DATA PROTECTION & PRIVACY NOTICE

DATA PROTECTION & PRIVACY NOTICE

The data privacy regulations of some countries require that a person making a report containing personal data must be notified of certain collection and retention practices regarding the information submitted by that person, and must accept the terms and conditions for the use of this Help Line service.

To proceed further, you are being asked to read this notice in its entirety, and if you agree, check the I CONSENT box that follows. You will then be able to submit a report or question using the Ethics Help Line. If you do not wish to accept the terms below, we are unable to accept any information through this Help Line system and suggest that you report this matter directly to your supervisor or manager or to a representative of Cigna's Ethics Office, Human Resources or Employee Relations, or the Legal or Corporate Compliance Departments, depending on the nature of the concern.

You may contact Cigna with any questions relating to this Notice or this service at Ethics@Cigna.com.

1. General

Cigna Ethics Help Line (“Ethics Help Line”) is a web and phone-based intake system provided by the Cigna Corporation, 900 Cottage Grove Road, Bloomfield, Connecticut 06002 USA (“Cigna” or “Company”) to all Cigna employees whether full-time, part-time or hourly, as well as to Cigna vendors, suppliers and business partners and those of its subsidiaries and joint ventures (“Reporters”) for reporting suspected violations of laws or regulations, the Code of Ethics and Principles of Conduct or other company policies related to financial, accounting, auditing and bribery matters.

In certain countries, such as the United States, the Ethics Help Line may also be used to report suspected violations of other matters. It and the database in which the personal data and information that you may report is stored, are operated in the United States by NAVEX.

2. Use of the Ethics Help Line

Use of the Ethics Help Line is entirely voluntary. You are encouraged to report possible violations directly to your supervisor or manager, or to a representative of Cigna's Ethics Office, Human Resources or Employee Relations, or the Legal or Corporate Compliance Departments, depending on the nature of the possible violation. If you feel that you are unable to do so, you may use the Ethics Help Line to make your report.

The Ethics Help Line is a confidential online reporting system that allows you to report suspected violations of laws or regulations, Cigna's Code of Ethics and Principles of Conduct, or other company policies, as well as other concerns you may have. In certain countries, Cigna may only accept reports through the Ethics Help Line that relate to certain types of conduct. If your concern pertains to a matter that, under local law, may not be accepted by Cigna through the Ethics Help Line, you will be so advised, and you will need to contact your supervisor or local management, or a representative of Cigna's Ethics Office, Human Resources or Employee Relations, or the Legal or Corporate Compliance Departments to report the matter.

Please be aware that the information you supply about yourself, your colleagues, or any aspect of Cigna’s operations may result in decisions that affect others. Therefore, we ask that you only provide information that you believe is true. You will not be subject to retaliation from Cigna for any report of a suspected violation that is made in good faith, even if it later turns out to be factually incorrect. Cigna prohibits retaliation against anyone who reports a concern in good faith or participates in the investigation of a suspected violation. Please be aware, however, that knowingly providing false or misleading information will not be tolerated.

The information you submit will be treated confidentially except in cases where this is not possible because of legal requirements or in order to conduct an investigation or address a concern, in which case the information will be handled sensitively. We encourage you to identify yourself in order for us to follow up with questions we may have.

3. What personal data and information is collected and processed?

The Ethics Help Line captures the following personal data and information that you provide when you make a report: (i) your name and contact details (unless you report anonymously) and whether you are employed by Cigna; (ii) the name and other personal data of the persons you name in your report if you provide such information (i.e., description of functions and contact details); and (iii) a description of the alleged misconduct as well as a description of the circumstances of the incident. Note that depending upon the laws of the country in which you are residing, the report may not be made anonymously; however, your personal information will be treated confidentially and will only be disclosed as set out below.

4. How will the personal data and information be processed after your report and who may access personal data and information?

The personal data and information you provide will be stored in a database which is located on servers hosted and operated in the United States by NAVEX. NAVEX has entered into contractual commitments with Cigna to secure the information you provide in accordance with applicable law. NAVEX is committed to maintaining stringent privacy and security practices including those related to notice, choice, onward transfer, security, data integrity, access, and enforcement.

For the purpose of processing and investigating your report and subject to the provisions of local law, the personal data and information you provide may be accessed, processed and used by the relevant personnel of Cigna, including Cigna's Ethics Office, Human Resources or Employee Relations, Internal Audit, the Privacy Office, Global Security, the Executive Office of Complaints, Legal, Corporate Compliance, management, external advisors (e.g. legal advisors), or, in limited circumstances, by technical staff at NAVEX. Those individuals may be located in the United States or elsewhere.

Personal data and information you provide may also be disclosed to law enforcement, regulatory and/or other authorities. The relevant bodies that receive and process personal data may be located in the US or in another country that may not provide the same level of data protection available elsewhere, such as in the European Union.

The personal data you provide will be kept as long as necessary to process your report, or, if applicable, as long as necessary to initiate sanctions or to meet our legal or financial needs.

5. Accessing information concerning the report

Where required by law, Cigna will promptly notify any person who is the subject of a report to the Ethics Help Line, that they are the subject of such a report, except where notice needs to be delayed to ensure the integrity of the investigation and preservation of relevant information.

Where required by law, and with some exceptions, the subject of a report may request information concerning the report (with the exception of the identity of the reporter), and request the deletion of personal data, or the correction of personal data that is inaccurate or incomplete, in accordance with applicable law.

You may contact Cigna with any requests relating to the use, transfer, correction, or deletion of any of your personal data stored by this service at Ethics@Cigna.com.

6. Special Country Regulations

Throughout much of the European Union and surrounding areas, reports may be limited in topics to concerns about accounting, auditing, bribery, competition law, discrimination and harassment, and environmental, health, hygiene, and safety matters. Further, some countries restrict reports such that only employees in key or management functions may be the subject of a report. In some countries, anonymous reports may not be permitted under the law except under extremely restrictive circumstances.

Any issues or concerns not permitted by law to be reported via the Ethics Help Line should be reported directly to your Manager or Supervisor or to a representative of Cigna's Ethics Office, Human Resources or Employee Relations, or the Legal or Corporate Compliance Departments as appropriate for the subject matter of the possible violation.

I CONSENT

I have read and expressly consent to the processing of my personal information as described in sections 3 and 4 above.