Solicitations and Distributions Policy

During working time The Hartford regulates the solicitation of employees and the distribution of non-work related literature to employees. The Hartford also regulates the posting of non-work related items on Company bulletin boards and using the company's electronic communication systems and social media systems. Employees should refer to the Electronic Communications and Social Media policies for further information about acceptable use.

As used in this policy,

 

• the term "working time" means the period of time that an employee spends performing actual job duties, and does not include meal periods or breaks;
• the term "work areas" includes all locations on The Hartford's premises where employees conduct work for the company, but does not include break areas, cafeterias or parking lots ("non-work areas"); and
• the term "solicit" means any effort to sell goods or services or to raise money on behalf of the soliciting party personally, or for any outside organization, club, society, religious group, political party, or similar organization, or the distribution of any materials such as leaflets or flyers for those organizations.

• Solicitation - Absent prior authorization from management, no employee may solicit another employee for any purpose not directly related to the employee's assigned work, if the solicitation occurs during the employee's working time or the working time of the employee being solicited. Solicitation is permitted when both parties are not on working time.
• Distribution - Absent prior authorization from management: (a) no employee may distribute written literature or materials for any purpose not directly related to the employee's assigned work, if the distribution occurs during either the employee's working time or the working time of any employee approached; and (b) distribution of these documents is prohibited at all times in all working areas on Company premises. Employees may distribute non-work related written documents to other employees in non-work areas during non-working time.
• Postings/Bulletin Boards - Generally, The Hartford's bulletin boards are intended to be used for business-related purposes. Absent prior authorization from management, the posting of other items not directly related to work is prohibited. However, the posting of personal items for sale or rent such as would appear in the classified section of a newspaper (e.g., cottage rental, auto for sale) is permitted. 

• Company fundraising events, such as the Annual Giving Campaign and other enterprise-wide events, provided that the requestor receives advance approval from the Executive Vice President of Marketing and Communications. These events may occur in work areas during work time and use corporate resources.
• Vendor sales at The Hartford locations through the corporate vendor program, and with approval of Real Estate Operations.
• Small-scale employee collections or sale of items for the benefit of non-profit organizations, such as schools, girl scouts and other youth clubs, or certain persons in need of charitable assistance, such as local families or employees in distress, provided that employees:
  • receive advance approval from their manager; 
  • raise funds to serve primarily charitable (vs. social) purposes and events; 
  • do so within their own work area during non-working time and before or after the department's work hours;
  • do not pressure other employees to participate;
  • do not use corporate resources (including e-mail and printers); and
  • do not interrupt other employees during their work time.
• Employees may not sell items to generate a profit for any other purpose, such as running a business.
• Managers and employees are responsible for adherence to company policy. Failure to do so may result in disciplinary action up to and including termination.

Rationale

Eligibility/Scope

Applying the Policy

• Employees may not use The Hartford's social media or electronic communication systems for purposes of solicitation or distribution, without prior approval by their management.
• Political candidates may be brought on-site only with advance approval from the Senior Vice President of Government Affairs.
• Individuals who are not employees or vendors of The Hartford may not solicit or distribute materials in locations where The Hartford controls.
• Vendor sales of goods, foods, and services on The Hartford’s property, including those involved in non-profit and charitable fundraising, is generally restricted, and not permitted without the approval of Real Estate Operations. In all cases, vendors must situate themselves in only non-work areas.
• The Hartford has no obligation to provide "equal time" for vendors in similar businesses.
• Local areas may implement a more restrictive policy with the approval of Real Estate Operations.
• The Hartford has the authority to monitor local bulletin boards and to remove items in violation of this policy.
• Raffles and gambling/betting pools (where money or anything of value changes hands), including those for the Annual Giving Campaign and other approved fundraising events, are prohibited.

• With management’s approval, employees may sell items to raise money for non-profit organizations and charitable purposes, including collections for employees/families in need.
• Employees should not engage in ongoing, long-term or year-round fundraising for broad or undefined purposes. All fundraising must support specific events and purposes with defined donation dates to the identified non-profits or charitable causes.
• Items should be sold only on non-work time (although this could be difficult to manage) and within the employee’s own workspace (cubicle or office).
• This type of fundraising should not be a distraction to other employees or disrupt the work environment.
• Employees cannot post signs or notices for small-scale fundraising events. Employees can use the e-mail system, only after securing advance written approval from department management.

• With department or local management’s approval, employees may raise money and organize events to benefit non-profit organizations and charitable purposes. These large-scale fundraisers are not operated at the corporate or enterprise-wide level, but instead are organized by departments or local offices.
• All fundraising must support specific events and purposes with defined donation dates to the identified non-profits or charitable causes.
• Employees can post signs or notices and use e-mail for this type of fundraising with local management’s approval.
• Items may be sold on non-work time and in common areas outside the employee’s own workspace, such as a department conference room.

• Fundraising on a large scale (event to raise money by company or departments) for any non-profit organization must have prior approval from Community Relations. Prior to utilizing common spaces for large-scale fundraising, Employees must obtain approval from local management and Real Estate Operations.
• Only small-scale fundraising for non-profits or local families in need (selling items within employee’s workspace) may be done without prior approval from Community Relations.
• Note that the sale of food items requires the approval of Real Estate Operations. Approval depends on whether food service contracts between The Hartford (or its landlord) and its vendors permit such an arrangement at the work site.

• Employees handling large-scale fundraising for corporate-sponsored events (such as the United Way) must coordinate money collection activities with Corporate Treasury, including the use of corporate tax identification numbers and bank accounts.
• All other fundraising (events not sponsored by The Hartford, such as department-based events) may not use a tax identification number or bank account affiliated with or using a Hartford entity name or address.
• Employees are prohibited from opening bank accounts in their individual or club name to collect funds. Rather, money collected for non-corporate sponsored fundraisers must be deposited directly to the charity; that is, through credit card transfer from employee to the designated charities’ bank/web-site. For instance, the family receiving donations should open an account at a local bank and then direct employees to the account to make a donation.
• Employees collecting funds for which the charity or non-profit does not have an account must secure funds in a safe, locked area (such as file cabinet, desk drawer) and exercise utmost caution to prevent theft prior to delivering the funds to the charity or beneficiary.
• Employees may not engage in ongoing, long-term or year-round fundraising for broad or undefined purposes, nor maintain accounts with monetary contributions any longer than absolutely necessary. Employees should collect funds only to support specific events and purposes and contribute collected funds to the non-profits or charitable causes involved as soon as practicable.
• Example: An individual employee organizes a golf outing to benefit a local charity. That employee must receive permission from Community Relations in advance of soliciting funds from employees. The employee should direct employee contributions to the charity or beneficiary of the event (not a Hartford work address). Alternatively, the employee may collect “registration fees” for the golf outing directly from employees to pay expenses associated with the event and deposit to the charity as soon as practical. Any cash contributions to the employee should be secured in a safe, locked area for as long as those funds are in the employee’s possession.

Donation of office supplies

 

The distribution of unused office supplies to community non-profit partners of The Hartford is permitted, but must be reviewed by the Corporate Social Responsibility and Strategic Sourcing/Real Estate teams prior to distribution. Any non-profits outside of The Hartford's community partnership portfolio may be considered for donations, but must be reviewed and approved by the Corporate Social Responsibility and Strategic Sourcing/Real Estate teams prior to distribution. For reviews and approvals of office supply donations, please contact csr@thehartford.com.