Ethics & Integrity
 

Training is important to ensure our workforce is prepared to exercise trusted judgment, act with integrity, and advance our mission in a manner consistent with our values and commitment to compliance. Our training and education programs are designed to help employees understand their responsibilities under the Code of Conduct and other compliance policies, including identifying and reporting concerns, available reporting channels, and use of the Ethics & Compliance Helpline, non-retaliation protections, and when to seek guidance regarding potential ethics and compliance matters. Training also addresses conflicts of interest, gifts and business courtesies, anti-corruption requirements, and compliance with applicable anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA).

At a minimum, the workforce is trained upon hire and annually. Training is designed to address general ethics and compliance risk areas, including fraud, waste and abuse; privacy and confidentiality; and ethical decision-making. Participation in training programs is mandatory, and completion is actively monitored to ensure our workforce remains prepared to act ethically and fulfill our obligations.

Centene is committed to fostering a culture where individuals feel comfortable asking questions, seeking guidance, and raising concerns without fear of retaliation. We believe that identifying and addressing concerns early helps protect the people and programs we serve and supports our commitment to integrity, accountability and trust.

The Ethics & Compliance Helpline is available to employees, members, providers, business partners, and others who have questions or concerns regarding potential violations of the Code of Conduct, Company policies, applicable laws or regulations, or matters involving ethics, compliance, bribery, corruption or misconduct. Reports may be made anonymously and in good faith when an individual has reasonable grounds to believe a concern may exist.

Centene does not tolerate retaliation against anyone who, in good faith, raises a concern, asks a question, seeks guidance or participates in an investigation. Individuals are encouraged to report concerns promptly so they can be reviewed and addressed through appropriate channels.

Centene also maintains a comprehensive fraud, waste and abuse (FWA) program focused on preventing, detecting and correcting FWA. The program is overseen by Centene's Special Investigations Unit and helps safeguard healthcare programs, protect members, and promote responsible stewardship of healthcare resources.

The Ethics & Compliance Helpline and FWA Helpline are independently administered, available 24/7, and support confidential and anonymous reporting. Concerns are reviewed through established processes designed to promote fairness, consistency and accountability. When appropriate, matters are investigated and corrective actions are taken to strengthen ethical business practices and compliance. Violations of the Code of Conduct or Company policies may result in corrective or disciplinary action consistent with applicable policies and procedures.

Centene is committed to making business decisions based on integrity, objectivity, and the best interests of the Company and the people we serve. Maintaining trust requires that decisions be made free from actual, potential or perceived conflicts of interest. A conflict of interest may arise when personal, family, financial or business interests interfere, or appear to interfere, with an individual's ability to act in Centene's best interests. Even the appearance of a conflict can undermine trust and confidence in business decisions.

Employees are expected to identify, disclose and appropriately manage potential conflicts of interest consistent with the Code of Conduct and applicable policies. Seeking guidance and addressing potential conflicts early helps protect the integrity of our decision-making processes and reinforces our commitment to ethical business practices.

Transparency, accountability and timely disclosure help identify and manage potential conflicts, support sound decision-making and strengthen trust in our business practices.

At Centene, we do not tolerate bribery, corruption, or any form of improper influence and are committed to complying with applicable anti-corruption and anti-bribery laws wherever we conduct business. Ethical business practices are essential to maintaining the trust of our members, providers, regulators, business partners, investors and the communities we serve.

Centene's policies and applicable anti-bribery laws, including the U.S. Foreign Corrupt Practices Act (FCPA), prohibit bribery and other forms of improper influence. Employees, business partners and anyone acting on behalf of Centene may not directly or indirectly offer, give, solicit or accept anything of value including gifts, entertainment, payments, favors, charitable contributions, or other benefits to improperly influence a decision, obtain or retain business, secure an unfair advantage or create the appearance of improper influence.

Extra care must be taken when interacting with government officials, healthcare providers, vendors, business partners, and others whose decisions may affect Centene's business. Gifts, entertainment, charitable contributions, and other items of value must never compromise objectivity, create actual or perceived conflicts of interest, or undermine trust in our business practices.

To avoid both actual and perceived improper influence, Centene prohibits facilitation payments and other improper payments intended to influence, or appear to influence, government actions or business decisions. Employees, business partners, and anyone acting on behalf of Centene are expected to comply with applicable anti-corruption laws and Company requirements and promptly seek guidance when questions arise regarding gifts, business courtesies, government interactions or other situations involving actual or perceived improper influence.

Centene is committed to fostering a culture of integrity, accountability and trust where individuals feel comfortable asking questions, seeking guidance and raising concerns in good faith without fear of retaliation. Speaking up helps identify and address concerns early, supports ethical decision-making and strengthens the trust placed in Centene.

Centene does not tolerate retaliation against anyone who, in good faith and based on reasonable grounds, reports a concern, asks questions, seeks guidance, participates in an investigation, or raises a potential ethics, compliance, legal or regulatory issue. Individuals who raise concerns in good faith will not be subject to retaliation, even if an investigation ultimately determines that no violation occurred.

Anyone who believes they have experienced, witnessed, or become aware of retaliation is encouraged to promptly report the concern through available reporting channels, including the Ethics & Compliance Helpline. Reports of suspected retaliation are reviewed through appropriate channels and, when warranted, investigated to ensure concerns are addressed fairly, consistently, and in accordance with Company policies and applicable requirements.

Individuals who knowingly engage in retaliation or interfere with an investigation may be subject to disciplinary action, up to and including termination of employment.