Reporting Suspected Noncompliance

We all must work together to help protect Premera from actions that could harm our operations, reputation, or future growth. All employees are therefore expected to report actual or suspected violations involving the following:

• This Code of Conduct
• Corporate and departmental policies
• Laws or regulations
• Third Party Codes of Conduct

Any employee who suspects violations should talk to a manager, Regulatory Compliance & Ethics, or Employee Experience. We value the right for employees to remain anonymous. Employees are encouraged to contact the Compliance & Ethics Hotline, our third-party-managed hotline, or MyComplianceReport.com, 24 hours a day, 7 days a week. Reports may be made anonymously and confidentially, if desired. Confidentiality is maintained to the extent permissible by law and deemed appropriate for the situation. Remember, we have a policy that prohibits retaliation and intimidation for a good faith report. Premera fully supports whistleblower protection laws.

Anyone choosing to report anonymously should include as many details as possible. We may not be able to complete our investigation if we do not have adequate information. Also, check back frequently to ensure additional information is not needed.

Managers who receive a possible violation report from an employee must have it investigated. Managers who do not feel they have the expertise to research and resolve the issue should contact Regulatory Compliance & Ethics or Employee Experience. Each incident must be thoroughly investigated, and corrective actions must be taken if necessary.

Q & A

I saw something that I think is against corporate or departmental policy, but I’m not sure of all the facts. I don’t want to report something inaccurately and get someone in trouble. What should I do?

You can discuss the situation with your manager, Employee Experience, Regulatory Compliance & Ethics, or you can report your concern using the Compliance & Ethics Hotline. If you choose to report anonymously, please check back frequently to ensure additional information is not needed.

When an incident is reported, it may be investigated by Regulatory Compliance & Ethics, Employee Experience, Internal Audit, Legal, Privacy, Regulatory Affairs, or the Special Investigations Unit.

Investigation details and identities are confidential to the extent permissible by law and deemed appropriate for the situation.

When a reported violation is confirmed, we will implement corrective action.

Please note that if an incident is reported, the person who reported it may not be informed of the outcome. This is to protect the confidentiality of those involved in the investigation.

We take our Code of Conduct seriously. Violations of the Code or our policies may be grounds for corrective action, up to and including termination of employment.

Examples of when corrective actions may be taken include:

• Participation in or authorization of actions that violate this Code
• Failure to report a violation
• Refusal to cooperate in an investigation, providing false or misleading information, or withholding information that may be deemed pertinent to the investigation
• Failure of a manager to detect and report a violation, if the failure reflects grossly inadequate supervision
• Retaliation and/or intimidation against an employee who reports a potential violation and/or participates in an investigation in good faith

Employees are encouraged to self-report a violation, which will be considered when determining corrective action. Intentional cover-up of violations is prohibited.

Q & A

I reported a concern via the Compliance & Ethics Hotline and I'm not sure what the outcome was. Why should I report concerns in the future?

All items reported via the Compliance & Ethics Hotline, or directly to Employee Experience or Regulatory Compliance & Ethics, are thoroughly investigated. There are several reasons it may appear that nothing happened: 1) not enough details were submitted to conduct a thorough investigation; 2) no wrongdoing was discovered after the investigation was complete; or 3) corrective action occurred but could not be publicized to protect all parties involved with the investigation. If the situation occurs again, or continues to occur, report it again and include as many specific details as possible.