ĤƵ

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ĤƵ Environmental, Social and Governance Policy

Policy Number: LD-22
Department: Legal
Original Effective Date: March 12, 2024

PURPOSE AND SCOPE:

ĤƵ (the “Company” or “ĤƵ”) believes in a commitment to transparency and accountability in the environmental sustainability and social impact of our operations and the services we provide to the U.S. healthcare system. The Company believes that it is our responsibility to operate in a manner that creates long-term value for all of our stakeholders, including our stockholders, customers, employees, and the communities in which we operate.

This policy is intended to lead our efforts with respect to our procedures and operational controls for environmental, social, and governance (ESG) principles and is led by the ĤƵ Sustainability Working Group with direction from our executive and senior leadership. The Sustainability Working Group meets regularly to review practices, establish baselines and best practices, set implementation timelines, and monitor progress and results. This policy may be updated from time to time. This policy is intended to be reviewed annually.

This policy is intended to supplement, and not to supersede, the Company’s other policies that may be applicable to or involve environmental, social, or governance matters.

POLICY STATEMENT:

The Company is committed to integrating ESG factors through our operations and we focus on matters that are meaningful to all of our stakeholders. We seek to ensure that solid ESG thinking is part of every aspect of our makeup and how we operate internally and externally.

There are three pillars to the Company’s ESG Policy:

  1. Environmental – We recognize the importance of improving our environmental footprint and addressing climate change by embracing opportunities in areas that advance our practices and the principles of sustainability.
    1. Climate Change: As we continue to evaluate our operational practices, we intend to comply with and monitor emerging legal and regulatory requirements on climate change and greenhouse gas (GHG) emissions reporting and are evaluating our ability to offer disclosures aligned with emerging frameworks, including the Task Force on Climate-Related Financial Disclosure. We will continue to evaluate and implement practices that may limit or reduce our current emissions and encourage more sustainable business practices.
    2. Remote workforce: We continue to carefully evaluate our employee work locations, particularly in light of our remote-first workplace strategy. By embracing hybrid and remote work arrangements, our employees generally no longer commute on a daily basis or frequently travel between locations for meetings. We also carefully and continuously evaluate our office space to ensure office-space optimization.
    3. Sustainable Operations: We seek to implement environmental processes and practices in the area of energy, waste, and water in order to minimize our carbon footprint and impact on our surrounding communities. We will continue to evaluate and identify opportunities to reduce the natural resources in our operations on an ongoing basis.
    4. Education and Awareness: We seek to promote sustainable practices among our employees and will seek to develop and engage them in environmental education and awareness programs and initiatives.
  2. Social – A commitment to social responsibility is core to who we are as a company and we take pride in our work culture. We strive to be an optimal employer to our workforce and valued partner to our customers and communities.
    1. Access to Healthcare and Healthcare Transparency: ĤƵ’s technology-enabled services provide value, price transparency, and information about healthcare benefits, which are essential to bringing fairness, efficiency, and affordability to the U.S. healthcare system. The Company will continue to promote actions and develop services that can help make a positive change and make our healthcare system more inclusive, equitable, and affordable for all, including within underserved communities.
    2. Data Privacy & Security: The Company is committed to upholding high standards of data privacy and security and being accountable for the practices we use to safeguard the personal health information (PHI) and personally identifiable information (PII) entrusted to us. Fundamental to this commitment is our emphasis on a robust and risk-based information security program. We prioritize regulatory compliance and audit requirements, including Sarbanes Oxley (SOX), SOC 1 Type II, SOC 2 Type II, HIPAA and various other privacy regulations. We are vigilant in solely using information shared with us for the purposes intended and applying access restrictions so that only users in specific business roles that require access may handle the information. Our commitment is reinforced by policies, procedures, training and awareness programs, technical controls, and continuous monitoring and improvement.
    3. Human Capital Management: Our employees are the foundation of our success, and we set clear expectations for our employees in our Code of Business Conduct and Ethics. We support our people by creating an environment where everyone feels valued, supported, and empowered. We offer competitive salaries and benefit packages and believe investing in our employees’ physical, mental, and financial health is not only the right thing to do, but supports our overall mission of improving people’s well-being. We have a Talent and Growth Department (TAG) that is dedicated to ensuring our employees have access to the resources they need to succeed at every stage of their careers. We have implemented and expanded on our core values: Accountability, Continuous Improvement, Teamwork, Service Excellence (ACTS), which serve as the foundation of our approach to our business and our people. These core values are further explained below:
      1. Accountability: We are accountable for our decisions and actions and strive to achieve desired results together.
      2. Continuous Improvement: We seek and embrace a better way and share ideas and problem solve with others.
      3. Teamwork: We listen, value and respect each other and communicate often, clearly, and with purpose.
      4. Service Excellence: We understand the business and common goals and focus on our customers’ needs and satisfaction to execute with excellence.
    4. Diversity, Inclusion and Belonging: We embrace and value diversity in all its forms, whether race, religion, national origin, age, sex, or disability. Equal opportunity is integral to our recruitment process, as we aim to develop a community of diverse talent. We seek to maintain a positive workplace, free from discrimination and harassment. We champion mutual respect, promoting an environment of fairness and equality. Our commitment to diversity and inclusion applies to everyone at the Company, including at the board level, and is reenforced through our training and awareness exercises. Our DIB Advisory Committee guides and works to advance our DIB efforts.
    5. Human Rights and Modern Slavery: The Company considers human rights paramount and works to preserve human rights throughout the Company. We support internationally recognized principles that promote and protect human rights, and we value occupational health and safety, the freedom to choose employment, the avoidance of child labor, standard working hours, and fair wages and benefits. We work to preserve and promote the protection of human rights and welfare within our own business activities, as well as those of our supply chain. With the support of our Procurement Department, we are promoting supplier diversity within our vendor pipeline to provide more opportunities to minority and women-owned businesses and other organizations that make a positive social impact.
    6. Excluded Businesses: We will not tolerate any form of corruption or violation of applicable anti-kickback laws, either in our business or in the businesses of those with whom we work. Accordingly, we have identified certain types of business relationships, which are prohibited, meaning we will not knowingly engage in, or engage with businesses directly involved in, the following activities:
      1. Bribery, Corruption, and Facilitation Payments – including giving, offering, receiving or requesting bribes or facilitation payments; and
      2. Child labor, forced labor or human trafficking.
        We ensure that our employees avoid knowingly engaging with these types of businesses or activities through our training programs and our Code of Business Conduct and Ethics.
    7. Strengthening our Communities. We have a long history of and will continue to provide meaningful support to the communities in which we operate as organized by our Charitable Giving Workgroup.
  3. Governance: We believe that good corporate governance is essential and this includes the expansion of our ACTS core values.
    1. Ethics & Transparency: We are dedicated to upholding the highest standards of ethics and integrity throughout our organization and developed our Code of Business Conduct and Ethics to be a guideline for responsible business conduct. Any act of misconduct is not tolerated at the Company and employees, network providers, and third-parties are encouraged to report any real or perceived violation, without fear of retaliation. They may report anonymously through our 24/7 third-party operated ethics line or with their Manager, the HR department, the Compliance Officer, or directly to the Audit Committee. Any allegations will be reviewed promptly and corrective actions will be implemented, when necessary.
    2. Corporate Governance: Good governance is essential to promoting trust and confidence among our stakeholders, which is why the Company has established clear Bylaws and Corporate Governance Guidelines.

ENFORCEMENT AND MONITORING:

The Company will leverage a multi-pronged approach to ensure that we are adhering to the core expectations and values in this ESG Policy.

  • The Company will deliver an annual ESG Report and publish it on our website.
  • The Sustainability Working Group will continue to meet regularly to understand our progress on our initiatives and to ensure we hold ourselves accountable for areas where we need to continue to grow.
  • The policy is intended to be reviewed annually by the Sustainability Working Group.
  • The Company will report, at least annually, to the Board of Directors and/or appropriate committees, and executive and senior leadership on ESG-related initiatives and progress.

EXCEPTIONS:

There are no exceptions to this policy.

NOTES AND CLARIFICATIONS:

None.

REFERENCE:

  • Code of Business Conduct and Ethics
  • Data Protection Policy
  • Security Awareness Training
  • Data Privacy Compliance Training
  • General Compliance Training
  • Multi-State Manager Harassment Prevention Training
  • Diversity, Equity and Inclusion Training
  • Bylaws
  • Corporate Governance Guidelines

HISTORY:

EFFECTIVE DATE

OF ACTION

ACTION

REPLACES POLICY NO.

REPLACED BY POLICY NO.

March 12, 2024

New Policy/Approved

n/a

n/a