UNITEDHEALTH GROUP

Employee Handbook

Helping people live healthier lives and helping make the health system

work better for everyone.

Welcome

UnitedHealth Group is a health care and well-being company whose people work

across UnitedHealthcare and Optum to help improve the health system and the

experience of the people it serves.

This handbook provides a practical guide to the principles, workplace expectations

and employee resources that support how we work together.

Our values

Integrity

We do the right thing and follow through

on our shared commitment to quality.

Compassion

We listen, advocate and act with urgency

for those we serve and our colleagues.

Inclusion

We welcome, value, respect and hear all

voices and diverse points of view.

Relationships

We work together to deepen connections

and collaboration for better outcomes.

Innovation

We invent a better future by learning from

the past.

Performance

We strive for high-quality results in

everything we do.

A shared responsibility

Every person has a role in protecting the people we serve, the information

entrusted to us, our colleagues, our communities and the reputation of

UnitedHealth Group.

UNITEDHEALTH GROUP

UNITEDHEALTH GROUP • EMPLOYEE HANDBOOK • RESEARCH-BASED RECREATION

EMPLOYEE REFERENCE

01. Purpose, Scope and Document Architecture

UnitedHealth Group describes its Code of Conduct as a global framework adopted by the Board and applicable to employees,

directors, and contractors. The Code states that it is a core element of the company’s compliance program and that enterprise,

business, and department policies provide more specific direction. This distinction is important: the public Code provides the

documented baseline, while many operational HR procedures are maintained through additional company resources.

What this reference covers

• Ethical behavior and accountability

• Privacy and information security

• Conflicts of interest and fair competition

• Government interactions and communications

• A safe and supportive working environment

• Publicly documented employment and workplace resources

• Reporting and escalation channels

What it does not attempt to reproduce

The public sources reviewed do not provide a complete, current internal manual for every compensation plan, leave program,

business-unit procedure, performance process, or employee benefit. Those subjects are therefore described only where public

documentation supports them, rather than being filled with assumptions.

Document logic

Code of Conduct

→

enterprise policies

→

business-unit or department procedures

→

manager / Employee Center /

Compliance & Ethics / Legal guidance. When requirements differ, employees should use the applicable authoritative

policy or obtain guidance from the appropriate company resource.

Core public-source foundation

Source

Role in the handbook

Code of Conduct: Our Principles of Ethics &

Integrity

Primary public framework for ethical behavior, compliance, reporting, privacy, competition,

government interaction, communications, and workplace conduct.

UnitedHealth Group People & Culture

Public description of mission, values, inclusion, employee experience, learning, development, and

workforce culture.

Policies and documents

Public employee-facing legal notices, privacy notices, employment-related documents, and

selected policies.

Drug Testing Policy

Publicly documented workplace policy covering testing, fitness for duty, inspections, and

consequences.

UnitedHealth Group Employee Handbook — page 3

UNITEDHEALTH GROUP • EMPLOYEE HANDBOOK • RESEARCH-BASED RECREATION

WORKING AT UNITEDHEALTH GROUP

02. Mission, Values and People Culture

UnitedHealth Group publicly describes its mission as helping people live healthier lives and helping make the health system

work better for everyone. Its public people-and-culture materials describe a workforce culture grounded in six values: Integrity,

Compassion, Inclusion, Relationships, Innovation, and Performance.

The six values

Value

Documented behavioral emphasis

Integrity

Do the right thing and follow through on the shared commitment to quality.

Compassion

Listen, advocate, and act with urgency for people being served and colleagues.

Inclusion

Welcome, value, respect, and hear diverse voices and points of view.

Relationships

Work together to deepen connections and collaboration for better outcomes.

Innovation

Invent a better future by learning from the past.

Performance

Strive for high-quality results in the work performed.

Culture and belonging

UnitedHealth Group publicly describes an inclusive environment in which people should feel welcomed, valued, heard, and

respected. Its careers materials also describe coaching, mentorship, leadership development, skills-based learning, culture

development, and voluntary employee resource groups as parts of its people and culture approach.

Practical application

For an employee, the values are not a substitute for a policy. They provide a behavioral lens that sits alongside laws, the

Code of Conduct, enterprise policies, business-unit requirements, and role-specific procedures.

Manager responsibility

The Code states that managers have an additional responsibility to understand the Code and policies applicable to their

business unit so they can serve as a resource and provide guidance to employees. Questions that cannot be resolved at the

team level should be directed to the appropriate Employee Center, Compliance & Ethics, Legal, or business compliance

resource.

UnitedHealth Group Employee Handbook — page 4

UNITEDHEALTH GROUP • EMPLOYEE HANDBOOK • RESEARCH-BASED RECREATION

STANDARDS OF CONDUCT

03. Ethics, Integrity and Accountability

The Code states that employees, directors, and contractors must act with integrity and comply with applicable laws,

regulations, company policies, and contractual obligations. It also makes clear that no employee is authorized to commit or

direct another person to commit an unethical or illegal act.

Accountability expectations

• Take responsibility for decisions and actions.

• Report suspected violations of law, regulation, the Code, company policy, or contractual obligations.

• Cooperate with investigations, lawsuits, and other company legal matters by providing timely, accurate, truthful, and complete

information.

• Ask questions when a situation is unclear rather than relying on an assumption.

• Do not use a third party to perform conduct that would be prohibited if performed directly.

Reporting and non-retaliation

The public Code says employees are required by company policy to speak up about potential violations. It describes multiple

reporting routes, permits anonymous reporting where legally allowed, and states that good-faith reporters are protected from

intimidation and retaliation. It also states that reports are reviewed and, when appropriate, investigated.

When you are unsure

The Code's decision framework encourages employees to consider legality, fairness, honesty, potential harm to the

company’s reputation, how the action would look in hindsight, and what advice they would give a colleague.

Consequences

The Code states that violations of the Code, company policies, contractual obligations, or laws may result in discipline up to

and including termination of employment and, where appropriate, legal action or referral to law enforcement.

UnitedHealth Group Employee Handbook — page 5

UNITEDHEALTH GROUP • EMPLOYEE HANDBOOK • RESEARCH-BASED RECREATION

HEALTHCARE-SPECIFIC RESPONSIBILITY

04. Privacy, Information Security and Confidentiality

Privacy and information security receive dedicated treatment in the public Code because UnitedHealth Group handles

sensitive personal and healthcare-related information. The Code describes maintaining the privacy and security of personal

information as an essential component of the company’s mission and commitment to integrity.

Documented expectations

• Protect personal, confidential, business, and otherwise private information from unauthorized access or disclosure.

• Use company-approved processes and security controls when handling sensitive information.

• Report privacy or security incidents even when only a small amount of information may have been exposed.

• Do not access information merely because you can access it; access must be appropriate to the work being performed.

• Secure devices and screens when they are unattended, including while working remotely.

• Do not move company business to personal email or other insecure channels when company policy prohibits that practice.

• Do not post protected, confidential, business, or private information on public social media or other public sites.

Examples documented in the public Code

Situation

Publicly documented response

Sensitive document sent to the wrong

external recipient

Report the incident so the company can address legal or other obligations, even if only one individual

is affected.

Work documents moved to a personal email

account for convenience

The Code's example says this is not permitted because personal email may not meet company

security requirements.

Family member asks an employee for records

the employee can access through work

The Code says access should remain within the employee's job authorization and the family member

should use the normal records process.

Unattended computer at home

The Code says an unattended computer should be locked and secured and the screen should not be

visible to unauthorized people.

Healthcare context

The public materials connect privacy and information security with protected health information and personal information.

Specific legal requirements can vary by role, geography, system, and data type; employees should follow the applicable

company policy and security guidance.

UnitedHealth Group Employee Handbook — page 6

UNITEDHEALTH GROUP • EMPLOYEE HANDBOOK • RESEARCH-BASED RECREATION

INTEGRITY IN BUSINESS RELATIONSHIPS

05. Conflicts of Interest, Gifts and Fair Dealing

The Code describes a conflict of interest as a situation in which an employee’s or immediate family member’s personal

interests, relationships, outside employment, or activities affect, or appear to affect, decision-making in a company role. It also

addresses conflicts between company businesses and relationships involving business partners, suppliers, healthcare

providers, patients, and government officials.

Recognize and address conflicts

• Disclose potential conflicts through the appropriate manager, Compliance, or Legal resource.

• Follow company rules concerning gifts and entertainment involving business partners, suppliers, healthcare providers, patients,

and other regulated relationships.

• Seek guidance before pursuing a business opportunity that arose through company activities.

• Consider both actual conflicts and situations that could reasonably appear to compromise impartial decision-making.

Fair competition

The Code states that UnitedHealth Group’s success is founded on honest competition and requires employees, directors, and

contractors to follow applicable competition laws and company antitrust and firewall policies.

Topic

Documented principle

Competitor discussions

Avoid discussions that may appear to restrain competition unreasonably.

Sensitive competitive information

Use competitively sensitive information only as permitted by applicable firewall policies.

Rates and prices

The Code identifies discussions or agreements with competitors concerning rates and prices as prohibited

conduct.

Compensation information

The Code also identifies competitor discussions about employee salaries, benefits, and other compensation

terms as prohibited.

Escalate early

When a relationship, gift, outside activity, investment opportunity, or competitor interaction could create uncertainty, the

safer documented approach is to seek guidance before acting.

UnitedHealth Group Employee Handbook — page 7

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COMPLIANCE IN A REGULATED ENVIRONMENT

06. Government Interactions and Regulated Healthcare

UnitedHealth Group operates across healthcare, insurance, technology, pharmacy, and care-delivery activities that can involve

government programs and regulators. The public Code therefore includes a dedicated section on government interactions and

requires compliance with laws governing those interactions.

Employee responsibilities

• Follow laws, regulations, company policies, and applicable contractual requirements when interacting with government entities.

• Use designated company resources when a government official, regulator, investigator, or other authority requests information or

contact on behalf of the company.

• Do not offer, promise, or provide improper benefits to influence a government decision.

• Maintain accurate records and cooperate honestly with authorized investigations and legal matters.

• Use business-unit Compliance and Legal resources when a question involves regulated healthcare activity or government

contracting.

Fraud, waste and abuse

UnitedHealth Group's public compliance materials emphasize preventing and combating fraud, waste, and abuse and describe

reporting and training expectations for certain delegated entities. The Code also requires employees to report suspected

violations and cooperate with investigations.

Do not generalize a business-unit rule

Healthcare requirements can differ across Medicare, Medicaid, commercial insurance, clinical services, pharmacy,

government contracting, and other business contexts. Use the policy applicable to the specific role and program rather

than assuming one procedure applies everywhere.

Why this matters

In a regulated environment, a routine operational decision can have compliance implications. Employees should therefore

escalate questions involving government programs, claims, clinical records, contracting, reimbursement, patient information, or

regulated communications to the appropriate company resource.

UnitedHealth Group Employee Handbook — page 8

UNITEDHEALTH GROUP • EMPLOYEE HANDBOOK • RESEARCH-BASED RECREATION

REPRESENTING THE ORGANIZATION

07. Communications, Marketing and Public Statements

The public Code treats communications and marketing as an area requiring accuracy, appropriate authorization, and

coordination. It addresses media inquiries, investor and analyst communications, social media, conferences, publications, and

ethical marketing.

Public-facing communication principles

• Communicate accurately, honestly, and appropriately.

• Do not act as a company spokesperson unless authorized and coordinated through the appropriate communications function.

• Direct media questions to Media Relations or another designated company resource.

• Only designated employees should communicate with investors and securities professionals on behalf of the company.

• Follow company policy before accepting public speaking or publication engagements when company representation is involved.

• Use good judgment on social media and do not disclose confidential or private company information.

Ethical marketing

UnitedHealth Group publicly states a commitment to ethical marketing based on transparency and honesty. The Code also

states that marketing and communications should support high standards of personal and institutional integrity.

Practical review checklist

Before communicating externally

Ask

Authority

Am I authorized to speak for the company or business?

Accuracy

Can every material statement be supported by reliable information?

Confidentiality

Does the material contain protected, confidential, private, or competitively sensitive information?

Audience

Could the communication affect members, patients, providers, regulators, investors, or partners?

Escalation

Does the topic require Communications, Legal, Compliance, or another designated review?

UnitedHealth Group Employee Handbook — page 9

UNITEDHEALTH GROUP • EMPLOYEE HANDBOOK • RESEARCH-BASED RECREATION

PEOPLE, SAFETY AND RESPECT

08. Safe, Supportive and Inclusive Workplace

UnitedHealth Group's Code states that the company strives to provide a safe and supportive working environment and

respects the human rights of people it employs or interacts with across its businesses. It says the company will not tolerate

behavior that endangers employees, members, customers, or business partners or subjects them to discrimination,

harassment, or threats.

Workplace expectations

• Treat colleagues and other workplace participants with respect.

• Do not engage in discrimination, harassment, intimidation, threats, or retaliation prohibited by applicable policy or law.

• Report workplace safety incidents, unsafe practices, threats, or violence through the designated company channels.

• Report discrimination, harassment, intimidation, or retaliation to an appropriate manager, Employee Center, People resource, or

Compliance & Ethics channel.

• Follow applicable workplace substance and fitness-for-duty requirements.

Publicly documented equal employment commitment

UnitedHealth Group's public careers materials state that it is an Equal Employment Opportunity employer under applicable law

and lists protected characteristics including race, national origin, religion, age, color, sex, sexual orientation, gender identity,

disability, and protected veteran status, along with other characteristics protected by applicable law.

Drug and alcohol policy

UnitedHealth Group publicly states that its drug-testing policy is implemented in compliance with federal, state, and local law.

The public policy addresses testing, fitness for duty, inspections, and potential disciplinary consequences for violations.

Prescription and over-the-counter medication is treated separately, with employees expected to address work restrictions

through the appropriate employee-relations resource.

Immediate danger

The Code directs employees to call police, fire, or medical emergency services in an emergency or when a threat is

imminent. Company reporting channels are appropriate for non-immediate workplace safety, conduct, and compliance

concerns.

UnitedHealth Group Employee Handbook — page 10

UNITEDHEALTH GROUP • EMPLOYEE HANDBOOK • RESEARCH-BASED RECREATION

WHERE EMPLOYEES GO FOR OPERATIONAL GUIDANCE

09. Employee Resources, Policies and Career Support

Because a complete internal employee handbook is not publicly available, employee-specific procedures should be obtained

from the company's designated internal resources. Public UnitedHealth Group materials identify Employee Center, business

compliance officers, Legal representatives, People resources, and other specialized functions as sources of guidance.

Publicly documented resource map

Resource

Publicly documented purpose

Manager

Often the first contact for workplace issues and day-to-day guidance.

Employee Center

Policy guidance and interpretation, workplace issues, compensation, and employee benefit concerns;

the public Code lists 800-561-0861 in the U.S. and employeecenter.uhg.com.

Compliance & Ethics HelpCenter

Questions and reports concerning the Code, company policies, laws, and regulations; the public Code

lists 800-455-4521 in the U.S. and the EthicsPoint portal.

UnitedHealth Group Compliance & Ethics

Questions about the Code, policies, training, and other compliance and ethics matters; the public Code

lists 952-936-7463 and EthicsOffice@uhg.com.

People / Employee Relations

Public materials identify People-related resources for workplace matters; exact internal processes can

vary by business and location.

Corporate Security

Workplace security, threats, violence, unauthorized persons, and related safety matters.

Health & Safety

Unsafe conditions, workplace hazards, and safety incidents through the designated company channel.

Benefits and leave

Public UnitedHealth Group materials confirm that employee benefits and employment policies exist, but detailed plan eligibility,

accruals, leave administration, retirement provisions, and local statutory rules are not presented here as universal

requirements. Employees should use the current plan documents and internal Employee Center resources applicable to their

role, work location, employment status, and business segment.

Learning and development

UnitedHealth Group publicly describes coaching, mentorship, leadership development, skills-based learning, and culture

development as elements of its people-and-culture approach. Internal training assignments and role-specific compliance

training may be governed by business-unit requirements that are not fully public.

UnitedHealth Group Employee Handbook — page 11

UNITEDHEALTH GROUP • EMPLOYEE HANDBOOK • RESEARCH-BASED RECREATION

A PRACTICAL EMPLOYEE CHECKLIST

10. Quick Reference and Decision Guide

If you encounter a difficult situation

Step

Action

Pause and identify the policy, law, contract, patient/member obligation, or workplace standard that may apply.

Ask whether the action is legal, fair, honest, safe, and consistent with company policy.

Protect confidential, personal, and healthcare information while the issue is being assessed.

Ask your manager or the appropriate Employee Center, Compliance, Legal, People, Security, or other designated resource.

Report suspected violations through an appropriate channel. Anonymous reporting may be available where permitted by law.

Cooperate with any resulting investigation and provide truthful, complete information.

If you believe retaliation occurred after a good-faith report, report the concern through an appropriate company channel.

Five reminders

• Integrity is the foundation of the Code and the first of the six public values.

• A company policy can be more specific than the Code; follow the policy applicable to your work.

• Access to information is not the same as authorization to use it.

• When a conflict or compliance concern is uncertain, seek guidance before acting.

• Good-faith reporting is protected from retaliation under the public Code and related materials.

Use the current source

This recreation is designed as a consolidated reference, not a replacement for current UnitedHealth Group policies, plan

documents, legal requirements, or internal systems. Where a current company policy or internal resource is available to

you, use that source.

UnitedHealth Group Employee Handbook

Prompt to Clone This UnitedHealth Group Employee Handbook

Apply this example's core structure, strategic pacing, and structural hierarchy directly to your own topic.

What are you generating today?