Rehired Employee Policy

Rationale

Rehiring retirees and former employees can have significant benefits for both the individual and the Company by providing the Company with a knowledgeable and experienced pool of candidates to help meet business needs. Although the rehire of retirees and former employees is permissible, certain protocols must be observed in order to comply with applicable IRS regulations, which require an individual to have truly separated from the service of the Company in order to receive retirement plan benefits. That is, the termination of employment cannot occur for the purpose of commencing a benefit if the employee has an intent or arrangement to return to the Company. In addition, federal law prohibits active employees from participating in certain retiree medical benefit plans sponsored by an employer.
 

Scope

This policy applies to all former employees of The Hartford and its participating subsidiaries who are based at U.S. locations of The Hartford, have terminated employment or retired and are being considered for hire as active employees, or for engagement as independent contractors or as employees or contractors of another company that provides services to The Hartford (such as a Pontoon vendor or other temporary agency).

Generally, retirees and former employees of The Hartford are eligible for rehire after a minimum of a four-month break in service. Individuals may be rehired as either full- or part-time employees or as non-employee contractors performing services for The Hartford. Individuals who have not worked for The Hartford during the last four months can work for the Company again as an employee, an independent contractor, or an employee or contractor of another company that provides services to The Hartford, provided they terminated under circumstances that make them eligible for rehire and their rehire was not planned at the time they left.

An individual who has worked for The Hartford in the past four months can work for the Company again as an employee, an independent contractor, or an employee or contractor of another company that provides services to The Hartford, under certain circumstances. The individual may be rehired if he or she has NOT taken any of the following actions since terminating/retiring from The Hartford:

(1) Commenced benefits under the final average pay formula of the Retirement Plan for U.S. Employees;

(2) Received a distribution (either lump sum or annuity) under the cash balance formula of the Retirement Plan for U.S. Employees;

(3) Received a distribution under the Investment and Savings Plan (ISP)

An individual who has taken one of the three actions listed above can only be rehired with specific approval, unless certain exceptions apply. Please contact the HR Business Partner, Hiring Manager, or The Hartford HR Service Center for additional information regarding how to obtain approval, or to determine whether the exceptions may be met.
 
In addition, an individual who, upon termination from the Company, received severance in the form of a lump sum cannot be rehired until he or she has reimbursed the Company the portion of the lump payment severance attributable to periodic severance payment described in the "Rehire" section of the Severance Pay Plan.
 
If an individual who is participating in a retiree medical plan sponsored by The Hartford (either the Retiree PPO or the Health Reimbursement Account) is rehired, upon rehire such individual will immediately lose eligibility to participate in retiree medical and will be required to waive, in writing, his right to participate in the plan permanently.

In no event should an arrangement or commitment be made to an employee at the time an employee terminates employment to later rehire him or her as an employee, or to engage their services as an independent contractor.