Corruption violates the public trust, threatens economic and social development, and impedes fair trade. To combat corruption, most of the countries in which MetLife conducts business have enacted anti-corruption laws and regulations that criminalize corrupt behavior. To comply with these laws and regulations, MetLife has adopted a zero-tolerance policy toward all forms of bribery and corruption, whether committed by MetLife employees or by a third party acting for or on behalf of MetLife. Our Global Anti-Corruption Policy sets forth guidelines and procedures designed to mitigate bribery and corruption risks; promote integrity, transparency and “do the right thing” as an integral part of our corporate culture; and advance our reputation for trustworthiness throughout the world.

MetLife is committed to maintaining processes and controls designed to combat money laundering and the financing of terrorist activities. MetLife has an established Anti-Money Laundering program which sets forth guiding principles and global minimum standards for:

1. Compliance with applicable anti-money laundering and trade and economic sanctions laws and regulations;
2. Protecting the company from being used by money launderers, terrorists and other criminals for illicit purposes; and
3. Educating employees about identifying money laundering and terrorist financing risks and behavior.

MetLife’s Antitrust Guidelines provide basic guidance on antitrust laws in the United States for employees of MetLife and its affiliates. MetLife’s policy is to conduct business in full compliance with antitrust laws. Those laws are designed to preserve and foster free and open competition, reasonable prices, efficient services and a productive economy. MetLife’s guidelines are intended to ensure that as we compete vigorously, we do so fairly. To help employees protect themselves and the company, we have included guidelines in our Code of Business Ethics to treat our competitors with respect and comply with competition laws.

MetLife’s commitment to diversity and inclusion plays an essential role in helping us create opportunities for employees, meet customers’ needs and expectations, deliver value to shareholders and make a positive impact on society. We deeply value and endorse the inclusion of intercultural diversity (race, ethnicity, culture, disabilities, generations, religion, gender, sexual orientation), work experiences, skills, perspectives and thinking styles. To reinforce this, we strongly consider multiple dimensions of diversity throughout the succession planning process and in evaluating the effectiveness of the Board. For more detail on Board diversity, see our latest Proxy Statement .

MetLife strives to conduct business fairly and transparently, always putting our customers first and staying true to our legacy. MetLife is proud of our reputation for integrity and honesty and is committed to these core values. Maintaining MetLife’s reputation depends on maintaining the highest standards of conduct in all business endeavors. MetLife’s Code of Business Ethics guides our actions, led by our Board of Directors through our Directors Code of Bussiness Ethics. We hold our suppliers to a high standard as well, following our MetLife Supplier Code of Conduct. For our By-Laws and additional codes, charters and guidelines, visit our comprehensive Statements, Policies, Codes & Archives.

We require MetLife employees to disclose outside business activities, personal investments and other situations that might cause a potential, perceived or actual conflict of interest through our Conflict of Interest Disclosure Program. Our objective is that employees do not put personal gain or benefit ahead of the interests of MetLife, our customers or our shareholders. The program emphasizes transparency and mitigation to manage risk.

To learn more about the risk management framework and practices, please see the Sustainability Report and our Corporate Governance webpage.

As part of the normal operation of our business, MetLife is entrusted with personal and confidential information every day. Our policies and procedures are designed to protect the confidentiality and security of personal information and create effective mechanisms to handle information appropriately worldwide, which includes key areas such as safeguards and risk management; monitoring; data incident response; cybersecurity and E-discovery investigation; and threat intelligence. MetLife continues to effectively mitigate cyberattacks directed at our systems with no material operational impact.

MetLife’s Information Security Program is overseen by our enterprise Chief Information Security Officer (CISO), with collaboration across businesses and functions.

The Information Security Program aims to prevent data exfiltration, manipulation and destruction, as well as system and transactional disruption. Our threat-centric and risk-based approach for securing our environment is based on the Cybersecurity Framework (CSF) developed by the U.S. government’s National Institute of Standards and Technology. Please see MetLife’s Proxy Statement for additional information.

MetLife Investment Management (MIM) integrates ESG factors in its investment decision-making processes, as outlined in our ESG Investment Policy. We believe material ESG factors have an impact on investment performance and are important considerations to effectively manage risk and achieve our clients’ investment objectives.

MIM’s investment methodology is based on a disciplined in-house research, underwriting and security selection process, which leverages the deep expertise of our seasoned investment teams. MIM’s capabilities include deal origination, asset acquisition, trading, portfolio construction and monitoring, risk analytics and risk management.

Our executive compensation practices are aligned with MetLife’s commitment to create value and help build a confident future for all. In aligning competitive total compensation with our business strategies, we help attract, retain, engage and motivate high-performing executives that aim to deliver business results in the best interest of our stakeholders. Compensation philosophy, objectives and details for key executives are disclosed in our latest Proxy Statement.

MetLife has established a culture of ethical sales practices that center on treating the customer fairly. Our Code of Business Ethics, our policies and governing laws require that we conduct business in a manner that ensures fairness, clarity and transparency. Our ethical sales practices strengthen MetLife’s reputation and help us earn the trust and loyalty of our customers as well as the privilege of partnering with them in their financial journey.

MetLife is committed to transforming the insurance industry through innovation. By engaging as many employees as possible in the creative process and building a safe environment for experimentation, we are able to tackle the real challenges confronting our global enterprise—providing breakthrough solutions for our businesses and customers.

MetLife has created an integrated innovation ecosystem designed to surface new ideas and rapidly move them to market to improve customer experiences, generate new sales approaches and new products and improve internal processes. We have an environment of continuous learning that provides MetLife “first mover” advantage in identifying and capitalizing on emerging trends.

• We invest in top venture capital firms, allowing us to interact with the venture capital firms daily to identify the best ideas across industrial sectors;
• We forge strategic partnerships with leading tech companies such as Cisco, IBM, Oracle, Microsoft, Dell, AT&T, Guidewire and others; and
• We take a direct investment stake in startups via MetLife Next Gen Ventures.

Employees participate in our internal crowdsourcing and facilitated ideation challenges. In February 2022, MetLife launched the MetLife Experimentation Fund, which provides resources for associates to launch low-cost experiments. The goal of the Fund is to better serve employees who wish to run experiments but are unable to secure funding.

Given the nature of business today, customers, employees and business partners around the world provide MetLife with personal and confidential information in order to conduct its global operations.

MetLife is committed to the protection of the confidential information of the company and its customers, employees and business partners, as well as the responsible use of personal information, respecting individual’s privacy rights and processing personal information in compliance with applicable laws and regulations. Our Global Privacy and Information Security Program document describes our safeguards, policies and governance processes that help us protect privacy and information. The objectives of the program are to:

• Protect the privacy and security of individuals’ personal information and our customer’s confidential information by adopting and implementing administrative, technical (including cybersecurity controls) and physical safeguards;
• Protect against known and unknown threats or hazards to the availability, confidentiality and integrity of personal information and other confidential information; and
• Protect against loss, destruction or unauthorized access to personal information and other confidential information.

The Program is shared by the Privacy Compliance Group and Information Security Office.

MetLife’s Government Relations team engages with policymakers and relevant stakeholders at international, regional and individual market levels to support our business, customers and employees. Government Relations supports opportunities and activities to promote diversity, inclusion, financial health and well-being of customers and communities in the markets in which we operate and advocates for public policy that enables companies to provide a secure retirement for their plan participants.

For more information, see our Political Activities Report and our Code of Business Ethics.

Our institutional investment management business, MIM, which manages much of MetLife’s General Account portfolio, regards “responsible investments” as investments that are intended to achieve both a market financial return and promote social and/or environmental benefits. MIM-managed responsible investments, which are described in our latest Sustainability Report, focus on the following core areas:

• Infrastructure
• Green investments
• Municipal bonds
• Affordable housing
• Impact investments

See the MIM ESG Investment Policy for additional detail on our investment methodology. Learn more about MIM’s approach to sustainability.

At MetLife, we are in the business of mitigating risk and protecting families and their futures. MetLife has a well-established risk management framework that constantly evolves and is designed to address material financial and non-financial risks to our business.

Our risk and control framework operates under a “Three Lines of Defense” model where everyone is responsible for risk management. Global Risk Management (GRM), the second line of defense, coordinates across risk committees to identify, measure, monitor, manage and report across the company.

MetLife’s risk management framework provides strong governance through multiple Board and senior management risk committees. ESG risks, including climate risks, are within the purview of multiple Board and senior management committees, as they underpin all aspects of risk management. These committees are established at the enterprise, regional and local levels, as needed, to oversee capital and risk positions, approve asset liability strategies and establish certain corporate risk standards. The risk committee structure is designed to provide a consolidated enterprise-wide assessment and management of risk. The committees are comprised of senior leaders from the lines of business and corporate functions as appropriate (e.g., Legal Affairs, Finance, Information Security, Actuarial Services, Internal Audit, etc.) which helps ensure comprehensive coverage and sharing of risk reporting. 

Learn more about our corporate governance and find MetLife policies, data and reports on topics such as governance and compliance, supply chain and human capital.

In addition to the ongoing outreach of the company’s Investor Relations team, Chief Executive Officer and Chief Financial Officer, MetLife conducts an annual governance-focused shareholder engagement process led by the Corporate Secretary and involving the Chief Sustainability Officer, the Senior Vice President, Executive Compensation and other members of management. MetLife invites shareholders and leading proxy advisory firms to meet and share their views on issues important to them.

Shareholders are invited to discuss topics such as corporate governance, board composition, sustainability commitments, metrics and disclosures, and DEI efforts and informs the company’s sustainability efforts, executive compensation programs and disclosure practices. Our latest Proxy Statement provides details on recent engagement with our investors. Our MetLife Investment Management (MIM) Engagement Policy describes our active engagement with the companies we invest in.

MetLife engages with a broad array of stakeholders on a regular basis. We deeply value the time and diverse input we receive from our stakeholders and the opportunities for two-way dialogue. Our latest Sustainability Report provides insight on the stakeholder groups with which we engage, the nature and frequency of our engagement, and programs and partnerships on which we collaborate.

MetLife’s Sustainable Financing Framework facilitates alignment of our business and investment activities to drive a sustainable future. The Framework guides our issuances of green, social and sustainable bonds, term loans, preferred stock, subordinated notes and funding agreements by MetLife, Inc. and its subsidiaries, including Metropolitan Life Insurance Company and Metropolitan Tower Life Insurance Company.

Learn more about MIM’s approach to sustainability.

We understand the importance of an environment in which employees feel empowered to speak up. We encourage employees to lead by example, holding themselves and others accountable by raising issues and concerns. Employees can speak up using the channel that is most comfortable for them and can report anonymously, where permissible by law.

Reporting channels include:

• Ethics & Fraud Helpline;
• Speak Up Tool, a desktop icon available to all employees;
• Corporate Special Investigations Unit;
• Local or Regional Compliance Risk Management;
• Local or Regional Helpline or Whistleblowing Contact;
• Local or Regional Human Relations or Employee Relations; and
• Direct supervisor, next level supervisor and any other level of management.

MetLife takes all reported concerns seriously, and each one is reviewed, investigated and addressed, as appropriate. When warranted, MetLife takes appropriate disciplinary or corrective actions, including termination of employment or contracts with business partners. MetLife prohibits any form of retaliation against an employee for raising a concern in good faith or assisting with an investigation regarding a potential violation of our Code, our policies, laws or regulations. 

Customer and external stakeholder concerns and grievances can be reported through MetLife customer service departments or the stakeholder’s relationship manager. Anyone can report potential ethics, fraud or misconduct concerns through the Ethics & Fraud Helpline (available globally)—either online or by phone. Concerns are escalated, as appropriate, to Legal, Risk, Compliance, the Executive Leadership Team or to MetLife’s Board of Directors. For more, visit our Corporate Governance webpage.