Overview
The Hartford prohibits any form of retaliation or intimidation against employees who report good-faith concerns of discriminatory, harassing or unethical conduct, or who participate in investigations of such conduct.
Rationale
A culture of diversity, respect and strong corporate ethics is best achieved through open communication, including open and candid discussion about compliance with applicable laws, regulations and Hartford policy. All managers are responsible for creating and maintaining a work environment that encourages employees to speak up about potentially inappropriate business practices or behavior.
Prohibition Against Retaliation
The Hartford provides a variety of avenues for employees to report good faith concerns about potentially inappropriate business conduct or behavior without retaliation or intimidation, in accordance with applicable laws and regulations (See Code of Ethics and Business Conduct). Likewise, The Hartford provides various means for employees to make good faith reports of alleged discrimination, harassment or intimidation as described in the Reporting and Investigating Discrimination and Harassment Policy.
In accordance with applicable laws and regulations, The Hartford prohibits any form of unlawful retaliation or intimidation against any person for making good faith reports concerning allegations of discrimination, harassment, violations of the Code of Ethics and Business Conduct, or any other allegations of inappropriate business practices or behavior. The Hartford similarly prohibits any form of unlawful retaliation against any person who participates in good faith in any investigation or other proceeding related to such a report, even if the Company ultimately concludes that no violation of law, regulation, the Code of Ethics and Business Conduct or Company policy has occurred.
Retaliation is any action this is likely to deter an employee from reporting concerns or participating in an investigation and is taken because an employee made a report or participated in an investigation. Examples of retaliation can include, but are not limited to:
- Suspension, demotion or termination
- Denial of promotions or pay increases
- Ostracization by colleagues
- Creating a hostile or intimidating environment
- Scrutinizing work or attendance more closely than that of other employees, without justification
- Adverse changes to the employees' job duties or work schedule
- Reassignment to a less desirable position or location
The Hartford does not prohibit employees from and will not discipline them for sharing information regarding their own wages (or the wages of another employee, if voluntarily disclosed by that employee), hours, or other terms and conditions of employment. Employees may not, however, disclose (without the prior written consent of The Hartford) confidential information including wage information of other employees to a competitor. Further, employees who have access to other employees' wage information as part of their job responsibilities are prohibited from sharing such information they acquire during the course of their employment, unless such disclosure is in furtherance of their job duties or the employee otherwise has a legal obligation to furnish the information.
Hartford employees who engage in unlawful retaliation or intimidation in violation of this Policy will be subject to disciplinary action, up to and including termination. Any person who retaliates against another person for reporting actual or potential violations of laws or regulations also may be subject to criminal and civil liability under federal and state laws.
Cooperation with Investigations
In accordance with the Code of Ethics and Business Conduct, all Hartford employees are required to cooperate with internal investigations undertaken by The Hartford. In particular, among other things, employees are required to make themselves available to internal investigators immediately upon request, be forthcoming and truthful with investigators, and provide complete and accurate information.
Scope
This policy applies to all employees and contractors of The Hartford and its participating subsidiaries who are based at U.S. locations of The Hartford. Non-U.S. units shall also apply the intent and provisions of this policy, unless local law requires otherwise.
Revised: 9/23/24