Ethics & Compliance HelpCenter

Frequently Asked Questions

24 hours a day, 7 days a week by phone, 1-800-455-4521, or online, via the Ethics &
Compliance HelpCenter Web site. Anonymous if desired.

As employees of UnitedHealth Group, it is our responsibility to ensure that we act with

honesty and integrity at all times. We must perform our jobs according to all laws,
regulations and contractual obligations and adhere to the company's policies, including
the Principles of Ethics and Integrity.

UnitedHealth Group requires employees and contractors to report all suspected illegal or
unethical conduct, including violations of law, contractual obligations and company
policies (including the Principles of Ethics and Integrity), or concerns about accounting,
internal controls, auditing matters, or suspected fraud and abuse. Employees who learn of
any situation that may jeopardize UnitedHealth Group’s integrity must promptly report
the information.

You should use the Ethics & Compliance HelpCenter to report possible violations of
law or regulation. If you have a general concern or complaint about management,
employee benefits, or other issues that relate to employment but are not possible
violations of law or regulations, you should contact your supervisor, your
supervisor's manager, or HRdirect (1-800-561-0861). HRdirect cannot accept
anonymous cases. If you want to remain anonymous, you can contact the Ethics &
Compliance HelpCenter. If the company determines the issue you have raised cannot be
addressed anonymously, you will be notified through the follow-up process through the
Ethics & Compliance HelpCenter. For more information about remaining anonymous,
please see “Can I remain anonymous?” below.

The following are answers to commonly asked questions about the reporting process.
Additional information is available in the guide, “Using the Ethics & Compliance
HelpCenter,” which is available on HelpCenter Web site.

• How do I report suspected misconduct?

• What should I report?
• Can I be disciplined if I report misconduct by someone else?
• What if I report something I did wrong?
• Can I call to just ask a question – like whether there is a company policy on a
specific issue, or how a policy applies?
• What happens when I contact the Ethics & Compliance HelpCenter?
• Can I remain anonymous?
• What happens after I report?
• How long will it take to investigate my allegations?
• How will I learn the results of the investigation?
• Who should I contact if I have questions?
How do I report suspected misconduct?

To report suspected illegal or unethical conduct, including violations of company

policies, you may contact your manager, or your local compliance officer. If you are not
comfortable contacting these resources, or if you have reported a situation and don’t think
it’s been investigated or resolved, then you should contact the Ethics & Compliance
HelpCenter by phone, 1-800-455-4521, or online via the Ethics & Compliance
HelpCenter Web site. The Ethics & Compliance HelpCenter is available 24 hours a day,
seven days a week. Ethics & Compliance HelpCenter staff do not have caller
identification available on their phones, so regardless of where you call from, you cannot
be identified. The HelpCenter Web site does not track computer names or IP addresses,
so online reports cannot be tied to a particular person. For more information about
remaining anonymous, please see Can I remain anonymous? below.

What should I report?

UnitedHealth Group requires employees to report all suspected violations of the law,
contractual obligations and company policies, including the Principles of Ethics and
Integrity. For example, you should contact the Ethics & Compliance HelpCenter if:

• your supervisor directs you to falsify information in a report, or

• you become aware of an employee who is using company systems to operate a
personal business, or
• you notice a contractor who works on site loading office equipment into his car.

Can I be disciplined if I report misconduct by someone else?

No. UnitedHealth Group policy expressly prohibits retaliating against employees who in
good faith report concerns or participate in an investigation of misconduct. In fact, if a
manager punishes you for making a good faith report, the manager would be subject to
disciplinary action. If you are concerned about retaliation, see the discussion about
making anonymous reports.

What if I report something I did wrong?

Although the company cannot guarantee that you will not be disciplined for your actions,
the company will take into consideration the fact that you are voluntarily reporting the
matter, which may lead to less severe disciplinary action, if any, especially if your actions
were done at a supervisor’s direction. Please keep in mind that the company can’t fix the
problem if it doesn’t know about it – so it is essential that you report it.
Can I call to just ask a question – like whether there is a company policy on a
specific issue, or how a policy applies?

Yes. The Ethics & Compliance HelpCenter is also intended to help you by providing
information and guidance. Typically, you should first contact your manager, your local
compliance officer, or the Legal Department. If you are uncomfortable doing so or are
dissatisfied with the response you have received, you should feel free to contact the
Ethics & Compliance HelpCenter.

What happens when I contact the Ethics & Compliance HelpCenter?

UnitedHealth Group has contracted with a third-party vendor, EthicsPoint, to provide the
Ethics & Compliance HelpCenter. The vendor's call center staff is trained to ask
questions that will help provide UnitedHealth Group with the information the company
needs to investigate and resolve the issues you identify.

The vendor's staff will not be able to answer your questions or resolve any issues on your
initial call. They will prepare a Web-based report of the information you provide and
send it to UnitedHealth Group’s Ethics & Integrity Office. The Ethics & Integrity Office
will then provide the vendor with the company’s response. Fifteen business days after
you complete your report, contact the Ethics & Compliance HelpCenter to see if the
company has any follow-up questions or if the matter has been resolved, to see the
company's response. When you initially report your concern or issue, you will be
assigned a report key and password. It is essential you remember the report key and
password since that is the only way you will be able to receive the company's response.

Can I remain anonymous?

You can remain anonymous.

• If you do so, UnitedHealth Group will take all reasonable steps to preserve your
anonymity. Your call will not be recorded, and we will not know what number or
location you called from. Your online report is submitted through a secure Web
site protected by the latest encryption technology. But there are some limits you
should know about.

• People may be able to figure out that you made a complaint. As a matter of
fairness, UnitedHealth Group will ordinarily investigate a complaint before taking
action. If you are complaining that another employee is doing something wrong,
there is a good chance we will ask that person to address the complaint.
Obviously, people can sometimes guess at who made that complaint.

• Sometimes, we cannot adequately respond to or investigate a complaint unless we

know who you are, or unless we have a way to contact you to get information.
You can identify yourself and ask us to keep your identity confidential. We will take
steps to preserve confidentiality.

• But we may not be able to do so if the government requires us to provide

information.
• And again, people might be able to figure out who made the complaint.

UnitedHealth Group has a non-retaliation policy. No UnitedHealth Group employee

should retaliate against you for making a good faith report of possible illegal, unethical,
or unlawful conduct.

We will try to be open with you about how we are responding to your report. But for
confidentiality reasons, you should understand that we cannot always tell you all the steps
we have taken.

For UnitedHealth Group's procedure for responding to reports made through this Ethics
& Compliance HelpCenter, please review What happens after I report?

What happens after I report?

All allegations of misconduct are investigated. Every call or online report received
through the HelpCenter is sent to UnitedHealth Group’s Ethics & Integrity Office. Based
on the type of allegations, the Ethics & Integrity Office either resolves the matter or
forwards the case to the appropriate contact for investigation and resolution. Many of the
calls involve Human Resources issues and are forwarded to Employee Relations. Cases
also may be forwarded to local compliance officers, the Legal Department, or other
departments as appropriate.

How long will it take to investigate my allegations?

Some investigations can be completed quickly; others may take several weeks. It all
depends upon the nature of the allegation and the necessary investigation. The size and
complexity of UnitedHealth Group can, at times, mean a complex and lengthy
investigation. The fact that an investigation is taking several weeks does not mean
UnitedHealth Group does not take the allegations seriously or is not aggressively
investigating the allegations.

How will I learn the results of the investigation?

In all cases, the Ethics & Integrity Office will provide a final response, which will be
available to you through the Ethics & Compliance HelpCenter. If you elected to remain
anonymous, you will need to contact the Ethics & Compliance HelpCenter and provide
your assigned case number to receive the company’s response.
If you identified yourself, you also may contact the Ethics & Compliance HelpCenter to
receive the company’s response. In addition, the person who had primary responsibility
for investigating and addressing your concerns will usually advise you of the results.

If you made an allegation of misconduct, after the investigation is completed,

UnitedHealth Group will decide whether the allegation was substantiated and inform you
accordingly. If the company says it cannot substantiate your allegation, it does not
necessarily mean the allegation is not true – it may mean the allegation cannot be proven.
If the allegation cannot be substantiated, UnitedHealth Group may notify you that if you
can provide any additional information to substantiate the allegations, the company will
investigate further.

If UnitedHealth Group determines that misconduct has occurred, the company will
usually notify you that the investigation is complete and appropriate action has been or
will be taken. Due to confidentiality and privacy concerns, you may not receive details of
findings from the investigation or actions taken, including any disciplinary action taken
against another employee for misconduct. The Ethics & Integrity Office may also ask you
to notify the company if you believe the problem continues after it was thought to be
resolved.

Who should I contact if I have questions?

If you have questions about the Ethics & Compliance HelpCenter or UnitedHealth
Group’s Ethics and Integrity Program, you can contact the HelpCenter or contact
UnitedHealth Group’s Ethics & Integrity Office, by e-mail at Ethics-
Integrity_Office@uhc.com, or by phone, at 952-936-7463.