Speak Up and Non-Retaliation

Change Healthcare is committed to providing a workplace conducive to open discussion of its business practices. It is our policy to protect Team Members who: (i) make Good Faith reports of potential violations of our Code of Conduct, Company policies or legal requirements; (ii) cooperate in Good Faith with an investigation; or (ii) refuse to do something they believe, in Good Faith, is a violation of our Code of Conduct, Company policies or legal requirements. In addition, we comply with all applicable legal requirements that protect Team Members against unlawful intimidation, discrimination or retaliation by the Company because of Team Members lawfully reporting information regarding corporate fraud or other violations of legal requirements by the Company or its Team Members.

Retaliation is a harmful action taken against a Team Member because he or she:

Anyone who retaliates against another individual for engaging in Good Faith in any of the above activities will be subject to disciplinary action, which may include termination of employment.

Change Healthcare encourages all Team Members to share their concerns and presumes all concerns are being raised in Good Faith. Further, the Speak Up and Non-Retaliation Policy applies even if an allegation that was made in good faith ultimately turns out to be unsubstantiated. However, Team Members who file reports or provide evidence that they know to be false or without a good faith belief in the truth of such information will be subject to appropriate disciplinary action.

Any Team Member who believes he or she has been subjected to any action that violates this Speak Up and Non-Retaliation Policy should raise the issue with his or her manager, Human Resources, Employee Relations, Legal, or the Chief Compliance and Ethics Officer.  Team Members may also report such conduct through the Company’s EthicsLine: 1.866.206.1106 (U.S. toll free number) or online here.