8/16/2019 CT Ethics Correspondence

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O Dowd, ;3rian

From:Sent:To:

Subject:

Hello Katie -

O Dowd, BrianFriday, February 26, 2016 2:45 P

Request

Given that there are no Cigna matters pending before you, and that you are therefore not required totake any official action concerning Cigna, the primary conflict provisions in the Code of Ethics forPublic Officials, namely, General Statutes§§ 1-85 and 1-86 a), are not triggered.

Instead, the relevant provision is General Statutes§ 1-84 c), under which a public official may notuse his public office or any confidential informat ion received through his holding such public

office to obtain financial gain for himself, his spouse, child, child's spouse, parent, brother orsister or a business with which he is associated."

Applying that provision here, your husband may divest the Cigna stock options as they vest fromFebruaty 25, 2016, through March 5, 2016, provided that you do not use any confidential informationgained in your state position to influence your husband's decisiOn as to whether to do so.

f you have any follow-up questions, please let me know.

Sincerely,

Brian

Brian J. O'DowdDeputy General Counsel

Connecticut Office of State Ethics18 20 Trinity Street f Hartford, CT 06106 1660

I F: I brian.odowd@ct.gov

Ethics Matters

From: Kaiharine Wade [mailto:Sent Thursday, February 25, 2016 9:05 AMTo O Dowd, BrianSubject Request

Brian:

I am seeking approval for my husband, Michael, to divest his Cigna stock and options as they vest February 25,2016 through March 5 2016.

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