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Governance, Ethics & Integrity

You rely on us to help you create a strong financial future, and we take that responsibility seriously. We feel that trust is essential in making any relationship work. We strive to create, maintain and enhance our relationships through our commitment to act ethically, with integrity and in compliance with all laws and regulations that govern our business.

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    MassMutual Code of Conduct
    The building block for our ethical conduct is the MassMutual Code of Conduct. Our Code of Conduct establishes the standards for our behavior and helps guide our decisions. Our Code of Conduct also embodies our Winning Ways, which are our core values.

    Each year, all employees must complete certain compliance and ethics education courses, and they must also acknowledge their understanding of the Code of Conduct and agree to comply with its content. In addition to the Code of Conduct, a number of other corporate policies help guide our actions and decisions.

    MassMutual Code of Conduct for Directors
    Our Code of Conduct for Directors applies to all members of the Board of Directors of Massachusetts Mutual Life Insurance Company. The Code of Conduct for Directors provides guiding principles for appropriate business behavior and conduct at MassMutual. In addition to the Code of Conduct for Directors, the Directors are subject to certain requirements relating to non-public information and personal trading contained in MassMutual’s Investment Advisory Code of Ethics. Directors who are officers of MassMutual are also subject to MassMutual's Code of Conduct.

    MassMutual Financial Group Principles of Conduct
    The Principles of Conduct describes the principles, values, and expectations of behavior that apply across the MassMutual Financial Group family of companies. It complements, but does not replace, MassMutual's Code of Conduct.

    MassMutual Code of Conduct for Suppliers
    We expect our suppliers to share our commitment to ethical, compliant behavior. To help our suppliers understand our expectations of them, we developed the Code of Conduct for Suppliers. Suppliers receive this document as part of our procurement process.

    MassMutual Code of Conduct for Temporary Personnel
    The Code of Conduct for Temporary Personnel applies to temporary personnel who provide services to MassMutual. The Code of Conduct for Temporary Personnel describes the principles, values, and expectations of behavior we have of all individuals who conduct business on behalf of MassMutual.

    MassMutual’s Investment Advisory Code of Ethics
    As an investment adviser registered with the Securities and Exchange Commission, MassMutual is required to establish, maintain, and enforce a Code of Ethics. Our Investment Advisory Code of Ethics describes the standards of conduct that apply to individuals who are engaged in MassMutual’s advisory business.

    Financial Management Code of Ethics
    The Financial Management Code of Ethics describes principles and expectations of behavior related to employees whose job responsibilities include gathering, reporting, managing or controlling financial information or who report to the Chief Financial Officer.

    Producer Compliance Manual
    Agents in the field are subject to the Producer Compliance Manual, which can be accessed through our secure FieldNet extranet site. FieldNet is dedicated to servicing and providing information to agents. Additionally, agents must complete compliance and ethics training which is conducted at the local agency level by the agency’s supervisory officers who generally have responsibility for implementing and executing compliance and supervisor procedures in the agency.

    Statement of Respect
    In addition to the codes and other company policies that set the standard for business interactions, we also have a Statement of Respect that reflects our commitment to providing all employees with a respectful work environment. It includes and explains our Equal Opportunity, Discrimination and Harassment Prevention, and Diversity policies. Employees receive a copy of the Statement of Respect annually, along with a cover letter from an executive officer emphasizing the strict enforcement of the Statement.

    Obligation to Report
    Employees are obligated to report known or suspected compliance or ethics issues or concerns. To ensure employees are able to raise issues regarding possible compliance or ethics violations, we have adopted the industry best practice of establishing a hotline maintained by an external third-party vendor. Employees can contact the Compliance and Ethics Reporting Hotline by phone or online to report any compliance or ethics issues or concerns on an anonymous or identified basis. In addition, employees still have the option of reporting potential violations through other reporting channels, including their manager, business or corporate unit compliance officer, Law Department counsel, Human Resources Business Partner, or the Chief Compliance Officer.

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