Ethics & Compliance HMIAT002182

Agenda Ethics Product Presentation Guidelines Complaint Handling Fraud Disciplinary Policy

Ethics HealthMarkets and its directors, officers, employees and agents are committed to a culture of compliance in all business dealings Doing the right thing at all times HealthMarkets requires all agents to observe the highest standards of business and personal ethics in the conduct of their duties and responsibilities Agents must practice honesty and integrity in every aspect of dealing with their customers and the business community

Ethics Insurance is a heavily regulated industry. Among the agencies that oversee insurance companies: State Departments of Insurance (DOI) State Offices of the Attorneys General Federal agencies, such as the United States Department of Health and Human Services (HHS), the Centers for Medicare and Medicaid Services (CMS), and the Federal Trade Commission In order to comply with state and federal laws and regulations and uphold our reputation, HealthMarkets has established mandatory policies and procedures

Ethics Agents must observe all insurance laws, and all HealthMarkets and other carriers’ policies These laws and policies, along with a strong sense of personal ethics, constitute a solid foundation for agents’ professional behavior

Together, laws and ethics underpin an agent’s code of conduct Laws are rules established by the government which dictate minimum standards of conduct Ethics are standards set by society that influence personal and professional conduct Together, laws and ethics underpin an agent’s code of conduct Legal Ethical

Ethics We are committed to Serving our customers by offering coverage that meets their needs Offering coverage in a manner that is compliant with state and federal requirements Fairly and accurately representing product benefits using approved materials and compliant sales practices Competing fairly in the marketplace by focusing on the strengths of the products and services we offer

Ethics As a licensed agent, you are expected to Treat all customers and carrier partners with courtesy and respect Stay current with and abide by all HealthMarkets and carrier requirements Disclose all plan provisions to customers, including exclusions and limitations Be accurate and forthright with information and truthful in answering questions Admit when you don’t know the answer and then find it

For concerns or questions, call the Ethics Hotline at (877)778-5463 Compliance As a licensed agent, you are the face of the company. Your actions directly influence your business and directly affect the reputation of HealthMarkets and its carriers partners. HealthMarkets requires that its agents provide the service that is expected by our customers and required by regulators. For concerns or questions, call the Ethics Hotline at (877)778-5463

Use and Disclosure of Information Fairness and Transparency – is providing customers with complete and accurate information clearly and understandably; inspires trust in our company and the products of our carriers Product Understanding – is educating current and prospective customers about our products; equips them to make informed choices, resulting in fewer misunderstandings and greater customer satisfaction

Unfair Inducements You may not do any of the following to persuade a customer to buy insurance Offer kickbacks (paying or rebating any portion of the premium) Imply that claims will be paid over the limits of the plan Claim that premiums are an introductory, initial, or special offer Advise a customer they have to have supplemental coverage in order to purchase health insurance

Fraud Fraud is a deception made for personal gain Forgery is a type of fraud that is an unauthorized alteration of documents, such as applications, bank authorizations, and other forms Other types of fraud include signing an application when you did not make the presentation, false advertising, and non-disclosure of known medical information Submitting applications for additional coverage without the customer’s knowledge

Fraud Don’t sign any document on behalf of a policyholder, applicant or beneficiary under any circumstances, even with written authorization Do not transfer a wet signature to an electronic signature, even at client request Don’t allow a customer to sign documents on behalf of another customer (for example, a wife cannot sign an application for her husband when she is not on the application or is not the primary insured)

Product Presentation Guidelines

Product Presentation Identify yourself as a licensed insurance agent representing the carrier before presenting any insurance benefits If selling multiple carriers’ products to the customer, you must name all of the carriers you are representing As a licensed and appointed agent with the company, you may represent the policies and contracts offered by carriers, but not change or amend coverage on behalf of the carrier Writing or notes made by the agent could change the terms of the coverage and ultimately become part of the contract. They are not allowed.

Product Presentation Review all benefits, exclusions and limitations with applicants Ensure that applicants understand all plan provisions including any benefit maximums and deductibles You may not compare the company’s products with other insurers’ products unless you provide a fair, complete, side-by-side comparison with the consumer’s current plan benefits Any personal or company Explanation of Benefits (EOB) should not be used to explain benefits Claims payment and discounts depend on the type of coverage purchased

Presentation Guidelines At the point of sale, leave any required disclosures with the applicant For example, in a Chesapeake Life Insurance Company sale, you are required to leave a product brochure, several disclosure forms, and an outline of coverage if required

Predicting Rate Increases Never predict rate increases Rate increases are based on numerous factors and cannot be anticipated

Complaint Handling

Complaint Handling HealthMarkets has established procedures to identify, log and respond to verbal and written complaints and grievances A complaint is an expression of dissatisfaction by a customer. Following are examples of indicators that a customer is making a complaint Customer states the agent: Didn’t provide the coverage requested Advised certain services would be covered and they were not Enrolled the customer in a plan they didn’t know about Did not cancel their coverage as requested Wants a company response to his/her complaint

Complaint Handling All complaints will be investigated by HealthMarkets. If an agent receives the complaint, the agent must report the complaint to the Agency Standards Unit at Agency.Standards@healthmarketshq.com If a customer complains about an agent, the agent will be asked to complete an Agent Statement to give his/her description of the sales presentation or situation When filling out an Agent Statement, it is important to give as much factual and specific information as possible. Personal opinion about the customer or the carrier should not be included Agent should confer with the Territory Vice President on the completion of the statement

Complaint Handling HealthMarkets and the carriers will evaluate the nature of the complaint and the agent’s complaint history to determine appropriate action For less severe issues, the company may send a coaching notification to the agent or recommend retraining Actions for more severe issues may include a warning, suspension or termination of appointment and/or contract

HealthMarkets Disciplinary Policy HealthMarkets has developed standard procedures for agent oversight and sales compliance to protect all agents The company will promptly review any complaint filed against an agent All agents are required to take the online compliance training under the HealthMarkets tab on your My Curriculum page Titled “Mandatory Training: Agent Guidelines”

Review You should now feel comfortable with HealthMarkets’ expectations on the following topics Ethical responsibilities Unlawful agent activity Acceptable advertising practices Marketing and Do Not Call regulations Complaint handling Company disciplinary policy