Bribery is never acceptable. As we strive to further our business interests and outperform our competitors, we will do so honestly, fairly, openly and with integrity. We have a zero tolerance policy towards bribery.
In keeping with our commitment to obey all laws and regulations that apply to our business, we will support and abide by all relevant laws and regulations regarding anti-bribery and anti-corruption. This includes all provisions of the U.S. Foreign Corrupt Practices Act, which addresses financial and other interactions with foreign government officials and institutions, as well as applicable anti-corruption requirements of other jurisdictions in which the Company does business, such as the UK Bribery Act 2010, which prohibits bribery in the private and public sectors.
Bribery is a criminal offence in most countries in which Aetna operates, and penalties can be severe. In the US, the Foreign Corrupt Practices Act (or FCPA) not only makes bribery and corruption illegal, it also requires companies to implement internal controls to ensure accurate books and records and to prevent bribery, including by 3rd parties acting on behalf of the company. Similarly, the UK Bribery Act 2010 requires companies to implement adequate procedures to prevent bribery by those working for the company or on its behalf. These laws are vigorously enforced by the US and UK authorities around the world. Regulators in other jurisdictions, such as China, are also enforcing their anti-corruption laws.
Our anti-corruption and anti-bribery policy is driven mainly by the following risk-based principles:
- We do not permit promising, making, approving or accepting bribes, kickbacks or illegal payments, whether directly or through a third party, to obtain an improper advantage. Even the appearance of paying bribes through other means (such as lavish trips, hospitality, meals, entertainment or gifts; and improper political or charitable contributions) must be avoided. Likewise, we prohibit making facilitating payments.
- We will maintain complete and accurate books and records, and internal controls to assure a complete, accurate and sufficiently detailed accounting of all business transactions, expenditures and use of assets, and to prevent concealment of bribes through unrecorded “off books” transactions or fake recordkeeping.
- Customary gifts, meals, entertainment, travel, promotional giveaways, sponsorships, remuneration or other things of value intended for public or government officials or for commercial persons or entities, if permitted and pre-approved by us, must be of reasonable value and justifiable with no intention to obtain improper advantage.
- Charitable donations must be to a bona fide charity and for bona fide and measurable charitable programs/purposes. These must also be pre-approved by us.
- The use of sub brokers or other third parties must be disclosed to Aetna and must be for bona fide and legitimate services, with reasonable and customary charges based on the services being provided.
- We will maintain anti-corruption due diligence procedures for sub-brokers or other third parties having business relationship with or acting on behalf of the company.
- We will maintain training procedures to assure that employees and representatives are aware of, understand and abide by these requirements.
- We will maintain procedures to test compliance with these requirements and to assure an appropriate level of review for potentially high risk transactions, including transactions involving public or government officials or institutions, and transactions with private persons or companies where there is a potentially high risk for bribery or corruption.
- We will maintain reporting mechanisms so that those who suspect, know or are concerned that a corrupt act of some kind is being considered or carried out – either within Aetna, by any of our business partners or by any of our competitors – can report the matter to us. One of these reporting mechanisms is our AlertLine®, which allows for confidential and anonymous reporting.