Among numerous other wrongdoings, the dispute notice alleged Aflac’s manipulation of one of its “key operational metrics” – the number of average weekly or monthly producers, i.e., sales associates actively selling Aflac insurance during the reporting period – that Aflac had represented to the market as an important indicator of the company’s growth and earnings potential.

“These numbers are inherently inflated due to the large-scale fraudulent recruiting and the resulting extremely high attrition rate within the first year,” the lawsuit states. “Moreover, these numbers are further inflated because they include the newly recruited associates as ‘producers’ even though many of them do not produce anything during their short stay at the company. In order to count them as ‘producers,’ at the end of a reporting period Aflac falsely assigns a minimal amount of production – as low as $1 – to the non-producing associates in order to count them towards the ‘average producer’ metric by taking that production amount from other, producing associates.”