Company Policies and Procedures

Anthem Supplier Code of Conduct

Procurement Process Technology and Electronic Signatures

Supplier Reimbursable Expense Guidelines

Anthem Requirements for Supplier Onsite Personnel

Anthem Supplier Code of Conduct

Anthem’s success is built on a commitment to our core values and behaviors that include being:

• Accountable

• Caring

• Easy to Do Business With

• Innovative

• Trustworthy

Our customers, stakeholders and regulators expect that we will conduct business with integrity and provide a

quality product. In turn, we expect the same of our Suppliers.

Anthem understands that our Suppliers are independent entities; however, the business practices of our

Suppliers may impact and/or reflect upon Anthem. It is for this reason that Anthem expects all Suppliers, their

employees, agents and subcontractors (hereinafter referred to collectively as “Supplier”) to adhere to the

Anthem Supplier Code of Conduct while conducting business with or on behalf of Anthem. The Anthem

Supplier Code of Conduct establishes minimum standards for conducting business with Anthem and to the

extent of any conflict between this Supplier Code of Conduct and any other transactional document entered

into by Anthem and Supplier, the latter shall control.

1. WORKPLACE STANDARDS AND PRACTICES

Suppliers will operate their facilities and conduct employment practices in an ethical manner and meet the

requirements required by law in all locations in which they operate. This includes, but is not limited to,

laws and regulations relating to health and safety, labor, compensation, work hours, and the

environment. Following are Anthem-specific guidelines for some of these matters applicable to Supplier:

Alcohol and Drug-free Workplace

Anthem is committed to providing an alcohol and drug-free workplace, which helps facilitate a safe and

healthy work environment. Anthem complies with the Drug-free Workplace Act of 1988. Associates,

temporary employees, agents, contractors, Suppliers and visitors are prohibited from the unlawful

manufacture, distribution, dispensation, possession or use of alcohol, illegal drugs, and/or drug

paraphernalia on Anthem owned or leased property, or while representing Anthem at any time.

Health and Safety

Suppliers will provide a safe and healthy work environment in compliance with all applicable laws and

regulations. Anthem does not tolerate acts of violence, threats, harassment, intimidation or other

disruptive behavior in our workplace or during the course of providing services to Anthem, whether on

Anthem premises or off-site, by associates, contractors or Suppliers.

Weapons

Anthem prohibits Suppliers from keeping weapons on Anthem property, including buildings, lockers, desks,

work spaces, storage areas and company-owned vehicles. In addition, weapons may not be kept in vehicles

parked in Anthem parking lots or in personal vehicles being used for business. Weapons include, but are

not limited to, guns, knives and ammunition.

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Compensation

Suppliers will not pay less than the minimum wage in accordance with local labor laws. In addition to

compensation for regular hours, Supplier employees will be fairly compensated for overtime work

in accordance with local labor laws. Other benefits must meet or exceed local laws and standards.

Equal Employment Opportunity

Suppliers will foster a positive work environment that promotes equal employment opportunity in

accordance with all applicable Equal Employment/Anti-Harassment laws, directives and regulations of

federal, State, and local governing bodies. Suppliers will prohibit discriminatory practices in the

recruiting, hiring, training, promoting, and compensating of its employees on grounds of race, color,

creed, religion, gender, national origin, sexual orientation, gender identity, veteran status, disability,

age, marital status, or any other legally protected characteristic.

As a federal contractor Anthem complies with federal EEO obligations. When Suppliers provide services

or goods to Anthem relating to one of its federal contracts, Suppliers agree to comply with the following

as required under federal regulations:

Supplier shall abide by the requirements of 41 CFR §§ 60-1.4(a), 60-300.5(a) and 60-741.5(a).

These regulations prohibit discrimination against qualified individuals based on their status as

protected veterans or individuals with disabilities, and prohibit discrimination against all

individuals based on their race, color, religion, sex, sexual orientation, gender identity or

national origin. Moreover, these regulations require that covered prime contractors and

subcontractors take affirmative action to employ and advance in employment individuals

without regard to race, color, religion, sex, sexual orientation, gender identity, national origin,

protected veteran status or disability.

Freedom of Association and Collective Bargaining

Suppliers will recognize and respect the right of its employees to form or join trade unions of their own

choosing and to bargain collectively. Where the right of freedom of association and collective

bargaining is restricted under law, Suppliers will not hinder the development of parallel means for

independent, free association and bargaining.

Labor Practices

Suppliers will not use forced or prison labor in the supply of materials, products, or services. Suppliers

will not employ workers under age 14 or the minimum age for completing compulsory education,

whichever is higher. Supplier employees will be treated with respect and dignity, therefore, no

employee shall be subject to any physical, sexual, psychological, or verbal harassment or abuse.

Work Hours

Supplier employees should not work more than the maximum hours of daily labor set by local laws.

These employees should receive a minimum of one day off every seven days.

Environmental Responsibility

Suppliers shall comply with all applicable environmental laws and regulations pertaining to hazardous

materials, air emissions, and waste and wastewater discharges, including the manufacture, transportation,

storage, disposal and release into the environment of such.

2. USE OF ANTHEM’S ASSETS

Anthem has a variety of tangible and intangible assets that are of great value to its competitiveness

and success as a leader in the health benefits industry. They include not only valuable proprietary

and confidential information but physical assets. Protecting all of Anthem’s assets is very important.

Their loss, theft or misuse jeopardizes the business and operations of Anthem and its stakeholders.

The safeguarding of information entrusted by Anthem to Suppliers is vital to Anthem’s continued

success, security and integrity. All Suppliers have an obligation to practice and promote a secure work

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environment that protects the confidentiality, integrity, and availability of the facilities, systems,

applications, and information under Anthem’s control.

Physical Assets

Suppliers may only use Anthem’s property and other physical assets to provide services or fulfill its

other contractual obligations to Anthem. Anthem assets include but are not limited to, computers,

email, internet/intranet, fax, phone, copiers and time. Inappropriate, inflammatory and derogatory

communications are prohibited, including chain emails, jokes, sending, and receiving or viewing

sexually explicit or suggestive communications. In addition, no unauthorized software is to be

downloaded to Anthem’s computers.

Suppliers must promptly report any activities that may compromise the security and the

confidentiality of Anthem’s data to the Anthem contact overseeing the contract.

Electronic Assets

User IDs and passwords are for the exclusive use of the intended recipient only and should never be

used or “tested” by others. Suppliers are responsible for what's done with their user ID and password.

Likewise, Suppliers may only use the user ID and password assigned to them to gain access to an

Anthem system. Violations of this policy can result in termination of your contract with Anthem.

Use of instant messaging services is permitted only when participating in authorized Anthem chat

sessions or other authorized use. Personal use of Anthem Internet resources to utilize any instant

messaging services is prohibited.

Suppliers have no expectation of privacy when using Anthem information and telecommunications

systems. Electronic mail content may be reviewed as part of an ethics and compliance investigation or

whenever deemed necessary.

3. BUSINESS PRACTICES

Recording, Reporting & Retaining Information

Accurate and complete records are vital to the Anthem corporate decision-making process and to the

collection and reporting of our financial, legal and regulatory data. All records, expense accounts,

vouchers, invoices, payroll and service records, reports to government agencies, measurement and

performance records, and other essential data must be prepared with care, honesty and accuracy.

Records Retention

In addition to any specific obligations regarding Anthem records and files that may exist in the

Supplier’s written agreement with Anthem, Suppliers must create, retain and dispose of business

records in full compliance with all applicable legal and regulatory requirements.

Conflicts of Interest

Suppliers must avoid the appearance of improprieties and/or conflicts of interest, as such relate to

Anthem. During the course of negotiating its agreement with Anthem or during performance of its

obligations thereunder, Supplier shall not deal directly with any Anthem employee whose spouse,

domestic partner or other family member or relative holds a significant financial interest in the

Supplier.

Legal and Regulatory Compliance

Anthem Suppliers shall conduct their business in full compliance with all applicable laws and regulations

while conducting business with and/or on behalf of Anthem. In addition to any specific

obligations under the Supplier’s agreement with Anthem, all Suppliers shall, without limitation:

• Comply with all applicable statutory and regulatory requirements for government contracts

entered into by Anthem and for which Supplier may be providing goods or services, directly or

indirectly, in connection with such government contract, including the False Statements Act,

federal anti-kickback statutes and the like.

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• Conduct business in full compliance with antitrust and competition laws.

• Comply with all applicable environmental laws and regulations regarding hazardous materials,

air emissions, waste and wastewater discharges, including the manufacture, transportation,

storage, disposal and release to the environment of such materials.

• Be honest and forthcoming in communications with and disclosures to regulatory

agency representatives and government officials.

• Comply with the anti-corruption laws of the countries in which they do business, including the

U.S. Foreign Corrupt Practices Act, and not make any direct or indirect payments or promises of

payments to foreign government officials for the purpose of inducing any individual to misuse

his/her position to retain services for or provide goods to Anthem.

Supplier Reporting

All Anthem Suppliers and subcontractors are responsible for promptly reporting actual or suspected

ethics or compliance issues (E&C Issues) involving Anthem, Inc. or any of its subsidiary or affiliated

entities or agents (Anthem) to the Anthem manager assigning their work or the Ethics and Compliance

department. Examples of E&C Issues include violations of applicable law and/or Anthem policies. The

Ethics and Compliance department provides various reporting mechanisms to submit reports or to ask

questions. Reports to the Ethics and Compliance department can be made using one of the following

channels:

1. Call the Ethics and Compliance HelpLine from the United States at 1-877-725-2702 and from

Ireland at (1-800-550-000) 877-725-2702

2. Send an email to ethicsandcompliance@Anthem.com

3. Send a letter to the following address:

Ethics and Compliance Department

Anthem, Inc.

Post Office Box 791

Indianapolis, IN 46206

Bribery and Corruption

Anthem prohibits any form of bribery or corrupt payments. When working on our behalf or on our

business, Suppliers are required to comply with all applicable U.S. and local anti-bribery laws, such as the

U.S. Foreign Corrupt Practices Act, the Travel Act and similar laws in foreign jurisdictions.

Suppliers must not, directly or indirectly, make or offer bribes, kickbacks, or other payments of money or

anything of value to anyone, including officials, employees, or representatives of any government,

company, or public or international organization, or to any other third party, for the purpose of

wrongfully obtaining, retaining or directing our business. This includes giving money or anything of value

to any third party where there is reason to believe it will be passed on to anyone involved in the decision

making process for the purpose of influencing the decision.

If Suppliers are aware of actual or suspected bribery or corrupt payments, Suppliers must notify the

Anthem Ethics & Compliance department through our Ethics & Compliance HelpLine at 1-877-725-2702

(in the US) or send an email to ethicsandcompliance@Anthem.com.

Assurances of Compliance

Upon reasonable request, Suppliers shall provide Anthem with assurances of Supplier’s compliance with

its Agreement and Anthem Policies and Procedures. Reasonable assurances include, but are not limited

to, Supplier’s response to annual surveys issued by Anthem related to its provision of goods or services,

certain contract requirements and/or the Agreement generally.

Meetings with Anthem Associates

Suppliers agree that their designated sourcing associate will be given advance notice or will be present in

any meetings with Anthem associates involving any of the following:

1) Existing contract terms and

conditions; 2) Sales presentations or proposals for new goods and/or services offered for sale; and/or 3)

Any proposed changes or updates to the scope, nature, duration or price of currently contracted goods or

services. If you are unfamiliar with your designated sourcing associate, notification must be made by

sending an email to Purchasing.Help@Anthem.com.

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4. ANTHEM PRIVACY AND SECURITY REQUIREMENTS

Privacy

Anthem, Inc. and its workforce have a responsibility to protect the confidentiality of the Protected Health

Information (PHI) it collects uses and discloses about its members and applicants. Suppliers that provide

a service to or on behalf of Anthem which requires the use or disclosure of PHI shall be deemed Business

Associates, in accordance with the Health Insurance Portability and Accountability Act of 1996, and shall

enter into a Business Associate Agreement and Security Addendum with Anthem.

Proprietary and Other Confidential Information

In addition to PHI, Suppliers may have exposure to information that is not PHI, but is confidential

and/or proprietary to Anthem. Anthem has a variety of information assets that are of great value to our

competitiveness and success as a leader in our industry. They include valuable confidential and

proprietary information, material non-public information, and information relating to our members,

associates and government contracts. Suppliers must protect all confidential and proprietary

information gained from Anthem against inappropriate access and disclosure at all times.

Misappropriation of Anthem confidential and proprietary information may constitute theft of Anthem

trade secrets and/or violation of unfair competition laws.

Supplier Facility Access Policy

Standard facility access policies and procedures have been established to provide specific guidelines for

Supplier access to Anthem facilities. Suppliers must adhere to Anthem security requirements and all

safety standards, practices, and procedures. Supplier representatives are not permitted to possess

permanent Anthem ID access badges for any Anthem facility. Suppliers who violate these policies may

be subject to disciplinary actions.

When considering facility access, the Supplier must adhere to the policy identified below:

• Review and follow guidelines identified in this Supplier Code of Conduct.

• Anthem security requirements and safety standards should be adhered to at all times.

• Visits must be scheduled directly with an Anthem contact prior to access.

• Anthem may, at its option, require Supplier and/or Supplier’s employees or Subcontractors to

sign separate agreements regarding access to Anthem facilities or equipment.

Under normal circumstances, Suppliers may be permitted access to Anthem facilities for the

following reasons:

• Urgent off boarding of temporary workers.

• Retrieval of temporary worker property.

• Return of Anthem property.

• Facilitating any temporary worker emergencies.

• Attend meetings where business related items will be discussed.

• Supplier meetings.

Supplier Use of Subcontracted Firms

Use of subcontracted firms by Suppliers may be permitted in order to fulfill Anthem requirements. If

such use is permitted by any written agreement between Anthem and the Supplier, the following shall

apply:

• Subcontractor firm personnel may use the SourcePoint system as a representative of the Supplier

(account logon obtained from Supplier’s system administrator).

• Subcontractor firm personnel may not represent their firm using their firm’s name or logo on

business cards, candidate resumes, etc. or any correspondence with Anthem personnel.

• Supplier must make all due and payable payments to Subcontractor firm.

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Procurement Process Technology and Electronic Signatures

Anthem may require Suppliers to facilitate purchase and sale transactions under the Agreement by

electronically transmitting and receiving data through the Ariba, Inc. Ariba Network (“AN”). The following

are requirements of facilitating such transactions:

Anthem and Supplier may electronically transmit and/or receive purchase and sale information and

related contract and other documents (collectively, “Documents”) to and from the other Party through

ASN.

AN Membership - Supplier agrees to enter into an AN agreement with Ariba, Inc., at Supplier’s sole

expense, in order to transmit and receive Documents to and from Anthem. AN pricing can be found on

the Ariba Network site at: http://www.ariba.com/suppliermembership/smp pricing.cfm

System Operations - Anthem and Supplier, each at its own expense, shall arrange for the provision

and maintenance of equipment, software, AN services and testing necessary to transmit and receive

Documents effectively and reliably.

Security Procedures - Anthem and Supplier shall be responsible for using security procedures that are

reasonably sufficient to ensure that all transmissions of Documents are authorized and to protect its

business records and data from improper access.

Signatures - Unless otherwise agreed to by the Parties, the purchase order number (issued by

Anthem) shall constitute Anthem’s electronic signature and consent to any order schedule and the

Supplier’s invoice number shall constitute Supplier’s electronic signature and consent to provide the

Licensed Products and/or other Services. Each Party agrees that the Anthem purchase order number

or the Supplier invoice number, as issued by the respective Party, shall be sufficient to verify that such

Party originated the document. Neither Party shall disclose to any unauthorized person the purchase

order number or the invoice number. The Parties acknowledge and agree that the issuance of a

purchase order or invoice number shall be valid and enforceable as to the signing Party to the same

extent as an inked original signature, (ii) these documents shall constitute “original” documents when

printed from electronic files and records established and maintained by either Party in the normal

course of business.

Garbled Transmissions - If any transmitted Document is received in an incomplete, unintelligible or

garbled form, the receiving Party shall promptly notify the originating Party (if identifiable from the

Document received) in a reasonable manner. In the absence of such a notice, the originating Party’s

records of the contents of such Document shall control.

Validity and Enforceability - Agreement of these procure-to-pay terms evidences the mutual intent of

the Parties to create binding purchase and sale obligations pursuant to the electronic transmission

and receipt of Documents specifying certain of the applicable terms.

Signed Document - Any Document properly transmitted pursuant to these procure-to-pay terms

shall be considered, in connection with any Transaction, or the Agreement, to be a “writing” or “in

writing”, and any such Document containing, or to which there is affixed, a Signature (“Signed

Document”) shall be deemed for all purposes (a) to have been “signed” and (b) to constitute an

“original” when printed from electronic files or records established and maintained in the normal

course of business.

Course of Dealing - The conduct of the Parties pursuant to these procure-to-pay terms, including the

use of Signed Documents properly transmitted pursuant to these terms, shall, for all purposes,

evidence a course of dealing and a course of performance accepted by the Parties in furtherance of

these procure-to-pay terms, any Transaction.

10. Validity - Anthem and Supplier agree not to contest the validity or enforceability of Signed Documents

under the provisions of any applicable law relating to whether or not certain agreements are to be in

writing or signed by the Party to be bound thereby. Signed Documents, if introduced on paper in any

judicial, arbitration, mediation or administrative proceeding, shall be valid to the same extent and under

the same conditions as other business records originated and maintained in documentary form. Neither

Party shall contest the admissibility of copies of Signed Documents under either, the business records

exception to the hearsay rule, or the best evidence rule on the basis that the Signed Documents were

not originated or maintained in documentary form or on any other basis.

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Supplier Reimbursable Expense Guidelines

Company recommends Suppliers establish behaviors associated with travel expenditures which are consistent

with best business practices and Anthem’s Supplier Reimbursable Expense Guidelines and Travel Policy

Guidelines.

1. General

• When practical to do so, Supplier shall book all travel for purposes of the Agreement through

Company’s travel service. Arrangements can be made for air fare, hotel and rental cars.

Supplier should communicate to Company’s travel service that the travel is on behalf of

Company and that any applicable discounts available to Company should be obtained.

Supplier shall provide to the travel service the name and telephone number of the

Procurement Representative assigned to Supplier by Company. Any airline ticket, car rental

and hotel charges should be paid directly by Supplier, with available discounts applied.

Company’s travel service telephone number is: (888) FLIWELL or (888) 354-9355 applicable

discounts available to Company should be obtained. Supplier shall provide to the travel

service the name and telephone number of the Procurement Representative assigned to

Supplier by Company.

• For purposes of reimbursement hereunder, Supplier shall submit original receipts for all

reimbursable expenses to Company whenever possible. Supplier must submit original

receipts to receive reimbursement of air travel expenses.

2. Air Travel

• All personnel of Supplier (“Travelers”) will fly coach class. Original airline receipts are required for

reimbursement in all cases.

3. Hotels

• Hotel accommodations shall be booked for all Travelers by Company’s travel service. Hotels will

be selected by Company’s travel service on the basis of rates, locations and availability as

determined by the travel service from time to time. Requests by Travelers for specific hotels will

be honored only at the discretion of Company’s travel service and only if the rates of such hotels

are the same as or lower than those selected by the travel service.

• Lodging expenses shall include the cost of a Traveler’s room plus applicable taxes, but shall not

include room service, recreation, or any other direct charges to the room. See Section 5 of

these Guidelines for further discussion of these charges.

4. Automobile Expense

• When arrangements are made through Company’s travel service, rental automobiles will be

provided by the rental car company selected by the travel service. Rental car charges shall

be billed directly to each Traveler.

• Reimbursement will cover no more than the cost of a mid-size rental car. Limousine service is

expressly prohibited, unless authorized in advance in writing by a Procurement Representative.

• Additional insurance coverage, as provided in the rental car agreement, will not be reimbursed.

• Mileage for travel in Supplier’s vehicles or in Travelers’ personal vehicles shall be reimbursed at

the same per-mile rate in effect from time to time for reimbursement of mileage incurred by

Company’s own employees. Toll-road charges will be reimbursed only if incurred for office-to-

office travel between Supplier’s offices and Company’s. Mileage and tolls should be supported by

appropriate, contemporaneous logs of such charges maintained by Travelers.

5. Miscellaneous Travel Expenses

• Original receipts must be submitted for expenses including the following: meals; taxi and hotel

shuttle fares; parking; and other costs for which receipts can be typically obtained. Expenses such

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as tips (for which receipts are usually are not provided) should be reasonable for the services

provided and supported by a personal log or other contemporaneous record kept by the Traveler.

• Travelers’ expense reports submitted as documentation for reimbursement are to be signed by

appropriate management personnel of Supplier and are to include copies of applicable receipts

as supporting documentation.

• Documentation of each business meal should include the names of all individuals for whom

the meal was ordered, the date of the meal, the business purpose, the relationships between

or among the individuals, and a summary of the business discussion.

• A per diem allowance for meals, tips, and incidentals, when agreed to in advance in writing by

the Procurement Representative, shall be in lieu of any other reimbursement for such expenses

and shall not exceed the following maximum per Traveler: $ 60.00 per day.

6. Other Expenses

• If incurred by Supplier exclusively for purposes of the Agreement, other costs (such as for

document reproduction, computer time, air freight, postage telephone, and facsimile) will be

reimbursed by Company only upon submission of documentation satisfactory to Company. Such

documentation may include office logs that identify specific costs with specific services

performed by Supplier under the Agreement.

7. Subcontractors

• If Supplier contracts with a third party (“Subcontractor”) for purposes of performing Supplier’s

obligations under the Agreement, these Guidelines shall apply to travel expenses incurred by a

Subcontractor and which Supplier is obligated to reimburse to the Subcontractor. Company shall

not be responsible to pay Supplier any amount in excess of Supplier’s actual cost of reimbursing a

Subcontractor, or the maximum amount permitted by these Guidelines, whichever is less. In no

event shall Company pay Supplier any percentage, fee, administrative charge or other mark-up.

Anthem Requirements for On-Site Personnel

The following background checks and on-boarding procedures are required to be performed for all Supplier

personnel placed on assignment at an Anthem location. Additional types of checks may be required based upon

the position and/or location and are at the sole discretion of Anthem.

Background Check Criteria

Below is a list of specific background check criteria that must be performed and documented prior to the start

date of all Supplier personnel that will be onsite at an Anthem location—no exceptions will be made.

Supplier is responsible for obtaining and maintaining documentation substantiating that all items listed have

been performed. Audits may be performed by Anthem to ensure compliance.

Type of Check

•

Social Security Number Verification (Includes Trace)

•

Criminal Search - All years reportable by the courts (County Criminal; residence, school, & employment)

- all counties provided or developed

•

National Criminal Database Search (+county criminal if any “hits” obtained from nationwide search)

•

10 Panel Non-DOT drug screen required for specified positions

•

US Department of Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated National or a

Blocked Persons

•

Employment Verification - last 3 employers or past 10 years, whichever comes first

•

Education Verification (highest level obtained post high school)

•

Professional License or Certificate Verification (if appropriate)

•

OIG List of Excluded Individuals/Entities*

•

GSA List of Parties Excluded from Federal Programs (now known as SAM)*

•

E-verify Contractor shall comply with the requirements of 48 C.F.R. 52.222-54 and the U.S. Citizenship

and Immigration Services’ E-Verify Program.

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