Governance and Accountability

believes that strong corporate governance is important to ensure we are able to create and sustain long-term value for our stakeholders.

Being a leader in government-sponsored healthcare means doing things the right way, every day. To ensure we are always at our best, we embrace and foster a culture of accountability that is shaped and supported by ’s Board of Directors, our Code of Conduct and a system of policies and procedures that encourage our employees to be responsible stewards of taxpayer dollars, our brand and company.

’s overall governance approach follows the Three Lines of Accountability model:

  • First Line of Accountability – Management: Corporate and business unit level leaders and operational management are responsible for both identifying risks within their business areas and implementing appropriate mitigation strategies to address them.
  • Second Line of Accountability – Enterprise Risk and Compliance Functions:’s enterprise risk and compliance functional areas, including Enterprise Risk Management (ERM), Enterprise Ethics & Compliance, Data Privacy and Security Risk Management, enable the ongoing identification of business risks and collaborate with first-line management to create and protect value.
  • Third Line of Accountability – Internal Audit: As the Third Line of Accountability, Internal Audit provides independent oversight of the first- and second-line functions, conducts independent audits and reviews and makes recommendations for continuous improvement.

The Board of Directors has overall responsibility for the oversight of enterprise-wide risk management at , while management is responsible for day-to-day risk management. The ERM group is responsible for facilitating the risk identification process, conducting quarterly and annual risk assessments and providing clear and timely direct reporting to executive leadership and the Board of Directors. Additionally, the ERM group annually performs quantitative and/or qualitative assessments of risk exposure in both normal and stressed environments for material risk categories, which include both financial and non-financial risks.

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is committed to fostering a culture of leadership and accountability across the organization.