Our People and Culture 87 2021 Sustainability Report Responsible Business Practices A Modern, High-Performing Health System Introduction Performance Data Environmental Health Third party due diligence Due diligence is required prior to engaging third parties that provide goods or services to UnitedHealth Group outside the U.S. The level of due diligence required will depend on the risks presented by each third party. The following reviews are performed for all prospective third parties that will provide goods or services to UnitedHealth Group outside the U.S.: • All thir d parties are screened through World Check, the company’s current online screening tool, to determine if there is a match with a person or entity in the World Check database. • Thir d Party Red Flag Considerations are reviewed to determine whether any red flags are present. • Whether the thir d party will interact directly or indirectly on behalf of UnitedHealth Group with public officials or public entities. The following additional requirements apply to Higher Risk Third Parties: • The U nitedHealth Group International Compliance group determines whether the third party being considered is a Higher Risk Third Party. When making its determination, UnitedHealth Group International Compliance may consider other available information, such as the nature and value of the services or products to be provided, and the reputation for corruption or bribery of the country in which the services or products will be provided. • The engagement of the thir d party cannot proceed without the written approval of UnitedHealth Group International Compliance. This approval may include conditions upon which the engagement may proceed. Ethical marketing and communications Our communications with customers, members, employees, clinicians and other stakeholders reflect our values and commitment to high standards of personal and institutional integrity. Our sales and marketing activities serve our business objectives, foster enduring relationships with our stakeholders and build trust one person at a time. Our reputation stands upon the relationships we maintain with the public, the media and those who interact with our company. We review all marketing materials to ensure accuracy, clarity and compliance with applicable laws and regulations, such as the Medicare Communications and Marketing Guidelines established by the U.S. Centers for Medicare & Medicaid Services. These materials seek to provide straightforward descriptions of services offered so our members can make informed decisions about their health care.