Elevance Health, Inc. (ELV)

Criticisms on file

No material criticisms on file for this pillar.

Disclosed initiatives

• Science Based Targets Initiative (SBTi) Approval

  Near-term target aligned with 1.5°C pathway approved in 2024; includes 46.2% absolute Scope 1 GHG emissions reduction by 2030 from 2019 baseline

  Demonstrates third-party validation of decarbonization pathway; addresses direct operational emissions
• 100% Renewable Electricity Sourcing

  Company sources 100% renewable electricity for operations and commits to continue through 2030

  Eliminates Scope 2 grid-based emissions; recognized by Newsweek as one of World's Greenest Companies (2025) and TIME's Top 20 Sustainable Growth Companies (2026)
• Supplier GHG Engagement

  Targets 75% of suppliers by spend to establish own science-based GHG reduction goals by 2028

  Begins to address Scope 3 supply-chain emissions; timeframe extends to 2028, limiting near-term impact
• Healthcare Decarbonization Research

  Studies environmental exposure impacts on health and healthcare costs (heat, wildfire smoke, chronic kidney disease); sponsored National Academy of Medicine Action Collaborative on Decarbonizing U.S. Health Sector

  Builds evidence base for systemic healthcare sector decarbonization; does not directly reduce company emissions
• Community Resilience Initiatives

  $10 million in grants for 2025 Southern California wildfire response and recovery; associate-led emergency relief efforts

  Supports climate resilience; not operational decarbonization

Criticisms on file

No material criticisms on file for this pillar.

Disclosed initiatives

• Pay Equity Analysis and Remediation

  2025 comprehensive gender and race pay equity review using third-party platform; female associates earn 99+ cents per dollar of similarly-situated male associates; ethnic minority associates earn 99+ cents per dollar of white associates

  Demonstrates commitment to pay fairness; proactive monitoring and annual remediation of disparities
• Enterprise Skills Academy and AI Fluency Certification

  New platform for structured learning; partnership with OpenAI to provide formal AI certifications ranging from foundational (prompt engineering) to advanced AI-enabled work; 85% of associates engaged in meaningful development in 2025

  Upskills workforce for evolving technology landscape; accessible to all associates
• Funded Education Programs

  Associates offered fully-funded associate or bachelor's degree programs

  Removes financial barrier to education; supports long-term career mobility
• Business Resource Groups (BRGs)

  Nine voluntary, associate-led BRGs; over 20% of U.S. workforce participation; open to all associates

  Fosters inclusivity and peer support; recognized for employment of veterans and people with disabilities
• Associate Voice Surveys

  Transitioned from annual engagement survey to shorter surveys throughout year; nearly 9 out of 10 respondents strongly believe work contributes to positive outcomes

  Provides real-time feedback mechanism; demonstrates high engagement and purpose alignment
• Whole Health Approach to Member Services

  Company addresses members' physical, behavioral, and social needs; prior authorization streamlining to improve outcomes and member experience

  Holistic approach to health equity; addresses social determinants of health

Criticisms on file

• Partisan 527 Political Contributions: Shareholder proposal (2026) requested independent study on impact of prohibiting corporate contributions to partisan 527 tax-exempt political groups. Shareholder proponent (Trillium ESG Global Equity Fund) cited company contributions of $1.3M+ to Republican Governors Association and $9M+ total to partisan 527s during 2010-2024 period. Board recommended AGAINST study, asserting robust existing oversight.

  Source: ELV_proxy.txt - Proposal 4, Shareholder Proposal Requesting Independent Study on Impact of Prohibiting Corporate Contributions to Partisan 527 Tax-Exempt Political Groups; Political Accountability report cited by proponent

Disclosed initiatives

• Independent Board Leadership

  Ramiro G. Peru serves as Independent Chair; 11 of 12 directors are independent per NYSE standards

  Strengthens Board independence and accountability; supports objective oversight of management
• Rigorous Board Evaluation and Refreshment

  Annual evaluation facilitated by independent outside party; regular assessment of Board composition against evolving strategy; staggered director tenure (average 8.3 years); new directors added: Steve Collis (pharmaceutical/healthcare background), Amy Schulman (healthcare innovation/governance expertise)

  Ensures Board remains strategically aligned and forward-looking; continuous skills assessment against company needs
• Skills Matrix and Director Qualification Framework

  Governance Committee maintains skills matrix evaluating desired competencies (CEO experience, COO/executive leadership, insurance industry, finance/capital markets, healthcare industry, marketing, technology, regulatory/public policy, governance & sustainability, diversity). Required characteristics include integrity, financial literacy, informed judgment, risk oversight ability, mature confidence, and high performance standards

  Systematic approach to Board composition ensuring comprehensive expertise; supports risk oversight
• Comprehensive Risk Oversight Structure

  Board delegates risk oversight by category to committees: Audit Committee oversees financial, IT, cybersecurity, compliance, privacy, ethics, AI, and operational risks; Governance Committee oversees board processes, corporate governance, ESG/sustainability, and political activities; Finance Committee oversees capital structure, financing, and M&A risks; Compensation Committee oversees compensation-related risks. Enterprise Risk Management (ERM) framework coordinates risk identification and monitoring across organization

  Multi-layered risk oversight; ERM function and Enterprise Risk Council embedded across all organizational layers
• Annual Political Activities Review

  Governance Committee (entirely independent directors) reviews company's core principles for public policy participation, endorses criteria for political contributions, and reviews all political contributions annually. Senior Vice President of Public Affairs reports to Chief Legal Officer with regular updates to Governance Committee

  Board-level oversight of political spending; transparency via annual Political Contributions & Related Activity Report
• Code of Conduct and Ethical Standards

  Code of Conduct for directors, executive officers, and associates; waivers only by Board or independent Board committee; no waivers granted in 2025

  Establishes ethical baseline; demonstrates adherence in 2025
• Shareholder Engagement and Proxy Access

  Active outreach with major shareholders (representing majority of shares) on governance topics; proxy access allows shareholder-nominated director nominees; majority voting for uncontested elections with resignation requirement for directors failing to receive majority

  Responsive governance; strengthens shareholder rights and Board accountability
• BCBSA Compliance and License Agreement Restrictions

  Company holds exclusive/non-exclusive Blue Cross and Blue Shield licenses in geographic territories. License agreements impose operational restrictions, minimum capital/liquidity requirements, and staggered three-class Board election requirement. Violation could result in loss of license and $98.33 per enrollee 'Re-establishment Fee' (approximately $3 billion based on ~34M enrollees as of Dec 31, 2025)

  External regulatory constraint on governance flexibility; substantial financial penalty risk creates Board accountability for compliance