UnitedHealth Group Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	UnitedHealth Group Inc demonstrates a moderate level of governance in its lobbying activities, with some mechanisms and oversight structures disclosed. The company states that its Public Policy Strategies and Responsibility Committee "assists the Board of Directors in fulfilling its responsibilities relating to our public policy, health care reform and modernization activities, political contributions, government affairs, community and charitable activities, third party activities (including trade associations and industry groups), sustainability, and corporate social responsibility." This committee also "receives regular reports from our leadership on these matters, oversees our policies, and reviews the purposes and benefits of these activities at each meeting." Additionally, the Governance Committee is tasked with "monitoring the Company’s advocacy lobbying processes and activities, including key trade associations and coalition memberships," and overseeing public policy and government relations activities. The company discloses that its advocacy activities are led by UHG External Affairs and are subject to oversight by the Executive Vice President of Corporate Affairs and the Public Policy Strategies and Responsibility Committee. However, while these disclosures indicate oversight and review mechanisms, there is limited evidence of specific processes for aligning lobbying activities with climate-related goals. For example, while the company mentions oversight of trade association memberships, it does not provide details on how alignment with climate policies is ensured or monitored. Furthermore, while the company publishes semi-annual political contribution reports and files lobbying disclosure reports, these actions focus on transparency rather than governance of lobbying alignment. The absence of a detailed climate lobbying alignment policy or audit limits the robustness of its governance framework in this area. View Sources	C

Overall Assessment

Analysis

Score

Moderate

UnitedHealth Group Inc demonstrates a moderate level of governance in its lobbying activities, with some mechanisms and oversight structures disclosed. The company states that its Public Policy Strategies and Responsibility Committee "assists the Board of Directors in fulfilling its responsibilities relating to our public policy, health care reform and modernization activities, political contributions, government affairs, community and charitable activities, third party activities (including trade associations and industry groups), sustainability, and corporate social responsibility." This committee also "receives regular reports from our leadership on these matters, oversees our policies, and reviews the purposes and benefits of these activities at each meeting." Additionally, the Governance Committee is tasked with "monitoring the Company’s advocacy lobbying processes and activities, including key trade associations and coalition memberships," and overseeing public policy and government relations activities. The company discloses that its advocacy activities are led by UHG External Affairs and are subject to oversight by the Executive Vice President of Corporate Affairs and the Public Policy Strategies and Responsibility Committee. However, while these disclosures indicate oversight and review mechanisms, there is limited evidence of specific processes for aligning lobbying activities with climate-related goals. For example, while the company mentions oversight of trade association memberships, it does not provide details on how alignment with climate policies is ensured or monitored. Furthermore, while the company publishes semi-annual political contribution reports and files lobbying disclosure reports, these actions focus on transparency rather than governance of lobbying alignment. The absence of a detailed climate lobbying alignment policy or audit limits the robustness of its governance framework in this area.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	UnitedHealth Group is highly transparent in explaining that it does not participate in climate-related lobbying. The company explicitly states, "No, we have assessed our activities, and none could directly or indirectly influence policy, law, or regulation that may impact the environment," and adds that it "would evolve business strategy as applicable" if climate risks became material. This clear declaration, accompanied by a rationale that its public-policy work is focused on health-care affordability, universal coverage and operational resilience rather than environmental regulation, provides full visibility on the absence of any climate policy engagements. Because the company is equally clear that it therefore deploys no direct or indirect lobbying mechanisms toward climate legislation and seeks no specific environmental policy outcomes, its disclosures meet a high standard of completeness despite the lack of actual lobbying activity.	A