WellCare Health Plans, Inc. Lobbying, Government Ethics & Political Activity Policy

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1 WellCare Health Plans, Inc. Lobbying, Government Ethics & Political Activity Policy Background/Purpose: 1. PREAMBLE WellCare Health Plans, Inc., and its affiliates and subsidiaries (collectively, WellCare or the Company ), participate in the policymaking process and engage in dialogue on public policy issues at the federal, state, and local levels in order to make the communities we serve better places to live, work, and do business. As a leading provider of managed care services for government-sponsored health care programs, we are subject to regulation at various levels of government, and the decisions and actions of policymakers and regulators can have a profound impact on our business, our Associates, and our members. The Company is engaged with public policymakers, governmental and regulatory agencies, industry trade associations, and political and advocacy organizations in support of the Company s legitimate business interests. WellCare Associates work closely with government agencies, officials, and employees in connection with those activities. This Policy has been developed to ensure that our lobbying and government affairs activities reflect the Company s commitment to integrity, transparency and high ethical standards, and are conducted in strict compliance with all applicable federal, state and local laws, regulations, and rules and good corporate governance practices. Moreover, this Policy is designed to provide specific guidelines for Associates whose duties require interaction with federal, state, and local governments. It is also intended to inform other Associates of the complex array of laws and regulations in this area and to underscore the importance of coordinating any covered activities with the Chief Strategy and Development Officer, or his or her designee, to ensure compliance with relevant laws and consistency with the Company s objectives. Policy Statement: 2. APPLICABLE LAWS WellCare is subject to a wide variety of laws, regulations, and sub-regulatory guidelines that govern the Company s lobbying and political activities. These include federal, state, and local campaign finance statutes, regulations and sub-regulatory guidance governing the offering of gifts to and the acceptance of gifts by government

2 officials and employees, laws against bribery and illegal gratuities, restrictions on the activities of government contractors, and lobbying registration and reporting regimes. 3. POLICY ON LOBBYING 3.1. Rationale for Lobbying by WellCare The Company and its directors, officers, and Associates actively lobby federal, state, and local officials, consistent with applicable laws and the principles of the First Amendment, on issues that impact the Company, its members and its Associates. As a business entity in a regulated industry, government decisions affect the operation and success of the Company. Therefore, it is in WellCare s interest to engage with policymakers in this manner. Regulated lobbying activities may include direct communications with government officials and employees as well as efforts in support of such contacts. But, lobbying is often defined more broadly than contacts just with respect to legislation; federal lobbying laws and the laws in many states and local jurisdictions can cover contacts regarding executive action, administrative matters, grassroots activity, the execution of government programs, regulatory proceedings, and the award and implementation of government contracts Prior Authorization Required It is important to the success of the Company that advocacy on behalf of WellCare be consistent, coordinated, and focused on the long-term interests of the Company, its members and its Associates. Advance approval of lobbying activities is also critical because lobbying is strictly regulated by federal, state, and local laws. As noted above in section 3.1, in many jurisdictions, lobbying includes more than just communications with respect to legislation. Many other contacts with government officials about contracts, programs, positions, and policies may be considered lobbying. Lobbying activities shall primarily be authorized through approval of the Government Affairs component of the annual business plans. Such plans shall be approved in the normal course of WellCare s business planning processes. Associates identified as engaged in lobbying activity in an approved business plan are authorized to undertake those lobbying activities described in each such plan. Associates not identified in an approved annual business plan shall not, unless otherwise engaged in routine compliance and contract management activities undertaken in the normal course of business, communicate with federal, state, or local government employees or officials on behalf of the Company without the prior authorization of the Chief Strategy and Development Officer, or his or her designee. Except activities undertaken by Associates in furtherance of an approved annual business plan, or routine compliance and contract management activities undertaken in the normal course of business, no director, officer, or Associate may contact any federal, state, or local legislative official or employee on behalf of the Company, or engage outside consultants to lobby on behalf of the company, without first obtaining the approval of the Vice President of Public Policy and Government Affairs, and the Chief Strategy and Development Officer, or their designees. 2

3 3.3. Obligations of WellCare as Lobbying Registrant or Principal When the lobbying activities of the Company or directors, officers, and Associates of the Company require registration in a jurisdiction as a lobbyist employer, the Company and its directors, officers, and Associates will follow all relevant registration, reporting, and disclosure requirements. These may include: the timely filing of an initial registration; periodic reporting of lobbying activities and expenditures; and other related requirements, including limitations on and disclosure of political contributions and expenditures on gifts to government officials and employees. Coordination of the Company s lobbying reporting obligations is overseen by the Vice President of Public Policy and Government Affairs, or his or her designee and must be reviewed by the Chief Strategy and Development Officer, or his or her designee Obligations of WellCare Associates Engaged in Lobbying Legal Obligations Lobbying is defined differently in various jurisdictions and may include communications with and/or efforts to influence both legislative and executive branch officials on a variety of topics, including legislation, policies, contracts, grants, and other government actions. In many jurisdictions, registration is required prior to engaging in lobbying activities and periodic disclosures may include information on contacts and communications made with government officials and employees, expenditures on lobbying activities, and corporate and personal political contributions and activities. When the activities of directors, officers, and Associates of the Company require registration in a jurisdiction as a lobbyist, such directors, officers, Associates will follow all relevant registration, reporting, and disclosure requirements. The Vice President of Public Policy and Government Affairs, in consultation with the Chief Strategy and Development Officer, shall oversee compliance with lobbying disclosure requirements, including informing Associates named in a business plan of what constitutes lobbying in relevant jurisdictions. If an individual has questions about whether contemplated activities may be considered lobbying for which registration and reporting may be required, such individual should consult with the Vice President of Public Policy and Government Affairs, or his or her designee. The Chief Strategy and Development Officer shall have final responsibility for determining whether lobbying activities have occurred in a particular jurisdiction WellCare Internal Obligations Federal, state, and local registration and reporting statutes vary by jurisdiction and place different requirements on companies that retain or employ lobbyists, on firms that engage in lobbying on behalf of clients, and on individual lobbyists. The Vice President of Public Policy and Government Affairs, or his or her designee, shall ensure that the Company maintains an auditable record of lobbying activities as may be necessary under a jurisdiction s disclosure requirements, including but not limited to time spent by Company directors, officers, and Associates on lobbying activities, the identity of those who serve as lobbyists, the issues on which lobbying occurs, the governmental officials and bodies before which lobbying occurs, and information on expenditures related to lobbying activities. 3

4 Directors, officers, and Associates who engage in lobbying activities on behalf of the Company are expected to inform the Vice President of Public Policy and Government Affairs, or his or her designee and, with respect to recording and tracking time spent on lobbying activities, progress on the annual business plan and Company resources devoted to lobbying activities, including political expenditures, contributions, and gifts and comply with all requests from the Vice President of Public Policy and Government Affairs, or his or her designee for information necessary to assure compliance with all relevant statutes, regulations and sub-regulatory guidance Standards of Conduct Directors, officers, and Associates who serve as advocates for WellCare are expected to maintain the highest standards of professional integrity and conduct. When communicating with government officials and employees on behalf of the Company, directors, officers, and Associates are expected to promote the best interests of WellCare at all times. In addition, those who lobby for the Company are expected to comply with the various federal, state, and local laws and regulations that regulate lobbying activities Retention of Outside Lobbyists and Lobbying Firms Engagement of outside lobbyists, lawyers, or consultants whose activities may involve lobbying activities or be considered lobbying activities must be undertaken through the processes established by the Vice President of Public Policy and Government Affairs, or his or her designee, under the direction of the Chief Strategy and Development Officer. No director, officer or Associate may engage outside lobbyists, lawyers or consultants whose activities may involve lobbying except in accordance with such processes. WellCare s outside lobbyists, lawyers, and consultants are expected to comply with the provisions of this Policy with respect to the registration, reporting, and disclosure of lobbying activities. Additionally, WellCare s outside lawyers, and consultants are expected to obtain approval from the Vice President of Public Policy and Government Affairs, or his or her designee, prior to engaging in lobbying activities on behalf of the Company Lobbying on Government Contracts Conducting lobbying activities in connection with procurement matters is often subject to additional restrictions under applicable laws and may impact the Company s ability to obtain or retain government business. For example, when a company responds to a Request for Proposals ( RFP ) issued by a government agency, lobbying activities outside the standard RFP process may subject the Company to certain requirements and prohibitions, including disqualification. In addition, under the law and/or the terms of certain contracts, proceeds from a government contract may not be used to lobby on certain actions, including the awarding, extension, renewal, amendment, or modification to a federal contract, grant, loan, or cooperative agreement. Questions about restrictions on lobbying in connection with government contracts should be directed to the Chief Strategy and Development Officer and the Vice President of Public Policy and Government Affairs, or their designees. 4

5 3.7. Former Government Officials Lobbying Former government officials and employees employed by the Company may be subject to restrictions on their ability to represent the Company before certain government officials and agencies under federal, state, and local laws, regulations, and rules. The extent and duration of such prohibitions vary widely. WellCare directors, officers, and Associates who are former government officials are expected to know and comply with any restrictions triggered by their former government service and are expected to notify the Vice President of Public Policy and Government Affairs, or his or her designee, of any such restrictions Recruiting When recruiting a government employee to join the Company, the employee and/or the Company may be subject to restrictions and reporting obligations under federal, state, and local laws, regulations, and rules. Such requirements may include: timing restrictions (particularly for elected officials); limits on meals, travel, and other benefits that might otherwise be provided to a prospective employee; and requirements that a potential employee recuse himself or herself from working on matters affecting the Company while negotiating for private employment. WellCare personnel involved in recruiting and hiring will abide by all such restrictions that apply to the Company, in consultation with the General Counsel and the Chief Strategy and Development Officer, or his or her designee Audit Although not required by federal or state law, WellCare will conduct an annual audit of the Company s lobbying activities. 4. POLICY ON GIFTS TO GOVERNMENT OFFICIALS 4.1. General Policy WellCare s primary business involves dealing with federal, state, and local government officials and employees who are governed by rules with respect to gifts and courtesies. In order to ensure compliance with these rules, the Company prohibits the offering or giving of any gifts or business courtesies to any government official or employee. Unless defined differently by applicable federal, state or local law or rule, a gift is defined as anything of value, including tangible items, services, meals, travel expenses, tickets to or attendance at events, and honoraria. This policy is not intended to prevent WellCare from supporting and sponsoring government and community events with financial or in-kind contributions if consistent with federal, state or local law. Contributions for such events should be made only to appropriate governmental or community entities; contributions to political candidates and committees are not contemplated under this provision (but may be permissible with prior approval under Section 5.2). Contributions to government entities or expenditures for events that involve government officials require the advance approval of the Vice President of Public 5

6 Policy and Government Affairs and the Chief Strategy and Development Officer, or their designees. In some cases, sponsorship of an event to which a government official attends could be considered a gift to that official. An expenditure that would otherwise amount to a gift, but is permissible under federal, state, or local law, may be eligible for an exception, to be granted by the Chief Strategy and Development Officer or his or her designee. Should WellCare provide financial or in-kind support to an organization or group sponsoring an event, attendance by a government official or employee at the event shall not result in a gift requiring an exception, provided WellCare has not invited the official or employee or caused the official or employee to be invited Members of Congress and Congressional Employees As a lobbying registrant under the federal Lobbying Disclosure Act of 1995, WellCare may not make any gift to a member of Congress or congressional employee unless allowed under an exception to the ethics rules of the United States Senate or House of Representatives. Any such gift must be reviewed in advance and be the subject of an exception, as detailed above, granted by the Chief Strategy and Development Officer or his or her designee. 4.3 Exception for Nominal Refreshments To the extent allowable by federal, state, or local law and regulations, food or refreshments of a nominal value provided to a government official or employee on Company property for a routine audit or other official business reason shall be permitted, except that no meal shall be provided to a member of Congress or congressional employee unless allowable under an exception and if an exception is granted, as detailed above Illegal Bribery and Gratuities The Company complies with applicable federal and state anti-bribery laws and regulations. No WellCare director, officer, or Associate may offer, give, or accept money, gifts, loans, rewards, favors, or anything of value that constitutes, or reasonably could be perceived as constituting, a bribe or other improper inducement. 5. POLICY ON POLITICAL ACTIVITIES 5.1. Rationale for WellCare Political Activities WellCare believes it has an obligation to participate constructively in the political process in order to be a strong advocate with policymakers on behalf of our Company, our Associates, and our members. As part of our government affairs program, we make prudent political contributions to support federal, state, and local elected officials and candidates seeking public office, to political parties, and to other political committees, where such contributions are allowed by law. Such contributions are only made to support candidates, committees, and/or issues that the Company has determined to be beneficial to the long-term interests of the WellCare and its members and consistent with the Company s policy positions and core values. All contributions are made without regard to the private political preferences of Company officers and executives. 6

7 5.2. Political Contributions Policy Political contributions are subject to extensive government regulation and public disclosure requirements. Various jurisdictions define contribution differently, and the term may include the provision of in-kind goods and services as well as direct financial contributions. The Company is committed to complying with all applicable federal and state laws that limit or prohibit such contributions and those that impose reporting requirements on those making such contributions. To ensure compliance with such laws, all political contributions made by WellCare or the Company s political action committees ( PACs ) are subject to prior review and approval by WellCare, as detailed below. No contributions will be given in anticipation of, in recognition of, or in return for an official act by an elected or appointed official Political Action Committee Contributions The Company may sponsor and support one or more PACs at the federal and state levels. The PACs may solicit and accept voluntary contributions from members of the Company s Board of Directors (the Board ), shareholders, directors, officers and Associates of the Company and their families. Consistent with federal and state regulations, only eligible Associates and others are asked to consider supporting the PACs. No corporate funds are contributed to or commingled with PAC funds, although corporate funds and resources may be used to administer the PACs, as consistent with relevant laws. The WellCare PACs are administered by a PAC Board of Directors, with ultimate oversight by the Chief Strategy and Development Officer and the Vice President of Public Policy and Government Affairs, or their designees, who are responsible for ensuring compliance with applicable campaign finance laws Corporate Contributions While federal law prohibits corporate contributions to federal candidates and committees, certain state and local laws permit WellCare to make contributions to candidates, political parties, and political committees. Accordingly, the Company may make corporate contributions in such states when WellCare believes contributions are in the best interests of the Company and its shareholders. The Company may also use corporate funds to support or oppose ballot measures, initiatives, or referenda, consistent with applicable laws and First Amendment principles Authorization and Oversight Political contributions, whether PAC or corporate, must be approved in advance, in writing, by the Chief Strategy and Development Officer and the Vice President of Public Policy and Government Affairs, or their designees. Contributions must comply with all applicable laws and regulations in the jurisdictions in which the contributions are to be made and are subject to legal review under the direction of the Chief Strategy and Development Officer or his or her designee. Prior to the release of contributions, the requestor shall provide all information necessary to review the appropriateness and timing of the contribution 7

8 request. At a minimum such information shall include the name of the company representative(s) delivering the contribution, location and date of contribution delivery. Even in instances where applicable law would permit the Company to make a contribution, a decision may be made to deny a contribution request for other reasons. In determining whether or not to approve a request to make a political contribution, the Chief Strategy and Development Officer and the Vice President of Public Policy and Government Affairs, or their designees, shall examine all relevant factors, including, but not limited to, the merits of the candidate, committee or political party, the timing of the proposed contribution, and the appropriateness of the Company s level of involvement. In making any determination with respect to a proposed political contribution, the Chief Strategy and Development Officer and the Vice President of Public Policy and Government Affairs, or their designees, may consult with outside legal counsel, compliance personnel, and other members of the Company s management. The WellCare Board, through its Regulatory Compliance Committee (the Regulatory Compliance Committee ) shall be provided with periodic reports on political contributions made by the Company and by PACs sponsored by the Company. The Regulatory Compliance Committee shall monitor the Company s political spending, receive periodic reports from the Chief Strategy and Development Officer and/or the Vice President of Public Policy and Government Affairs, or their designees, and review the purpose and benefits of the expenditures. In its periodic reports to the Board, the Regulatory Compliance Committee will cover these topics Reporting Obligations WellCare complies with all applicable reporting requirements in the jurisdictions where contributions are made. The contributions and expenditures of the Company and the PACs are all disclosed publicly through regular reports filed by WellCare, the Company s PACs, and/or the recipient candidates or committees with the Federal Election Commission or state and local campaign finance authorities Audit Although not required by federal or state law, it is the Company s practice to undertake an annual audit of the Company s corporate and PAC contributions Political Contributions and Government Contracts Doing business with governmental entities presents different risks from doing business in the commercial sector. Laws related to contracting with federal, state, and local entities are often stringent and complex. Under so-called pay-to-play and related laws, political contributions by the Company, its PACs, and individual WellCare directors, officers, and Associates (and in some cases immediate family members) may impact the Company s ability to obtain or retain government business. Under such laws, contributions to public officials, particularly those with responsibility for awarding government contracts, may result in the cancellation of existing contracts and the prohibition on receiving new contracts. WellCare directors, officers, and Associates potentially impacted by such laws will receive specific guidance on such laws and contributions from the Chief Strategy and Development Officer and the Vice President of 8

9 Public Policy and Government Affairs, or their designees. Questions about the application of such laws should be directed to the Chief Strategy and Development Officer and the Vice President of Public Policy and Government Affairs, or their designees Other Corporate Political Activities In addition to contributions to candidates and committees, the Company may, where permissible, engage in other political activities in support of the Company s government affairs objectives Political Communications WellCare may communicate with its directors, officers, and Associates, with its shareholders, with its members, and with the general public on political and policy matters, only as permitted by federal, state, or local law. In certain instances, the content of such communications may be limited by the intended audience and may mandate the inclusion of required disclaimers or statements. No political communication may be made on behalf of WellCare without the prior authorization of the Chief Strategy and Development Officer and the Vice President of Public Policy and Government Affairs, or their designees Use of Resources and Facilities WellCare s use of its resources and facilities for political purposes may be considered in-kind contributions to candidates or political committees and may be subject to limits and restrictions under federal, state, and local law. Such use may include the provision of a meeting room for a fundraiser or other campaign event, travel expenses in connection with campaign activities, food or beverages for campaign events, and promotional items provided to a candidate or campaign. Any use of WellCare resources and facilities for political purposes is subject to the same advance approval by the Chief Strategy and Development Officer and the Vice President of Public Policy and Government Affairs, or their designees, described in Section Personal Political Activity by WellCare Directors, Officers, and Associates The Company respects the rights of its directors, officers, and Associates to support candidates and issues and to seek elected and appointed office. WellCare personnel are encouraged to participate in political activities on their own time and in accordance with their individual desires and political preferences General Requirements Directors, officers, and Associates who engage in personal political activities must be clear at all times that such participation is as an individual and not as a representative of the Company. The Chief Executive Officer, President, Division Presidents, Regional Presidents, and Market Chief Operating Officers must have a heightened sensitivity to this issue and must make clear when they are participating in an event as individuals and not as representatives of the Company. In the course of voluntary political activity, no director, officer, or Associate shall use the Company s name in a way that could be interpreted as sponsorship or endorsement by WellCare. 9

10 No director, officer, or Associate may direct other WellCare personnel to assist or participate in personal political activities Political Contributions Political contributions by individual directors, officers, and Associates are entirely personal and voluntary. WellCare will not recognize, reimburse, or in any way compensate an individual for his or her personal political contributions. Moreover, directors, officers, and Associates may not use their position within the Company to coerce or pressure other WellCare personnel, or appear to coerce or pressure other Company personnel, to make political contributions or to support or oppose political candidates or elections. In some cases directors, officers and Associates may be required by law or statue to disclose personal political contributions Use of Resources and Facilities No director, officer, or Associate shall use corporate facilities or resources for personal political activity except as permitted by law. Any use of facilities or resources for such purposes that results in increased overhead or operating costs to the Company, without full reimbursement by the relevant candidate or committee, is prohibited. No corporate resources may be utilized to make or facilitate personal political contributions, including the bundling of personal contributions by WellCare directors, officers, or Associates Requirements for Those Seeking Political Office A director, officer, or Associate considering becoming a candidate for an elected public office shall advise the Chief Strategy and Development Officer and the Vice President of Public Policy and Government Affairs, or their designees, to ensure that all applicable laws that impact the Company are followed in the course of the individual s candidacy. 6. POLICY EXCEPTIONS WellCare personnel may request, in writing, exceptions or modifications to this Policy by contacting their supervisor, who will refer the request to the Chief Strategy and Development Officer and the Vice President of Public Policy and Government Affairs, or their designees. 7. POLICY VIOLATIONS WellCare will take appropriate disciplinary action, up to and including termination, against any director, officer, or Associate whose actions are found to violate this policy. Disciplinary action also may be taken against responsible personnel who unreasonably fail to detect or fail to report such violations, as well as those who retaliate. Penalties may include criminal, civil, and regulatory penalties for WellCare and its directors, officers, or Associates individually, including imprisonment and fines. 8. ADDITIONAL PROCEDURES This policy is to provide specific guidance on lobbying, government ethics, and political activity. Additional procedure and workflow controls will be 10

11 developed to ensure compliance with the policy. These additional procedures and workflow controls will be approved by the Vice President of Public Policy and Government Affairs, the Chief Compliance Officer and the Chief Strategy and Development Officer. 9. AMENDMENTS Amendments to this policy must be approved by the Regulatory Compliance Committee or by the full Board. Originally approved: September 10, 2009 Revised: October 28, 2009 (effective December 15, 2009) Revised: November 17, 2011 Revised: March 1, 2012 Revised: February 11, 2013 Revised: December 12, 2013 Revised: June 16, 2014 Revised: December 11,

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