Our Responsibilities

We’re committed to upholding the principles outlined in our Code of Conduct. We also uphold our corporate and departmental policies and the laws that govern us. By following these principles, we safeguard our own integrity. We also nurture a culture of trust and accountability within Premera.

We recognize that speaking up is an act of courage and responsibility. So, we encourage every employee to report any suspected violations. They may report to their manager, Regulatory Compliance & Ethics, or the Employee Experience departments. Employees can also use the C&E hotline. Voicing concerns can be challenging. That’s why we provide the Compliance & Ethics Hotline. It’s a confidential reporting system managed by a trusted third party. Premera does not tolerate retaliation or intimidation. We protect those who act in good faith or take part in an investigation.

We expect employees to do the following:

Let ethics guide all business decisions. We never compromise our integrity or ask others to commit unethical or illegal acts
Be informed of laws, regulations, and policies. We all have a duty to comply with applicable laws
When in doubt, ask! Employees should promptly discuss ethical or compliance concerns or questions. They can do this with their manager, Regulatory Compliance & Ethics, or their HR business partner. We encourage questions and concerns. Together we can navigate ethical decision-making to always Do the Right Thing.

Q & A
I am new in my role, and it is unclear whether a process I am responsible for is compliant with various requirements. What can I do about it?
Talk to your manager. If you are not comfortable doing that, talk to the next level of management, contact Regulatory Compliance & Ethics or Employee Experience. Another option available to you is to use the Compliance & Ethics Hotline. Open discussions of ethics strengthen our culture at Premera.

Leader responsibilities

Our leaders play an important role in fostering our culture of ethics and compliance. Leaders ensure their teams uphold the principals outlined in the Code of Conduct. They serve as role models of appropriate behavior and set a good example.

We expect leaders to follow these guidelines:

Embrace our Code and make sure employees understand the behaviors expected of them.
Create a positive environment. Employees should feel comfortable raising concerns or challenging questionable conduct. When an employee raises a concern, ensure that it is investigated. If you’re unsure about what to do, reach out to Regulatory Compliance & Ethics or Employee Experience for help.
Be transparent. Never disregard ethical standards to achieve any business objective or personal goal.
Recognize and reward employees whose behavior demonstrates our values. This creates a ripple effect that inspires others to follow suit.
Report known or suspected non-compliance, fraud, waste, and abuse (FWA), or Code violations immediately.
Model behaviors. This means that we show personal accountability and ensure our own actions align with Premera’s values and ethical standards.
Follow our non-retaliation policy. Periodically remind employees about this policy. Reinforce our values and encourage employees to speak up when they suspect something is wrong.
Ensure their teams complete all mandatory trainings, required disclosures, and certifications in a timely manner.
Monitor the business partners, contractors, and contingent workers they engage with. Ensure their conduct is consistent with our Code.

Our pledge to respond

If you know or suspect an incident of non-compliance, fraud, waste, and abuse (FWA), or a Code violation, report it immediately. Don’t ignore the issue, wait to confirm, or consult a coworker.

The Regulatory Compliance & Ethics department reviews and investigates reported potential Code violations. We partner with Employee Experience. They review and consider all relevant information. They may involve other departments if necessary.

The Corporate Compliance & Ethics Officer directs the investigation. They report the results to the Audit and Compliance Committee of the Board of Directors, or the full Board of Directors. They also report Code violations to appropriate regulatory agencies or business partners. This includes violations of law, regulation, and applicable government contracts.