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EthicsIt is the long-standing policy of theCompany to observe all applicablelaws. Even where the law is permissive,the Company shall choose thecourse of the highest integrity. Localcustoms and traditions differ fromplace to place. Honesty and integrity,however, are cornerstones of goodbusiness in any culture. A well-foundedreputation for scrupulous dealings is aninvaluable asset. All directors, officers,and employees must understand thatat Centene, we care how results areobtained, not just that they are obtained.Each director, officer, and employee mustbe honest and forthcoming at all times,even when it is awkward or uncomfortable.“It is the policy of Centene Corporation to conduct itsbusiness affairs in accordance with the standardsand rules of ethical business conduct and to abideby applicable laws, both in letter and spirit. In this,there is no room for compromise.”— Michael F. NeidorffChairman and Chief Executive OfficerBUSINESS ETHICS AND CODE OF CONDUCT11

ANTITRUST & COMPETITIONCompetition: Bringing Out the Best in a CompanyCompetition is valuable because it brings out the best ina person, a company, or an industry. Even when we arecompeting, we hold ourselves to the highest standard ofuncompromising integrity.Antitrust laws cover a broad range of conduct that maybe illegal. In general, antitrust laws prohibit makingagreements or sharing information with competitorsregarding:〉 Competitive bids or quotes〉〉〉 Selling/leasing prices or pricing policies〉 Terms or conditions of sale〉 Credit information〉〉 Marketing strategies〉〉 Market survey information〉 Costs〉 Profits or profit margins12COMPLIANCE IS EVERYONE’S RESPONSIBILITYAs a rule, we never discuss these subjects with a competitor.Always use extreme care when speaking with a competitoror when answering questions from regulatory agencies oroutside attorneys. Because antitrust laws are so complex, youshould consult the Ethics & Compliance Department or LegalAffairs Department in advance of any planned action involvingcommunication with competitors, regulatory agencies, oroutside attorneys.If you are a member of an industry-specific trade associationor attend industry conferences, exercise caution by avoidingany activities prohibited by this Code of Conduct. Prior writtenapproval from the Chairman and CEO must be obtained beforesubmitting any non-public information to a trade association orany of its committees. Furthermore, written approval must alsobe obtained from the Chairman and CEO prior to the Company’sparticipation on standards-setting bodies.Centene is committed to being fair, honest, and accountable.We compete on the basis of our superior offerings, health careservices, and employees. The Company should never competeby using unlawful measures intended to harm another company,force it from a market, or prevent it from entering a market.

AntitrustLOOKS LIKE Two competitive companies conferand agree to set prices that they willcharge customers or pay vendors.In a casual phone conversation,employees from two companiesagree to split customers or a marketterritory: “You stay off of our turf,and we’ll stay off of yours.”During a conference a few weeks ago, I chatted with representativesfrom our competitor. We began to discuss how profits have beenshrinking in the past few years. Now these companies are loweringreimbursement rates. Did I do something wrong?These types of discussions can definitely be problematic. A courtmight conclude that everyone present during the conversation wasengaged in a price fixing scheme. If you ever find yourself presentduring a reimbursement discussion with competitors, immediatelydiscontinue the conversation and make it clear you consider this typeof conversation inappropriate. You should then contact the Ethics &Compliance Department for further guidance.BUSINESS ETHICS AND CODE OF CONDUCT13

Procurement IntegrityCentene maintains its high ethical standards when obtaining new business. Centene complies with all laws and regulations thatapply to the procurement of goods and services. All procurement decisions are based on appropriate criteria.FINANCIAL RECORDS & CONTROLSProtection of Reputation and Financial StrengthCentene is committed to encouraging candidcommunication and transparency by keeping completeand accurate records and implementing appropriatecontrols. This commitment includes general businessand financial records. Accurate documentation shouldalways be a priority. No employee should enter into anytransaction with the understanding that it is anythingother than what is described in the agreement andsupporting documentation.All transactions must be transparent and properlyrecorded. There must be no disbursement or receiptof Company funds outside the Company’s system of14COMPLIANCE IS EVERYONE’S RESPONSIBILITYaccountability. This means there will be no “off books” or“unofficial” funds, payments, or transactions; and all funds,payments, and transactions must be recorded in accordancewith applicable accounting principles (e.g., U.S. GAAP, SpanishGAAP, U.K. GAAP, International Financial Reporting Standards).Our records must be complete and accurate, fully reflectingthe Company’s activities and transactions, including claimpayments, medical billing documentation, expenses, purchases,accounts receivable, and sales. The information derived fromthese records is provided to the Company’s shareholders as wellas governmental agencies; therefore, processes must followapplicable accounting principles and all relevant laws and

regulations. Centene’s reputation for integrity, as well as itsfinancial strength, depends on this.It is difficult to delineate every practice that is or is notpermissible, but certain general guidelines can be set forth.For example, a payment is prohibited if:〉 It is illegal〉 It is inconsistent with Centene’s defined values〉 No record of its disbursement or receipt is enteredinto the accounting records of the Company〉 It is entered into the accounting records of theCompany in a manner which is false or misleadingIntra-company transactions must also comply with thehighest standards of transparency. To ensure this, it is ourpolicy to price all intra-company transactions so they complywith international regulations, U.S. federal and state laws,and contractual obligations. The Company also adheres toall applicable local tax transfer pricing regulations, includingdocumentation and notification requirements. Where anappropriate market price can be determined, intra-companytransactions will be priced at a level consistent with fairmarket value. In the absence of market pricing, chargesfor intra-company transactions will be based on cost andreasonable profit data so as to approximate fair marketvalue. Further, material intra-company transactionsare supported by intra-company agreements, whichamong other things, identify the parties involved in thetransaction and the basis for the pricing. For all intracompany transactions, transfer pricing will be regularlyreviewed (including reviews by independent thirdparties) to ensure compliance with Company policies.Because business records and controls can be complex,you should consult the Ethics & Compliance Departmentor Internal Audit Department when questions arise.BUSINESS ETHICS AND CODE OF CONDUCT15

Improper financial records and poor controlsLOOKS LIKE James, a business analyst,estimates and changes dataon a monthly report to makeperformance appear better.Sally, a senior accountant,does not accrue theappropriate amount forclaims expenses in the rightperiod.Q.A.I have been asked to sign a certification that a report we submit isaccurate. Is this important?Report certifications are very important. Certification demonstratesCentene’s commitment to the integrity, accuracy, and completeness ofinformation contained in reports, serving as an acknowledgment that theinformation submitted has been reviewed and is correct to the certifier’sbest knowledge. You must immediately report discrepancies you are awareof to your people leader, the Ethics & Compliance Department, or theEthics & Compliance Helpline or Inbox.U.S.-based employees may call: 1-800-345-1642 (toll-free, operated byindependent third party) or go to www.centene.ethicspoint.comReports are confidential and may be made anonymouslyRibera Salud employees may e-mail: compliance@riberasalud.esOperose Health employees may e-mail: governance@operosehealth.co.uk16COMPLIANCE IS EVERYONE’S RESPONSIBILITY

FRAUD, WASTE, & ABUSEHonesty is Always Centene’s PolicyHonesty means communicating candidly and truthfully inall of our business relationships and transactions. Whileanyone can make an honest mistake, fraud is different.Fraud is not a mistake. Fraud involves deliberate deception.Fraud is not only unethical, it is also illegal.Examples of fraud include:〉〉 Submitting false expense reports〉 Misappropriating assets or misusing Centene property〉〉〉 Improperly changing Company records orfinancial statementsFRAUD, WASTE, AND ABUSE (FWA) PROGRAM:We have a comprehensive program at the corporateand operating unit level for the prevention, detectionand reporting of fraud and abuse. The FWA Programencompasses industry best practices and processes andimplements them throughout the Company. Centene’sSpecial Investigations Unit (SIU) oversees the FWA program.The FWA Program is designed to prevent and reduce fraud,waste, and abuse among providers, members, patients,employees, and subcontractors. It may also help to preventpotential health risks to members and patients. A toll-freeFraud and Abuse Hotline is available to U.S. employees,members, patients, business partners, and networkproviders: 1-866-685-8664. For more information, see theFraud, Waste, and Abuse policy (CC.COMP.16).BUSINESS ETHICS AND CODE OF CONDUCT17

FraudLOOKS LIKE Michael, a contracting manager,always records a few more hours on histimesheet than he actually worked. Inaddition, when traveling on companybusiness, he takes a free shuttle from theairport to his hotel but includes a 20taxi charge on his expense report.Dr. Jones, who is a primary carephysician, bills a high-level office visit forevery member or patient he sees. He isbilling the same code regardless of themember’s illness.18COMPLIANCE IS EVERYONE’S RESPONSIBILITYQ.A.I noticed some unusual things on a claim submitted by aprovider. The services provided don’t appear to match theprovider’s specialty or the member’s condition. I’m not sureif this provider is committing fraud. Should I report it?Yes, all concerns about potential fraud, waste, and abuseshould be immediately reported to the Special InvestigationsUnit (SIU). The SIU will evaluate the situation and, if needed,request documentation from the provider to supportthe information submitted on the claim. While it mightnot necessarily be fraud, the Company wants to stopany wasteful or abusive billing. In addition, reviewing theappropriate information could also identify issues with thequality of care being provided to our members and patients.

FRAUD, WASTE & ABUSEThe U.S. False Claims ActUnder the U.S. False Claims Act (FCA), any individual or entity thatknowingly keeps an overpayment or submits a false or fraudulentclaim for payment of U.S. Government funds can be held liable forsignificant penalties and fines. The FCA applies to claims by healthcare organizations to Medicaid, Medicare, and other governmentsponsored health care programs. Potential fines for violating the FCAinclude a penalty of: (1) up to three times the amount of the damagessustained by the government for each false claim; (2) additionalcivil penalties for each false claim; and (3) payment of the cost ofthe civil action by the entity or individual that submitted the falseclaims. Criminal penalties may also apply. If found liable under theFCA, the entity or individual may also be excluded or suspended fromparticipating in all federal health care programs.The FCA contains “whistleblower provisions” that allow people withevidence of fraud against the government to sue, on behalf of the U.S.Government, in order to recover the stolen funds. In some cases, theU.S. Government may join the whistleblower suit. If a whistleblowersuit is ultimately successful, the person who initially brought the suitmay be awarded a percentage of the recovered funds.The FCA also contains a provision that protects the whistleblowerfrom retaliation by their employer. This provision applies to anyemployee who is discharged, demoted, suspended, threatened,harassed, or discriminated against as a result of the employee’slawful acts in a whistleblower suit. Centene affords employeesall protections required by the FCA.In addition to the U.S. FCA, a number of U.S. states and othercountries also have false claims legislation with similar penaltiesthat work to discourage fraud perpetrated against localgovernments.NHS COUNTER FRAUD AUTHORITYThe National Health Services (NHS) is a publicly fundedhealthcare system that provides a comprehensive rangeof free services to UK citizens through its collaborationwith providers.The Counter Fraud Authority is charged with preventingfraud and other economic crimes and protecting vitalresources intended for patient care. Fraud within theNHS includes making false representations, failing todisclose information or abuse of position of trust.BUSINESS ETHICS AND CODE OF CONDUCT19

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Potential violations of the U.S. False Claims Act include:〉〉 Double billing - Charging more thanonce for the same goods or services〉〉 Upcoding - Inflating bills by usingdiagnosis codes that suggest amore expensive illness or treatment〉〉〉 Billing for brand-named drugswhen generic drugs are provided〉〉 Billing for procedures or testsnot performed〉 Being overpaid by the governmentfor sale of a good or service, andnot reporting that overpayment〉 Winning a contract throughkickbacks or bribes〉〉 Unbundling - Using multiple billingcodes instead of one billing code inorder to increase reimbursementBUSINESS ETHICS AND CODE OF CONDUCT21

INSIDE INFORMATIONFairness and Honesty in the Investment CommunityCentene is committed to alwaysbeing transparent in how it managesinformation of interest to theinvestment community. Employeeswho have access to confidentialor non-public information are notpermitted to use or share thatinformation for stock trading purposesor other non-business purposes thatmight result in personal financialbenefit or to serve as a “tip” to others.Using inside information in thismanner is unethical, illegal, and couldresult in civil or criminal penalties.It also violates our commitment toacting with the highest standard ofintegrity.“Inside information” is any non-publicinformation that a reasonable investoris likely to consider important inmaking investment decisions.22COMPLIANCE IS EVERYONE’S RESPONSIBILITYExamples of non-public inside information include:〉〉〉〉〉〉〉〉〉Projections of future earnings or lossesNews of a pending merger or acquisitionNews of any significant sale of assets or the disposition of a subsidiaryDeclaration of a stock split or an offering of additional securitiesPlanned changes in senior managementSignificant new productsImpending bankruptcy or financial liquidity problemsThe gain or loss of a significant vendor or customerThe possible awarding or cancellation of a significant contractCentene discloses financially significant information to the public by issuing pressreleases and/or by filing reports with the U.S. Securities and Exchange Commission.Information becomes public once a release appears on a national news wire, or afiling is made, after which the information is posted on Centene’s website atwww.centene.com.Centene’s directors, officers, employees, and their related family members may notbuy or sell Centene securities based on inside information. Once the information hasbeen properly disclosed, directors and certain employees and their closely relatedfamily members must wait two full business days after the announcement before

Misuse of insider informationbuying or selling Centene securities.Centene’s directors, officers, andemployees must not disclose insideinformation to anyone outsidethe Company, provide tips, orrecommend the purchase or sale ofCentene’s securities to anyone if theinformation has not been disclosedpublicly.Although individual businessunits may not be publicly tradedcompanies, all employeesworldwide must comply with theserequirements and any additionallocal directives. Any employee mayhave access to insider information,which if improperly disclosed, willhave legal consequences.For more information, see theInsider Trading policy (CC.COMP.01).LOOKS LIKE Over lunch, Mary, a department manager, learns of a potential acquisitionthat will improve Centene’s market share and future profitability. She returnsto her office and calls her broker to purchase additional Centene stock beforethe acquisition is publicly announced.One week before a public announcement of higher-than-expected profitsby Centene, James, an associate in the marketing and communicationsdepartment who knows of this information, calls his mother and encouragesher to purchase Centene stock.just learned that Centene is considering buying another publicly tradedQ. Icorporation.I want to purchase some stock in the company being acquiredor have my spouse do so. Can I do this?Neither you, your spouse, nor any immediate family member canA. No.purchase this stock until the inside information you have is known to thepublic. If you use this information or convey it to others, you will be violatingCentene policies and U.S. securities laws. You will also be exposing yourselfto termination of employment and possible criminal penalties. If you havequestions about these laws and regulations, contact the Corporate LegalDepartment or the Corporate Ethics & Compliance Department before youmake the trade.BUSINESS ETHICS AND CODE OF CONDUCT23

PROTECTING CONFIDENTIAL INFORMATIONTrade Secrets, Proprietary Information & Other Information AssetsCentene is committed to beingconscientious and accountable whenhandling confidential Companyinformation. Business, health andfinancial information is consideredconfidential and therefore must be:〉 Protected by an effective internalcontrol environment, includingpolicies and procedures to securethe Company’s assets〉24COMPLIANCE IS EVERYONE’S RESPONSIBILITYCertain kinds of business and financial information are crucial to Centene’ssuccess. Knowledge and information of this sort

Dear Employee, Since its foundation in 1984, Centene has built an honorable reputation and an exceptional culture through the hard work and integrity of its employees.