Our People and Culture 85 2021 Sustainability Report Responsible Business Practices A Modern, High-Performing Health System Introduction Performance Data Environmental Health Governance Senior leadership oversees our Compliance and Ethics program and provides regular reports to the Audit and Finance Committee of the UnitedHealth Group Board of Directors that detail performance on key compliance and ethics indicators. UnitedHealth Group’s Internal Audit department provides objective audit and advisory services that identify and mitigate risks throughout the company, including periodic audits of the Compliance and Ethics program. UnitedHealth Group’s Compliance and Ethics Office maintains our code, reviewing it regularly to ensure continued support of our commitment to integrity and good corporate conduct. 96% of employees agreed that the compliance and ethics training provided them with adequate information to operate in compliance with the policies, laws and regulations associated with their job. 96% Compliance and ethics policies and related documents Compliance and Ethics Assessment Periodically, UnitedHealth Group engages external consultants to assess the enterprise Compliance and Ethics program against government compliance guidance, regulatory expectations and industry practices to evaluate program effectiveness. In addition, UnitedHealth Group, UnitedHealthcare and Optum conduct regular assessments consistent with the Department of Health and Human Services Office of Inspector General and Centers for Medicare and Medicaid Services requirements, Department of Justice guidance and other applicable regulatory requirements. In 2022, our Compliance and Ethics team began building an interactive cloud repository to automate input from our business partners and aggregate results, reaching a broader group of individuals who provide insight. UnitedHealth Group maintains internal policies at the enterprise, business segment and department levels that provide more specific direction beyond the core elements of the Code of Conduct. Examples of key compliance and ethics policies include: • Anti-Corruption P olicy • Anti-Kickback P olicy • Antitrust P olicy • Conflicts of Inter est Policy • Economic Sanctions and Sanctions Monitoring P olicy • F alse Claims Acts Compliance Policy • Gif ts and Entertainment Policy • Human Rights P olicy • En vironmental Health and Safety Policy • Insider T rading Policy • Inter actions with Pharmaceutical, Medical Device or Biotech Manufacturers, Wholesalers or Distributors • Non-Discrimination P olicy • Non-R etaliation Policy • P ersonal Information Privacy and Data Protection • R eporting Misconduct • P olitical Contributions Policy • Outside Dir ectorships Policy • R elated-Person Transactions Approval • Social Media P olicy and Guidelines • St atement of Ethical Marketing • T ravel and Expense Management Policy • U .S. Federal Government Contracting Policy