good faith, and they are obligated to prevent others from retaliating as well. When evaluating a workforce member’s performance, managers consider adherence to our Code. Managers may never encourage or direct workforce members to achieve business results at the expense of ethical conduct.
Be an example of ethical decision-making.
Create an environment where our teams can discuss issues in a professional and respectful manner and without bullying.
Never engage in or tolerate retaliation.
Never encourage or direct our teams to achieve business results at the expense of ethical conduct.
Promptly respond to concerns related to misconduct by contacting the Ethics Office and Human Resources as needed.
