Legal & Regulatory Compliance

LEGAL & REGULATORY COMPLIANCE

TRANSPARENCY IN COVERAGE RULE: MACHINE READABLE FILES

In compliance with Transparency in Coverage (TIC) regulations, effective July 1, 2022, we are making the machine-readable files (MRFs) for plans we administer available to the public on our website:

https://www.cigna.com/legal/compliance/machine-readable-files

ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT

Tavant is committed to preventing acts of modern slavery and human trafficking from occurring within its business. We take responsibility for protecting fundamental human rights and eliminating modern slavery by ensuring that slavery, human trafficking, and child labor have no place in our business. We are committed to ensuring that our employees, workers, and contractors are treated fairly, that their human rights are respected, and that they feel confident that they can expose wrongdoing without any risks to themselves. We do not enter into business with any organization which knowingly supports or is found to be involved in slavery, servitude, and forced or compulsory labor.

EQUAL OPPORTUNITY AND WORKPLACE DIVERSITY

Tavant is an equal-opportunity provider. We believe in providing equal employment and advancement opportunities to all individuals. Employment decisions at Tavant are based on merit, qualifications, and abilities. Tavant does not discriminate in employment opportunities or practices based on race, color, religion, sex, national origin, age, disability, or any other characteristic protected by law. Any employee with questions or concerns about any type of discrimination at his/her workplace is encouraged to bring those issues to the attention of their immediate manager or the HR department. Employees can raise concerns and make reports without the fear of reprisal. Anyone found engaging in any type of unlawful discrimination will be subject to disciplinary action, up to and including termination of employment.

PREVENTION OF SEXUAL HARASSMENT AT THE WORKPLACE

Tavant has zero-tolerance against any act constituting sexual harassment. Tavant is committed to creating a safe and healthy work environment that enables its employees to work without fear of prejudice, gender bias, and sexual harassment. The company also believes that all its employees have the human right to be treated with dignity. Sexual Harassment at the workplace or in the course of official duties, if involving Employees /Contractors/ Project Trainees/Interns/ Partners/ Visitors of the company shall be considered a grave offense and is therefore punishable under the applicable laws.All forms of discrimination and conduct which can be considered harassment, coercive, or disruptive, or which create a hostile or offensive environment, are strictly prohibited, and shall not be tolerated. Instances of sexual harassment whenever brought to the notice of the company’s management shall be dealt with expeditiously and inquired as per the law.

CODE OF CONDUCT

This Code of Ethics and Conflict of Interest Policy for Directors, Officers, and Employees, as defined below, is designed to maintain the standards of business conduct of Tavant, its subsidiaries, and affiliates, and their successors and assigns (collectively and severally, the “company”), and to assure compliance with applicable law. The company is committed to conducting its business in accordance with the highest ethical standards. It is the policy of the company to conduct its business fairly, ethically, and in compliance with applicable law.

The company adopts and conducts its business in a fair, ethical, and transparent manner. The company expects that each of its employees imbibes this ethical behavior and works towards upholding the principles and standards laid down by the company. Any actual or potential violation of this policy, howsoever insignificant or perceived as such, will be a matter of grave concern.

This policy applies to all employees and directors of the company.

WHISTLEBLOWER POLICY

“Whistleblower” means any person who decides to inform the company against any noted violations of the code of conduct of the company, including abuse of authority, mismanagement of financial reports, violation of law, etc.

The objective of this policy is to encourage timely, safe, and open reporting of any alleged wrongdoings or suspected impropriety or violations of law. The company encourages its employees and directors to report any matter that they think may be a potential or a perceived threat. Failure to promptly raise a known or suspected violation will be considered unethical behavior and will go against the company’s code of conduct.

If a director or an employee notices any unethical act or wrong doings prejudicial to the interest of the business of the company, he/she should immediately raise a complaint. A complaint should be made in writing to the email address ([email protected]) with complete details of the noted violation. The company does not encourage the employee to investigate the violation and only seeks information and details. Any violation will be promptly investigated by the company. A complaint can be made anonymously without revealing the identity of the complainant.

The company will ensure to protect whistleblowers against retaliation and will keep the whistleblower’s identity confidential unless the person agrees to be identified or the identification is necessary to allow the company or law enforcement officials to investigate or if the identification is required by law.

Employees are strictly advised against making any false complaints. If the complaint is investigated and discovered to be false and is found to be made with an ulterior motive, the company will initiate disciplinary action against such employees.

The company has adopted and conducts its business in a fair, transparent and an ethical manner. The company expects that each of its employees imbibes this ethical behavior and works towards upholding the principles and standards laid down by the company. Any actual or potential violation of this policy, howsoever insignificant or perceived as such, will be a matter of serious concern.