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Supplier Code of Conduct - MassMutual

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<strong>MassMutual</strong><br />

<strong>Code</strong> <strong>of</strong> <strong>Conduct</strong><br />

for <strong>Supplier</strong>s<br />

The Winning Way


Overview<br />

At Massachusetts Mutual Life Insurance<br />

Company (“<strong>MassMutual</strong>”) and our affiliates,<br />

acting ethically, with integrity and in<br />

compliance with applicable laws and<br />

regulations is not only the right thing to do,<br />

it is how we do business. Our <strong>MassMutual</strong><br />

<strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> describes our company<br />

principles and values and establishes the<br />

standards for our employees’ behavior.<br />

As one <strong>of</strong> our suppliers, we expect you to<br />

share our commitment to act ethically, with<br />

integrity and in compliance with applicable<br />

laws and regulations. This <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong><br />

for <strong>Supplier</strong>s articulates the principles,<br />

values and expectations <strong>of</strong> behavior we<br />

have for our suppliers when doing business<br />

with <strong>MassMutual</strong>. You are responsible<br />

for understanding the <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> for<br />

<strong>Supplier</strong>s and adhering to its contents.<br />

If you have questions about the <strong>Code</strong> <strong>of</strong><br />

<strong>Conduct</strong> for <strong>Supplier</strong>s, please contact<br />

<strong>MassMutual</strong> Procurement at 413-744-3800.<br />

Focus on the Customer | Act with Integrity | Value People | Work Collaboratively | Achieve Results


Principles <strong>of</strong> <strong>Conduct</strong><br />

We will conduct business ethically, with integrity and in<br />

compliance with applicable laws and regulations.<br />

We expect our suppliers to always act ethically, with integrity<br />

and in compliance with applicable laws and regulations<br />

when doing business with <strong>MassMutual</strong>. Unethical or illegal<br />

behavior is not justified in any circumstance.<br />

We will be respectful to others and welcome and encourage<br />

diverse opinions, attitudes, attributes and feelings.<br />

We expect our suppliers to share our commitment to<br />

maintaining a diverse, respectful and productive workplace<br />

where individuals work together and value and learn from<br />

each other. Certain behavior, including illegal harassment or<br />

discrimination, has no place in a respectful workplace and<br />

will not be tolerated when doing business with <strong>MassMutual</strong>.<br />

We will protect confidential information related to<br />

<strong>MassMutual</strong> and its customers and employees against<br />

unauthorized access, use or improper disclosure.<br />

<strong>MassMutual</strong> takes the protection <strong>of</strong> confidential<br />

information, including non-public information about<br />

<strong>MassMutual</strong> and its customers and employees, very<br />

seriously. We expect our suppliers to take protective<br />

measures to safeguard our confidential information against<br />

unauthorized access, use or improper disclosure.<br />

We will create and maintain documents and records,<br />

including financial information, that are accurate, honest,<br />

and timely.<br />

When doing business with <strong>MassMutual</strong>, we expect our<br />

suppliers to create documents and records that are authentic,<br />

accurate, complete, unaltered, and readily accessible<br />

and understandable.<br />

We will avoid conflicts <strong>of</strong> interest.<br />

We base our business relationships on objective factors<br />

such as quality, performance and price. Our employees are<br />

instructed to avoid conflicts <strong>of</strong> interest, and to the extent<br />

possible, even the appearance <strong>of</strong> conflicts <strong>of</strong> interest. This<br />

includes prohibitions against our employees soliciting<br />

business courtesies or entertainment or giving or accepting<br />

business courtesies or entertainment that creates the<br />

appearance <strong>of</strong> an improper attempt to influence a business<br />

decision. We expect our suppliers to avoid conflicts <strong>of</strong><br />

interest when doing business with <strong>MassMutual</strong>, including<br />

not <strong>of</strong>fering to or accepting from our employees any<br />

business courtesies or entertainment that could be perceived<br />

as an improper attempt to influence a business decision.<br />

We will be honest and forthright and comply with applicable<br />

laws and regulations in our dealings with the government.<br />

When interacting with government <strong>of</strong>ficials or agencies<br />

on behalf <strong>of</strong> <strong>MassMutual</strong>, we expect our suppliers to be<br />

honest and transparent and to comply with applicable<br />

laws and regulations governing corporate political<br />

activity, lobbying, gifts and entertainment with respect to<br />

government <strong>of</strong>ficials, and interactions with current or former<br />

government employees.<br />

Speaking Up<br />

If you suspect or observe a violation <strong>of</strong> the <strong>Code</strong><br />

<strong>of</strong> <strong>Conduct</strong> for <strong>Supplier</strong>s, either by you or one<br />

<strong>of</strong> <strong>MassMutual</strong>’s employees, we expect you to contact<br />

your <strong>MassMutual</strong> <strong>Supplier</strong> Relationship Manager or<br />

Procurement contact. You may also report conduct<br />

that violates, or that you suspect violates, the <strong>Code</strong> <strong>of</strong><br />

<strong>Conduct</strong> for <strong>Supplier</strong>s to <strong>MassMutual</strong>’s Compliance and<br />

Ethics Reporting Hotline.<br />

The Hotline is accessible via phone (1-800-422-1381) or<br />

online (www.massmutual.com/ethicspoint).


© 2012 Massachusetts Mutual Life Insurance Company, Springfield, MA 01111-0001. All rights reserved. www.massmutual.com. <strong>MassMutual</strong> Financial Group is a marketing name for<br />

Massachusetts Mutual Life Insurance Company (<strong>MassMutual</strong>) and its affiliated companies and sales representatives.<br />

COR1709 912 CRN000000-000000

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