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Medibank Private Ltd

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FY2021 Annual Report · Medibank Private Ltd
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Annual Report 2021

Better health
for better lives

Medibank Private Limited

ABN  47 080 890 259

Contents

About Medibank  
2021 highlights  
Chairman’s message  
CEO’s message  

Our strategy 
Creating value for our stakeholders 
Better for customers 
Better for health 
Better for people and communities 
Our sustainability highlights 

Operating and financial review  

Directors  
Executive leadership team  
Corporate governance statement  
Directors’ report  
  Remuneration report 

Financial report 
  Consolidated statement of comprehensive income  
  Consolidated statement of financial position  
  Consolidated statement of changes in equity  
  Consolidated statement of cash flows  
  Notes to the consolidated financial statements  
  Directors’ declaration  
  Auditor’s independence declaration  

Independent auditor’s report  

Shareholder information  

Financial calendar 

Corporate directory 

1
2
4
5

6
7
8
12
16
20

22

30
33
35
47
50

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76 
77
78
79
80 
121
122 
123

131

133

133

Sustainability Report 2021

Building a
healthier future

This report is part of  
our suite of reporting 
for the 2021 financial 
year. You can find more 
information about our 
performance in our  
Full Year Results  
Investor Presentation  
& Sustainability Report

2021 full year 
results  
Investor presentation

David Koczkar – Chief Executive Officer   

Mark Rogers – Chief Financial Officer

Medibank Private Limited
ABN  47 080 890 259

25 August 2021

Annual Report 2021

Better health
for better lives

Cover – Shelley and family enjoy a day in the park together

Financial calendar

Key dates

Full year results announcement 

25 August 2021

Ex-dividend share trading commences 

8 September 2021

Record date for final dividend 

9 September 2021

Payment date for final dividend 

30 September 2021

Annual general meeting 

18 November 2021

Half year results announcement 

February 2022

Payment date for interim dividend 

March 2022

The above dates and payments are subject to confirmation.

Any change will be notified to the Australian Securities Exchange (ASX).

Corporate directory

Company

Share registry

Medibank Private Limited 

Computershare Investor Services 

Pty Limited 

GPO Box 2975 

Melbourne VIC 3001

Telephone: 

1800 998 778 (within Australia) 

+61 3 9415 4011 (outside Australia) 

132 331 (within Australia) 

computershare.com.au

+61 3 8622 5780 (outside Australia)

Registered Office 

720 Bourke Street 

Docklands Vic 3008

GPO Box 9999 

Melbourne VIC 3001 

Telephone: 

medibank.com.au

Annual Report 2021    133

 
About Medibank

At Medibank, we believe in Better Health 
for Better Lives. For 45 years, we’ve been 
supporting millions of people in Australia  
as one of the leading private health insurers. 
We’re also changing into a health company  
as we provide people with greater support  
to manage their health and wellbeing. 

We’re doing this by offering more choice to  
customers about where they can receive their care, 
more control over what they pay for it and innovating  
to provide greater access to preventative healthcare. 
We’re partnering with leaders in the health sector  
– doctors, hospitals and research institutes – building 
new care options that deliver quality care, and we’re 
helping to reform Australia’s healthcare system so it 
can continue supporting all Australians. We also offer 
other insurance, including travel, pet and life, to make 
things easier for our customers – because everyone 
deserves to live their best quality of life. 

Purpose
Better Health for Better Lives

Vision
Everyone in Australia deserves to live their best quality of life 
– for themselves, their communities and future generations

Focus on our  
customers and people

Strategic pillars

Grow our  core 
business

Transform into a 
health company

Health Insurance

Diversified Insurance

Health Services

Our business

Health, Support, Value

Simple, Easy, Affordable

Travel

Pet

Life

Health and wellbeing 
and preventative programs

Clinical homecare 

Primary care investment and 
health system navigation support

Car and home

Fund short-stay, no-gap programs

Customers First

Show Heart

One Team

Own It, Do It

Values

Annual Report 2021    1 

2021 highlights

Customer

3.7m

total customers 

at 30 June 2021

c. $300m

total COVID financial support  
to date – includes $103 million  
customer give back

82,500  (+4.6%)

reported net resident  
policyholder growth

27.3%

market share 
(up 37 basis points in FY21)  

37.137.1 (+5.3)  Medibank 
43.043.0 (+1.8)  ahm 
customer advocacy  
(average Service NPS) 

c. 760k

interactions with Live Better 
Rewards and Activities 

$5.6b (+2%)

in claims paid 
to customers

Services supported

1.11.1m+m+

25.925.9m+m+ 430430k+k+

hospital admissions

extras services

surgical procedures

Health services
$63m

c. 77,650650 (+32%)  

preventative  
health  
investment

customers used 
Medibank at Home

c.133133k k (+51%) 9595

900900++

customers engaged 
with Member 
Health Services 

Myhealth  
GP clinics

patients used  
My Home Hospital 

since January 2021 launch

All data is presented on a statutory basis

2    Medibank 

 
Our performance

$441.2m (+39.8%)

Group net profit after tax 

6.9

cents  
per share

12.7

cents  
per share

 final ordinary dividend 

 total ordinary dividend

from continuing operations

fully franked

fully franked

$6,680.3m 

Health Insurance  
segment revenue 

$283.8m 

Medibank Health  
segment revenue 

$120.0m 

net investment  
income

Composition of  
2021 segment 
operating profit

94.594.5%  
$538.6m
Health Insurance

5.55.5%  
$31.4m
Medibank Health

  c. $20m

in productivity 
savings

83%

including around

33,866866 11,400400

employee engagement 

employees

health professionals

Headcount at 30 June 2021

Annual Report 2021    3 

 
Chairman’s message

Mike Wilkins  AO 

This year has again been challenging for people, 
with the COVID pandemic continuing to make an 
impact through a wide range of health, economic 
and social factors. I am proud of how Medibank 
and our people have supported our customers, 
community and each other through these uncertain 
times. This demonstrates the strength of the 
Medibank team and their steadfast commitment  
to our Better Health for Better Lives purpose.

During the year we published our first Modern Slavery 
Statement which details our approach to preventing 
modern slavery and human trafficking within 
Medibank’s business operations and supply chain. We 
also shared our progress in supporting greater health 
equity and better health outcomes for Australia’s First 
Peoples. We are taking this momentum and our strong 
partnerships with Aboriginal and Torres Strait Islander 
communities to inform the development of Medibank’s 
5th Reconciliation Action Plan.

With this purpose driving our actions and decisions, 
Medibank saw above market policyholder growth, 
achieved record customer advocacy and maintained 
strong employee engagement. We also made progress 
in driving broader health system change to support its 
sustainability for the future. This focus helped us deliver 
a net profit after tax of $441.2 million for the 2021 
financial year. The Board has determined a final ordinary 
dividend of 6.9 cents per share, bringing the total fully 
franked dividend for the year to 12.7 cents per share. 
Our capital position remains strong, with the Board 
maintaining a prudent approach to capital management.

At Medibank we believe that delivering on our 
business goals and contributing in a positive way to 
society do not need to be mutually exclusive. We’ve 
demonstrated this through the record level of financial 
support for customers in response to COVID, through 
the leadership we have shown in getting behind the 
nation’s vaccination drive, and through the ways we 
seek to address the sustainability issues we can 
impact that are most important to our customers, 
people and community. 

We listen to a diverse range of voices to guide our 
actions in areas such as the environment, modern 
slavery, and diversity and inclusion. This year we 
undertook our first climate scenario analysis to 
understand the risks and opportunities of climate 
change. On top of our ongoing commitment to carbon 
neutrality within our operations, we are now working 
towards Net Zero by 2050, setting short, medium 
and long-term science-based targets to reduce our 
environmental footprint.

We also recognise the vital role that carers play in 
providing unpaid support for family and friends who 
are aged or living with an illness or disability. With a 
significant number of our people providing such care 
in the community, we are developing a comprehensive 
support package to help them balance their work and 
caring commitments.

What we have achieved this year is not only the result 
of staying true to our purpose, but is also due to the 
efforts of our leadership team and our people. Our 
leadership team changed this year, with David Koczkar 
appointed as Chief Executive Officer in May, following 
the retirement of Craig Drummond. On behalf of 
the Board, I’d like to thank Craig for his outstanding 
contribution during his five years at the helm. The 
Board and I look forward to working with David as 
he and the leadership team take Medibank on the 
next stage of its journey. I also want to acknowledge 
former Chairman Elizabeth Alexander who retired 
from the Board in October 2020. Elizabeth has been 
instrumental in making Medibank the company it is 
today and it is a privilege to succeed her as Chair.

While some of the uncertainty of the past year is set 
to continue for a time, I am pleased that Medibank’s 
ongoing transformation to a health company positions 
us strongly to deliver for our customers, our community 
and our shareholders. To my Board colleagues, the 
Executive Leadership Team and everyone at Medibank, 
thank you all for making this possible. And to our 
shareholders, thank you for your continued support  
of our company this year and into the future.

4    Medibank 

CEO’s message

David Koczkar

For many of us, the 2021 financial year has not 
been the year we anticipated, with COVID defying 
expectations and with restrictions and lockdowns 
continuing. Yet despite this, our team has risen 
above the challenges of the past 12 months 
to continue to deliver for our customers, our 
community, and you – our shareholders.

We grew more in the past 12 months than we have 
in over 10 years, our Medibank and ahm brands 
both achieved their highest ever levels of customer 
advocacy and we saw customers engaging with our 
broader health offerings in record numbers. We were 
disciplined in how we ran our business, continuing to 
manage our costs.  

We saw more and more people continuing to prioritise 
their health and wellbeing and see more value in private 
health, given the uncertainty around COVID and heightened 
pressure on the public health system. Our investments 
over the last few years have enabled us to step up and 
provide broader support to our customers during this 
period, while accelerating our growth at the same time.

Our COVID financial support package for customers 
is the largest in our 45 year history. To date we’ve 
provided around $300 million, including $103 million in 
COVID permanent net claims savings we are currently 
returning through premium relief. We stand by our 
commitment not to profit from COVID and will continue 
to return any related permanent net claims savings to 
our customers. We're also supporting the government’s 
80% vaccination target, working towards this with our 
employees and rewarding eligible customers who are 
fully vaccinated with 1,000 Live Better points.

This year we evolved our strategy to reflect our ongoing 
transformation to a health company and prioritised 
our efforts to more broadly support the health of our 
customers, while growing our business and driving 
broader system change.

We worked hard to give our customers more value 
from our products and services, investing in technology 
to simplify and personalise our customers’ experience.  

We delivered our lowest average premium increase 
in 20 years and helped customers save more than 
$20.5 million in out-of-pocket costs through our 
Members’ Choice Advantage network. 

Our customers are trusting us to help them with their 
broader health needs – whether it be through enrolling 
in our preventative health programs, participating in 
our health and wellbeing activities or accessing our 
in-home care or telehealth services. 

We partnered with doctors, hospitals and governments 
to develop new models of care that offer people greater 
choice about where to receive their care and how 
much they pay for it; such as the short-stay, no-gap 
program which expanded to seven hospitals this year. 
We continued to advocate for the changes needed 
to ensure the sustainability of our health system – 
reforms to improve choice, value and patient outcomes.  

At the heart of each of these achievements is the 
incredible team of people we have at Medibank, who 
once again have proved themselves to be adaptable, 
resilient and committed to our purpose of Better 
Health for Better Lives. This purpose has also seen 
us evolve our environmental, social and governance 
responsibilities, as we continued working to become a 
more sustainable business. We introduced new ways 
of working that have helped us to collaborate more 
effectively, but it is the way that our people have looked 
out for each other – the support that is integral to our 
culture – that has helped us through this year.

This is my first year as CEO and I am indebted to 
the many people who have supported me in my first 
few months including Mike Wilkins and the Board. 
In particular, I want to recognise former CEO Craig 
Drummond who has been essential to our company’s 
transformation over the past five years. 

Thank you for supporting us. I believe we have an 
exciting future ahead as we continue to grow and 
broaden our business and transition into a health 
company, committed to helping more people in 
Australia access the care they need and supporting 
them on their health journey. 

Annual Report 2021    5 

Our strategy

As we continue changing into a health 
company, we’ve refined our strategy  
to better reflect our approach to  
helping our customers manage their  
health and wellbeing. 

It prioritises the work we are doing to provide 
customers and patients with greater choice,  
support and value. It acknowledges the importance  
of empowering our people to deliver improved 
customer experiences. And it marks our shift to 
preventative health and innovative approaches to 
patient-centred care, highlighting our role to help 
transform and sustain health in Australia. It is  
by succeeding in these areas that we will grow  
the business and help people in Australia to have  
Better Health for Better Lives.

Building a strong and connected business to drive  broader 
system change and sustainability 

Focus on our  
customers and people

Grow our  core 
business 

Transform into a 
health company

Deliver leading 
 customer experiences

Further differentiate 
 our customer offerings 

Empower our people

Deliver more value

Be a partner of choice

Maintain cost discipline 

Invest in prevention, 
choice and better care

Build successful   
standalone businesses

Bring benefits back   
to our core business

Better Health for Better Lives

6    Medibank 

Creating value for our stakeholders 

We’re focused on creating sustainable long-term value for our customers, 
our people, our shareholders and the broader community.

Customers  

Employees  

We’re supporting our customers to 
manage their health and wellbeing. 
We’re delivering affordable healthcare, 
providing more choice in where people 
can receive their care and investing in 
preventative healthcare. 

We’re helping customers better 
navigate the health system and make 
more informed healthcare choices.

We’re building an employee  
experience that ensures our people 
can be at their best, challenge and 
improve how things are done and  
feel more empowered. 

We’re enabling them to enhance their 
knowledge and skills and supporting 
them to reach their health and 
wellbeing goals. 

GOALS

WORK

LIFE

Shareholders  

Community  

We’re committed to delivering 
sustainable shareholder returns in a 
way that also meets the expectations  
of our customers and the community.

We’re delivering this through our 
purpose-led culture supported by  
a focus on performance, sustainability, 
governance and risk management. 

We’re targeting some of Australia’s 
biggest health issues, prioritising 
mental health support and preventative 
health, and providing access to health 
and wellbeing activities. 

We’re also working to help close  
the gap that exists for First Nations 
people and playing our part in tackling 
the impact of climate change on 
human health.  

CO2

Government 

Health system 

We’re working with government to 
support Australia’s world-class dual 
public private health system and 
ensure its ongoing sustainability  
for future generations. 

We’re also advocating for our 
customers, contributing to public 
policy and helping deliver reform.   

We’re working to reshape Australia’s 
health system, partnering with 
hospitals and doctors on innovative 
ways of providing healthcare in the 
home and community, targeting 
chronic disease with prevention 
programs and sharing information  
with hospitals to help them improve 
patient experiences. 

Annual Report 2021    7 

 
 
 
 
 
c. 760k

interactions with  
Live Better Rewards  
and Activities 

Better for customers

Through our Live Better program, we’re 
encouraging people to make better 
health choices every day; rewarding 
eligible customers for healthy actions 
through our Live Better Rewards app, 
supporting community events and 
sharing online content. 

This year, we integrated Live Better Rewards 
into our My Medibank app. Customers can now 
join the program, find and earn points at their 
nearest Members’ Choice Advantage providers, 
be rewarded for a weekly step goal and view 
their points and rewards all within the one 
app. Rewards can be redeemed for savings on 
health cover or boosts to extras, alongside other 
rewards. We had around 760,000 interactions 
with our Live Better program, either through 
people joining our rewards program or taking 
part in activities, and there is so much more 
ahead as we continue personalising the app 
experience and expanding our partnerships to 
provide greater health and wellbeing support. 

8    Medibank 

Better for customers

$$5.65.6bb  

in claims paid 
to customers

3.7m 

customers

at 30 June 2021

37.1 (+5.3)  Medibank 
43.0 (+1.8)  ahm 
customer advocacy 
(average Service NPS)

c. $$300300mm

total COVID financial support  
to date – includes $103 million  
customer give back

There are reasons we grew more over the  
past 12 months than we have in over 10 years. 
We listened to our customers and worked  
hard to do things better, improving our services 
and delivering greater value for both new  
and existing customers. 

With Medibank offering more health and 
wellbeing support for customers and 
ahm building upon its premise of simple, 
straightforward and affordable health insurance, 
our dual brands are giving people in Australia 
real choice. Together they have grown our 
market share to 27.3%. 

We’ve paid $5.6 billion in claims this year.  
We’re also returning $103 million in COVID 
permanent net claims savings to our customers 
through premium relief, in recognition of the 
impact COVID restrictions had on people’s  
ability to use their health insurance. We’ve  
now provided around $300 million in COVID 
customer support since March last year and  
we will continue to assess known claims  
savings and return any COVID related permanent 
net claims savings back to our customers 
through additional support in the future. 

Stronger relationships,  
simplified services

We’re working to better support our customers, 
investing in our digital capabilities so we can 
provide a more personalised experience, tailored 
to their individual healthcare needs. We’re 
spending more time talking with our customers 
about their health, connecting them to relevant 
prevention programs or general health support. 
We checked in with almost 540,000 customers 
to ensure they were on the cover best suited to 
their needs. And we provided more support to 
those who needed hospital treatment, assisting 
20% of these customers through our Health 
Concierge program this year.   

We have big digital ambitions and this year 
delivered a more seamless digital experience, 
putting tools and information into our 
customers’ hands so they could make more 
informed decisions about their healthcare. 

Annual Report 2021    9 

c. 1.31.3mm

Medibank customers  
registered for a  
digital account

20%

of customers going  
to hospital supported  
through Health Concierge

c. 540540,000000

customer check-ins 

We upgraded our My Medibank app making it 
easier for customers to manage their cover, 
book and claim for more services, access our 
Live Better Rewards program and get health 
information – all from the palm of their hand.  
We were among the first health insurers 
worldwide to launch a digital membership  
card in Apple Wallet so customers could claim 
on-the-spot through HICAPS terminals at  
20,000 healthcare practices nationwide, 
without having to carry their membership card; 
complementing our Android phone offering. 
We enhanced self-service options and digital 
support tools, with online chat and messaging 
options. And we’ve seen our customers respond 
positively to these changes with around  
1.3 million Medibank and ahm customers 
registered for a digital account.  

We gave our people more autonomy and 
greater accountability to improve our customer 
experience, changing the way our people worked 
and improving the systems they used. We were 
able to quickly manage retail shutdowns due to 
COVID restrictions, moving retail team members 
to supporting customers through our phone and 
digital channels. We launched a new program 
to make it easier for our customer team to tell 
us what needed fixing, and then we fixed the 
issues that they raised. While there’s more to be 
done, we're pleased our customer advocacy is at 
record levels, and for the fifth year running, our 
share of industry complaints is well below our 
market share. And for the second year running, 
ahm was named Major Private Health Insurer 
of the Year as part of the Roy Morgan Customer 
Satisfaction Awards.

#jabdone

Paid community 
leave and charity gift 
voucher donations  
to support employees 
to get COVID 
vaccinations 

10    Medibank 

We improved the claims and payments 
experience for the thousands of healthcare 
providers that we work with. Through our 
payment integrity program, we’re working 
to ensure we pay all customer and provider 
claims correctly, implementing a new case 
management approach this year. We’re 
now developing a new self-service portal 
for providers to make it easier to exchange 
information and resolve any incorrect  
payments quickly.

Providing greater value

We delivered our lowest average health 
insurance premium increase in 20 years, 
after postponing increases for six months 
earlier in 2020 as part of our COVID support 
package. We built stronger partnerships with 
organisations like Amcal and Velocity, along 
with hospitals, health professionals, corporates 
and university partners to provide greater value 
for our customers. We also added to our range 
of life, pet and travel insurance options, with 
ahm introducing car and home insurance this 
year. Through our productivity program we’ve 
delivered around $20 million in cost savings  
this year and remain committed to managing  
our own costs, targeting a further $40 million  
in savings over the next three years.  

1.81.8mm
  customers are using Members’ Choice Advantage 
  which has delivered c. $20.5m in out-of-pocket savings

c. $$2020mm  

in productivity savings

Annual Report 2021    11 

900900++

patients used My Home Hospital 

since January 2021 launch

Better for health

My Home Hospital is a window into the 
future of healthcare. It’s delivering 
hospital-level care to patients in 
the comfort of their own home, by 
bringing together innovative remote 
monitoring technologies and a team 
of in-home care professionals. 

A Wellbeing SA service delivered by a joint venture 
between Calvary and Medibank, it has now treated 
more than 900 public patients in Adelaide and 
Gawler for a range of conditions such as infections 
requiring IV antibiotics, deep vein thrombosis, post-
operative care and supportive cancer treatment, 
delivering positive patient experiences. 

It illustrates our approach to improving the 
experience and the affordability of the care 
people receive when they enter the private and 
public health systems. We’re collaborating with 
governments, doctors and hospitals and harnessing 
new technologies and innovations to build a new 
style of care centred around the needs of patients. 
We’re connecting our customers with more 
treatment options and focussing on preventative 
health opportunities. And in doing so, we’re helping 
to change healthcare for the better in Australia.

12    Medibank 

Better for health

c. 77,650650
(+32%)  

customers used 
Medibank at Home

347347  

virtual 
hospital 
beds

c. 2.52.5mm  

contacts supported  
by our telehealth 
services

Annual Report 2021    13 

More choice in affordable care

Healthcare where you want it

We’re supporting doctors and hospitals to offer 
patients a short-stay experience which allows 
people to recuperate at home with support 
from a multi-disciplinary care team, reducing 
time spent in hospital – with no medical out-of-
pocket costs for our customers. This doctor-led 
approach has seen patients in our no-gap joint 
replacement program save more than $1,500 
in out-of-pocket costs on average and is now 
being offered by hospitals in Melbourne, Sydney, 
Brisbane, Adelaide, Canberra and Perth. 

We also announced a joint venture with 45 
specialist doctors and surgeons to build a new 
private hospital in Melbourne that will expand 
the short-stay, no-gap model to additional 
surgical procedures. The 30-bed hospital 
will offer services in orthopaedics, ENT, 
vascular, plastics, urology, general surgery, 
gastroenterology, anaesthetics, oncology, 
and radiology when it opens in 2023. We’re 
investing in this approach so we can provide 
our customers with greater choice and control 
when it comes to how and where they access 
healthcare and what it will cost.

Our Homecare business has continued to  
grow, with more than 20,000 customers having 
now received support from our Medibank at 
Home program since launch. COVID continued to 
drive demand, particularly for our Chemotherapy 
at Home and Dialysis at Home programs, and 
our Rehab at Home program is available to 
eligible customers across the country.  

Telehealth has kept up its momentum from last 
year. Not only is it proving popular with younger 
people, but it’s improving healthcare accessibility 
for rural and regional customers. We’ve made a 
major investment in upgrading the technology 
platforms we use to provide telehealth services 
so we can expand our support across digital 
channels, including video and online chat. 

We managed around 2.5 million phone and 
digital contacts this year. In addition to our 24/7 
general health and mental health services for 
our customers, we delivered telehealth services 
for 1800RESPECT, Beyond Blue, Victoria’s Nurse 
on Call, and the NSW Mental Health Line. We 
also supported the COVID health response with 
helplines, contact tracing services, welfare 
checks and mental health counselling.  

No-gap joint replacement program

$$11,500500++  

average out-of-pockets  
saved by customers

44  

average nights  
in hospital saved  

77,000000++  

customers enrolled  
in preventative  
health programs
in FY21

 1,385 kg

weight lost by 
customers

Getting in early  
– preventative health

Based on Australian public health data, around 
3.3 million Medibank and ahm customers 
are likely to have some health risk. We know 
they want support to improve their health 
and wellbeing, which is why we’re focused on 
preventative care and embedding more health 
expertise across our customer-facing teams.  

Since 2015, we’ve supported more than 40,000 
customers through nine preventative health 
programs. This year our Better Knee, Better 
Me program became a permanent program 
after a successful trial partnership with the 
University of Melbourne, which saw participants 
losing 10.6 kgs on average. We launched our 
Healthier Weight, Healthier Me: Type 2 Diabetes 
pilot to examine whether type 2 diabetes can be 
better managed through a personalised weight 
loss and exercise program; and saw referrals 
increase to Heart Health at Home, with 31% of 
participants from regional and remote areas.  

c.133133k k  (+51%)  

customers engaged with  
Member Health Services 

Almost  88kk  

people got their  
blood pressure checked

14    Medibank 

We’re now integrating preventative health 
activities into our Live Better Rewards app  
and for the first time took a challenge to 
customers, rewarding them for getting  
their blood pressure checked. 

Our ahm business is reimagining what a 
simplified approach to health support for 
customers can look like, this year experimenting 
with ways to engage new customers in managing 
their health and wellbeing, launching a program 
offering lower priced access to health and 
lifestyle services. We’re also working with 
some of our corporate customers to develop 
customised health support programs to  
address the specific needs of their employees. 

We’re serious about our commitment in 
preventative healthcare, which is why we 
invested in the Myhealth Medical Group this  
year. This national group of GP clinics already 
has a strong focus on prevention and the 
wellbeing of patients, and our goal is to help 
accelerate the business, supporting their  
vision for a future of general practice that  
better addresses the needs of Australia in  
2021 and beyond.  

Driving system reform

We know the challenges our health system 
faces – an ageing population, increasing 
chronic disease, rising demand for mental 
health support and private health insurance 
affordability concerns. We believe we have 
a critical role to play in driving change in 
Australia’s healthcare system to help address 
these issues. It’s why we’re transforming into 
a health company. We’re working to influence 
change by engaging with governments and the 
sector on system reform. 

We’ve continued pursuing prostheses pricing 
reform. As one of the largest drivers of health 
insurance premium increases, reforms could 
deliver up to $500 million in value back to 
customers. We welcomed this year’s Federal 
Budget announcement of potentially significant 
changes to lower the costs of these medical 
devices. We expect to see the impact of these 
changes flow through over the next four years 
and remain committed to returning prostheses 
reform savings to our customers through lower 
premium increases.

We’re actively engaging with the Federal 
Government on reforms to private health 
insurance designed to improve affordability  
and value – supporting proposed changes  
like the expansion of home and community-
based rehabilitation and mental health care,  

and increasing the age of dependents to 
encourage younger people and people with a 
disability to maintain private health insurance.  

As the longer-term impacts of the ongoing 
COVID pandemic are felt with already long 
elective surgery wait times extending even 
further in the public system, more can and 
should be done to improve healthcare delivery 
and affordability. Encouraging more care in 
homes and community settings especially for 
those with chronic conditions, and accelerating 
value-based funding to deliver better health 
outcomes for patients can help achieve 
meaningful industry change. As will incentivising 
employers to fund private healthcare for their 
employees and promoting greater cost and 
quality transparency in the health system.

While we advocate on behalf of our millions of 
customers, we do so knowing these reforms will 
positively impact all Australians. Our healthcare 
system is built upon the public and private systems 
working together. It’s in everyone’s interests to 
ensure both sides are strengthened to support 
our healthcare needs now and in the future. 

Challenges facing 
our health system

Getting older  
Chronic disease 
Mental health 
Affordability

Prostheses costs are around

3030% higher

than in NZ, France  
or the UK

Private Healthcare Australia

Annual Report 2021    15 

 83%

employee 
engagement

Better for people
and communities

Last year when the COVID outbreak 
started, Mike and partner Colin realised 
it was the right time for their family  
to pack up and make a tree change. 
Together with 8-year-old daughter 
Maple and 18-year-old son Jack, they 
moved from the hustle and bustle of 
Sydney’s inner west to a small farm  
on the South Coast of NSW, closer  
to Mike’s parents, sister and brother.

Instead of tackling a 40 minute commute into 
the office, Mike helps with homework, school 
drop-off and pick-ups, as well as spending time 
outdoors landscaping and attending to the farm. 
Mike has enjoyed a better work/life balance 
since the move and is even more productive.  
He makes time to build strong connections 
with his team with daily calls to touch base and 
check-in, balancing screen time with walking 
meetings and organising face-to-face time 
together outside of the office.

Our pursuit of health and wellbeing is at the 
heart of our business. We know when our  
people feel good, they do their best work for  
our customers and community. Our world  
has changed and so has the way we work  
and connect with our community. 

16    Medibank 

and communities

5151% 

Group and 
senior  
executives  
are women 

4444% 

of Board 
(including CEO) 
are women 

6464% 

employees 
worked flexibly 

++2626

employee 
advocacy

0.00.0%

gender  
pay gap

33 Aboriginal and 

Torres Strait Islander 
employees 

We’re strengthening our focus around our 
purpose, people and performance, to ensure our 
people can be at their best, challenge and improve 
how things are done and feel more empowered. 
Our latest employee engagement survey shows 
our people are engaged, inspired by our vision 
and purpose and are optimistic about our future. 

An employee experience fit  
for the future

We’re building an employee experience that is 
best in class. We’re focussing on how we better 
connect and collaborate across the business, 
embedding our new Future Fit way of working 
that draws upon the lessons learnt in 2020 and 
the success of our progressive support of flexible 
working. We continued to prioritise our people’s 
health and wellbeing, with many of our initiatives 
focused on mental health support and staying 
connected to one another.  

We moved our learning and development 
programs to a virtual model, which opened up 
programs to people regardless of role or location. 

Our Customer Obsessed program, which 
connects employees to our customers so they 
can better understand their needs, also took a 
more digital focus due to COVID this year. Instead 
of the usual range of activities that employees, 
including Board members undertake, we utilised 
calls and immersion sessions as face-to-face 
opportunities were restricted. 

We’re a diverse and inclusive business with a 
team that reflects the customers and community 
we support. We are a leading voice on gender 
equality, and keeping ourselves accountable by 
setting targets on pay equity and representation. 
44% of our Board and more than half of our 
Group and senior executives are women. We’ve 
been working towards increasing the number of  
First Nations people in our business and now 
have 33 Aboriginal and Torres Strait Islander 
team members. We’re also working to develop  
a package to help a group of employees we  
know need more support – those caring for 
elderly parents or a family member with a 
disability or chronic condition – a responsibility 
held by 17% of our team members.

Our cultural pillars

Feel good
We know that fulfilling our 
purpose starts with our 
people. We are dedicated to 
their health and wellbeing; 
that they feel heard and 
valued for who they are.

Impact bigger
We create a culture that is 
rewarding and challenging so 
that our people are inspired 
to do meaningful work that 
makes a real difference to our 
customers and communities.

Step in step up
We innovate to find better ways of 
working for our people so they feel 
empowered to be at their best.  
We are committed to strengthening 
our performance edge in striving  
to deliver our purpose.

Annual Report 2021    17 

Building healthier communities

A big part of bringing our purpose to life is 
helping all Australians feel healthy, both 
physically and mentally. Through our support of 
community partners and events and investment 
in research, we’re targeting some of the most 
prominent health issues facing Australians so 
we can make a bigger impact. 

Mental health doesn’t discriminate. It continues 
to impact millions of Australians every day. 
In response, we’re providing support through 
accessible channels, using the knowledge and 
expertise we’ve developed through our delivery 
of telehealth counselling, including Beyond Blue, 
the NSW Mental Health Line and 1800RESPECT. 
We launched an online mental health portal with 
information and resources connecting people to 
support services and integrated Smiling Mind 
into our Live Better app. We created tailored 
support programs, including a workplace 
resilience program for corporate partners  
and a wellbeing initiative for international 
high school students in partnership with 
DE International (which is part of the NSW 
Department of Education), and continue to 
develop our plan to help address loneliness. 
Employee volunteering 2.3%

We’re using our voice to call out issues of 
domestic, family and sexual violence. We’ve  
been delivering 1800RESPECT for more than  
10 years and this year we launched our Disability 
Pathways Project to improve the support we 
provide people with disability experiencing 
violence. We’re now exploring how to play a 
bigger role with employees who use domestic 
and family violence against others, developing  
a sensitive response that prioritises the safety  
of the person experiencing the violence.

We released our fourth Reconciliation Action 
Plan progress report detailing our work to help 
achieve equity in health and wellbeing outcomes 
for Aboriginal and Torres Strait Islander people. 
This year marks a decade of our relationship 
with the Wadeye Indigenous community and we 
got behind the Thamarrurr Youth Indigenous 
Corporation’s 6,000km bike ride to spread 
health and wellbeing messages to Indigenous 
communities. We also worked to support our 
health services teams and others to provide 
culturally safe care, in partnership with the 
Australian Indigenous Doctors’ Association.  
64% of our employees participated in our 
Cultural Awareness program, with the online 
training module developed as part of the 
Climate 3.3%
program, the most popular course of FY21. 

286286k+k+   

1800RESPECT  
phone and web  
chats answered 

6464% 

of employees 
participated in our 
Cultural Awareness 
program 

Mental health 5.8%

Indigenous 
health equity
6.5%

Health & medical
research/training

36.1%

Climate 3.3%

Mental health 5.8%

Indigenous 
health equity
6.5%

Health & medical
research/training

36.1%

$$1.11.1mm

 invested in 11 research projects 
with 35 organisations

Workplace giving 2.2%
Community 
investment
Community health 
sponsorships 
19.6%

Employee volunteering 2.3%

Workplace giving 2.2%

Loneliness 14.8%

Community health 
sponsorships 
19.6%

Community donations
9.4%

Loneliness 14.8%

Community donations
9.4%

18    Medibank 

Through our Medibank Better Health 
Foundation, we collaborated with world-class 
research teams and university partners on 
research projects to improve the quality of life 
and health outcomes for people in Australia. 
New projects this year include working with 
La Trobe University and the AFLW on ways to 
reduce serious knee injuries among female  
AFL players and exploring the relationship 
between out-of-pocket costs and healthcare 
outcomes, affordability and experience, in 
partnership with Macquarie University.  

With COVID impacting many of the community-
based events we support, we looked to online 
channels to provide health and wellbeing 
activities to inspire and engage all Australians. 
We created our Live Better at Home program  
in response to the first COVID restrictions, but 
over the past year we’ve used the program 
to deliver live interactive events through 
social channels, including our Heavy Metal 
Mindfulness, Sleep Better Live with Michael 
Mosley and the World’s Fittest Dance Move 
with Sydney Dance Company. We continued to 
support our community partners even when 
events couldn’t occur, and were then raring  
to go when parkrun and Feel Good events 
resumed around the country. 

Carbon neutral 
certified under the 
Australian Government’s 
Climate Active program

Sustainable business practices

We choose to partner with suppliers and 
organisations that share our approach to  
ethical conduct, environmental performance  
and diversity and inclusion. We published 
our first Modern Slavery Statement in 2020, 
highlighting our work to address modern 
slavery and human trafficking in our business 
operations and supply chain. We also launched 
a new employee training program focused 
on sustainability when purchasing goods and 
services, and continued our partnerships 
with Supply Nation and Indigenous Defence 
and Infrastructure Consortium (iDiC) to help 
grow our Aboriginal and Torres Strait Islander 
procurement opportunities. 

We believe the environment plays a vital role 
in the health and wellbeing of our people, our 
customers and our community and we recognise 
the science of climate change. We remain 
committed to being environmentally responsible, 
working to minimise our impact, maintain our 
carbon neutral status and positively influence 
our employees’ behaviour. To better understand 
the risks and opportunities that climate change 
presents, we conducted our first climate scenario 
analysis as part of our alignment to the Task 
Force on Climate-related Financial Disclosures 
(TCFD) recommendations. We’re now working 
to enhance our reporting and analysis and over 
the next 12 months will be setting science-based 
short, medium and long-term targets for our 
business, as we work towards Net Zero by 2050. 

Learn more about our progress on TCFD  
and our journey towards sustainability in  
our Sustainability Report 2021

100100k+k+ 

   people engaged 
with Smiling Mind's 
Families program

Annual Report 2021    19 

Our sustainability highlights

Ensure healthy lives  
and promote wellbeing  
for all ages

Material topics
–  Affordable healthcare 
–  Trusted healthcare, customer-
centred products and services

–   Healthcare innovation, 

personalisation and choice 

–  Healthy and engaged  

communities

–  Supporting mental health 

FY21 highlights

Provided c. $300m COVID financial support  
for customers including returning $103m 
in COVID permanent net claims savings to 
customers through premium relief

c. 760k Live Better Rewards and Activities 
interactions 

Lowest average premium increase in 20 years

Extended the short-stay, no-gap model  
of care to 7 hospitals across the country

Launched Healthy Mind website to connect  
people to mental health information and support

Partnered with 45 doctors to develop a  
new private hospital in Melbourne to  
extend short-stay, no-gap procedures

c. 7,650 customers used Medibank at Home

Invested $63m in Myhealth medical group  
of GP clinics

Managed c. 2.5m telephone and digital  
health interactions  

Supported 20% of customers going to  
hospital through Health Concierge

133k+ customers engaged with a  
Member Health Service (+51% on FY20)

370,197 COVID-related telehealth interactions

100k+ people utilised the Smiling Mind  
Families program

Targets / next steps 
Engage around 480k customers in  
our Live Better Rewards and Activities,  
preventative health programs and any  
new care offerings developed

Expand support for the no-gap surgery program  
to new surgery types and new locations

Deliver our telehealth services through  
more digital channels and our customer  
apps and integrate them with other health  
services like primary care

Build new health and wellbeing offering  
for the next generation of health consumers

Achieve gender equality  
and empower all  
women and girls

Material topic
–  Diverse and inclusive workforce 

Women represent 51% of Group and  
senior leaders and 44% of our Board 

0.0% gender pay gap 

27% of parental leave taken by men

More than 70% of STEM roles  
in Medibank are held by women

Employer of choice by WGEA, 6th year in a row 

Recognised in the top 3 Best Australian 
Workplaces for New Dads

Targets / next steps 
Ensure at least 40% of senior leaders  
and Board members are women 

Maintain at least 40% women across  
our manager workforce

Improve the representation of men in our  
non-manager workforce  

Review the gender pay gap annually to ensure  
it is no greater that 1%

Deliver online domestic and family violence 
training for our people and corporate partners

83% employee engagement

Targets / next steps 

64% of employees worked flexibly

25% increase in employees attending 
personal development courses 

Published 1st Modern Slavery Statement

Paid community leave and charity gift 
voucher donations to support employees 
to get COVID vaccinations

Launched our Carers Support Network

Employee advocacy benchmark 
+24 place to work  
+19 products and services
Deliver $15m in productivity savings in FY22 

Expand our preventative healthcare programs  
to employees

Provide a market leading comprehensive and 
targeted support carers package to improve 
the engagement of employees with caring 
responsibility for elderly parents, or a person  
with a disability or chronic condition

Promote sustained, inclusive  
and sustainable growth, full  
and productive employment  
and decent work for all

Material topics
–  Sustainable supply chains 
–  Engaged purpose-led culture,  

attract and retain talent 
–  Healthy and safe workers 
–  Privacy and data security
–  Corporate governance

20    Medibank 

 
FY21 highlights

Increased to 33 the number of employees who 
identify as Aboriginal and Torres Strait Islander,  
1% of all Medibank employees

64% of employees participated 
in Cultural Awareness program 

Launched our Aboriginal Employee Network

Published our interim RAP report 

10 years partnering with the Wadeye 
community in the NT

Made 1800RESPECT information  
available in 37 languages

Improved access to 1800RESPECT  
for people with a disability

Ranked joint 2nd on the Australian Network  
on Disability Access and Inclusion index

Targets / next steps 
Deliver our 5th Reconciliation  Action Plan

Cultivate a disability confident culture  
leading to an increase in the representation  
and improved self-reported engagement  
of employees with a disability
Develop our 2nd Accessibility and Inclusion Plan

Reduce inequality within  
and among countries

Material topics
–     Indigenous engagement
–  Disability access  
and inclusion 

Take urgent action to combat 
climate change and its impacts

Material topics
–     Address climate change 
through environmental 
sustainability 

1st climate scenario analysis

Maintained our carbon neutral status  
for our scope 1, 2 and 3 emissions

Launched sustainable procurement  
training module

$24.5m invested in green bonds

Launched 1st environmental Live Better 
Rewards challenge for customers 

Targets / next steps 

Set short, medium and long-term  
science-based targets

Establish Net Zero targets and pathways

Maintain carbon neutral status  
for our scope 1, 2 and 3 emissions

Ongoing commitment to low carbon domestic 
and international equity investments

Embed environmental sustainability into  
plans for our new Melbourne workspace

Strengthen the means of 
implementation and revitalise 
the global partnership for  
sustainable development

Material topics
–     Contribute to public policy
–     Ethical business

$1.1m invested in 11 health research projects  
with 35 organisations

Advocated for healthcare system reform 

Partnered with University of Melbourne 
to research impact of out-of-pocket cost 
transparency on patients and doctors

5 years of partnering with the Grattan Institute

Worked with La Trobe University and the  
AFLW to help reduce knee injury among  
female footballers

Supported the Continuity of Care Collaboration 
#dontwaitmate campaign

Community partnerships 
•  parkrun Australia
•  Smiling Mind 
•  Feel Good Program, Brisbane
•  Dr Michael Mosley and The Fast 800 Program 
•  Beyond Blue

Aboriginal and Torres Strait Islander 
partnerships
•  Wadeye community, Northern Territory
•   Adam Goodes’ iDiC (Indigenous  

Defence and Infrastructure Consortium) 

•  Supply Nation 
•  Australian Indigenous Doctors’ Association 
•  Thamarrurr Indigenous Youth Corporation

Targets / next steps 

Increase investment on research that 
improves health experiences, outcomes 
and affordability for all Australians

 For the full list of highlights view our Sustainability Report 2021

Annual Report 2021    21 

Operating and financial review

1. About Medibank

Medibank Private Limited (Medibank) is a leading private 
health insurer in Australia. Our core business is Health 
Insurance, whereby we underwrite and distribute private 
health insurance policies under the Medibank and ahm 
brands. Medibank Health complements our Health Insurance 
business by leveraging our experience and expertise to provide 
and coordinate health services to support our customers and 
the community. Medibank Health also includes diversified 
insurance products such as travel, life and pet. As we maintain 
assets to satisfy our regulatory reserves, we also generate 
investment income from our portfolio of investment assets.

Medibank was founded in 1976 as a private health insurer 
owned and operated by the Australian Government. We have 
operated on a for-profit basis since 2009, and on 25 November 
2014, Medibank was sold by the Australian Government 
by way of an initial public offering (IPO) and listed on the 
Australian Securities Exchange. As at 30 June 2021, we  
had 3,409 full-time equivalent (FTE) employees, including 
1,094 health professionals (excluding employees in  
associates and joint ventures). 

2.1 Group summary income statement

Year ended 30 June ($m)
Group revenue from external customers1 
Health Insurance operating profit
Medibank Health segment profit1
Segment operating profit
Corporate overheads
Group operating profit – continuing operations 
Net investment income
Amortisation of intangibles
AASB 16 Leases transition adjustment
Other income/(expenses)
Profit before tax
Income tax expense
Group net profit after tax (NPAT) – continuing operations
Effective tax rate2
Earnings per share (EPS) (cents)2 
Underlying NPAT3
Underlying EPS (cents)3
Dividend per share (cents)
Dividend payout ratio4

1.  Excludes discontinued operations. 

2.  Calculated on total operations.

2. Financial and operating performance

References to “2020”, “2021” and “2022” are to the financial 
years ended on 30 June 2020, 30 June 2021 and 30 June 2022 
respectively, unless otherwise stated. The “Group” refers 
to the consolidated entity, consisting of Medibank and its 
subsidiaries. 

Despite the challenging environment of the last year, our 
business has proved resilient. Our people remain engaged, 
our balance sheet remains strong, we have made good 
progress in growing policyholder numbers, managing our 
own expenses and setting up Medibank Health for growth. 

2021
6,910.4
538.6
31.4
570.0
(41.7)
528.3
120.0
(4.6)
-
(11.4)
632.3
(191.1)
441.2
30.2%
16.0
398.7
14.5
12.7
87.7%

2020
6,769.6
470.6
27.8
498.4
(37.4)
461.0
2.4
(9.0)
3.3
(7.5)
450.2
(134.6)
315.6
29.9%
11.4
367.3
13.3
12.0
90.1%

Change
2.1%
14.4%
12.9%
14.4%
11.5%
14.6%
n.m.
(48.9%)
n.m.
52.0%
40.4%
42.0%
39.8%
30bps
39.8%
8.5%
8.5%
5.8%
(2.7%)

3.  Underlying NPAT, which adjusts for the normalisation of investment income, is from continuing operations.

4.  Dividend payout ratio based on underlying NPAT from total operations.

22    Medibank 

Group operating profit from continuing operations increased 
by $67.3 million or 14.6%, largely due to Health Insurance 
operating profit, which increased by $68.0 million. 

Net investment income was significantly higher than 2020 
when investment markets were impacted by COVID-19, 
increasing by $117.6 million to $120.0 million.

The combination of the above factors resulted in a 
$125.6 million, or 39.8% increase in NPAT to $441.2 million 
on a continuing basis. Underlying NPAT, which adjusts for 
the normalisation of investment returns, increased 8.5% 
or $31.4 million to $398.7 million. 

The key reasons for the movements in the Health Insurance 
and Medibank Health results, as well as net investment 
income, are outlined in this report.

Health Insurance 

Year ended 30 June ($m)
Premium revenue
Net claims expense (including risk equalisation)
Gross profit
Management expenses
Operating profit
Gross margin
Management expense ratio
Operating margin

The solid result in our Health Insurance business 
demonstrates the benefit of the customer-led journey we 
have been on for the last five years. During the year we saw 
strong policyholder growth, improved retention, and we 
continued our focus on managing our costs. 

Health Insurance revenue grew 2.1% to $6,680.3 million 
alongside strong policyholder growth. When adjusted for  
our COVID-19 customer support measures of $226.0 million 
in 2021 and $80.0 million in 2020, underlying revenue  
grew 4.2% to $6,906.3 million.

There has been encouraging hospital participation growth 
in the private health insurance market, with the Australian 
Prudential Regulation Authority (APRA) data for the  
12 months ending 30 June 2021 indicating an increase 
of 95 basis points to 44.53%, and the number of people 
with hospital cover increasing by approximately 245,000. 
Customers are more focused on their health and  
wellbeing and are less likely to switch providers which  
has impacted favourably on our policyholder trajectory.

Our reported net resident policyholders increased by 82,500 or 
4.6%. Adjusting for COVID-19 related suspensions, policyholder 
growth was 3.5% with the Medibank and ahm brands growing 
1.3% and 10.9% respectively. Our ahm brand continues to 
attract younger customers which will have positive impacts on 
the overall sustainability of the health system. The acquisition 
rate was up 110 basis points, largely driven by strong growth 
in the new to industry segment, particularly in the Medibank 
brand. There was a significant improvement in customer 
retention which improved 130 basis points, reflecting 
improving customer advocacy across both brands and the 
benefit of increasing product value and differentiation in the 
Medibank brand. Our market share grew by 37 basis points 
over the year and stands at 27.3% as at 30 June 2021. 

4.6%
0.6%
0.8%
0.3%

2020
2021
6,545.6
6,680.3
Reported net resident policyholder growth 
(5,531.6)
(5,610.8)
2021 
1,014.0
1,069.5
2020 
2019 
(543.4)
(530.9)
2018 
470.6
538.6
15.5%
16.0%
8.3%
7.9%
7.2%
8.1%

Change
2.1%
1.4%
5.5%
(2.3%)
14.4%
50bps
(40bps)
90bps

Reported net resident policyholder growth

FY21

FY20

FY19

FY18

4.6%

0.6%

0.8%

0.3%

0

1

2

3

4

5

Medibank’s net claims increased 1.4% and gross claims 
expense increased 0.8%. This includes a $223.0 million 
reduction in claims expense due to lower than expected 
hospital and ancillary claims as a result of COVID-19, and 
a decrease in the COVID-19 deferred claims liability. Risk 
equalisation changed from a $7.9 million receivable in 2020 
to a $24.6 million payable in 2021, reflecting our claims 
growth continuing to be below industry growth and strong 
policyholder growth in ahm which has a younger customer 
demographic. Underlying claims per policy unit which 
adjusts for both outstanding claims provision movements and 
COVID-19 impacts grew 3.1%. Resident underlying claims 
growth per policy unit was 2.5% with stable extras claims 
growth and lower hospital claims growth of 2.5% reflecting 
lower public hospital utilisation. Our COVID-19 claims  
liability, which is in recognition of claims that have likely been 
deferred during the pandemic, decreased to $223.8 million 
(30 June 2020: $297.1 million), largely due to hospital  
deferral assumptions moving from 100% to 59%. 

Annual Report 2021    23 

Operating and financial review

Health Insurance management expense ratio
2021 
2020 
2019 
2018 
2017 

7.9%
8.3%
8.7%
8.8%
9.1% 

Health Insurance management expense ratio

2021

2020

2019

2018

2017

7.9%

8.3%

8.7%

8.8%

9.1%

0

2

4

6

8

10

Our productivity agenda and increasing scale resulted in 
our management expense ratio falling 40 basis points to 
7.9%. Management expenses reduced by 2.3% due to lower 
overseas sales commissions and operating costs. Overseas 
sales commissions reduced by 41.2%, or $5.4 million, with 
the closed borders reducing the number of new overseas 
customers. Operating expenses were down 1.4% and reflect 
productivity savings of approximately $20 million, partially 
offset by cost inflation and volume impacts. We are targeting 
productivity savings of approximately $40 million over the  
next three years, including $15 million in 2022. 

Our Health Insurance operating profit of $538.6 million was 
14.4% higher than 2020, and the operating margin improved  
90 basis points to 8.1%. Underlying operating profit increased 
6.6% to $541.6 million and the underlying profit margin was 
7.8%.

Medibank Health

The role of Medibank Health is to strengthen and complement 
our core Health Insurance business, support long-term 
customer retention and to build successful standalone 
businesses. We build smarter healthcare models that focus 
on giving patients choice, making care more affordable 
and improving the health and wellbeing of all Australians. 
It includes the provision of health management, telehealth 
services for government and corporate customers, hospital 
care in the home, wellbeing programs and diversified 
insurance products. Our investments in associates and joint 
ventures also form part of this segment. They include our 
non-controlling investments in Myhealth (a leading operator 
of primary care clinics), East Sydney Private Hospital and a 
Medibank-Calvary joint venture to deliver My Home Hospital, a 
Wellbeing SA service.

The external environment remains favourable to the long-
term prospects of Medibank Health, with increasing take up 
of care delivery in the home, focus in the community on health 
and wellbeing, and heightened pressure on the public health 
system. Revenue increased 5.1% with increased demand 
for in-home care and telehealth services, partly offset by 
significantly lower travel insurance sales. Medibank Health 
gross margin was stable at 41.2%.

24    Medibank 

Management expenses increased 1.7% largely due to inflation, 
however the management expense ratio improved 100 basis 
points to 29.9% as a result of the strong revenue growth.

Operating profit improved 15.8% to $32.2 million and 
Medibank Health segment profit, which includes our share 
of the results of Myhealth and other investments, improved 
12.9% to $31.4 million. Myhealth contributed $0.7 million, 
while there was a loss (including interest income) of  
$1.5 million in relation to the other investments. We  
expect these losses to largely unwind in 2022. 

Net investment income

Medibank’s investment portfolio was $3.0 billion as at  
30 June 2021. This investment portfolio, which includes  
$2.8 billion relating to the fund portfolio, provides liquidity 
to cover insurance liabilities related to the Health Insurance 
business and satisfies Medibank’s obligations to maintain 
regulatory reserves to meet health claims and to fund 
ongoing operations. It includes an elevated defensive 
allocation of $326.8 million of assets to fund claims deferred 
due to COVID-19, which sits outside our target allocation of 
growth and defensive assets of 20% and 80% respectively.

Net investment income in 2021 was significantly higher 
than 2020, increasing by $117.6 million to $120.0 million. 
The increased income in the growth portfolio reflects strong 
equity markets, and in the defensive portfolio the benefit of 
narrowing credit spreads was offset by the lower interest  
rate environment. 

Our investment portfolio is subject to and compliant with our 
Responsible Investment Policy. Domestic and international 
equity investment portfolios remain aligned with socially 
responsible investment principles.

2.2 Group financial position

Medibank’s net asset position increased by $108.3 million  
or 6.0% to $1,906.1 million as at 30 June 2021.

Some of the major movements in the consolidated statement 
of financial position include:

•  A decrease in cash and cash equivalents driven by the  

shift to longer duration financial assets. 

•  An increase in financial assets as a result of the shift  

from cash and stronger returns. 

•  An increase in equity accounted investments due to the 

acquisition of new associates and joint ventures during the 
year. Refer to section 3 “Strategy and future prospects”  
for further details about associates and joint ventures.

•  An increase in provisions due to the recognition of the 

$103.0 million customer give back provision relating to  
the return of permanent COVID-19 net claims savings  
to customers through premium relief announced by the  
Group on 29 June 2021. 

As at 30 June 2021, Medibank’s consolidated statement  
of financial position remained debt free.

 
 
 
2.3 Capital management and dividends

Medibank’s capital management objective is to maintain a 
strong financial risk profile and capacity to meet financial 
commitments. As at 30 June 2021:

•  Our total Health Insurance business-related capital was 

$942.0 million; equivalent to 13.0% of premium revenue after 
the allowance for determined but unpaid dividends. This 
was at the top end of Medibank’s target range of 11%-13%.

•  Non-fund required capital was $147.6 million.

•  Unallocated capital surplus was $170.7 million.

above the outlook statement provided in our half year results 
announcement, where we advised the market that the 
dividend payout ratio was expected to be towards the top end 
of our annual payout ratio range of between 75% and 85%  
of underlying NPAT, and reflects our strong capital position. 

2.4 Management changes

On 24 February 2021, Chief Executive Officer Craig Drummond 
announced his retirement. Our Group Executive – Chief 
Customer Officer David Koczkar was appointed as Managing 
Director and Chief Executive Officer effective 17 May 2021.

In November 2018, APRA announced its intention to 
harmonise the health insurance capital framework with  
Life and General Insurance Capital (LAGIC) standards.  
Since then, APRA has consulted with the industry and 
undertaken a partial Quantitative Impact Study (QIS). APRA 
is expected to release draft capital standards and a full QIS 
by December 2021. Final standards are then due in mid-
2022 and planned to be effective from 1 July 2023. We are 
well placed to implement this framework as our Capital 
Management Policy is already closely aligned with LAGIC. 

Dividends paid or payable in respect of profits from the 
financial year totalled 12.7 cents per share fully franked, 
amounting to $349.8 million comprising:

•  An interim ordinary dividend of 5.8 cents per share fully 

franked, amounting to $159.7 million paid on 25 March 2021 
in respect of the six-month period ended 31 December 2020.

•  A final ordinary dividend of 6.9 cents per share fully franked, 
amounting to $190.0 million to be paid on 30 September 
2021 in respect of the six-month period ended 30 June 2021.

The full year 2021 ordinary dividend of 12.7 cents per 
share represents a 87.7% payout ratio of underlying NPAT, 
normalising for investment market returns. This is slightly 

Subsequent management changes were:

•  Dr Andrew Wilson was appointed to the role of  

Group Executive – CEO Health Services.

•  Mark Rogers took on expanded accountability as  

Group Executive – Chief Financial Officer & Group Strategy.

•  Milosh Milisavljevic was appointed Group Executive – 

Customer Portfolios, responsible for the Group’s consumer 
products and services and provider partnerships.

•  Rob Deeming was appointed Group Executive –  

Customer & Brands, responsible for the Medibank  
and ahm brands and customer channels as well as  
digital platforms and capabilities. 

3. Strategy and future prospects

Medibank’s purpose is Better Health for Better Lives. As an 
organisation, we are committed to improving the health and 
wellbeing of Australians and helping them lead better quality 
lives. By working to provide affordable and quality health 
outcomes, we seek to sustainably build our customer base and 
grow shareholder value. With David Koczkar’s appointment  
to CEO in May, our strategy has evolved but our customers 
and people remain at the centre of everything we do.

Our strategy 

Building a strong and connected business to drive broader system change and sustainability

Focus on our  customers and people

Grow our  core business 

Transform into a health company

Deliver leading 
 customer experiences

Empower our people

Be a partner of choice

Further differentiate 
 our customer offerings 

Deliver more value

Maintain cost discipline 

Better Health for Better Lives

Invest in prevention, 
choice and better care

Build successful   
standalone businesses

Bring benefits back   
to our core business

Annual Report 2021    25 

Operating and financial review

During 2021 we saw a shift in Australians prioritising their 
health and wellbeing given COVID-19 and heightened 
pressure on the public system. This has resulted in private 
health insurance becoming more compelling for many 
Australians, including those who were previously uninsured. 
We have continued to focus on differentiating and growing  
our private health insurance business by leveraging our  
dual brand strategy to create a competitive advantage. We  
are also continuing our transformation into a health company. 

We know that affordability continues to be an issue for 
consumers and have worked hard to deliver our lowest 
average premium increase in 20 years, with premiums rising 
by an average of 3.25% from 1 April. Our focus has been 
on making our business more efficient and to reduce and 
eliminate unnecessary costs in the health system, so that  
we can deliver greater value and choice for our customers.

We maintained strong cost discipline and have delivered 
approximately $60 million of productivity savings over the  
past three years. We will also target a further $40 million  
in productivity across the next three financial years,  
including $15 million in 2022.

We supported our customers during the COVID-19 pandemic 
with a package of approximately $300 million to date, 
including $195 million in support measures and $103 million 
of permanent COVID-19 net claims savings we are returning 
to customers through premium relief. We are committed to 
returning all permanent net claims savings due to COVID-19 
to our customers once they are known.

Customers are at the heart of what we do and we are working 
to better support their healthcare needs by providing greater 
choice, more personalised advice and helping to reduce out-
of-pocket medical costs.

My Home Hospital, a Wellbeing SA service delivered by a  
joint venture between Calvary and Medibank, was launched  
in January. It is a public hospital-level service that delivers 
care to patients in the comfort and privacy of their own 
homes. Since launch, the service has had more than 900 
admissions, reducing pressure on the wider health system 
while still providing the hospital-level care patients need.  
We see an opportunity to utilise the market leading 
technology platform behind My Home Hospital across  
both public and private settings.

In March, Medibank and 45 specialist doctors formed an  
entity to develop a new private hospital in Melbourne that  
will provide short-stay surgical procedures. The investment  
is aimed at supporting our doctor partners to deliver a  
short-stay model of care that is already widely available at 
scale in other health systems internationally and for which 
there is a strong body of evidence. The entity will give patients 
more choice in where their care is delivered, reduce out-of-
pocket medical costs, and most importantly deliver a great 
customer experience. The facility is due to open in 2023.

26    Medibank 

This investment follows our 49% investment in East Sydney 
Private Hospital in August 2020 which provided funding to  
the hospital and doctors to scale its short-stay model of care. 
It also complements Medibank’s no-gap joint replacement 
pilot that is underway in seven hospitals across Australia. 

We have strengthened our focus on preventative and doctor-
led partnerships through the acquisition of a non-controlling 
interest in the Myhealth Medical Group, a leading operator 
of primary care clinics. Our investment will support GPs to 
enhance the health and quality of life of their patients which 
helps reduce high-cost hospital admissions and alleviate 
pressure on the health system. The investment will also give 
the GPs access to additional capabilities to improve data 
analytics and information management and enable Myhealth to 
continue its rapid growth. There were 95 Myhealth clinics at the 
end of 2021 and further growth will be supported by investment 
in greenfield practices and acquisition of existing practices. 

These investments all demonstrate Medibank’s commitment 
to putting patients at the centre of treatment, and supporting 
healthcare providers to improve patient experience. We  
will continue to invest and partner to evolve new models of 
care in Australia, accessible to patients in both private and 
public systems.

We also continue to deepen relationships with our customers 
through other avenues. More customers are engaging with our 
health offerings. Approximately 133,000 Medibank customers 
engaged with a Member Health Service, representing a 
51% increase on 2020. Around 20% of Medibank customers 
admitted to hospital were supported by our Health Concierge 
program in 2021, while there was a 32% increase in the 
number of customers receiving a Medibank at Home service. 

Our Live Better program continues to scale, with more  
than 760,000 people joining our Live Better Rewards  
program or taking part in Live Better activities, a 51% 
increase since last year. In 2022 we will finish integrating the 
Live Better app into the My Medibank app to provide a single 
digital health experience across health insurance and health 
and wellbeing – transforming our customer relationship from 
‘one day’ to ‘every day’. We see further opportunities for Live 
Better in the broader health and wellbeing market through 
new partnerships and tapping into other market segments.

7,183 Medibank customers engaged in a preventative health 
program in 2021, an increase of 23% from 2020. Our Healthier 
Weight, Healthier Me: Type 2 Diabetes pilot is supporting 
customers with this condition, which is one of the fastest 
growing chronic diseases in Australia. The program offers an 
evidence-based weight management program and aims to 
improve management of the condition. Better Knee, Better 
Me was made a permanent national program for all eligible 
customers this year following the success of our two-year 
pilot program combining personalised plans for exercise, 
weight loss and pain management.

Our people have responded well under difficult circumstances 
this year, navigating through lockdowns and other challenges 
that COVID-19 has created. When retail stores were closed, 
our team members were upskilled and redeployed to other 
customer support channels. We introduced our new Future 
 Fit way of working that focuses on how employees connect 
and collaborate across the business, drawing upon the 
lessons learnt in 2020 and the success of our progressive 
support of flexible working. We continued to prioritise our 
people’s health and wellbeing, with many of our initiatives 
focused on mental health support and staying connected 
to one another. 

The impact of COVID-19 in 2022 cannot be predicted with any 
certainty; however, Medibank remains positioned for growth. 
Our investment in our people, technology, and digitisation has 
been critical to our business resilience, and stood us apart 

from many of our competitors. In the year ahead, our focus 
will shift more towards embedding and scaling our existing 
health and wellbeing offers into our customers’ experience. 
We will have an even sharper focus on enhancing value by 
moderating health system cost growth, particularly in a post-
COVID-19 environment. Continuing to offer more choice to 
our customers and reducing out-of-pocket costs remains a 
priority, with clinically led, alternative ways of delivering care 
a key part of the solution. To achieve this, we will continue 
to strengthen and broaden our partnerships with healthcare 
providers and corporates. 

Our strategy is the right strategy for our business and will 
continue to inform our decisions. Aligned with our evolved 
strategy, some of the milestones have been revised and 
are detailed below. 

FY21 milestone scorecard

Pillars

Milestones

Focus on our  
customers  
and people

Grow the  
core business  

Customer advocacy: Service NPS (average)
FY21 FY22 benchmark1

Medibank 37.1
43.0
ahm

>35
>35

Employee advocacy: eNPS

FY21
Place to work
+30
Products & services +26

FY22 benchmark2
≥24
≥19

Net policyholder growth
FY213
+3.5% / 
+64.3k

FY22⁴
c. 3%, including 
continued growth in 
the Medibank brand

Market share

Health Insurance productivity delivered

FY24 aspiration

FY21
27.3% Up 25-75 bps

FY21
c. $20m

FY22-FY24 target
$40m including 
$15m in FY22

Transform into a  
health company 

Health and wellbeing 

Medibank Health operating profit  
(excluding Myhealth and other investments)

Customers 
engaged with 
Live Better5

FY21
c. 366k 

FY22
c. 480k 

FY21
$32.2m 

FY22
Organically replace the reported FY18  
$30m operating profit of Garrison by FY22  
(tracking broadly in line on an underlying basis) 

1.  Benchmark reflects sustaining service levels while continuing to digitise the service delivery model.

2.  FY22 benchmarks are based on the global average adjusted for Australian healthcare and financial insurance industry context.

3.  Adjusted for suspensions and reactivations occurring as a result of COVID-19.

4.  Assumes slowing participation growth compared to FY21.

5.   Includes total customers who have engaged with our preventative health offering, including Live Better Rewards, Live Better activities,  

preventative health programs and any new offerings developed.

Annual Report 2021    27 

 
 
 
 
Operating and financial review

4. Material business risks

The material business risks which could affect Medibank’s operations, business strategies and financial prospects are 
summarised below. 

The COVID-19 pandemic has, and will continue to have in 2022, the potential to impact Medibank’s material and strategic 
business risks. Medibank continuously monitors the uncertainty introduced by COVID-19 and its impact on its risk profile, 
both on financial and non-financial risks. Ongoing and emerging risks related to the pandemic include the demand for 
clinical services and therefore pressures on resourcing, attraction, retention and cost, and expectations regarding employee 
vaccination. Where appropriate, Medibank has strengthened its governance, monitoring and internal control system to address 
increased risk exposures caused by the pandemic in relation to its operational, financial and strategic risks.

Risk description

Risk management strategy

Material sustainability 
categories

Strategic 

The risk that we are 
unable to identify 
and execute the right 
strategic initiatives 
and projects on target 
and on time that  
deliver measurable 
and agreed outcomes 
to support our goals

Operational 

The risk of financial 
loss resulting from 
inadequate or failed 
internal processes, 
people and systems or 
from external events

Medibank’s strategic risks are identified and assessed as 
part of our annual strategic planning process and endorsed 
by the Board. Key strategic risks identified include loss 
of private health insurance customers, healthcare costs 
and utilisation, regulatory risk, and execution of non-
private health insurance growth. These risks influence the 
prioritisation of investments and resources in the Corporate 
Plan, which is approved by the Board. To effectively 
understand and assess some key strategic risks that are 
broad in nature (e.g. regulatory and customer risks), we 
undertake detailed analysis on threats or opportunities  
that specific scenarios may pose to our business.

We have established risk management policies and 
procedures for identifying, assessing, monitoring and 
reporting operational risks and controls. This includes 
the important areas of information security, technology, 
business continuity, outsourcing, fraud, people, and  
health and safety risks. Management of operational  
risk is overseen by divisional risk committees, the 
Executive Risk Committee and the Board’s Risk 
Management Committee.

Credit

The risk of financial loss 
due to counterparties 
failing to meet all  
or part of their 
contractual obligations

Exposure to this risk is primarily through Medibank’s 
investment portfolio. This risk is managed through the 
application of the Investment Management Policy. The effective 
implementation of this policy is overseen by the Board’s 
Investment and Capital Committee to ensure that credit risk 
is managed in line with the risk appetite set by the Board.

Capital & liquidity 

The risk of not being 
able to meet financial 
commitments as and 
when they are due and 
in complying with APRA 
prudential standards on 
solvency and liquidity

Medibank has a Board-approved Liquidity Management 
Policy and a Board-endorsed plan designed to ensure it 
meets or exceeds regulatory solvency requirements and 
is able to meet all payments as and when they fall due. 
Liquidity risk is managed by our treasury function through 
daily cash management of cash flows and liquid asset 
positions and projected future cash flows, supported 
by actuarial forecasts that take into account anticipated 
seasonality as well as stressed market conditions.

28    Medibank 

 
 
Risk description

Risk management strategy

Material sustainability 
categories

Market & investment 

The risk of adverse 
financial impact market 
factors e.g. foreign 
exchange rates, interest 
rates and equity prices

Insurance 

The risk of  
misestimation of 
incurred and expected 
costs, frequency  
and severity of  
insured events

Clinical

The risk of unexpected, 
adverse clinical 
outcomes from a  
health service provided 
by Medibank, or a  
third party acting on 
behalf of Medibank

Regulatory compliance 

Failure to comply  
with regulatory 
requirements

We have a Board-approved Investment Management Policy. 
The Board’s Investment and Capital Committee oversees 
the investment process and compliance with investment 
mandates, performance against benchmarks and asset 
allocation. Our strategic asset allocation is weighted  
largely towards defensive assets and with limits applied 
to illiquid assets.

The Board approves the Pricing Policy, which includes 
pricing and profitability objectives and forms a key part of 
the Capital Management Plan. Our objective is to support 
customer growth through balancing the offer of competitive 
value to all customers with profitability objectives and 
the need to meet capital management and regulatory 
requirements. Insurance risk is a key part of regular 
portfolio monitoring and treatment plans are formulated 
and implemented in response to any potential for deviation 
from target measures.

Clinical risk arises from clinical services that Medibank 
provides and procures, the provision of health-related 
information, and customer health initiatives. We 
have implemented a clinical governance and quality 
management framework that defines the principles, 
structures and processes that underpin service quality, 
continuous improvement and patient safety. Our Chief 
Medical Officer, supported by a clinical governance team, 
provides oversight and assurance. The Risk Management 
Committee and Board receive regular reporting on the 
performance of clinical risk management.

We have established compliance management policies 
and procedures for identifying and managing Medibank’s 
regulatory obligations and incidents that may arise. 
Management of compliance risk is overseen by divisional 
risk committees, the Executive Risk Committee and the 
Board’s Risk Management Committee.

Customer 
health

Employee 
health

Community 
health 

Environmental 
health

Governance

For further information  
about our material  
categories please see our  
Sustainability Report 2021. 

Annual Report 2021    29 

 
 
Directors

 44%

are women

38%

were born 
overseas

Top L to R: Mike Wilkins, David Koczkar, Tracey Batten. Middle L to R: Anna Bligh, Gerard Dalbosco, David Fagan. 
Bottom L to R: Peter Hodgett, Linda Bardo Nicholls, Christine O'Reilly.

Name and title

Biography

Mike Wilkins AO

Chairman and 
Independent  
Non-executive Director

BCom, MBA, FAICD, FCA

Age: 64

Mike was appointed a director in May 2017 and Chairman effective 1 October 2020.  
He is Chairman of the Nomination Committee and a member of the Investment and  
Capital Committee and the People and Remuneration Committee.

Mike is the Chairman (since March 2020) and a director (since November 2016) of QBE Insurance 
Group Limited. He is also a director of Scentre Group Limited (since April 2020).

Mike has more than 30 years of experience in financial services, predominantly in Australia and 
Asia. He served as Managing Director and Chief Executive Officer at Insurance Australia Group 
(November 2007 to November 2015), Managing Director and Chief Executive Officer at Promina 
Group Limited and Managing Director at Tyndall Australia Limited. He also served as Acting  
Chief Executive Officer (April 2018 to December 2018), Executive Chairman (April 2018 to June 
2018) and a director (September 2016 to February 2020) of AMP Limited. He was previously 
a director of Maple-Brown Abbott Limited, Alinta Limited, The Geneva Association and the 
Australian Business and Community Network.

David Koczkar 

David was appointed Chief Executive Officer in May 2021. 

Chief Executive Officer

BCom, PG Dip Finance, MAICD

Age: 48

He commenced at Medibank in 2014, holding the roles of Chief Operating Officer from March 
2014 and then Group Executive – Chief Customer Officer from September 2016, where he was 
responsible for the Health Insurance and Diversified portfolios, Live Better and the ahm business. 
David was also appointed Acting Chief Executive Officer between April 2016 and June 2016.

Prior to joining Medibank, David was the Group Chief Commercial Officer at Jetstar where he 
was responsible for the airline group’s network management, sales and marketing, customer 
channels and commercial operations, including as a director of Jetstar Pacific (Vietnam),  
Jetstar Hong Kong and NewStar (Singapore) JV businesses.

David has more than 25 years of strategy, customer and commercial experience, including 
previous work in the strategy consulting and financial services industries.

30    Medibank 

 
Top L to R: Mike Wilkins, David Koczkar, Tracey Batten. Middle L to R: Anna Bligh, Gerard Dalbosco, David Fagan. 

Bottom L to R: Peter Hodgett, Linda Bardo Nicholls, Christine O'Reilly.

Name and title

Biography

Dr Tracey Batten

Independent  
Non-executive Director

MBBS, MHA, MBA,  
FAICD, FRACMA

Age: 55

Tracey was appointed a director in August 2017. She is a member of the Risk Management 
Committee and the People and Remuneration Committee.

Tracey has extensive experience in the health services sector, with strong commercial, business 
and change leadership skills.

Tracey is currently a director of EBOS Group Limited (since July 2021), the National Institute of 
Water and Atmospheric Research in New Zealand and the New Zealand Accident Compensation 
Corporation, and a former director of Abano Healthcare Group.

Anna Bligh AC

Independent  
Non-executive Director

BA (QLD)

Age: 61

Gerard Dalbosco

Independent  
Non-executive Director

M.AppFin, B.Comm,  
FCA, FFIN, GAICD 

Age: 58

David Fagan

Independent 
Non-executive Director

LLB, LLM, GAICD

Age: 64

Tracey was previously the Chief Executive of the Imperial College Healthcare NHS Trust in the United 
Kingdom. In that role, Tracey focused on change leadership, in particular improving organisational 
culture and strengthening patient safety and experience. Tracey also oversaw the implementation 
of a range of digital initiatives as Chief Executive. Tracey is a former Chief Executive of St Vincent’s 
Health Australia, which runs a group of public hospitals, private hospitals and aged care facilities.

Anna was appointed a director in December 2012. She is a member of the Investment and  
Capital Committee and the People and Remuneration Committee.

Anna is currently the Chief Executive Officer of the Australian Banking Association and a director  
of the International Banking Federation (IBFed).

Anna has extensive experience in leadership and public policy, including in the fields of healthcare, 
finance, infrastructure and project management. She has held several roles in the Queensland 
Government, including Premier, Treasurer, Minister for Finance, Minister for State Development, 
Minister for Trade and Innovation and Minister for Education. She was also a member of the 
Queensland Cabinet Budget Review Committee for 11 years. Anna was a director of Bangarra Dance 
Theatre Australia (2012-2020) and is currently a non-executive director of Australian Plays Transform.

Gerard was appointed a director in May 2021. He is a member of the Audit Committee and the 
Risk Management Committee.

Gerard held a number of senior leadership roles as a Partner of EY until September 2020.  
His most recent role was Melbourne Managing Partner where he led a large team responsible  
for EY’s go-to-market and client service strategies. Prior to this, Gerard held other roles at  
EY including Asia Pacific Managing Partner – Markets and Co-Deputy CEO where he led EY’s 
client-serving activities across the Asia Pacific market. He was also Oceania Managing Partner 
and CEO, and Oceania Managing Partner of Transaction Advisory Services where he was 
responsible for EY’s Transaction Advisory Services business across Oceania. 

Gerard is currently Chair of Melbourne Archdiocese Catholic Schools and Co-Deputy Chair and 
Chair of the Finance Committee of the Committee for Melbourne. He has previously held roles  
as a director and Chair of the Finance & Audit Committee of Mercy Health & Aged Care, director 
and member of the Finance Committee of Berry Street Victoria, and Chair of the National Gallery 
of Victoria’s Business Council.

David was appointed a director in March 2014. He is Chairman of the Risk Management Committee 
and a member of the Investment and Capital Committee and the Nomination Committee.

David is a highly experienced commercial lawyer. He held a variety of leadership positions at 
Clayton Utz culminating in the role of Chief Executive Partner for nine years. In this role, David  
had responsibility and accountability for leadership and transformation, strategy, finance, 
stakeholder engagement, and governance, including risk management. During David’s tenure 
as Chief Executive Partner, Clayton Utz entrenched itself as a first class top tier commercial 
law firm. David also chaired the Medibank Privatisation Committee which operated during 2014 
in preparation for the privatisation process. David is a former director and Chair of the Audit 
Committee of The Global Foundation, a former director of Grocon Funds Management Group,  
the Hilco Group and UBS Grocon Real Estate Investment Management Australia Pty Limited  
and a former member of the advisory board of Chase Corporate Advisory.

David is currently a director of PayGroup Limited (since November 2017). He is Chair of BDO  
Group Holdings Limited and a member of the ASIC Corporate Governance Consultative Panel.

Annual Report 2021    31 

Directors

Name and title

Biography

Peter Hodgett

Independent 
Non-executive Director

BSc (Hons)

Age: 66

Peter was appointed a director in June 2013. He is Chairman of the Investment and Capital 
Committee and a member of the Audit Committee and the Nomination Committee.

He held a number of other non-executive directorships from 2008 and is currently a director  
of the Leukaemia Foundation of Australia.

Previously, Peter worked for AMP for more than 20 years in a wide variety of business and 
functional roles, including Chief Actuary during its demutualisation, General Manager of  
Human Resources and Strategy, and as Global Director of Finance and Operations for  
Henderson Global Investors in the United Kingdom. 

Linda Bardo Nicholls 
AO

Linda was appointed a director in March 2014. She is Chairman of the People and Remuneration 
Committee and a member of the Nomination Committee.

Independent  
Non-executive Director

BA, MBA (Harvard), FAICD

Age: 73

Linda has more than 30 years of experience as a senior executive and director in banking, 
insurance and funds management in Australia, New Zealand and the United States.

She is currently Chairman of Japara Healthcare Limited (since March 2014) and a director  
of Inghams Group Limited (since November 2016). Linda is also Chairman of the Board of 
Melbourne Health and a member of the Museums Board of Victoria.

Christine O’Reilly

Independent  
Non-executive Director

BBus

Age: 60

Linda’s previous directorships include Fairfax Media Limited (February 2010 to December 2018), 
Pacific Brands Limited (October 2013 to July 2016), Sigma Pharmaceuticals Limited (December 
2005 to December 2015) and Healthscope Limited, as Chairman (October 2008 to October 2010) 
and a director (January 2000 to October 2010).

Christine was appointed a director in March 2014. She is Chairman of the Audit Committee  
and a member of the Risk Management Committee and the Nomination Committee.

Christine is currently a director of Stockland (since August 2018), BHP Group Limited  
(since October 2020), and the Baker Institute. 

Christine has more than 30 years of financial and infrastructure experience both in Australia  
and internationally in various roles including as Co-head of Unlisted Infrastructure at Colonial 
First State Global Asset Management and Chief Executive and Managing Director of GasNet 
Australia Group. Christine’s early career includes eight years in investment banking and audit 
experience with Price Waterhouse, where she qualified as a chartered accountant. Her previous 
directorships include CSL Limited (February 2011 to October 2020) and the Transurban Group 
(April 2012 to October 2020).

Company Secretary

Name and title

Biography

Mei Ramsay

Group Executive –  
Legal, Governance  
& Compliance and  
Company Secretary

BA, LLB, LLM

32    Medibank 

Mei was appointed Group Executive – Legal, Governance & Compliance (previously Legal, Governance 
& Regulatory Affairs) in September 2016 and has been the Company Secretary for Medibank 
Private Limited since 2014. Mei previously held the position of Group General Counsel from 2011. 

She is responsible for leading the legal and governance functions, including compliance, 
regulatory affairs and company secretariat, and providing legal and corporate governance  
advice to Medibank’s Board, Chief Executive Officer and senior management.

Mei has more than 25 years of experience in the legal profession, both as a senior in-house  
legal adviser for multinational and international companies, as well as a private practitioner.

Prior to joining Medibank, Mei was the General Counsel and Company Secretary for the  
Asia Pacific region at Cummins Inc, and before that held various senior legal positions at  
Coles Myer Ltd and Southcorp Limited. Mei started her legal career at Arnold Bloch Leibler  
and also worked as a Senior Associate at Minter Ellison.

Mei is currently the Vice President of the Association of Corporate Counsel (ACC) Australia,  
a member of the Executive of the ACC GC100 and former Chair of the ACC GC100, and a  
member of Chief Executive Women. 

Executive 
Leadership  
Team

 25%

are women

50%

were born overseas

Top L to R: David Koczkar, Kylie Bishop, Rob Deeming. Middle L to R: John Goodall. Milosh Milisavljevic, Mei Ramsay. 
Bottom L to R: Mark Rogers, Andrew Wilson.

Name and title

Biography

Kylie Bishop 

Group Executive –  
People & Culture

Kylie has held the position of Group Executive – People & Culture with Medibank since 2013. She is a 
registered psychologist, specialising in organisational psychology and is responsible for leading the 
key people functions, as well as Environment, Social and Governance (ESG) across Medibank. This 
includes culture, talent and capability, performance and rewards, shared services, talent acquisition, 
workplace relations, health, safety and wellbeing, employee experience and community. 

Rob Deeming

Group Executive –  
Customer & Brands

Kylie is responsible for leading Medibank’s culture and new ways of working program focused  
on purpose and inclusion, customer first and health & wellbeing. This includes leading the  
design and build of a new Melbourne workspace to be delivered in 2024. Kylie began her career 
in human resource consulting and prior to joining Medibank in 2010, held senior positions with 
National Australia Bank (NAB). 

Kylie is also currently a non-executive director of Melbourne Health and Basketball Victoria, and 
was previously a director with Rugby Victoria.

Rob was appointed Group Executive – Customer & Brands in June 2021. He is responsible for 
the Medibank and ahm brands and our customer channels, as well as our digital platforms and 
capabilities. He is accountable for growing and sustaining Medibank’s consumer businesses,  
and creating leading customer experiences to improve the advocacy, engagement and experience 
for our customers. Prior to this role, Rob held the role of Senior Executive within Medibank since 
August 2020 where he was responsible for leading ahm, Australia’s fastest growing private health 
insurance brand.

Rob has extensive experience in entrepreneurial leadership, leading consumer brands and 
growing digital-led businesses. Before joining Medibank Rob was the CEO of Billy, a multi  
award-winning hardware/software business supporting older people living independently at  
home across Australia and the US. In this role he built and led the vision, strategy and team  
for the business alongside the two technical founders.

Rob also spent several years in commercial leadership roles at Jetstar and Qantas. At Jetstar, he 
led the commercial teams that looked after the digital channels, as well as the ancillary products 
and hotels businesses. Prior to this he was the CEO of the travel booking engine, Jetsetter, with 
teams based in New York, Boston and London. Rob led the sale of Jetsetter to TripAdvisor in 2013.

Annual Report 2021    33 

Executive Leadership Team

Name and title

Biography

John Goodall

Group Executive 
– Technology & 
Operations

John was appointed Group Executive – Technology & Operations in December 2016. He is 
responsible for Medibank’s core IT platforms, property, procurement and operations with a focus 
on leveraging our systems, processes and information to deliver improved, personalised digital 
experiences for Medibank’s customers.

John has more than 25 years of experience working in and leading IT functions across the retail 
and financial services industries and utilising technology to drive business growth and align 
business systems and processes to customer needs.

Prior to joining Medibank, John held the role of General Manager Enterprise Technology at 
Sportsbet, and before his time at Sportsbet he spent 20 years at GE Capital Australia and  
New Zealand where he held a number of roles, including Chief Information Officer.

Milosh Milisavljevic

Group Executive –  
Customer Portfolios

Milosh was appointed Group Executive – Customer Portfolios in June 2021. He is responsible for 
Medibank‘s customer portfolios, including member health programs, Live Better and diversified 
insurance portfolios. He is also accountable for growing and sustaining Medibank’s consumer, 
corporate and overseas portfolios, managing our relationship with our provider network and 
diversifying our propositions to improve the quality of life and health of our customers.

Milosh joined Medibank in 2016 and has held a number of roles, most recently as the Senior 
Executive Customer Strategy & Portfolio. In these roles he led Medibank’s customer strategy, 
commercial transformation, product innovation and portfolio management, strategic partnerships 
and data science. Milosh has extensive experience leading customer focused and data driven 
transformations across health, media and telecommunications industries, including proposition, 
innovation and new business growth. Prior to joining Medibank, Milosh held senior roles at SEEK 
and McKinsey & Company.

Mark Rogers

Group Executive –  
Chief Financial Officer  
& Group Strategy

Mark was appointed Group Executive – Chief Financial Officer & Group Strategy in May 2021. 
Previous to this, he held the role of Group Executive – Chief Financial Officer since January 2017. 
Mark is responsible for the finance, actuarial, treasury, internal audit and investor relations 
functions across Medibank as well as strategy development and M&A. 

He has more than 20 years of global experience across the healthcare, pharmaceuticals and 
financial services sectors.

Before joining Medibank, Mark held the role of General Manager, Group Performance and 
Planning at National Australia Bank (NAB) since 2013, where he was responsible for management 
reporting, performance management, planning and forecasting, and capital allocation. Preceding 
this, Mark was General Manager, Group Development.  Prior to this, Mark was responsible for 
Group Strategy and Development for the Mayne Group, a diversified healthcare, pharmaceuticals 
and pharmacy business, where he was accountable for the management of the Group’s strategy, 
capital management and mergers and acquisitions. Prior to that role, Mark led Group Investor 
Relations at Mayne Group. Mark is a director of Private Healthcare Australia Limited and East 
Sydney Private Hospital, and Chairman of Myhealth Medical Group. 

Andrew was appointed Group Executive – CEO Health Services in May 2021. Previous to this,  
he held the roles of Group Executive – Healthcare & Strategy since September 2016 and  
Executive General Manager – Provider Networks & Integrated Care since 2013. He is responsible 
for Medibank’s growing role as a broader health services provider. This includes responsibility for 
the health services we deliver on behalf of business and government, including telehealth, virtual 
healthcare, in-home care, and services into residential aged care. Andrew is also responsible for 
Medibank’s hospital and healthcare investments and joint venture healthcare partnerships, which 
support both Medibank customers and other Australians in acute care and community settings. 

Andrew has 25 years of experience in the health system, and remains a practising clinician and 
lecturer. He was a founder and Co-president of McKesson Asia-Pacific, which was acquired by 
Medibank in 2010.

Andrew is a director of Calvary MHIH JV Pty Ltd, East Sydney Private Hospital and Myhealth 
Medical Group. He is also a director of a joint venture between Medibank and specialists to 
develop a private hospital facility in Kew, Melbourne.

Dr Andrew Wilson

Group Executive –  
CEO Health Services

34    Medibank 

Corporate governance statement

Medibank was founded in 1976 as a private health insurer 
and was operated by the Australian Government. In 1998, 
Medibank Private Limited became the operating entity with 
the Commonwealth of Australia as the sole shareholder.  
In 2014 the Australian Government sold Medibank by way 
of an initial public offering, and divested all its shares in 
Medibank. Medibank listed on the Australian Securities 
Exchange (ASX) on 25 November 2014.

The Medibank Board is committed to improving our 
customers’ experience and providing them with greater  
value. In line with this, the Board seeks to ensure that 
Medibank is properly managed to protect and enhance 
shareholder interests, and that Medibank, its directors, 
officers and employees operate in an appropriate  
environment of corporate governance.

Governance structure

The Board has a framework in place for governing  
Medibank. This includes adopting internal controls, risk 
management processes and corporate governance policies 
and practices, designed to promote responsible management 
and ethical conduct.

During the year, Medibank had in place policies and practices 
which comply with the recommendations in the ASX Corporate 
Governance Council Corporate Governance Principles and 
Recommendations (CGPRs), 4th edition. As a registered private 
health insurer, Medibank also complies with a governance 
standard issued by the Australian Prudential Regulation 
Authority (APRA). The key corporate governance practices 
applied at Medibank are described in this statement and the key 
corporate governance policies are available on the corporate 
governance section of our website at medibank.com.au.

The governance and performance of Medibank is overseen  
by the Board elected by the shareholders.

Medibank Private Limited Board
Oversees management of Medibank on behalf of shareholders

Audit 
Committee
Oversees 
financial 
reporting

Risk Management 
Committee
Oversees current 
and future risk 
management

Investment and 
Capital Committee
Oversees investment  
and capital management 
activities

People and Remuneration 
Committee
Oversees key remuneration  
and people policies 
and practices

Nomination 
Committee
Oversees board and 
committee membership 
and succession planning

Chief Executive Officer
Responsible for the day-to-day management of Medibank and implementation of the strategic objectives

Executive Leadership Team
Supports the Chief Executive Officer with running the business and delivering on the strategic objectives

Roles and responsibilities of the Board and management

The Board provides overall strategic guidance for Medibank 
and effective oversight of management. Responsibility for 
the governance of Medibank, including establishing and 
monitoring key performance goals, rests with the Board.  
The Board monitors the operational performance and 
financial position of Medibank, as well as overseeing  
the business strategy and approving strategic goals.  
In performing its role, the Board is committed to ensuring 
sound corporate governance practices.

The Board Charter, which is available on our website, 
articulates the Board’s roles and responsibilities, its 
membership and operation, and which responsibilities  
may be delegated to committees or to management.  

Specific responsibilities have been reserved by the Board in 
key areas of: strategy (including approval and monitoring of the 
corporate strategy and performance objectives); governance 
(including disclosure); appointment, performance evaluation 
and remuneration of the CEO and other senior executives, 
including the Company Secretary; approving the Code of 
Conduct and overseeing Medibank’s purpose, culture and 
values; financial approvals and reporting; risk management, 
compliance and workplace health and safety; and culture 
(including diversity and inclusion). The Board has established 
standing committees to assist in performing its responsibilities. 
These committees examine particular issues in detail and 
make recommendations to the Board. A description of these 
committees can be found on pages 39 to 40.

Annual Report 2021    35 

Corporate governance statement

The Chief Executive Officer (CEO) has responsibility for 
managing the day-to-day affairs of Medibank. The CEO, with 
the support of the Executive Leadership Team (ELT), manages 
Medibank in accordance with the Board-approved Corporate 
Plan, the corporate strategy and Medibank’s policies within 
the risk appetite set by the Board. A detailed delegation 
of authority framework defines the decision making and 
expenditure limits that apply at various levels of management.

Key areas of focus for the Board in 2021
Corporate governance (including COVID-19)

•  Oversight of COVID-19 impacts and response, including:

 – Ensuring the health and wellbeing of our customers, 

people and the community.

 – Customer give backs and hardship policies.

 – Accounting and regulatory responses, including in 
relation to claims liability and capital stress testing.

 – Business continuity management.

 – Managing retail stores and offices in a safe manner.

•  Oversight of the enhancement of the enterprise risk 

and compliance management framework and risk and 
compliance culture, including review and monitoring of 
financial and non-financial material risks and emerging 
risks and the coordination of the first independent 
comprehensive review required by APRA Prudential 
Standard CPS220.

•  Oversight of environmental, social and governance 

(ESG) strategy and the governance framework, including 
implementing policies and processes to comply with the  
4th edition of the CGPRs.

Strategy and execution

•  Review of strategy, including transformation into a  
health company and evaluation of opportunities to  
execute on our strategic pillars and key objectives.

•  Oversight of investments, partnerships and organic  
growth initiatives to support execution of the strategy.

•  Review and approval of the Corporate Plan, budget 
and performance targets and oversight of business 
performance against these targets.

People, remuneration and culture

•  Selection of new Chairman and CEO and oversight  

of transition.

•  Review of Board composition and consideration of succession 
planning, including selection of new non-executive director.

•  Oversight of our people and our culture, including 

monitoring of the remuneration framework and ensuring we 
have a strong people agenda focused on skills development.

•  Oversight of succession planning for the Executive 

Leadership Team.

•  Undertaking an external independent evaluation of the 

Board, committees and non-executive directors.

36    Medibank 

Structure and composition of the Board

The Board comprises nine directors in total – eight  
non-executive directors, including a non-executive  
Chairman, and the CEO.

The Chairman of the Board is responsible for providing 
leadership to the Board and Medibank as a whole.  
The Chairman’s other key responsibilities are outlined  
in the Board Charter. 

The current Chairman is Mike Wilkins AO, an independent 
non-executive director who has served as Chairman since 
1 October 2020 and on the Board since May 2017. Prior to 
Mike Wilkins’ appointment, Elizabeth Alexander served as 
Chairman and as an independent, non-executive director  
until her retirement effective 1 October 2020. The current  
CEO is David Koczkar, who commenced in the role on  
17 May 2021. Previously, Craig Drummond served as CEO 
until his retirement effective 17 May 2021.

Biographies of the directors, including their skills, experience 
and year of appointment, are set out on pages 30 to 32 of the 
annual report. Details of directors’ attendance at Board and 
committee meetings during the year ended 30 June 2021 are 
on page 48. The length of service of the non-executive directors 
ranges from three months to eight years and eight months.

Independence

Directors are expected to bring an independent judgement 
to bear on all Board decisions. A director is considered 
independent if they are a non-executive director who is not  
a member of management and are free of any business  
or other relationship that could materially interfere with  
the exercise of their unfettered and independent judgement  
or could reasonably be perceived to do so.

Each director provides periodic updates of their interests, 
positions, associations and relationships, and all directors 
must keep the Board advised on an ongoing basis of any 
interest that could potentially conflict with those of Medibank. 
Directors will be required to abstain from participating in 
discussions or voting on any matters in which they have,  
or may be perceived to have, a material personal interest.

The Board regularly assesses the independence of each 
director in light of the interests disclosed. The Board 
has assessed the interests, positions, associations and 
relationships of each director as at the date of this statement. 
It has determined that all non-executive directors satisfy the 
independence criteria recommended by the ASX Corporate 
Governance Council and prescribed by APRA.

To provide an opportunity for independent discussion, the 
non-executive directors meet without management present 
at the commencement of each Board meeting.

Appointment and re-election of directors

Medibank’s Constitution provides that a director may be 
appointed by the Board, and if so, is subject to election  
by shareholders at the annual general meeting (AGM) 
following their appointment if they wish to remain a director 
(other than the CEO). Individuals may also be nominated  
by shareholders to stand for election as a director at the  
AGM. The Constitution requires an election of directors at 
each AGM, and a director must retire and may stand for  
re-election by the third AGM following the director’s election.  
Gerard Dalbosco will stand for election at the upcoming AGM,  
having been appointed on 21 May 2021. Further information 
about Gerard is set out on page 31 of the annual report,  
and in the notice of annual general meeting.

Before appointing a person as a director, the Board 
undertakes checks as to that person’s character, experience 
and background, including criminal and bankruptcy checks. 
Medibank has a Fit and Proper Policy that complies with 
APRA’s Fit and Proper Prudential Standard. This standard 
requires that a person in a position of responsibility, including 
a director, be assessed prior to appointment (or in some 
cases, as soon as possible after appointment) and on an 
ongoing basis as to whether the person meets the fit and 
proper requirements. The person must have the appropriate 
skills, experience and knowledge to perform the role and  
act with the requisite character, diligence, honesty, integrity 
and judgement.

Upon appointment, each non-executive director enters into a 
service agreement setting out the terms of their appointment. 
This includes the requirement to build a shareholding in 
Medibank in order to align the interests of directors with those 
of shareholders. The Minimum Shareholding Policy requires 
non-executive directors to acquire shares equal to the value  
of one year’s base fee after tax over a period of five years.

As part of the appointment process, Medibank enters into a 
deed of indemnity, insurance and access with each director. 
Each director is indemnified against liability in connection 
with their role as a director and Medibank is required to 
maintain a directors’ and officers’ insurance policy. The  
deed confirms and extends the director’s general law rights  
of access to Board papers and other records of Medibank.

Remuneration policies and practices applying to non-
executive directors are detailed in the remuneration  
report from page 50.

Director induction, continuing education and  
access to information

The Board is committed to enhancing the capabilities of  
each director and the performance of the Board generally. 
Upon joining the Board, all new non-executive directors 
undertake a tailored induction program. This includes 
meetings with the Chairman, CEO, ELT and senior leaders  
on Medibank’s business, strategy and operation. 

The Board is provided with ongoing professional development 
opportunities during the year to maintain the skills and 
knowledge needed to effectively perform their role. This 
involves formal briefing sessions on a range of subjects by 
key stakeholders, including regulators and industry experts, 
to provide deeper insights on industry context and trends. 
This also includes visits to Medibank’s retail stores, customer 
engagement, conference attendance, and participation in the 
management-led Executive Risk Committee and Divisional 
Risk Committees. The professional development program  
is periodically reviewed by the Nomination Committee to 
ensure it meets the needs of the directors. 

The directors have complete and open access to the CEO, 
ELT and senior management following consultation with the 
CEO. A director may, following consultation with and consent 
from the Chairman, seek independent professional advice at 
Medibank’s expense in respect of any matter connected with 
the discharge of the director’s responsibilities. Directors also 
have direct access to the advice and services of the Company 
Secretary, who is accountable to the Board through the 
Chairman, and advises the Board and the Chairman on all 
governance matters.

Board skills, experience and diversity

The Nomination Committee regularly reviews the balance  
of skills, experience, independence, knowledge and diversity 
of the Board, and is committed to ensuring that the directors 
collectively have the appropriate skills mix. The evolution 
of the mix of skills and diversity of the Board is a long-
term process and must reflect the current and emerging 
challenges for the organisation.

The Nomination Committee takes into account the 
organisation’s strategic areas of focus, customer needs and 
external environment, including stakeholder sentiment, and 
assesses these various factors to ensure that an appropriate 
balance of skills and diversity is achieved on the Board.

•  Expertise and experience in developing and implementing 
strategy and financial and risk management are seen as 
critical skills required for the Board to be able to effectively 
govern and oversee the organisation. As a result, these 
skills are widely held by the Board members. 

•  Our core business of the provision of private health 

insurance products with an unwavering focus on our 
customers means that the Board must have skills and 
experience in the insurance sector as well as in customer 
facing businesses for Medibank to be successful. Board 
members have expertise in both these areas from a 
number of different industry sectors, including the general 
insurance and healthcare sectors.

•  Our vision to become a health company and our recent 

acquisitions in the healthcare delivery sector make it critical 
for the Board to have members with experience in the 
delivery of health services. This is captured in the collective 
experience of our directors, ranging from operational 
expertise through to strategic oversight.

Annual Report 2021    37 

Corporate governance statement

•  Health industry reform is not only inevitable, but also vital 
for the ongoing sustainability of our healthcare system.  
To play a role in this area, the Board must have members 
with experience and expertise in both building and 
maintaining government relations and influencing policy 
creation. Once again the Board has a number of highly 
experienced individuals in this area.

•  Finally, the Board has identified as critical enablers, skills  
in human resources and remuneration and technology,  
and has ensured that the Board has covered these areas  
of expertise in constituting the current Board.

The skills and expertise that the Board has identified as 
relevant to the performance of its role and the success of the 
organisation, along with the collective strength of the Board 
for each skill, are summarised in the Board skills matrix. 

The very nature of diversity means that not all members of 
the Board have all the skills listed below to the same degree. 
However, the Board believes the current mix of expertise  
and experience of members of the Board creates a diverse 
range of views and perspectives, and results in the Board 
providing effective governance, oversight and strategic 
leadership for Medibank.

During the reporting period, the Nomination Committee 
considered the mix of skills on the Board given the above 
considerations, and appointed Mr Gerard Dalbosco to the 
Board effective 21 May 2021. Mr Dalbosco brings a high  
level of financial skills and not-for-profit health experience  
to the Board. 

Board skills matrix

Strategy
Developing and implementing organisational 
strategies, and appropriately challenging 
management on delivery of strategic objectives

Financial and capital management
Proficiency in financial accounting and 
reporting, corporate finance, internal 
financial controls, corporate funding and 
capital management and investments, and 
understanding of associated risks

Risk management, governance  
and compliance 
Establishing risk management frameworks, 
setting the risk appetite, and overseeing 
organisational risk culture

Overseeing operations in a complex regulated 
environment, and demonstrating commitment 
to the highest governance standards

Insurance and healthcare sector experience 
Knowledge, experience and expertise in the 
insurance industry and healthcare sector

38    Medibank 

Customer experience and marketing
Developing product and/or customer 
management strategies, and experience  
in marketing

Human resources and executive 
remuneration 
Understanding the link between strategy, 
culture, performance, long-term shareholder 
value creation and remuneration outcomes

Government relations and public policy
Interacting with government and regulators 
and being involved in public policy decisions

Technology
Understanding technology and innovation, and 
overseeing development and implementation 
of initiatives to enhance productivity and 
customer experiences

Board performance evaluation

The Nomination Committee is responsible for reporting  
on the evaluation of the performance of the Chairman,  
Board, committees and individual directors to the Board.  
The evaluation is conducted annually either through an 
internal review process or an external process.

In 2021, the Board undertook an independent external 
review of the performance of the Board, committees and 
non-executive directors (including the Chairman). The 
evaluation was primarily conducted through in-depth one-
on-one interviews with the directors and ELT members. 
The Board discussed the external consultancy’s report and 
recommendations, and identified a number of opportunities 
to enhance its efficiency and effectiveness, including further 
opportunities to improve the Board’s operating rhythm, 
particularly in the context of the impact of the pandemic,  
and continuing to focus on Board renewal and diversity as 
part of director succession planning.

Committees of the Board
The Board has established five standing committees to 
assist in the execution of its responsibilities – the Audit 
Committee, Risk Management Committee, Investment and 
Capital Committee, People and Remuneration Committee 
and Nomination Committee. Each committee is governed by 
a charter setting out the committee’s role, responsibilities, 
membership and processes. The membership, roles and 
responsibilities of each committee are summarised in the 
table below. The charters can be accessed on our website.

The relevant qualifications and experience of the members  
of each committee can be found in the director biographies  
on pages 30 to 32 of the annual report. The number of 
meetings of each committee, and the individual attendance  
of their members, are provided on page 48. 

Committee 
membership as at  
25 August 2021

Audit Committee 

•  Christine O’Reilly 

(Chairman)

•  Gerard Dalbosco1

•  Peter Hodgett

Composition

Key roles and responsibilities

•  At least three members, all of whom  

•  Overseeing and reviewing the integrity of external 

are non-executive directors, a majority  
of whom are independent directors  
and at least one of whom is a member  
of the Risk Management Committee.

•  Structured so that members are all 

financially literate, and between them 
have accounting and financial expertise 
and experience and an understanding  
of Medibank’s industries.

•  The chairman must be an independent 
non-executive director, and must not 
be the chairman of the Board (but the 
chairman of the Board may sit on the 
committee).

financial reporting and financial statements.

•  Endorsing and recommending the appointment 

and removal of, and reviewing the terms of 
engagement, performance and independence  
of external auditors.

•  Reviewing management processes for 

compliance with relevant laws, regulations 
and other accounting and external reporting 
requirements.

•  Overseeing and reviewing internal and  

external audit processes and the internal  
control framework.

Risk Management 
Committee 

•  David Fagan 
(Chairman)

•  Tracey Batten

•  Gerard Dalbosco2

•  Christine O'Reilly

•  At least three members, all of whom  

are non-executive directors, a majority 
of whom are independent directors  
and at least one of whom is a member  
of the Audit Committee.

•  Structured to have the necessary 

knowledge and a sufficient understanding 
of Medibank’s industries.

•  Approving and recommending to the Board the 
adoption of policies and procedures on risk 
oversight and management to ensure effective 
risk management systems are in place.

•  Ensuring that Medibank has in place a robust 
risk management framework and procedure 
to support the effective identification and 
management of risks.

•  The chairman must be an independent 
non-executive director, and must not 
be the chairman of the Board (but the 
chairman of the Board may sit on the 
committee).

•  Evaluating the adequacy and effectiveness of the 
management and reporting and control systems 
associated with material risks.

•  Establishment and monitoring of Medibank’s 

overall risk appetite.

•  Monitoring and review of Medibank's risk culture.

•  Oversight of, and monitoring progress against, 

Medibank's sustainability strategy.

•  Oversight and prior endorsement of the 
appointment and replacement of the  
Chief Risk Officer.

Investment and 
Capital Committee

•  At least three members, all of whom  

•  Assisting and advising the Board on capital  

are non-executive directors.

and investment related matters.

•  Peter Hodgett 
(Chairman)

•  Anna Bligh

•  David Fagan

•  Mike Wilkins

•  The chairman must be an independent 
non-executive director, appointed by  
the Board.

•  Overseeing the investment strategy and  

Capital Management Policy.

•  Monitoring the effectiveness of the investment 

process.

•  Authorising delegated investment decisions.

1.   Gerard Dalbosco was appointed a member of the Audit Committee on 21 May 2021, following Mike Wilkins’ retirement from the committee. Mike Wilkins 
was a member of the committee from 1 October 2020 until his retirement effective 21 May 2021, replacing Elizabeth Alexander who was a member  
of the committee during the period from 1 July 2020 until her retirement effective 1 October 2020.

2.   Gerard Dalbosco was appointed a member of the Risk Management Committee on 21 May 2021, following Mike Wilkins’ retirement from the committee. 

Mike Wilkins was a member of the committee during the period from 1 July 2020 until his retirement effective 21 May 2021. Separately, Elizabeth 
Alexander was a member of the committee during the period from 1 July 2020 until her retirement effective 1 October 2020.

Annual Report 2021    39 

 
 
 
 
Corporate governance statement

Committee 
membership as at  
25 August 2021

People and 
Remuneration 
Committee

•  Linda Bardo Nicholls 

(Chairman)

•  Tracey Batten

•  Anna Bligh

•  Mike Wilkins3

Nomination 
Committee 

•  Mike Wilkins 
(Chairman)4

•  David Fagan

•  Peter Hodgett

•  Linda Bardo Nicholls

•  Christine O'Reilly

Composition

Key roles and responsibilities

•  At least three members, all of whom  

•  Reviewing and overseeing people and 

are non-executive directors, a majority  
of whom are independent directors  
and at least one of whom is a member  
of the Risk Management Committee.

•  The chairman must be an independent 
non-executive director, appointed by  
the Board.

organisational culture strategies, including 
employee engagement, values and behaviours.

•  Reviewing the remuneration framework and 

arrangements for the non-executive directors, 
CEO and ELT.

•  Reviewing executive succession planning,  
talent management, industrial relations  
and diversity strategies.

•  Reviewing and overseeing key incentive  
schemes and equity incentive plans.

•  Recommending to the Board the measurable 

objectives for diversity.

•  Reviewing and monitoring Medibank’s health, 

safety and wellbeing performance.

•  At least three members, all of whom  

•  Director selection and appointment.

are independent directors.

•  The chairman of the Board will be the 

chairman of the committee.

•  Director induction and professional development.

•  Board composition.

•  Board succession planning and renewal.

•  Performance evaluation of the Board, 
committees and individual directors.

3.  Mike Wilkins was appointed a member of the People and Remuneration Committee effective 21 May 2021. 

4.   Mike Wilkins was appointed Chairman of the Nomination Committee effective 1 October 2020. Elizabeth Alexander was a member and Chairman  

of the committee during the period from 1 July 2020 until her retirement effective 1 October 2020.

Executive Leadership Team

Values and ethical standards

Central to the Board’s governance framework is a culture 
of integrity and ethical behaviour based on Medibank’s key 
values: Customers First; Own It, Do It; Show Heart; and One 
Team. These values are intended to guide the way employees 
work together and engage with customers, business partners, 
governments and the wider community, and are supported 
by a range of policies and procedures. Our values are further 
articulated on our website and in our Sustainability Report. 

The CEO, supported by the ELT, is responsible for the 
day-to-day management and performance of Medibank. 
ELT members have a clear understanding of their roles 
and responsibilities through position descriptions and 
a structured performance management system. Profiles and 
accountabilities for ELT members are set out on pages 33  
to 34. Each ELT member has entered into a service 
agreement with Medibank which sets out the terms of their 
employment. Remuneration policies and practices applying to 
the ELT are detailed in the remuneration report from page 50.

The remuneration report (from page 50) contains the 
performance measures applied to ELT members and the 
process for the annual evaluation of their performance. 
A performance evaluation was undertaken during 2021 
in accordance with that process for each ELT member,  
noting that Rob Deeming and Milosh Milisavljevic had  
their 2021 performance evaluated against the positions  
they held prior to joining the ELT.

40    Medibank 

 
 
 
 
Key Policies

Details of key policies supporting our commitment to integrity and ethical behaviour are set out below.  
Copies of each policy can be found on our website.

Purpose

Key provisions 

Code of 
Conduct

Medibank employees are 
required to conduct their 
activities ethically and 
with integrity. The Code of 
Conduct sets out the ethical 
standards that are expected 
of all directors, managers, 
employees and contractors 
in their dealings with 
customers, suppliers and 
each other.

Requires directors, managers, employees 
and contractors to behave with high 
standards of personal integrity, and in  
a manner that:

•  complies with applicable laws,  
standards and internal policies;

•  promotes health, safety and wellbeing;

•  fosters relationships of trust, 

accountability and transparency;

•  avoids conflicts of interest (including  

not offering or accepting inducements, 
secret commissions or bribes); and

•  respects privacy and protects  

confidential information.

Breaches and reporting

Sets out different 
approaches to dealing 
with breaches of the 
Code, depending on the 
circumstances – including 
raising concerns with 
immediate or senior 
managers, the People & 
Culture team, the CEO, or  
via the Whistleblower Policy.

Breaches of the Code of 
Conduct are reported to the 
People and Remuneration 
Committee.

Whistleblower 
Policy

Anti-Bribery 
and  
Corruption 
Policy

Medibank is committed to a 
culture where our people are 
encouraged to speak up if 
something doesn’t look right, 
and to support them when 
they do. The Whistleblower 
Policy establishes what is 
reportable conduct, how to 
contact Medibank Alert, and 
the protections available to 
whistleblowers. 

Medibank has zero tolerance 
for bribery and corruption. 
The Anti-Bribery and 
Corruption Policy describes 
conduct that is prohibited  
for directors, employees  
and contractors when 
conducting business on 
behalf of Medibank, and how 
breaches can be reported. 

Share Trading  
Policy

The Share Trading Policy 
describes restrictions on 
buying and selling Medibank 
shares for the Board, the ELT, 
senior executives and other 
Medibank employees. 

Sets out the types of conduct that can be 
disclosed, who may make a disclosure under 
the policy and what to include in a report.

Sets out support and protection available 
to whistleblowers, and the processes 
for managing whistleblower complaints 
(including key roles and responsibilities).

Provides details of 
the Medibank Alert 
whistleblower service, which 
is available through an 
external provider, enabling 
whistleblowers to report 
anonymously or limit who is 
informed of their identity.

Requires that directors, employees and 
contractors: 

•  not offer, pay or accept inducements, 

bribes, kickbacks, secret commissions  
or improper payments, or engage in 
corrupt business practices;

•  not accept gifts, hospitality or anything 
of value which may have obligations 
attached;

•  not offer or give anything of value, or 

solicit any inducement, that may conflict 
with their work or duties to Medibank; and

•  ensure approved grants and donations  

are appropriately recorded.

Prohibits directors, executives and 
employees from dealing in Medibank or 
other securities if they possess inside 
information.

Prohibits trading by directors, executives and 
certain restricted employees in Medibank 
securities during blackout periods, which 
apply in the lead-up to the release of financial 
results and at other times as required.

Breaches of the policy 
are reported to the Risk 
Management Committee.

Requires requests for  
bribes or facilitation 
payments to be reported  
to the Chief Risk Officer.

Requires other breaches  
or potential breaches to  
be reported to the Chief  
Risk Officer or the 
Whistleblower Hotline.

Breaches of the policy 
are reported to the Risk 
Management Committee.

Details the penalties at 
law for breaches of insider 
trading laws and the 
consequences as a director 
or employee for a breach  
of law and the policy.

Annual Report 2021    41 

Corporate governance statement

Ethical conduct is also supported by a range of other 
corporate policies, including in the areas of conflicts of 
interest, health, safety and wellbeing and modern slavery. 
Copies of these policies are also available on our website. 

The Health, Safety and Wellbeing Policy underpins our 
objective of preventing injury and illness through a culture 
of health promotion, injury prevention and early intervention. 
Medibank has a health and safety management system 
in place to ensure it meets legislative requirements and 
proactively addresses its key risks in health and safety. 

Diversity and inclusion

Medibank is committed to creating an inclusive culture that 
acknowledges and embraces difference in all its forms and 
ensures that every voice is heard. Medibank recognises that 
all employees are different, and these differences benefit  
our employees, shareholders, customers and the community. 

The Board has adopted a Diversity and Inclusion Policy  
that supports and facilitates an inclusive environment.  

The policy outlines the role of the People and Remuneration 
Committee in recommending to the Board measurable 
objectives for diversity and annually assessing progress 
against these. The policy is reviewed annually and is available 
on Medibank’s corporate website. A Diversity and Inclusion 
Strategy supports the policy and sets out the measurable 
objectives established by the Board.

The Board emphasises the importance of having a gender 
diverse leadership team, which is supported by Medibank’s 
commitment to having and maintaining at least 40 percent 
female representation in the Group and senior executive 
population. As at end June 2021 the actual representation 
was 51%.

In June 2021, Medibank completed the reporting of its gender 
equality indicators under the Workplace Gender Equality Act 
2012 (Cth). The reports can be accessed on the corporate 
website. As at end June 2021, the respective proportions of 
men and women on the Board, in senior executive positions 
and across the organisation were as follows:

Position
Board (including CEO)
Group Executives (including CEO)1
Senior executives2
Group and senior executive total
Senior managers
Other managers
Non-managers
Overall (excluding Board)

Women
4
2
25
27
106
334
2,288
2,755

Men
5
6
20
26
112
305
650
1,093

Other

2
8
10

% Women
44%
25%
56%
51%
49%
52%
77%
70%

1.  Group Executive positions refer to the CEO and the Executive Leadership Team (ELT). All of the ELT report directly to the CEO. 

2.   Senior executive positions include all roles classified as senior executives as part of Medibank’s broad based banding framework. As at 30 June 2021,  

they represent the 45 most senior positions in the Group outside of Group Executive roles.

42    Medibank 

In 2020 the Board set measurable objectives for achieving diversity at Medibank, including gender diversity, and committed  
to reporting progress achieved against these in the 2021 corporate governance statement. The table below shows our  
progress against these objectives:

Measurable objective

Progress towards achievement

Medibank will remain committed  
to ensuring a representation of  
at least 40% women across our 
senior leadership population,  
and at least 40% of women on  
the Medibank Board.

Medibank will aim to improve  
the gender balance across our 
manager and non-manager 
population by maintaining at least 
40% women across our manager 
workforce and improving the 
representation of men in our  
non-manager workforce.

Medibank will continue its focus on 
increasing the representation and 
self-reported engagement of:

•  Aboriginal and Torres Strait 

Islander employees (with a target 
set of at least 32 employees); and

•  Employees with a disability.

As at June 2021, women represented 51% of Group and senior executives, 
with the number of women at senior executive level increasing by 3% to 56%.  
Female representation on the Medibank Board was still above target at 44% 
(including the CEO), a decrease from 56% in FY20.

Women represented 50% of all manager roles (excluding Group and senior 
executives) and 77% of non-manager positions (compared to 78% in FY20).  
This was largely driven by our Healthcare & Strategy division where women  
made up 84% of non-manager roles (compared to other divisions where  
women represented 70%). This is characteristic of the broader Australian  
health workforce, which is comprised of 79.6% women1. 

In FY21, the number of employees identifying as Aboriginal and Torres Strait  
Islander increased to 33 people (up from 16 people in FY20), which equates to  
1% of Medibank employees. Our employee survey showed the engagement score  
for this cohort was 6.9 which is lower than the Medibank average of 7.8. 

We launched a Cultural Awareness program, including online, face-to-face and 
immersive experiences, as well as bespoke content related to our health operations. 
64% of our people participated in the program. We also launched our Aboriginal 
Employee Network, which aims to create a safe space for Aboriginal and Torres 
Strait Islander people and to help grow, develop and retain our Aboriginal  
and Torres Strait Islander workforce. 

In FY21, 4% of employees identified as having a disability, down from 6% in FY20. 
Engagement for this group was consistent with the Medibank average of 7.8. 

We continued to focus on inclusion of people with disabilities through our 
Accessibility and Inclusion Plan, and ranked 2nd in the 2020 Australian Network  
on Disability Index. We worked to improve the process for workplace adjustments  
for people with disability and ensured that our digital platforms and retail spaces  
are accessible for customers with a disability.

Medibank will improve the support 
available to employees with caring 
responsibilities for elderly parents, 
people with a disability or chronic 
condition.

In FY21, we launched a Carers Support Network, the first stage of a broader  
targeted carers support package we are developing to assist the significant 
proportion of employees (17%, as measured by our employee engagement survey) 
who have caring responsibilities; either elderly parents, or a family member with  
a disability or chronic condition.

1.  Workplace Gender Equality Agency (2020). Australia’s gender equality scorecard.

Annual Report 2021    43 

Corporate governance statement

For 2022, the Board has set the following measurable 
objectives for achieving diversity at Medibank, including gender 
diversity, and is committed to reporting progress achieved 
against these in the 2022 corporate governance statement:

 1.    

 2.    

 3.    

 4.    

 Medibank will remain committed to ensuring a 
representation of at least 40% women across  
our senior leadership population, and at least  
40% women on the Medibank Board.

  Medibank will aim to improve the gender  
balance across our manager and  
non-manager population by maintaining at  
least 40% women across our manager  
workforce and improving the representation  
of men in our non-manager workforce.

 Medibank will continue to focus on the  
representation of Aboriginal and Torres Strait 
Islander employees with a target set of at least 42 
employees (approx. 1.4% of our organisation) and 
their improved self-reported engagement through 
the delivery of a new Reconciliation Action Plan.

  Medibank will cultivate a disability confident  
culture leading to an increase in the  
representation and self-reported engagement  
of employees with a disability.

  5.   

  Medibank will provide a market leading 
comprehensive and targeted support carers  
package to improve the engagement of employees 
with caring responsibility for elderly parents,  
or a person with a disability or chronic condition.

Market and shareholder communication
Market disclosure

We promote investor confidence and the rights of shareholders 
by ensuring the immediate disclosure of market sensitive 
information regarding Medibank. The measures to further 
these commitments are detailed in the Disclosure and 
Communication Policy approved by the Board, which is 
available on our website.

This policy is designed to facilitate compliance with 
Medibank’s obligations under the ASX Listing Rules and 
the Corporations Act 2001 (Cth) by assigning authorisation 
processes for market announcements and reserving certain 
matters for approval by the Board. The policy also requires the 
Board to receive copies of material market announcements 
promptly after they have been made. Processes for 
engagement with analysts and investors are detailed in the 
policy as well as the assignment of spokespersons for market 
and media communications. Awareness and compliance is 
promoted by compulsory periodic online employee training 
and additional information sessions for those likely to  
become aware of potentially market sensitive information. 

44    Medibank 

The Board is supported by a management Disclosure Committee 
responsible for considering potentially market sensitive 
information and monitoring Medibank’s disclosure processes 
and reporting framework. The Disclosure Committee Charter 
is available within the Disclosure and Communication Policy.

Medibank’s full year financial reports are audited, and our 
half year financial reports reviewed, by our external auditor. 
For other periodic corporate reports, such as the Annual 
Report and Sustainability Report, relevant subject matter 
experts confirm the factual accuracy of relevant statements; 
final reports are also reviewed by senior executives who 
have the knowledge and skills to verify the accuracy of the 
information. Periodic corporate reports are reviewed and 
where appropriate, approved by the Board prior to publication. 

Information about Medibank and its governance

Our website provides information about Medibank and 
its corporate governance, and an investor centre that 
provides information specifically for prospective and existing 
Medibank shareholders which links to Medibank’s results, 
investor presentations, annual reports, share price, ASX 
announcements and AGM materials. We also maintain a 
shareholder calendar of upcoming events within the investor 
centre, along with information to assist investors in managing 
their shareholdings. Medibank’s share register is managed by 
Computershare Investor Services Pty Limited which provides 
an accessible online platform for shareholders to access and 
manage their shareholdings.

Medibank encourages shareholders to receive communications 
securely by email for reasons of speed, security, environmental 
friendliness and cost reductions. If a shareholder so elects, 
Medibank will communicate with them via email and other 
electronic channels, including providing notices of meetings 
and facilitating online voting on the AGM resolutions.

Investor engagement

We conduct briefings, meetings, telephone calls and webcasts 
for institutional and retail investors, analysts and proxy 
advisors to provide a greater understanding of the business 
and results. Investor briefings and ad hoc meetings with 
institutional and retail investors, analysts and proxy advisors 
provide a forum for two-way communications between 
Medibank and the investment community. During the year,  
we participated and presented at a number of conferences 
and investor events, including the Citi Australia and  
New Zealand Annual Investment Conference in October  
2020, the UBS Australasia Conference in November 2020,  
the Morgan Stanley Private Healthcare Forum in April 2021 
and the Macquarie Australia Conference in May 2021. 

We generally communicate with the investment community 
through the CEO, the Group Executive – Chief Financial  
Officer & Group Strategy and the Senior Executive  
– Investor Relations.  

 
 
 
  
 
  
 
  
  
 
We also communicate through the Chairman for governance 
and remuneration issues and the Company Secretary and 
Group Executive – People & Culture for environmental,  
social and governance issues. Feedback from engagement 
with the investor community is communicated to the Board  
at each Board meeting.

In all communications with investors, analysts and media, 
only publicly available information and information that is 
not market sensitive is discussed. In order to ensure that 
all shareholders have equal and timely access to material 
information concerning Medibank, advance notification of 
investor and analyst results briefings is announced via the 
ASX. The briefing materials are released first via the ASX  
and then on the investor centre section of our website, 
together with a recording of the half and full year results 
briefing. We also release the materials for new and 
substantive investor and analyst presentations to the  
ASX before the presentation starts. 

Shareholder meetings

The Board encourages shareholders to attend the AGM and  
to take the opportunity to ask questions. Given the health 
risks and government restrictions associated with the 
COVID-19 pandemic, the Board has decided to hold the 2021 
AGM virtually. Shareholders will be able to attend, participate 
and vote in the AGM via an online platform. The meeting is 
also accessible via a live webcast, and then made available  
on our website. All substantive resolutions at the meeting  
are decided by a poll. 

The external auditor attends the AGM and is available at the 
meeting to answer questions relevant to the auditor’s report. 

We provide shareholders with a clear and concise notice of 
meeting, setting out the business to be considered, including 
all material information relevant to the election or re-election 
of directors. These materials, together with the presentations 
at the AGM and the voting results, are released to the ASX  
and then made available on our website.

Integrity of financial reporting

The Board has a strong commitment to the integrity and 
quality of its financial reporting and its systems for risk 
management, compliance and internal control.

The role of the Audit Committee is to provide an objective, 
non-executive review of the effectiveness of Medibank’s 
internal control, financial reporting and risk management 
framework, to assist the Board in carrying out its accounting, 
auditing, and financial reporting responsibilities. Details  
of the composition and key roles and responsibilities of  
the Audit Committee are set out on page 39. 

In addition to the members of the Audit Committee, 
any director may attend Audit Committee meetings. 
Representatives of management and the Senior Executive 
– Internal Audit may attend Audit Committee meetings 

by standing invitation, and the Chief Actuary and external 
auditors are invited as required. 

Financial reporting assurances

The preparation of the full year and half year financial 
statements is subject to a detailed process of review and 
approval by the Board supported by the Audit Committee.

As required under section 295A of the Corporations Act 2001 
(Cth), the Board receives a declaration from the CEO and 
the CFO that the financial records of the company have been 
properly maintained and that the financial statements and 
notes comply with accounting standards and give a true and 
fair view of the consolidated entity’s financial position and 
performance for the financial period. This includes a written 
declaration that their opinion has been formed on the basis 
of a sound system of risk management and internal control 
which is operating effectively in all material respects.

This declaration was received by the Board prior to  
approving the financial statements for the half year ended  
31 December 2020 and the full year ended 30 June 2021.

Internal audit

Medibank has an internal audit function. The purpose of 
the internal audit function is to provide the Board and Audit 
Committee with an independent evaluation of the adequacy 
and the effectiveness of Medibank’s financial and risk 
management framework. The rolling 12-month Internal  
Audit Plan, which is approved by the Audit Committee, is 
developed using a risk-based approach and is driven by 
Medibank’s strategy, risk profile and assurance priorities.

The Internal Audit Charter provides the internal audit team 
unrestricted access to review all activities of the business. The 
internal audit function is supplemented by the engagement of 
external subject matter experts when required.

The head of the internal audit function is the Senior Executive 
– Internal Audit. To ensure the independence of the internal 
audit function, the role reports directly to the Audit Committee 
chairman, with a direct communication line to the CEO and 
administrative reporting line to the Group Executive – Chief 
Financial Officer & Group Strategy. The Senior Executive – 
Internal Audit (in addition to their standing invitation to attend 
Audit Committee meetings) reports to each Audit Committee 
meeting on progress against the rolling 12 month Internal 
Audit Plan, audit findings and recommendations, business 
insights and the status of management actions.

Risk management

Medibank’s risk management framework encompasses  
the systems, structures, policies, processes and people  
that manage risks across the business. It guides risk 
management activities across the business to effectively 
identify, assess, manage, monitor and report risks.  

Annual Report 2021    45 

Corporate governance statement

The framework is implemented through the three lines of  
defence model and its effectiveness is assessed by the 
internal audit function on an annual basis with a full 
comprehensive review on a three yearly basis in accordance 
with the Risk Management Committee Charter and 
APRA Prudential Standard CPS220, with these reports 
being provided to and reviewed by the Risk Management 
Committee. Both annual and three yearly reviews of the 
framework were completed in 2021. The Risk Management 
Committee reviews the documents comprising the risk 
management framework at least yearly and regularly 
monitors the framework’s effectiveness.

A key component of the framework is the definition of 
Medibank’s risk appetite by the Board which informs 
management's decision making process. The annual and 
three yearly reviews of the framework consider whether  
the framework is sound and Medibank is operating with  
due regard to the risk appetite set by the Board.

Medibank continues to operate and strengthen enterprise  
risk management practices in alignment with the 
requirements outlined in the APRA Prudential Standard 
CPS220 – Risk Management.

Material risks

Material business risks are those risks deemed to have 
a significant impact on Medibank’s operations, financial 
prospects and business objectives. These are discussed  
in the operating and financial review on pages 28 to 29 of  
the annual report. The material risks are strategic, credit, 
capital and liquidity, market and investment, insurance, 
clinical, operational and regulatory compliance. 

Environmental, social and governance risks

Medibank’s risk management framework also applies  
to environmental, social and governance (‘ESG’) risks. 
Medibank’s material ESG topics, as identified in our social  
and governance framework, have been mapped to our 
material categories in the operating and financial review  
on pages 28 to 29 of the annual report. 

Medibank commissioned an independent external review to 
assess our exposures to climate change risks in line with 
the recommendations of the Task Force on Climate-related 
Financial Disclosures (TCFD). The review did not identify 
material exposures at this time for Medibank; however, the 
outcomes of the review, and Medibank’s response, have been 
reported on page 53 of our Sustainability Report. Further 
detail on Medibank’s approach to sustainability and ESG 
issues can also be found in our Sustainability Report. 

Governance

The Board has overall responsibility for Medibank’s risk 
management framework including setting the risk appetite 
for Medibank. The Board reviews the risk management 
framework at least annually and satisfies itself that 
management has developed and implemented a sound 

46    Medibank 

system of risk management and internal control to  
effectively manage risk across the business in line  
with regulatory and statutory requirements.

The Risk Management Committee assists the Board in 
overseeing the implementation of the risk management 
framework. Currently, the committee comprises four  
non-executive directors, at least one of whom is a member  
of the Audit Committee. The chairman of the committee  
is an independent non-executive director who is not the 
chairman of the Board. Committee members are appointed 
based on their qualifications and experience to ensure that 
the committee can adequately discharge its duties.

Risk management plays an important role in remuneration 
outcomes. For an incentive award to be made to any 
employee, a risk, compliance and behaviour gateway must be 
achieved. Further, all employees have a risk KPI incorporated 
into their performance scorecard under the company-wide  
‘I Perform Better’ performance framework. More information 
on the relationship between risk and remuneration can be 
found in the remuneration report on pages 58 to 59.

The Board is further assisted by the Investment and 
Capital Committee, which oversees the implementation 
and monitoring of the investment strategy and Capital 
Management Policy approved by the Board, including 
monitoring the effectiveness of the investment process in 
achieving optimum return relative to risk. The Executive Risk 
Committee and Divisional Risk Committees are management 
committees that assist the CEO with the oversight of risk 
management activities across the business to ensure material 
risks are managed in line with the approach defined in the risk 
management strategy and the risk appetite set by the Board.

Medibank has adopted a three lines of defence approach 
to define risk management roles, responsibilities and 
accountability:

First line: Management is accountable for identifying, 
assessing, monitoring and managing material risks in the 
business. They are responsible for decision making and the 
execution of business activities, whilst managing risk to 
ensure it is in line with the Board’s risk appetite and strategy.

Second line: The enterprise risk and compliance functions 
provide objective advice and challenge to the first line on risk 
and control activities and provide assurance and guidance 
on the design and implementation of appropriate risk 
management activities.

Third line: The internal audit function provides independent 
assurance to the Audit Committee and the Board on the 
adequacy and effectiveness of the risk management 
framework, financial reporting processes and internal control 
and compliance systems operating in the first and second line.

This corporate governance statement is accurate and up to 
date as at 25 August 2021 and has been approved by the Board.

Directors’ report
For the financial year ended 30 June 2021

The directors of Medibank Private Limited (Medibank) present 
their report on the consolidated entity consisting of Medibank 
and the entities it controlled (collectively referred to as the 
Group) for the year ended 30 June 2021.

References to 2020 and 2021 are to the financial years 
ended on 30 June 2020 and 30 June 2021 respectively unless 
otherwise stated.

Directors

The names of directors in office during the year and up to  
the date of this directors’ report, unless stated otherwise,  
are as follows:

Current:

•  Mike Wilkins AO – Chairman

•  David Koczkar – Chief Executive Officer  

(appointed effective 17 May 2021)

•  Dr Tracey Batten

•  Anna Bligh AC

•  Gerard Dalbosco (appointed effective 21 May 2021)

•  David Fagan

•  Peter Hodgett

•  Linda Bardo Nicholls AO

•  Christine O’Reilly

Former:

•  Elizabeth Alexander AO (retired effective 1 October 2020)

•  Craig Drummond (ceased as Chief Executive Officer 

effective 17 May 2021)

Mike Wilkins AO commenced as Chairman effective 
1 October 2020, following the retirement of Elizabeth 
Alexander AO. Gerard Dalbosco commenced as a director 
effective 21 May 2021. 

Principal activities

The principal activities of the Group during the financial year 
were as a private health insurer, underwriting and distributing 
private health insurance policies under its two brands, 
Medibank and ahm. Medibank is also a provider of health-
related services through the Medibank Health businesses, 
which capitalise on Medibank’s experience and expertise, 
and support the Health Insurance business. There were no 
significant changes in the nature of those activities during 
the year.

Operating and financial review

Details of the operating and financial review of the Group 
including a review of operations during the year and results 
of those operations is included in the operating and financial 
review on pages 22 to 29.

Significant changes in state of affairs

There were no significant changes in the state of affairs 
of the Group during the year.

Events since end of financial year

No matter or circumstance has arisen since the end of 
the financial year that has significantly affected, or may 
significantly affect, Medibank’s operations, or the results 
of those operations, or Medibank’s state of affairs in future 
financial years. Details of subsequent events are set out 
in Note 20(d).

Future developments

Details of developments in Medibank’s operations in future 
financial years and the expected results of those operations 
are included in the operating and financial review on pages 
25 to 27.

Dividends

Dividends paid or determined by Medibank during and since 
the end of the year are set out in Note 6 to the financial 
statements and further set out below:

•  A fully franked final ordinary dividend of 6.30 cents 

per share was determined in respect of the six-month 
period to 30 June 2020 and paid on 24 September 2020 
to shareholders registered on 3 September 2020. 

•  A fully franked interim ordinary dividend of 5.80 cents 
per share was determined in respect of the six-month 
period to 31 December 2020 and paid on 25 March 2021 
to shareholders registered on 4 March 2021.

•  A fully franked final ordinary dividend of 6.90 cents per 
share has been determined in respect of the six-month 
period to 30 June 2021, payable on 30 September 2021 
to shareholders registered on 9 September 2021.

Directors’ qualifications, experience 
and special responsibilities

Details of the qualifications, experience and special 
responsibilities of each director in office as at the date  
of this report are set out on pages 30 to 32 and form  
part of the directors’ report.

Annual Report 2021    47 

Directors’ report
For the financial year ended 30 June 2021

Directors’ attendance at meetings

The table below shows the number of Board and committee meetings held and the number of meetings attended  
by directors during the year. 

Director

Board 
(scheduled)

Board 
(unscheduled)

Audit 
Committee

Mike Wilkins
Elizabeth Alexander6
Dr Tracey Batten
Anna Bligh
Gerard Dalbosco7
Craig Drummond8
David Fagan
Peter Hodgett
David Koczkar9
Linda Bardo Nicholls
Christine O’Reilly

A
10
3
10
10
1
8
10
10
2
10
10

B
10
3
10
10
1
8
10
10
2
10
10

A
8

8
8

6
8
8

8
8

B
8

8
8

6
8
8

8
8

A
2
2

1

5

5

B
52
2
4*
1*
1
4*
5*
5
1*
4*
5

Risk 
Management 
Committee
B
A
53
5
2
2
6
6
3*

5*
6
4*
1*
4*
6

6

6

5

5
5

Investment 
and Capital 
Committee
A1
5

Nomination 
Committee
B
A
44
3
1
1
3*
1*

4
4

4
4

4
4

4
4

4
4

People and 
Remuneration 
Committee
B
A
45
1
1*
4
4
1*
3*
4*
3*
1*
4
3*

4

B
5
1*
5*
4

5*
5
5
1*
5*
4*

A    Indicates the number of meetings held during the time the director held office or was a member of the committee during the year. 

B   Indicates the number of meetings attended during the period.

*   Indicates that the director attended committee meetings as an invitee.

1    Includes one unscheduled meeting of the Investment and Capital Committee.

2    Mike Wilkins was appointed a member of the Audit Committee effective 1 October 2020 and retired as a member of that committee effective 21 May 2021.  

He attended 2 meetings as a member and 3 as an invitee. 

3    Mike Wilkins retired as a member of the Risk Management Committee effective 21 May 2021. He attended 4 meetings as a member and 1 as an invitee. 

4    Mike Wilkins was appointed a member of the Nomination Committee effective 1 October 2020. He attended 3 meetings as a member and 1 as an invitee.

5  

 Mike Wilkins was appointed a member of the People and Remuneration Committee effective 21 May 2021. He attended 1 meeting as a member and 3 as an invitee.

6   Elizabeth Alexander retired as a director effective 1 October 2020.

7    Gerard Dalbosco was appointed as a director and a member of the Risk Management Committee and Audit Committee effective 21 May 2021. 

8   Craig Drummond retired as a director effective 17 May 2021.

9   David Koczkar was appointed as a director effective 17 May 2021.

In addition, ad-hoc committees were convened for special 
purposes, including in relation to financial reporting,  
selection of the new Chairman and Chief Executive Officer  
and other matters.

Directors’ interests in securities

The relevant interests of directors in Medibank securities 
at the date of this directors’ report were:

Options and performance rights

During the financial year, 3,168,794 performance rights 
were issued to senior executives pursuant to Medibank’s 
Performance Rights Plan. No performance rights have  
been issued since the end of the financial year up to the  
date of this directors’ report.

During the financial year, 1,980,272 performance rights 
became eligible to vest and were exercised. Further 
information regarding performance rights is included  
in the remuneration report from page 50.

48    Medibank 

Director
Mike Wilkins
David Koczkar
Elizabeth Alexander1
Dr Tracey Batten
Anna Bligh
Gerard Dalbosco
Craig Drummond2
David Fagan
Peter Hodgett
Linda Bardo Nicholls
Christine O’Reilly

Performance 
rights

590,232

1,488,044

Ordinary 
shares
100,000
793,689
124,786
50,000
44,623
24,432
1,313,839
47,016
67,800
45,000
69,930

1.   Elizabeth Alexander retired from the Board effective 1 October 2020,  

and her ordinary shareholding information is as at that date.

2.   Craig Drummond retired from the Board effective 17 May 2021, and his 
ordinary shareholding information is as at that date. Craig Drummond’s 
performance rights information reflects the lapsing of performance 
rights in accordance with Medibank’s Performance Rights Plan as set 
out in the ASX announcement dated 9 July 2021. 

Environmental regulation

The Group’s operations are not subject to any particular 
or significant environmental regulation under either 
Commonwealth or State law.

Indemnification and insurance of  
directors and officers

The Medibank Constitution permits Medibank to indemnify, 
to the maximum extent permitted by law, every person who 
is or has been a director, secretary, officer or senior manager 
of the Group. The indemnity applies to liabilities incurred by a 
person in the relevant capacity (except liability for legal costs). 
The indemnity may however also apply to certain legal costs 
incurred in obtaining advice or defending legal proceedings. 
Further, the Medibank Constitution permits Medibank to 
maintain and pay insurance premiums for a director and 
officer liability insurance covering every person who is or  
has been a director, secretary, officer or senior manager 
of the Group, to the extent permitted by law.

Consistent with the provisions in Medibank’s Constitution, 
Medibank has entered into deeds of indemnity, insurance  
and access with current and former directors and secretaries 
of the Group. Under these deeds, Medibank:

•  Indemnifies current and former directors and secretaries 

against liabilities incurred as a director or secretary, as the 
case may be, to the maximum extent permitted by law.

•  Maintains a directors’ and officers’ insurance policy 

covering current and former directors and secretaries 
against liabilities incurred in their capacity as directors 
or secretaries, as the case may be. Disclosure of the 
insurance premium and the nature of the liabilities covered 
by the insurance are prohibited by the contract of insurance.

•  Grants current and former directors and secretaries access 

to Medibank’s records for the purpose of defending any 
relevant action.

The amounts paid or payable for services provided 
by PwC were:

Year ended 30 June
Audit fees
Assurance services fees:
 Audit of regulatory 
compliance returns
 Accounting and other 
assurance services
Total Audit and other 
assurance services fees
Non-audit service fees
Total

2021 
$
1,570,108 

2020 
$
1,581,094 

231,830 

342,264

15,530 

64,260 

1,817,468 
199,517 
2,016,985 

1,987,618 
-
1,987,618 

Based on advice provided by the Audit Committee, the directors 
are satisfied that the provision of non-audit services during 
the year by PwC is compatible with the general standard 
of independence for auditors imposed by the Corporations 
Act, and that the provision of the non-audit services did not 
compromise the auditor independence requirements of the 
Corporations Act, for the following reasons:

•  All non-audit services provided were approved in 

accordance with the process set out in Medibank’s policies, 
including being reviewed by the Audit Committee Chair to 
ensure that provision of the services did not impact the 
integrity and objectivity of the auditor. 

•  The non-audit services provided do not undermine the 
general principles relating to auditor independence 
as set out in APES 110 Code of Ethics for Professional 
Accountants issued by the Accounting Professional and 
Ethical Standards Board. 

Remuneration report

The remuneration report on pages 50 to 74 forms part  
of the directors’ report.

Auditor’s independence declaration

Rounding of amounts

A copy of the auditor’s independence declaration given  
by PricewaterhouseCoopers (PwC) in relation to its 
compliance with independence requirements of section  
307C of the Corporations Act is set out on page 122.

Non-audit services

During the year, PwC, the Group’s external auditor,  
performed certain other services to the Group in  
addition to its statutory responsibilities as auditor. 

The amounts contained in this directors’ report and in the 
financial report have been rounded to the nearest hundred 
thousand dollars (where rounding is applicable) unless 
specifically stated otherwise under the relief available 
pursuant to ASIC Corporations (Rounding in Financial/ 
Directors’ Reports) Instrument 2016/191. Medibank is an  
entity to which that relief applies.

This report is made in accordance with a resolution  
of the directors.

Mike Wilkins AO   
Chairman 

David Koczkar 
Chief Executive Officer

Annual Report 2021    49 

 
 
 
 
 
Remuneration report
For the financial year ended 30 June 2021

Dear Shareholder,

On behalf of the Board, I am pleased to present Medibank’s 
remuneration report for 2021 which describes how non-
executive directors and Executive Leadership Team (ELT) 
members are paid. Included in this report are the variable 
remuneration outcomes for the ELT, which were determined 
after considering the Company’s results and the individual 
performance of our executives. 

Our remuneration strategy has been developed to ensure 
remuneration is fair and competitive, and in 2021 the Board 
has continued to focus on a governance framework that 
rewards responsible behaviours, aligns remuneration with 
regulatory requirements and has regard for the expectations 
of our customers, shareholders and the community. 

In his previous role as Medibank’s Chief Customer Officer, 
David has been a champion for our customers and has played 
an instrumental role in the growth and re-positioning of 
Medibank. The Board is now working with David to progress 
our strategy of becoming a broader health company.

Changes to the Executive Leadership Team  
and key management personnel

Following the CEO transition, changes were made to the 
structure of the ELT to ensure Medibank continues to focus 
on providing greater choice for our customers, as well as 
working with our partners to be a driver of change within the 
health system. The key changes are outlined below, with all 
appointments completed prior to 30 June 2021:

As an organisation providing insurance and healthcare with 
a clear purpose of ‘Better Health for Better Lives’, the Board 
is proud of how Medibank has continued to support our 
customers, employees and the broader community through 
these challenging times. 

•  Milosh Milisavljevic was appointed to the role of Group 

Executive – Customer Portfolios. Milosh’s experience leading 
customer transformations across various industries will 
be instrumental to strengthening Medibank’s products and 
services for our customers, and our provider relationships. 

Medibank has supported our customers through the 
pandemic with initiatives totalling around $300 million in 
financial support to date, the largest in our 45 year old history. 
This includes the return of $103 million of permanent net 
claims savings due to COVID-19 through premium relief. 
These initiatives are part of Medibank’s standing commitment 
to return all permanent net claims savings due to COVID-19 
to our customers once they are known. Our employees 
showed great resilience during 2021 delivering high quality 
services and support throughout lockdowns and other 
challenges created by the pandemic. During the year we 
continued to prioritise our employee’s health and wellbeing, 
with initiatives focused on mental health support and staying 
connected to one another through the launch of our new 
Future Fit way of working. As stated last year, Medibank has 
been able to support our employees and customers without 
accessing any form of taxpayer-funded government relief.

Chief Executive Officer transition

In February 2021, after nearly five years as Chief Executive 
Officer (CEO), Craig Drummond announced his intention 
to retire. The significant improvement in our dual brand 
proposition, customer acquisition and retention, brand 
advocacy and the expansion into delivering a broad suite 
of health services, demonstrate the strength and diversity  
that has been created at Medibank under Craig’s leadership.  
Craig has left the company in a much stronger position,  
on a clear strategic path, with a great team and accordingly 
has been deemed a ‘good leaver’ by the Board.

Following the announcement of Craig’s retirement, the  
Board was pleased to appoint David Koczkar as Medibank’s 
Chief Executive Officer, effective from 17 May 2021.  

•  Rob Deeming was appointed to the role of Group Executive 

– Customer & Brands. Rob’s entrepreneurial spirit combined 
with his experience leading consumer brands and growing 
digital businesses will be key to continuing to grow the 
Medibank and ahm brands and our customer channels.

•  Dr Andrew Wilson took on an expanded accountability 
as Group Executive – CEO Health Services. Andrew’s 
experience and expertise within the health sector is an 
asset to the company and he is well placed to oversee our 
growth in becoming a broader health services provider.

•  Mark Rogers took on an expanded accountability as Group 
Executive – Chief Financial Officer (CFO) & Group Strategy. 
Mark’s knowledge of our company, our sector and the 
broader market, as well as his previous experience in 
strategy development and mergers and acquisitions will be 
beneficial to expanding our role in health, including through 
future inorganic growth.

Following the changes to Medibank’s ELT composition and 
changes in ELT operation effective 1 July 2021, the Board 
assessed which ELT members had the requisite authority 
and responsibility within the Medibank Group to meet the 
definition of key management personnel (KMP) as set out 
in AASB 124 – Related Party Disclosures for the purposes of 
our remuneration reporting obligations. As a result of these 
changes, from 1 July 2021, Medibank’s Executive KMP will 
now include the following roles: CEO, Group Executive – CFO 
& Group Strategy, Group Executive – CEO Health Services 
and Group Executive – Customer Portfolios. Please note that 
the newly established Group Executive – Customer & Brands 
position is not recognised as a KMP under the accounting 
standard and is therefore not included in this report.

50    Medibank 

Changes to the Board

After joining the Medibank Board in October 2008 and serving 
as Chairman since March 2013, Elizabeth Alexander retired 
from Medibank on 1 October 2020. During her tenure, Elizabeth 
led Medibank through its highly successful public listing in 2014 
and helped reposition the company for growth as it pursues 
a strategy of developing into a broader health company.

Following Elizabeth’s retirement, Mike Wilkins was appointed 
as the Chairman on 1 October 2020 and Gerard Dalbosco 
joined the Board as a non-executive director on 21 May 2021.

These performance outcomes resulted in STI awards for ELT 
members that averaged 80% of their maximum opportunity. 
However, with consideration of the challenging social and 
economic environment of the pandemic and the expectations 
of our shareholders, customers and the broader community, 
the Board exercised its discretion to reduce ELT incentive 
outcomes resulting in STI awards for ELT members that 
averaged 70% of their maximum opportunity. A similar 
reduction was applied to the Company-wide incentive pool. In 
the Board’s view, final incentive awards reflect an appropriate 
outcome based on Medibank’s 2021 performance.

Remuneration decisions at a glance

Long-term incentives

•  All ELT members met their individual risk, compliance  

and behaviour gateways for 2021.

•  Discretion was exercised to reduce 2021 short-term 
incentive (STI) outcomes for ELT members from an  
average of 80% of their maximum opportunity, to 70%.

•  32% vesting of Medibank’s 2019 long-term incentive (LTI)  

in line with the terms of grant.

•  Adjustments to ELT remuneration aligned with recent 

appointments – further details in section two of this report.

•  Non-executive director fees maintained at their current 
levels and within the cap approved by shareholders at  
the 2018 annual general meeting.

Short-term incentives

Despite the challenging environment, the resilience of 
our business and our highly engaged people have enabled 
Medibank to deliver a solid operational and financial 
performance aligned to our values and purpose of ‘Better 
Health for Better Lives’. In assessing Medibank’s 2021 
performance against our STI measures, the Board adjusted 
outcomes to normalise for unbudgeted COVID-19 related 
impacts (both negative and positive) outside of management’s 
control to ensure that executives did not benefit from windfall 
gains. Following this assessment, Group operating profit and 
Brand Net Promoter Score (NPS) performance both exceeded 
target expectations, while Health Insurance revenue growth 
landed just below target expectations.

Medibank’s 2019 LTI was tested following the completion  
of the performance period on 30 June 2021 and resulted  
in a vesting outcome of 32% in line with the terms of grant. 
This outcome reflects no vesting against the earnings per 
share compound annual growth rate (EPS CAGR) measure, 
and partial vesting against the relative total shareholder 
return (TSR) measure, with a performance rank at the  
57th percentile against our comparator group.

ELT remuneration and non-executive director fees

The remuneration settings for ELT members recently 
appointed to new or changed positions were adjusted 
following a review of benchmark data, with details of  
these changes outlined in section two of this report. For  
the second consecutive year, non-executive director fees  
have been maintained at their current levels. The Board 
considered this to be an appropriate outcome with 
consideration of the current economic conditions and  
social environment of the pandemic and the positioning  
of non-executive directors against the benchmark data.

Shareholders are encouraged to vote to adopt the report  
at our annual general meeting in November.

Yours sincerely,

Linda Bardo Nicholls AO 
Chairman, People and Remuneration Committee

Annual Report 2021    51 

Remuneration report
For the financial year ended 30 June 2021

Contents

1. 

 Key management personnel overview

8. 

 2021 actual remuneration

2. 

 Summary of remuneration outcomes

3. 

 Medibank’s remuneration strategy

4. 

5. 

6. 

7. 

 Remuneration governance
 4.1  The role of Board in remuneration
 4.2  Executive remuneration policies

 Risk and remuneration
 5.1  Risk culture
 5.2  Alignment of remuneration with prudent risk-taking
 5.3  Consequence management

 Executive remuneration components
 6.1   2021 target remuneration mix
 6.2   Total fixed remuneration
 6.3   Short-term incentive
 6.4   Long-term incentive

 Linking remuneration and performance in 2021
 7.1   2021 STI performance scorecard
 7.2   Medibank’s 2021 financial performance
 7.3   2021 STI awards
 7.4   2019 LTI Plan outcomes

9. 

 Statutory remuneration tables
 9.1   Statutory remuneration table
 9.2   Performance-related remuneration statutory table

10. Executive Leadership Team equity awards

 10.1  ELT equity award transactions
 10.2  ELT members’ ordinary shareholdings

11.   Non-executive director remuneration strategy  

 and framework
 11.1  Non-executive director remuneration
 11.2  Non-executive director superannuation
 11.3  Shareholding policy for non-executive directors

12.  Non-executive director statutory remuneration table

13.  Non-executive director ordinary shareholdings

14.  Medibank’s comparator groups

1. Key management personnel overview

Medibank’s key management personnel (KMP) includes all non-executive directors and executives  
who have authority and responsibility for planning, directing and controlling the activities of Medibank. 

In 2021, KMP were as follows: 

Executive Leadership Team (ELT) member

David Koczkar1 
Chief Executive Officer 
Full-year

Kylie Bishop 
Group Executive  
– People & Culture 
Full-year 

John Goodall 
Group Executive – 
Technology & Operations 
Full-year

Milosh Milisavljevic 
Group Executive  
– Customer Portfolios 
From 22 June 2021

Mei Ramsay 
Group Executive – Legal, Governance  
& Compliance and Company Secretary 
Full-year

Mark Rogers 
Group Executive – Chief Financial 
Officer & Group Strategy 
Full-year 

Andrew Wilson 
Group Executive –  
CEO Healthcare Services  
Full-year

1.  David Koczkar was in the position of Chief Customer Officer until his appointment as Chief Executive Officer on 17 May 2021.

52    Medibank 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Non-executive directors

Mike Wilkins2 
Chairman 
Full-year

Tracey Batten 
Non-executive director 
Full-year

Anna Bligh 
Non-executive director 
Full-year

Gerard Dalbosco3 
Non-executive director 
From 21 May 2021

David Fagan 
Non-executive director 
Full-year

Peter Hodgett 
Non-executive director 
Full-year

Linda Bardo Nicholls 
Non-executive director 
Full-year

Christine O’Reilly 
Non-executive director 
Full-year

Former KMP

Elizabeth Alexander4 
Retired Chairman 
Retired 1 October 2020

Craig Drummond5 
Retired Chief Executive Officer 
Ceased as CEO on 17 May 2021

2.  Mike Wilkins was a non-executive director for the full year and was appointed Chairman on 1 October 2020.

3.  Gerard Dalbosco commenced as a non-executive director on 21 May 2021.

4.  Elizabeth Alexander retired from the position of Chairman on 1 October 2020. 

5.   Craig Drummond retired from the position of Chief Executive Officer and Managing Director on 17 May 2021,  

however remained employed through to 30 June 2021.

Annual Report 2021    53 

Remuneration report
For the financial year ended 30 June 2021

2. Summary of remuneration outcomes

Key remuneration outcomes for ELT members and non-executive directors during the year are summarised below, 
with more detailed information contained throughout the report.

Executive Leadership Team (ELT) member

Component

Outcomes

Fixed 
remuneration 

•  Following a review of benchmark data the fixed remuneration for ELT members recently  

appointed to new or changed positions are as follows:

 – David Koczkar – $1,500,000
 – Milosh Milisavljevic – $780,000
 – Mark Rogers – $1,000,000
 – Andrew Wilson – $1,000,000

Short-term 
incentive  
(STI)

•  STI awards for ELT members reflected Group operating profit and Brand Net Promoter Score (NPS) 
performance exceeding target expectations, while Health Insurance revenue growth landed just 
below target expectations.

•  Discretion was exercised to reduce the 2021 STI outcomes for ELT members from an average  

of 80% of their maximum opportunity, to 70%.

•  50% of STI awards for ELT members deferred for 12 months in the form of performance rights.
•  Changes to the 2022 target and maximum STI percentages for ELT members recently appointed 

to new or changed positions are as follows:

 – David Koczkar – 100% target / 150% maximum
 – Milosh Milisavljevic – 65% / 100%
 – Mark Rogers – 65% / 120%
 – Andrew Wilson – 65% / 120%

Long-term 
incentive  
(LTI)

•  Medibank’s 2019 LTI was tested following the completion of the performance period on  
30 June 2021 and resulted in a vesting outcome of 32% in line with the terms of grant.

•  This outcome reflects no vesting against the earnings per share compound annual growth rate  
(EPS CAGR) measure, and partial vesting against the relative total shareholder return (TSR) 
measure, with a performance rank at the 57th percentile against our comparator group.
•  Changes to the 2022 LTI opportunity percentages for ELT members recently appointed to  

new positions are as follows:

 – David Koczkar – 150%
 – Milosh Milisavljevic – 65%

Former  
Chief Executive 
Officer (CEO)

•  In line with the terms of Medibank STI and LTI plans and on the basis of being a 'good leaver',  

Craig Drummond’s variable remuneration was treated as follows:
 – Full entitlement to a 2021 STI award on the basis of being employed for the entire performance 
year. 50% of Craig’s STI award will be paid in cash in September 2021, and 50% awarded as 
deferred cash, due to vest in September 2022.

 – Craig’s outstanding 2019, 2020 and 2021 LTI performance rights will be retained on a pro-rata 

basis and remain in restriction subject to the original performance hurdles.

 – Craig will retain 253,972 of his 761,920 2021 LTI performance rights; 443,352 of his 665,028 2020 

LTI performance rights; and all 790,720 of his 2019 LTI performance rights.

Non-executive directors

Component

Decisions

Non-executive 
director fees

•  Non-executive director base and committee fees have been maintained at current levels for the 

second consecutive year.

•  Based on this decision, Medibank’s aggregate non-executive director fee spend will remain at 

$1,940,000 in 2022.

•  The total fee pool approved by shareholders at the annual general meeting in 2018 remains unchanged.

54    Medibank 

3. Medibank’s remuneration strategy 

At Medibank, we believe that remuneration is a key influencer 
of behaviour and can be used as a tool to reinforce our culture. 
Our people are guided by our strong set of values which are 
anchored to the core pillars of our culture – our purposes,  
our people and customers and our performance. We focus  
on our values every day to ensure we do the right thing by  
our customers, employees and the community. 

Our remuneration strategy has been developed to focus ELT 
members on responsibly executing Medibank’s strategy, 
role-modelling behaviours that strengthen our values-based 

culture and achieving business objectives that increase value 
for our customers and shareholders. Supporting this strategy, 
our remuneration framework is designed to link reward to 
business outcomes, individual performance and behaviour, 
and to support Medibank’s long-term financial soundness  
and risk management framework.

The diagram below illustrates the relationship between 
Medibank’s remuneration strategy, reward framework  
and the timeline of when 2021 remuneration is delivered 
to ELT members.

 Medibank’s remuneration strategy

Focus ELT members on responsibly executing Group strategy to increase customer 
and shareholder value with behaviours aligned with Medibank’s values and purpose

Attract and retain 
key talent through 
competitive and fair 
fixed remuneration

Incentivise 
high performance 
through variable, 
at risk payments

Reward ELT members for 
the achievement of business 
outcomes aligned with 
Medibank’s culture

Align the interests of ELT 
members with increasing 
long-term customer and 
shareholder value

Medibank’s total target reward framework

Total fixed 
remuneration 
(TFR)

•  Determined with reference to capability, experience, the complexity of the role, as well as median pay levels  

of Medibank’s comparator group

•  Paid on a fortnightly basis in base salary and superannuation

Gateways

Performance measures

Delivery

Short-term 
incentive 
(STI)

Long-term 
incentive 
(LTI)

•  Individuals must pass a risk,  
compliance and behaviour 
gateway to be eligible for  
an STI or LTI award

•  Financial Gateway (STI only) 
– Medibank must achieve 
a baseline Group operating 
profit target for an STI to  
be awarded

•  Group operating profit

•  Health Insurance revenue growth

•  Brand Net Promoter Score (NPS)

•  Role-specific metrics

•  Earnings per share compound annual growth rate

•  Relative total shareholder return

•  Growth of Medibank’s private health insurance 

market share

•  50% cash

•  50% performance 
rights deferred  
for 12 months

•  Three-year deferred 
performance rights

2021 remuneration timeline

FY21

FY22

FY23

TFR

Base salary + super

STI

Cash

Deferred

Relative total shareholder return

LTI

Earnings per share compound annual growth rate

Private Health Insurance market share growth

50%

50%

35%

35%

30%

   date earned 

   date granted 

   eligible for payment or vesting

Annual Report 2021    55 

 
 
Remuneration report
For the financial year ended 30 June 2021

4. Remuneration governance

4.2 Executive remuneration policies

Medibank has a robust governance framework in place to 
ensure that our remuneration and performance practices are 
fair, reasonable and aligned with the requirements outlined in 
our risk management framework. Our governance framework 
also considers regulatory compliance, customer outcomes, 
community expectations and the delivery of sustainable 
shareholder value.

4.1 The role of the Board in remuneration

The People and Remuneration Committee (P&RC) is a 
committee of the Board. The diagram below outlines the role 
of the P&RC in assisting and advising the Board on people 
and culture policies and practices, including remuneration.

While there are four permanent members of the P&RC, 
a standing invitation exists to all non-executive directors 
to attend meetings. The Chief Executive Officer (CEO) and 
Group Executive – People & Culture are also invited to attend 
P&RC meetings, except where matters associated with their 
own performance or remuneration are considered. Specific 
governance activities with respect to the P&RC include 
regular reviews of the P&RC Charter to ensure consideration 
of changing regulations, guidelines and best practice and an 
annual audit of committee minutes against the P&RC Charter. 
For P&RC meeting attendance information, refer to the table 
on page 48 of the directors’ report.

4.2.1 Performance evaluation of ELT members

At the outset of each performance year, the Board determines 
the measures against which ELT members will be assessed. 
The measures are a combination of Medibank (Company) 
and role-specific performance measures that are aligned 
to the achievement of Medibank’s customer and financial 
milestones set out in the annual report. Aligned with 
Medibank’s Group-wide performance framework ‘I Perform 
Better’, the role-specific measures for ELT members are 
known as ‘Big Goals’ (an acronym for Bold, Impactful Goals). 
Big Goals are designed to be ambitious, aspirational and shift 
expectations from delivering at a base level against core job 
requirements to driving strong, impactful performance. The 
Big Goals adopted by each ELT member then form the basis 
for the Big Goals adopted by their leadership team members 
and their respective teams to ensure all employees across the 
Group are working towards a shared and consistent strategy. 

At the completion of the performance year, ELT members 
are individually assessed against the risk, compliance and 
behaviour gateway which is outlined in section 6.3. ELT 
members are then attributed an outcome against a 5-point 
rating scale (with a minimum rating of 3 required to receive 
a short-term incentive (STI) award) that assesses ELT 
member performance and behaviours against business 
outcomes and achievement of role-specific performance 
measures. The individual performance ratings of ELT 
members are then combined with performance against 
Company measures to determine STI outcomes. 

Reviewing and overseeing 
Medibank’s key people and 
organisational strategies, 
including employee 
engagement, values, 
behaviours and diversity 
and inclusion

Ensuring that Medibank’s 
remuneration practices 
are consistent with the 
risk management 
framework and drives 
appropriate behaviours

P&RC

Reviewing employee 
remuneration arrangements 
with consideration for 
behaviours, regulatory 
compliance, customer 
outcomes, community 
expectations and 
shareholder value

Reviewing and monitoring 
Medibank’s strategies 
for executive succession, 
talent acquisition 
and retention

Reviewing and monitoring 
Medibank’s health, safety 
and wellbeing strategy 
and performance, 
workplace relations 
and payroll integrity

Independent remuneration 
consultant

•  KPMG provides information 

to assist the P&RC in making 

  remuneration decisions 
  and recommendations 

to the Board

•  The work undertaken by 
  KPMG in 2021 did not 
  constitute a remuneration 
  recommendation

56    Medibank 

 
 
With respect to fixed remuneration adjustments, 
consideration is given to role-specific performance, 
experience, the complexity of the role and Medibank’s market 
comparator group. Additional detail on STI performance 
measures are included in sections 6 and 7 of this report and 
further information on fixed remuneration levels for ELT 
members is outlined in section 6.2.

The CEO provides his performance assessment of each ELT 
member to the Board for consideration. The Chairman, in 
consultation with the Board, assesses the performance, 
behaviour and conduct of the CEO. The Board has ultimate 
discretion over final individual performance outcomes 
for all ELT members to ensure alignment with Medibank 
performance, customer outcomes, community and 
shareholder expectations.

4.2.2 Clawback of executive performance-based 
remuneration

Medibank has an Executive Remuneration Clawback Policy 
that provides discretion to the Board to reduce, cancel, or 
recover (clawback) any performance-based awards made 
to a senior executive employee in certain circumstances 
and subject to applicable laws, including the following:

•  Serious misconduct, fraud or dishonesty by the employee.

•  Any behaviour, act or omission by the employee that impacts 
on the Group’s reputation or long-term financial soundness. 

•  A material misstatement of the Group’s financial statements.

The Executive Remuneration Clawback Policy provides that if 
any of these events have occurred in the previous five financial 
years the Board may, in its absolute discretion, withhold 
an employee’s performance-based payments, require the 
repayment of all, or part of, previous performance-based 
awards, lapse previously deferred and unvested performance-
based rewards, or otherwise alter an employee’s 
remuneration subject to applicable laws. In addition to a 
stand-alone policy, Medibank’s remuneration clawback 
provisions are outlined in executive employment contracts 
and employee equity offer documentation.

4.2.3 Executive shareholding requirements

ELT members are subject to a Minimum Shareholding Policy 
that is designed to strengthen their alignment with customers 
and shareholders by requiring them to hold Medibank 
shares with a value equivalent to 100% of their annual fixed 
remuneration within five years of appointment to the ELT.  
The policy does not require an ELT member to purchase shares, 
however they are restricted from selling their vested employee 
equity holdings (other than to satisfy income tax obligations) 
until they meet the minimum shareholding requirement.

All Medibank shares and unvested performance rights that 
are subject to a tenure-based hurdle held by, or on behalf  
of, the ELT member (for example within a family trust or  
self-managed superannuation fund where they are the 
beneficial owner) will count towards satisfaction of the 
minimum shareholding requirement.

•  The Board becomes aware of any other action or behaviour 
that it determines (acting in good faith) has resulted in the 
employee receiving an inappropriate benefit.

As at 30 June 2021, progress towards the minimum 
shareholding requirement for each ELT member is  
provided below:

ELT member

David Koczkar
Kylie Bishop
John Goodall
Milosh Milisavljevic
Mei Ramsay
Mark Rogers
Andrew Wilson

Minimum 
shareholding 
requirement $1

Value of eligible 
shareholdings as 
at 30 June 2021 $2

1,500,000
580,000
555,000
780,000
555,000
1,000,000
1,000,000

2,508,057
1,339,834
467,494
45,719
652,919
1,085,555
2,927,740

Minimum 
shareholding 
requirement timeline

Requirement satisfied
Requirement satisfied
5 December 2021
22 June 2026
Requirement satisfied
Requirement satisfied
Requirement satisfied

1.  Minimum shareholding requirement based on ELT members’ total fixed remuneration (TFR) as at 30 June 2021.

2.   Holding value is calculated with reference to the total number of eligible shares or performance rights held by each ELT member, multiplied by the closing 

price of Medibank’s shares on 30 June 2021 ($3.16).

3.  Craig Drummond ceased to be a KMP on 17 May 2021 and was therefore no longer subject to this policy as at 30 June 2021.

Annual Report 2021    57 

Remuneration report
For the financial year ended 30 June 2021

4.2.4 Share Trading Policy

5.1 Risk culture

We have a Share Trading Policy to ensure that all employees 
understand their obligations in relation to dealing in Medibank 
shares. The Share Trading Policy describes restrictions 
on buying and selling Medibank shares for non-executive 
directors and other Medibank employees.

In addition, non-executive directors, ELT members, all 
senior leaders and employees with potential access to inside 
information are deemed to be ‘Restricted Employees.’ They are 
required to seek approval before dealing in Medibank shares 
and are subject to share trading blackouts prior to financial 
result announcements and other times, as required. The policy 
also prohibits employees from entering into transactions 
relating to Medibank shares which limit their economic risks, 
including in relation to the long-term incentive (LTI) Plan and 
equity-based component of the STI Plan.

Our Share Trading Policy can be found within the corporate 
governance section on our website. 

4.2.5 Termination provisions in ELT member contracts

All current ELT members are employed under ongoing 
contracts with notice periods set at three months (employee) 
and six months (employer), or in the case of the CEO, six 
months (employee) and six months (employer). Termination 
provisions included in ELT member contracts are limited to 
six months payment of fixed remuneration, in lieu of notice. 

If an ELT member is assessed by the Board as a ‘good leaver’ 
(meaning they cease employment by reason of death, serious 
disability, permanent incapacity, retirement, redundancy or 
with Board approval), the cash STI award in respect of the 
performance year in which they leave would be paid on a 
pro rata basis at the end of the STI performance period. The 
deferred component of the STI award will be paid in cash 
(rather than performance rights) on a pro rata basis with 
payment deferred until 12 months following the payment of 
the cash component. Any previously deferred STI remains 
restricted until the applicable vesting date, unless determined 
otherwise by the Board. Performance rights issued as LTI 
are retained on a pro rata basis by a ‘good leaver’. Retained 
performance rights remain unvested and subject to the 
same vesting conditions that will be assessed at the end of 
the performance period. Further details of the termination 
provisions that relate to the STI and LTI plans are detailed 
in section 6 of this report.

5. Risk and remuneration

A key focus for Medibank’s Board and People and 
Remuneration Committee (P&RC) is ensuring our 
remuneration policies and practices are consistent with  
our risk management framework, aligned with prudent  
risk taking and support the effective management of  
financial and non-financial risks.

58    Medibank 

An engaged culture is contingent on alignment between 
purpose, values, behaviours and strategic direction. With a focus 
on ensuring we do the right thing for our people, customers 
and community, Medibank’s purpose and values provide 
guidance for the behaviours we expect of our employees. Our 
strong purpose and values focus is the cornerstone of our 
organisational culture and has been consistently positive over a 
seven-year cultural transformation. This builds on Medibank’s 
Code of Conduct which sets out the way we work at Medibank 
and outlines practical principles and standards of behaviour and 
conduct which are expected of all Medibank employees.  
As further guidance, Medibank’s risk culture framework clearly 
articulates the behaviours employees are expected to exhibit 
from a risk culture perspective. As an organisation, we are 
committed to not only complying with legal obligations, but 
also acting ethically and responsibly in relation to our people, 
customers and the community. The behaviours that support  
our risk culture include:

We actively challenge risk decisions to 
ensure benefit for our customers, our 
employees, our brand and our shareholders

We escalate risk issues without fear  
or favour

We all own risk issues

 We expect that all our risk and reward 
discussions are viewed through our  
values and business goals

 We learn from our experiences and  
mistakes to ensure we do better

5.2 Alignment of remuneration with prudent  
risk taking

We believe that the effective alignment of remuneration 
with the risk appetite set by the Board is critical to our 
remuneration strategy and framework. Under Medibank’s 
Group-wide performance framework ‘I Perform Better’, at the 
end of each financial year all employees are assessed against 
their personal scorecard, which is a combination of financial 
and non-financial measures, including performance against 
their risk, compliance and behaviour obligations. Through the 
performance assessment process, both positive and negative 
risk, compliance and behaviour outcomes are considered as 
part of a holistic performance assessment. Employees are 
then attributed an outcome against a 5-point rating scale 
(with a minimum rating of 3 required to receive a short-term 
incentive (STI) award) that focuses on behaviours, business 
outcomes and achievement of role-specific performance 
measures. This then informs remuneration and performance-
based incentive outcomes for the period. 

The management of financial and non-financial risks by senior 
executives is reviewed by the Risk Management Committee 
(RMC). As part of this review the RMC considers the effective 
operation of divisional risk committees, incident identification, 
audit findings, remediation actions, health and safety, and 
feedback on risk culture from employees. In addition, the 
Chief Risk Officer, Group Executive – People & Culture and 
Group Executive – Legal, Governance & Compliance are 
specifically tasked with notifying the Board of any relevant risk 
and compliance outcomes and/or conduct which may impact 
performance and remuneration outcomes for ELT members 
(including the CEO) and other senior executives.

Further, as outlined throughout this report, Medibank’s 
executive reward framework includes long-term deferral 
across both our STI Plan and long-term incentive (LTI) Plan to 
ensure risk outcomes are considered over extended periods.

5.3 Consequence management

A well understood and consistently applied consequence 
management process is a key part of our risk culture and 
ensures risk, compliance and behaviour outcomes are aligned 
with remuneration outcomes. Consequences of employees 
breaching Medibank’s Code of Conduct are clearly articulated 
and may include an employee attending further training 
or counselling, a formal written warning being applied, or 
in certain circumstances, termination of employment. The 
issue of a final written warning automatically results in the 
employee being given an ‘unsatisfactory’ performance rating 
for the relevant performance period, meaning the individual 
is ineligible for any performance-based reward outcome or 
fixed remuneration increase. Medibank’s individual incentive 
plan rules also clearly articulate that failure to meet the risk, 
compliance and behaviour gateway in any given performance 
period will consequently lead to ineligibility for an incentive 
award for a period of 12 months and potential termination.

In 2021, 19 employees were issued with final written warnings 
following a breach of Medibank’s Code of Conduct, or another  
Medibank Group policy. In all cases, each employee received 
a performance rating of ‘unsatisfactory’ and was ineligible 
for any applicable performance-based incentive or fixed 
remuneration increase. A further 12 individuals in 2021 
had their employment terminated following an incident 
of misconduct. 

Further details on consequence management can be found  
in our Sustainability Report 2021.

6. Executive remuneration components

Target remuneration for Executive Leadership Team 
(ELT) members is designed to reward sustained business 
performance with behaviours aligned with Medibank’s values 
and purpose that benefits both customers and shareholders. 

The Board aims to find a balance between:

•  Fixed and at-risk remuneration.

•  Short-term and long-term remuneration.

•  Remuneration delivered in cash and deferred equity.

6.1 2021 target remuneration mix

The 2021 target remuneration mix for Medibank’s ELT 
members is shown below.  

David 
Koczkar1

Kylie 
Bishop

John 
Goodall

Mei 
Ramsay

Mark 
Rogers

Andrew 
Wilson

43.5%

14.1% 14.1%

28.3%

46.5%

12.8% 12.8%

27.9%

46.5%

12.8% 12.8%

27.9%

46.5%

12.8% 12.8%

27.9%

43.5%

14.1% 14.1%

28.3%

43.5%

14.1% 14.1%

28.3%

Former ELT member

Craig 
Drummond 

28.6%

14.3% 14.3%

42.8%

Fixed

STI cash

Deferred 
STI (equity)

LTI 
(equity)

1.   David Koczkar’s remuneration mix reflects his Chief Customer Officer 

position which is applicable to the 2021 performance period.

2.   Milosh Milisavljevic has been excluded from this list as his 2021 target 
remuneration mix reflects his former position as Senior Executive 
Customer Strategy & Growth.

6.2 Total fixed remuneration (TFR)

This is the fixed portion of remuneration and includes base 
salary and employer superannuation contributions. Fixed 
remuneration is determined with reference to the executive’s 
capabilities, experience, the complexity of the role, as well  
as median pay levels for similar roles at companies in the  
ASX 11-100 (excluding mining and energy companies).  
This ensures that fixed remuneration is set at competitive 
levels and enables Medibank to attract and retain high  
quality executives. Further details of Medibank’s comparator 
group of companies is outlined in section 14 of this report.

Annual Report 2021    59 

Remuneration report
For the financial year ended 30 June 2021

The table below outlines the current TFR settings for ELT 
members as at 30 June 2021. The TFR for David Koczkar, 
Milosh Milisavljevic, Mark Rogers and Andrew Wilson reflect 
adjustments to their fixed remuneration following their  
recent appointments and a review of benchmark data.

6.2.1 Total fixed remuneration

ELT member
David Koczkar1
Kylie Bishop
John Goodall
Milosh Milisavljevic2
Mei Ramsay
Mark Rogers3
Andrew Wilson4
Former ELT member
Craig Drummond

30 June 2021 $
1,500,000
580,000
555,000
780,000
555,000
1,000,000
1,000,000

1,534,000

1.   This represents David Koczkar’s TFR as at 30 June 2021 following his 

appointment as Chief Executive Officer. David’s previous TFR of $960,000  
was used for the purposes of calculating his 2021 short-term incentive 
and long-term incentive awards.

2.   This represents Milosh Milisavljevic’s TFR as at 30 June 2021 following  

his appointment as Group Executive – Customer Portfolios. Milosh’s 2021 
short-term incentive and long-term incentive awards were calculated 
based on his TFR prior to his appointment as a KMP.

3.   This represents Mark Rogers’ TFR as at 30 June 2021 following his 

expanded accountability as Group Executive – Chief Financial Officer 
& Group Strategy. Mark’s previous TFR of $925,000 was used for the 
purposes of calculating his 2021 short-term incentive and long-term 
incentive awards.

4.   This represents Andrew Wilson’s TFR as at 30 June 2021 following his 
expanded accountability as Group Executive – CEO Health Services. 
Andrew’s previous TFR of $960,000 was used for the purposes of 
calculating his 2021 short-term incentive and long-term incentive awards.

6.3 Short-term incentive (STI)

STI is an at-risk element of remuneration, which is designed 
to reward executives for the creation of customer and 
shareholder value during the financial year. Executives must 
pass two separate gateways to participate in the plan. Once 
both gateways are achieved, executives have the opportunity 
to earn a percentage of their fixed remuneration as an 
incentive, based on company and individual performance.

6.3.1 STI gateways

For an STI award to be made to an ELT member, the  
following gateways must be achieved:

Risk, compliance and behaviour gateway

Individually assessed, the risk, compliance and behaviour 
gateway requires ELT members to:

•  Adhere to Medibank’s Code of Conduct which covers 
standards of behaviour and conduct which includes  
anti-harassment, anti-discrimination and anti-bribery and 
corruption obligations. Our Code of Conduct requires all 
employees to not only comply with our legal obligations,  
but also to act ethically and responsibly in relation to  
our customers, colleagues and the community.

60    Medibank 

•  Complete all mandatory compliance training which includes 

privacy, cyber-security, health and safety, bullying and 
harassment, bribery and corruption and meeting our legal, 
ethical and governance requirements.

•  Ensure that the risks in respect of their position are well 

managed. Multiple factors are considered when assessing 
risk management (including environment, social and 
corporate governance and climate risks where relevant), 
which differ based on an executive’s role. Common 
elements include the effective operation of divisional 
risk committees, incident identification, audit findings, 
remediation actions, health and safety, and feedback  
on risk culture from employees.

Assessment of the risk, compliance and behaviour gateway 
is also subject to feedback provided by the Chief Risk Officer, 
Group Executive – People & Culture and Group Executive – 
Legal, Governance & Compliance as outlined in section 5.2.

Financial gateway

•  Assessed at the Group level, Medibank must achieve a 
baseline of financial performance as determined by the 
Board for the performance period. In 2021, this baseline 
financial performance was a Group operating profit target.

6.3.2 STI performance measurement

The Board determines challenging levels of performance for 
each Medibank and role-specific STI performance measure. 
When setting performance expectations, the Board considers 
numerous factors, including Medibank’s strategic objectives, 
prior year performance, the external environment, customer 
outcomes and shareholder expectations. The Board also 
ensures that performance levels are set for the current year 
in the context of achieving longer term customer and financial 
strategic goals. Further detail on each performance measure 
is outlined in section 7.1.

At the completion of the performance year, an assessment 
is first made on the achievement of the STI gateways. If 
achieved, ELT members are then assessed against the 
company and role-specific performance measures to 
determine STI award outcomes. As an example, for an ELT 
member to achieve a target STI award, performance against 
Medibank and role-specific measures must be at the target 
level of performance as set by the Board (for that element 
of the award) and delivered with behaviours aligned with 
Medibank’s purpose and values.

For an ELT member to achieve a stretch STI award (therefore, 
award at maximum), performance against all Medibank 
and role-specific measures must be at or above stretch 
performance as set by the Board (for that element of the 
award) and delivered with behaviour aligned with Medibank’s 
purpose and values. This would represent exceptional 
performance, well above that of Medibank’s strategic plan.

 6.3.3 Key features of the STI Plan

Over what period is 
performance assessed?

How are STI payments 
delivered?

The STI performance period is the financial year 1 July to 30 June.

50% of STI awarded to ELT members is paid as cash, with the remaining 50% deferred 
for 12 months (deferred STI). Deferred STI is provided in the form of 12-month deferred 
performance rights.

When are STI payments 
made?

The cash component of STI is paid following the release of audited financial results,  
with performance rights for the deferred STI component granted shortly thereafter.

What method is used to 
determine the number of 
performance rights granted 
to each participant as part 
of the deferred STI?

Performance rights under the STI plan are granted at face value. The deferred STI value 
for each ELT member is divided by the volume weighted average share price (VWAP) of 
Medibank shares to determine the number of units granted. 

For the 2021 deferred STI component the VWAP will be calculated on the 10 trading days 
 up to and including 16 September 2021.

Are deferred STI 
performance rights  
entitled to receive a 
dividend payment?

What gateways apply  
to the STI plan?

What are the performance 
measures under the  
STI plan?

Deferred STI performance rights do not attract dividends during the deferral period.  
To align participant outcomes with shareholders, on vesting of these performance rights 
additional Medibank shares are granted to ensure each participant receives a benefit 
equivalent to any dividends paid during the deferral period. 

For an STI award to be made to an ELT member, both the risk, compliance and behaviour 
gateway, and the financial gateway must be achieved. Further detail on these gateways 
is outlined in section 6.3.1.

Performance measures under the STI plan are determined by the Board at the 
commencement of each performance period. For 2021, the performance measures were:

•  Group operating profit (excluding investment income).
•  Health Insurance premium revenue growth.
•  Brand Net Promoter Score (NPS).
•  Role-specific metrics.

Further detail on each performance measure is outlined in section 7.1.

Does Medibank disclose  
STI performance targets?

Section 7.1 of this report provides a detailed description of Medibank’s STI performance 
measures and a description of how the organisation has performed against each measure 
in 2021. Actual target values are not disclosed as this is considered to be commercially 
sensitive information.

Does Medibank have 
a clawback policy that 
applies to the STI plan?

Medibank has an Executive Remuneration Clawback Policy that provides discretion to the 
Board to reduce, cancel, or recover (clawback) any award made under the STI plan to an  
ELT member in certain circumstances subject to applicable laws. Further detail on this  
policy is outlined in section 4.2.2.

What happens to STI 
entitlements if an ELT 
member leaves Medibank?

If an ELT member is a ‘good leaver’ (meaning they cease employment by reason of death, 
serious disability, permanent incapacity, retirement, redundancy, or with Board approval),  
pro rata payment of STI applies.

In what circumstances are 
STI entitlements forfeited?

Section 4.2.5 provides additional information on the treatment of STI for people deemed  
as ‘good leavers’ by the Board.

In the event an ELT member is not considered a ‘good leaver’ (meaning they cease 
employment for any reason other than death, serious disability, permanent incapacity, 
retirement, redundancy or with Board approval), the ELT member will forfeit any payment 
under the STI plan, including any unvested deferred STI grants, unless otherwise  
determined by the Board.

Annual Report 2021    61 

Remuneration report
For the financial year ended 30 June 2021

6.3.4 Annual STI opportunity

The target and maximum annual STI opportunity as a percentage of TFR for ELT members is outlined in the table below.

ELT member

David Koczkar1
Kylie Bishop
John Goodall
Mei Ramsay
Mark Rogers
Andrew Wilson
Former ELT member
Craig Drummond

2021

Target

Maximum

65%
55%
55%
55%
65%
65%

100%
100%
100%
100%
100%
100%

100%

150%

1.   David Koczkar’s 2021 target and maximum STI opportunity reflects his previous position as Chief Customer Officer and is applicable for the  

2021 performance period.

2.   Milosh Milisavljevic’s 2021 STI opportunity is based on his previous position as Senior Executive Customer Strategy & Growth prior to his  

appointment as a KMP and is excluded from this table. 

6.4 Long-term incentive (LTI)

LTI is an at-risk element of remuneration designed to reward executives for delivering sustainable business performance  
over the long term. Given the nature of the private health insurance industry and the fact that it is highly regulated, the  
Board considers it appropriate to measure long term performance over a three-year period. Each year executives are eligible 
to receive an LTI which is calculated as a percentage of their fixed remuneration. This incentive is subject to performance 
hurdles that will be tested at the end of the three-year performance period. Based on performance against these hurdles 
a percentage of the incentive will be retained by the executive with the remainder being forfeited. 

6.4.1 Key features of the LTI Plan

What is the aim of the  
LTI plan?

The Medibank LTI Plan is designed to:

•  Align the interests of ELT members more closely with the interests of customers and 
shareholders, by providing an opportunity for those executives to receive an equity  
interest in Medibank through the granting of performance rights.

•  Assist in the motivation, retention and reward of ELT members over the three-year  

deferral period.

What is the performance 
period for 2021 LTI plan?

The performance period for the 2021 LTI plan is three financial years commencing 1 July 
2020. A three-year performance period strikes a balance between providing a reasonable 
period to align reward with shareholder return and the LTI acting as a vehicle for executive 
motivation and retention.

What are performance 
rights?

Performance rights issued to ELT members under the LTI plan are conditional rights for  
the participant to subscribe for fully paid ordinary shares in Medibank.

What method is used to 
determine the number of 
performance rights granted 
to each participant?

Each performance right entitles the ELT member to subscribe for one ordinary share if the 
performance hurdles are met at the conclusion of the performance period. No amount is 
payable by the participant upon exercise of the performance rights once they have vested.

Performance rights under the LTI plan are granted at face value. Each ELT member receives 
a percentage of their fixed remuneration in LTI (refer to section 6.4.2 for details). This amount 
is then divided by the face value of Medibank shares.

For the 2021 LTI plan, the number of performance rights granted to each ELT member was 
determined using the volume weighted average price of Medibank shares on the ASX during 
the 10 trading days up to and including, 30 June 2020. This average price was $3.02.

What gateways apply to  
the LTI plan?

For an LTI award to be granted to an ELT member, the risk, compliance and behaviour 
gateway must be met prior to grant. Further detail on this gateway is outlined in section 6.3.1.

62    Medibank 

What are the performance 
hurdles under the 2021  
LTI plan?

Performance rights issued under the 2021 LTI plan are subject to three separate 
performance hurdles:

•  35% of the performance rights are subject to a performance hurdle based on Medibank’s 
earnings per share compound annual growth rate (EPS CAGR) over the performance 
period. The starting point for EPS will be calculated using Medibank’s underlying profit  
as at 30 June 2020 and the performance period for the EPS performance hurdle will run 
for three years from 1 July 2020 through to 30 June 2023. Further detail on the profit 
measure used in the calculation of EPS is provided in section 6.4.3.

•  35% of the performance rights are subject to a relative total shareholder return (TSR) 

performance hurdle, measured over the performance period. Medibank’s relative TSR will 
be compared to a comparator group comprising companies with a market capitalisation 
positioned within the ASX 11-100 (excluding mining and energy companies).

•  30% of the performance rights are subject to a performance hurdle based on the growth 
of Medibank’s private health insurance market share (as reported by APRA) over the 
performance period.

These performance hurdles were chosen by the Board as they are aligned with the  
interests of our customers and shareholders and represent well understood and  
transparent mechanisms to measure performance and provide a strong link between 
executive reward and shareholder wealth creation.

The performance hurdles under the 2021 LTI plan have threshold levels which need  
to be achieved before vesting commences. Details of these thresholds are outlined  
in the vesting schedule in section 6.4.3.

When do the performance 
rights vest?

Performance hurdles are assessed as soon as practicable after the completion of the 
relevant performance period. The number of performance rights that vest (if any) will 
 be relative to the achievement against the performance hurdles. See section 6.4.3 for  
the vesting schedule associated with each performance hurdle.

Are the performance 
hurdles re-tested?

No. Performance hurdles are only tested once at the end of the performance period. 
Any performance rights that remain unvested at the end of the performance period are 
immediately forfeited.

Are LTI performance  
rights entitled to receive  
a dividend payment?

LTI performance rights do not attract a dividend during the performance period, as they  
are still subject to performance hurdles that will determine the number of rights that  
convert to ordinary Medibank shares. 

Does Medibank have  
a clawback policy that 
applies to the LTI plan?

Medibank has an Executive Remuneration Clawback Policy that provides discretion to the 
Board to reduce, cancel, or recover (clawback) any award made under the LTI Plan to an  
ELT member in certain circumstances subject to applicable laws. Further detail on this  
policy is outlined in section 4.2.2.

What happens to LTI 
entitlements if an ELT 
member leaves Medibank?

In what circumstances  
are LTI entitlements 
forfeited?

If an ELT member is a ‘good leaver’ (meaning they cease employment by reason of death, 
serious disability, permanent incapacity, retirement, redundancy, or with Board approval), 
a portion of the performance rights held (granted, but not vested) by that participant on 
cessation of employment will be forfeited on a pro rata basis according to a formula which 
takes into account the length of time the participant has held the performance rights  
relative to the performance period for the grant. The retained performance rights will  
remain unvested and will be tested at the end of the performance period against the  
existing performance hurdles. 

LTI entitlements are forfeited if performance hurdles are not met. In the event an ELT 
member is not considered a ‘good leaver’ (meaning they cease employment for any reason 
other than death, serious disability, permanent incapacity, retirement, redundancy or with 
Board approval), the performance rights held (granted, but not vested) by that participant  
on cessation of employment will be automatically forfeited.

Annual Report 2021    63 

Remuneration report
For the financial year ended 30 June 2021

The annual LTI allocation value as a percentage of TFR for ELT members is outlined in the table below. 

6.4.2 Annual LTI allocation

ELT member

David Koczkar1
Kylie Bishop
John Goodall
Mei Ramsay
Mark Rogers
Andrew Wilson
Former ELT member
Craig Drummond

2021

LTI allocation value as % of TFR

65%
60%
60%
60%
65%
65%

150%

1.  David Koczkar’s 2021 LTI opportunity reflects his previous position as Chief Customer Officer and is applicable for the 2021 performance period.

2.   Milosh Milisavljevic’s 2021 LTI opportunity is based on his previous position as Senior Executive Customer Strategy & Growth prior to his appointment  

as a KMP and is excluded from this table.

6.4.3 LTI hurdles explained

2021 TSR performance rights (35% of award)

Each year, the Board reviews the LTI targets and vesting 
conditions in the context of Medibank’s operating 
environment. The Board is committed to setting targets 
which are appropriately challenging for management to 
meet while not being unattainable and which ultimately 
support the delivery of strong outcomes for our customers 
and shareholders. For the 2021 LTI offer, the Board also 
considered the uncertainty surrounding the economic 
and social impact of COVID-19 on Medibank’s operating 
environment and the PHI landscape more broadly.

2021 EPS performance rights (35% of award)

In this context, the Board approved maintaining a threshold 
EPS CAGR target of 3% for the 2021 LTI grant. The number 
of EPS performance rights that vest on achievement of the 
threshold EPS CAGR target has been increased by the Board 
to 50% of the EPS performance rights. The EPS CAGR target 
that must be met for 100% of the EPS performance rights 
to vest has been reduced by the Board to 7%. This change 
was made to achieve a more appropriate balance between 
the goals of attainability and challenge. Details of the vesting 
schedule are outlined in the table below:

Medibank’s EPS CAGR over 
the performance period

Percentage of EPS 
performance rights that vest

Less than 3% EPS CAGR
At 3% EPS CAGR
Between 3% and  
7% EPS CAGR
7% EPS CAGR or greater

Nil
50%
Straight-line pro rata vesting 
between 50% and 100%
100%

Medibank’s performance against the EPS hurdle is calculated 
based on the compound annual growth rate (CAGR) of 
Medibank’s EPS over the performance period. EPS is based 
on underlying profit, which adjusts statutory net profit after 
tax (NPAT) where appropriate, for short-term outcomes that 
are expected to normalise over the medium to longer term, 
most notably in relation to the level of gains or losses from 
investments, due to the limited control that management  
has over these outcomes.

64    Medibank 

Medibank’s TSR will be compared against companies within 
the ASX 11-100 (excluding mining and energy companies), 
which is the same comparator group used for executive and 
non-executive remuneration benchmarking. For any of the 
2021 TSR performance rights to vest, Medibank must achieve 
the threshold TSR ranking over the performance period.  
The percentage of the 2021 TSR performance rights that  
vest, if any, will be based on Medibank’s TSR ranking at the 
end of the performance period, as set out in the following 
vesting schedule:

Medibank’s TSR rank in  
the 2021 comparator group

Percentage of TSR 
performance rights that vest

Less than 50th percentile
Equal to 50th percentile
Greater than 50th and up to 
75th percentile
At or above 75th percentile

Nil
50%
Straight-line pro rata vesting 
between 50% and 100%
100%

The TSR of Medibank and other companies within the 
comparator group, expressed as a compound annual rate  
of return, will be comprised of:

a)   The change in share price of each company over the 
performance period. The change in share price is 
calculated using the volume weighted average price 
(VWAP) of each entity over the 20 trading days leading up  
to and including the performance period start and end 
dates. The VWAP at the end of the performance period  
will be adjusted for any stock splits that occur during  
the performance period.

b)   The value of all dividends and other shareholder benefits 
paid by each company during the performance period 
assuming that:

 i.  

 The dividends and shareholder benefits are reinvested 
in the relevant company at the closing price of the 
securities on the date the dividend or shareholder 
benefit was paid.

 ii.  Franking credits are disregarded.

 
 
The entities comprising the 2021 comparator group are 
determined at the commencement of the performance 
period. If the ordinary shares or stock of a member of the 
2021 comparator group is not quoted on the ASX at the 
end of the performance period (for example if the member 
has been delisted for any reason), then it will be excluded 
from calculations of the TSR calculation, unless the Board, 
acting in good faith and in its absolute discretion, determine 
otherwise. In exercising its discretion, the Board may have 
regard to such matters it deems relevant including (but not 
limited to) the length of time that the member was quoted 
on the ASX during the performance period.

2021 market share performance rights (30% of award)

The Board approved maintaining a threshold private health 
insurance (PHI) market share growth target of 25 basis points. 
To maintain the balance between the goals of attainability and 
challenge, the number of market share performance rights 
that vest on achievement of the threshold target has been 
increased to 50% of the market share performance rights. 
The PHI market share growth target that must be met for 
100% of the market share performance rights to vest has 
been maintained at 75 basis points. Details of the vesting 
schedule are set out below:

Medibank’s PHI market share 
growth

Percentage of market share 
performance rights that vest

Less than 25 basis points
Equal to 25 basis points
Greater than 25 basis points 
and up to 75 basis points
At or above 75 basis points

Nil
50%
Straight-line pro rata vesting 
between 50% and 100%
100%

7. Linking remuneration and performance 2021
7.1 2021 short-term incentive (STI) performance scorecard

The following table details the 2021 STI performance scorecard measures, weightings and assessment  
as applied to the Chief Executive Officer (CEO) and other Executive Leadership Team (ELT) members.

Measure

Description

Weighting

Other ELT 
members

CEO

2021 
performance 
assessment

Risk,  
compliance 
and behaviour 
gateway

Individually assessed, ELT members must adhere to Medibank’s 
Code of Conduct, ensure that the risks in respect of their position 
are well managed and complete all mandatory compliance 
training. Medibank’s Code of Conduct requires all employees  
to not only comply with our legal obligations, but also to act 
ethically and responsibly in relation to our customers,  
colleagues and the community. 

The management of risks (including environment, social  
and corporate governance and climate risks where relevant)  
is reviewed by the Risk Management Committee and considers 
the effective operation of divisional risk committees, incident 
identification, audit findings, remediation actions, health  
and safety, feedback on risk culture from employees, and  
feedback provided by the Chief Risk Office, Group Executive 
– People & Culture and Group Executive – Legal, Governance 
& Compliance as outlined in section 5.2.

Gateway Gateway

All achieved

Financial 
gateway

Medibank must achieve a baseline of financial performance,  
as determined by the Board for the performance period.  
In 2021, this baseline financial performance was a Group  
operating profit target.

Gateway Gateway

Met

Annual Report 2021    65 

Remuneration report
For the financial year ended 30 June 2021

Measure

Description

Group operating 
profit

Group operating profit represents the core financial measure  
for the annual STI Plan and reflects the Board’s belief that  
it is the best measure of underlying business performance 
and value created for customers and shareholders over the 
performance period.

Health Insurance 
premium 
revenue growth

Measured alongside the core metric of Group operating  
profit, the focus of this measure is sustainable and profitable 
revenue growth to ensure optimal value creation for customers  
and shareholders.

Brand Net 
Promoter  
Score (NPS)

Brand NPS is a key customer advocacy metric that measures  
the likelihood of people recommending Medibank or ahm to  
their families and friends.

Weighting

Other ELT 
members

CEO

2021 
performance 
assessment

45%

35%

Above target

20%

25%

Below target

20%

20%

Above target

Role-specific  
big goals

Aligned to one or more of the following milestones:

1.  Customer and employee advocacy – Continue to achieve  

a high level of advocacy by delivering exceptional experiences 
for our customers and employees.

2.  Health and wellbeing differentiation – Double the uptake  
of Medibank’s Live Better and Health Assist programs  
by FY22 while ensuring every customer has at least one 
personalised health interaction through the year.

3.  Health insurance growth – We aim to increase market  

share and achieve total policyholder growth in excess of 3%, 
including an expectation of growing the Medibank brand  
by c. 1% during FY21.

4.  In-home care – More than 300 virtual hospital beds by the  

end of FY22.

5.  Medibank Health – By FY22 organically replace the  
reported FY18 $30m operating profit of Garrison.

6.  Productivity – FY21 productivity target of $20 million  

and additional $30 million during FY22-FY23.

15%

20%

Ranging 
between  
‘on-track’  
to ‘ahead  
of target’

66    Medibank 

7.2 Medibank’s 2021 financial performance

Medibank’s 2021 annual financial performance is provided in the table below in addition to the average 2021 STI award  
achieved by ELT members, as a percentage of maximum opportunity. This table illustrates the relationship between the  
key indicators of shareholder wealth creation and STI outcomes for ELT members

Measure
Health Insurance premium revenue growth
Group operating profit1
Group net profit after tax (NPAT)
Dividend 
Share price as at 1 July
Share price as at 30 June
Average ELT STI as a percentage 
of maximum opportunity

2021
2.1%
$528.3m
$441.2m
12.7 cents p/s
$2.99
$3.16

2020
1.3%
$461.0m
$315.0m
12.0 cents p/s
$3.49
$2.99

2019
2.4%
$558.7m
$458.7m
13.1 cents p/s
$2.92
$3.49

2018
1.2%
$548.8m
$445.1m
12.7 cents p/s
$2.80
$2.92

2017
1.2%
$500.5m
$449.5m
12.0 cents p/s
$2.95
$2.80

70%

0%

56%

58%

44%

1.  2019 Group operating profit of $558.7 million includes $30.2 million of operating profit attributable to discontinued operations.

7.3 2021 STI awards

The table below provides a summary of STI awards for the 2021 performance year. As outlined earlier in the report, 
in assessing Medibank’s 2021 performance against our STI measures, the Board adjusted outcomes to normalise for  
unbudgeted COVID-19 related impacts (both negative and positive) outside of management’s control to ensure that  
executives did not benefit from windfall gains. Further to this assessment, the Board exercised discretion to reduce  
the 2021 STI outcomes for ELT members from an average of 80% of their maximum opportunity, to 70%.

ELT member
David Koczkar
Kylie Bishop
John Goodall
Mei Ramsay
Mark Rogers
Andrew Wilson
Former ELT member
Craig Drummond1

Total STI 
achieved  
$
729,792
395,792
353,758
353,758
670,810
662,592

STI 
cash (50%)  
$
364,896
197,896
176,879
176,879
335,405
331,296

STI deferred 
(50%)  
$
364,896
197,896
176,879
176,879
335,405
331,296

Total STI 
achieved as 
% of target
117.0%
124.1%
115.9%
115.9%
111.6%
106.2%

Total STI 
achieved 
as % of max 
opportunity
76.0%
68.2%
63.7%
63.7%
72.5%
69.0%

1,742,624

871,312

871,312

113.6%

75.7%

1.  The deferred component of Craig Drummond’s 2021 STI outcome will be awarded as deferred cash, due to vest in September 2022.

2.   The 2021 STI outcome for Milosh Milisavljevic was based on his performance and remuneration settings prior to becoming a KMP on 22 June 2021  

and has therefore not been included in this table.

7.4 2019 Long-term incentive plan outcomes

The performance period for the 2019 LTI plan concluded on 30 June 2021. The table below outlines the final outcome  
against each performance hurdle and associated vesting percentage for each hurdle, and the plan.

Performance hurdle
EPS CAGR
Relative TSR
Total 2019 LTI vesting percentage

Weighting
50%
50%

Outcome
-2.8%
57th percentile

Vesting percentage
0%
64%
32%

Medibank’s 2019 LTI was tested following the completion of the performance period on 30 June 2021. Both performance  
hurdles were assessed in line with the terms of the plan and the Board did not use discretion in determining the final  
outcome. The performance rights under the 2019 LTI Plan that did not vest as a result of the performance hurdle  
outcomes not being met, lapse immediately.

The 2020 and 2021 LTI Plans remain in restriction and will be assessed against their performance hurdles at the  
completion of the 2022 and 2023 financial years respectively. 

Annual Report 2021    67 

Remuneration report
For the financial year ended 30 June 2021

8. 2021 actual remuneration (Non-IFRS disclosure)

The table below represents the 2021 ‘actual’ remuneration for ELT members and includes all cash payments made in  
relation to 2021, in addition to deferred short-term incentive (STI) awards that vested in 2021.

Statutory remuneration disclosures prepared in accordance with the Corporations Act 2001 and Australian Accounting Standards 
differ to the numbers presented below, as they include (among other benefits) expensing for equity grants that are yet to  
realise or may never be realised. The statutory remuneration table in respect of the ELT members is presented in section 9.

Base salary 
and 
superannuation 
$
1,011,923
580,000
540,731
555,000
895,220
960,000

Cash STI for 
performance 
to 30 June 
2021 
$
364,896
197,896
176,879
176,879
335,405
331,296

Total cash 
payments 
in relation 
to 2021 
$
1,376,819
777,896
717,610
731,879
1,230,625
1,291,296

Deferred 
equity awards 
that vested in 
20211  
$
503,064
283,113
259,159
258,618
378,433
523,759

Total 
2021 actual 
remuneration 
$
1,879,883
1,061,009
976,769
990,497
1,609,058
1,815,055

Equity awards 
that lapsed in 
20212 
$
283,546
170,359
162,617
162,076
213,725
315,424

1,534,000

871,312

2,405,312

1,699,960

4,105,272

1,187,878

ELT member
David Koczkar
Kylie Bishop
John Goodall
Mei Ramsay
Mark Rogers
Andrew Wilson
Former ELT member
Craig Drummond

1.   Deferred equity awards that vested in 2021 relate to the 2018 LTI performance rights that vested during the year and the deferred STI  

performance rights in respect to the 2019 performance year that vested during the year.

2.   Equity awards that lapsed in 2021 relate to the portion of the 2018 long-term incentive (LTI) performance rights that lapsed following the  

testing of the performance hurdles in July 2020.

3.   Milosh Milisavljevic’s 2021 actual remuneration was primarily based on his remuneration settings prior to becoming a KMP on 22 June 2021  

and has therefore not been included in this table.

9. Statutory remuneration tables
9.1 Statutory remuneration table
The following table has been prepared in accordance with Section 300A of the Corporations Act 2001 and details the statutory 
accounting expense of all remuneration-related items for the ELT members. In contrast to the table in section 8 that details 
2021 actual remuneration, the table below includes accrual amounts for equity awards being expensed throughout 2021 that 
are yet to, and may never be realised by the ELT member.

Short-term 
benefits

Post-employment 
benefits

Long-term  
benefits

Equity-based 
benefits

Other

ELT member

Financial 
year

Salary  
$1

STI 
$

Other  
$

Non-monetary 
benefits  
$2

Superannuation  
$

Leave  
$3

Deferred 
STI  
$4

Performance 
rights  
$5

Termination 
benefits 
$

Total 
remuneration 
$

2021 1,027,440

364,896

2020

2021

2020

2021

2020

2021

2020

2021

2020

2021

2020

2021

2020

919,211

-

537,080

197,896

555,459

-

533,772

176,879

530,146

21,818

-

-

4,772

-

503,674

176,879

503,330

-

838,236

335,405

759,523

-

963,798

331,296

935,307

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

18,895

19,444

13,387

13,209

18,191

12,721

212

-

14,460

14,224

17,457

13,246

22,936

16,273

22,650 174,791

21,174

58,896

25,365

40,266

25,192

40,978

25,365

17,029

25,192

15,821

740

-

8

-

25,365

40,362

25,192

50,019

21,802 191,358

21,174

84,014

25,096

33,501

25,192

25,593

-

-

-

-

-

-

-

-

-

-

-

-

-

-

512,839

230,115

284,154

123,040

265,642

110,038

1,762

-

265,642

109,952

458,958

178,851

498,587

225,710

-

-

-

-

-

-

-

-

-

-

-

-

-

-

2,121,511

1,248,840

1,098,148

757,878

1,036,878

693,918

29,312

-

1,026,382

702,717

1,863,216

1,056,808

1,875,214

1,228,075

David  
Koczkar

Kylie  
Bishop

John  
Goodall

Milosh 
Milisavljevic6

Mei  
Ramsay

Mark  
Rogers

Andrew 
Wilson

68    Medibank 

ELT member

Financial 
year

Salary  
$1

Former ELT member

Short-term 
benefits

Post-employment 
benefits

Long-term  
benefits

Equity-based 
benefits

Other

STI 
$

Other  
$

Non-monetary 
benefits  
$2

Superannuation  
$

Leave  
$3

Deferred 
STI  
$4

Performance 
rights  
$5

Termination 
benefits 
$

Total 
remuneration 
$

Craig 
Drummond

Total ELT 
remuneration

2021 1,555,477

871,312

2020 1,567,526

-

2021 5,981,295 2,459,335

2020 5,770,502

-

-

-

-

-

15,364

19,296

120,902

108,413

25,096

51,868

871,312

1,227,715

25,192

47,723

-

663,660

171,479 549,183

871,312

3,515,299

168,308

323,044

-

1,641,366

-

-

-

-

4,618,144

2,323,397

13,668,805

8,011,633

1.   Salary includes annual base salary paid on a fortnightly basis and accrued but untaken annual leave entitlements which are expected to be taken  

in the next 12 months.

2.   Non-monetary benefits may include death, total and permanent disablement insurance, salary continuance insurance, subsidised Medibank health 

insurance and fringe benefits that are on the same terms and conditions that are available to all employees of the Group.

3.   Long-term leave comprises an accrual for long service leave and accrued but untaken annual leave entitlements which are not expected to be taken 
in the next 12 months. The significant year-on-year movements in this expense for David Koczkar and Mark Rogers reflect adjustments to their fixed 
remuneration following their new appointments and additional untaken annual leave entitlements accrued during the year.

4.   Deferred STI is in relation to Craig Drummond’s deferred component of his 2021 STI which will be awarded as deferred cash (rather than performance 

rights) and vest in September 2022, in accordance with Medibank’s Executive STI plan rules.

5.   Performance rights include equity-based remuneration incurred during the relevant financial year. The values are based on the grant date fair value 

amortised on a straight-line basis over the performance period and any reversals required by AASB 2 Share-based Payments.

6.  The remuneration figures disclosed for Milosh Milisavljevic reflect the period from his commencement as a KMP on 22 June 2021.

9.2 Performance-related remuneration statutory table
The following table provides an analysis of the non-performance-related (fixed remuneration) and performance-related  
(short-term incentive (STI) and long-term incentive (LTI)) components of the 2021 remuneration mix for Medibank’s ELT 
members as detailed in the ‘statutory remuneration table’.

Non-performance-related

Performance-related remuneration

Financial 
year

Fixed 
remuneration1

Cash 
STI

Deferred 
STI2

2021

2021

2021

2021

2021

2021

2021

58.6%

56.1%

57.3%

77.7%

56.9%

57.4%

55.7%

17.2%

18.0%

17.1%

16.3%

17.2%

18.0%

17.7%

8.6%

9.0%

8.5%

0.0%

8.6%

9.0%

8.8%

LTI3

15.6%

16.9%

17.1%

6.0%

17.3%

15.6%

17.8%

ELT member

David Koczkar

Kylie Bishop

John Goodall

Milosh Milisavljevic

Mei Ramsay

Mark Rogers

Andrew Wilson

Former ELT member

Craig Drummond

2021

35.7%

18.9%

18.9%

26.6%

Total  
performance-related 
remuneration

41.4%

43.9%

42.7%

22.3%

43.1%

42.6%

44.3%

64.4%

1.   Fixed remuneration includes the accounting expense from all columns of the ‘statutory remuneration table’ other than ‘cash STI’, ‘performance rights’  

and ‘deferred STI’.

2.   Deferred STI includes the 2021 accounting expense of the 2021 deferred STI components within the ‘performance rights’ and ‘deferred STI’ columns  

of the ‘statutory remuneration table’.

3.   LTI includes the 2021 accounting expense of the 2019, 2020 and 2021 LTI component within the ‘performance rights’ column of the ‘statutory  

remuneration table’.

Annual Report 2021    69 

Remuneration report
For the financial year ended 30 June 2021

10. Executive Leadership Team (ELT) equity awards
10.1 ELT equity award transactions

Details of 2021 ELT equity award transactions and outstanding holdings granted in previous years are set out below.

Units 
granted

Grant 
date

Vesting and 
exercise date1

Unit price  
at grant $2

Fair value  

at grant $3

Units

%

Units

%

$

Units

Vested

Lapsed

Other changes

Unvested balance 

at 30 June 20214

ELT member

Award type

David Koczkar

2021 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

Kylie Bishop

2021 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

John Goodall

2021 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

Milosh Milisavljevic5

2021 LTI performance rights

2020 LTI performance rights

2019 LTI performance rights

206,622

180,346

86,766

203,264

198,284

115,230

100,578

44,567

117,524

119,132

110,264

96,242

38,159

112,370

113,718

42,980

36,814

30,154

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

06/12/2018

Mei Ramsay

2021 LTI performance rights

110,264

26/11/2020

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

Mark Rogers

2021 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

Andrew Wilson

2021 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

Former ELT member

Craig Drummond6

2021 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

96,242

38,159

112,370

113,340

199,088

150,288

65,102

152,576

149,458

206,622

180,346

82,346

214,432

220,576

761,920

665,028

202,404

790,720

830,684

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

01/07/2021

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

3.02

3.46

3.41

2.91

2.77

3.02

3.46

3.41

2.91

2.77

3.02

3.46

3.41

2.91

2.77

3.02

3.46

2.91

3.02

3.46

3.41

2.91

2.77

3.02

3.46

3.41

2.91

2.77

3.02

3.46

3.41

2.91

2.77

3.02

3.46

3.41

2.91

2.77

86,766

100

219,518

99,142

50

283,546

99,142

50

283,546

44,567

100

112,755

59,566

50

170,359

59,566

50

170,359

38,159

100

96,542

56,859

50

162,617

56,859

50

162,617

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

$

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

38,159

100

96,542

56,670

50

162,076

56,670

50

162,076

65,102

100

164,708

74,729

50

213,725

74,729

50

213,725

82,346

100

208,335

110,288

50

315,424

110,288

50

315,424

202,404

100

512,082

415,342

50

1,187,878

415,342

50

1,187,878

(761,920)

(665,028)

(790,720)

2.20

2.23

-

1.91

1.90

2.20

2.23

-

1.91

1.90

2.20

2.23

-

1.91

1.90

2.20

2.23

1.91

2.20

2.23

-

1.91

1.90

2.20

2.23

-

1.91

1.90

2.20

2.23

-

1.91

1.90

2.20

2.23

-

1.91

1.90

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

Units

206,622

180,346

$

455,395

402,172

203,264

387,218

115,230

100,578

253,967

224,289

117,524

223,883

110,264

96,242

243,022

214,620

112,370

214,065

42,980

36,814

30,154

110,264

96,242

94,728

82,095

57,443

243,022

214,620

112,370

214,065

199,088

150,288

438,790

335,142

152,576

290,657

206,622

180,346

455,395

402,172

214,432

408,493

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

1.   The vesting and exercise dates represent the earliest possible date the performance rights may vest, being the end of the performance period. The actual 
vesting and exercise date will be at a time and manner determined by the Board, with Medibank to notify the holder at that time. Any performance rights 
that do not vest at this point will immediately expire.

2.   The unit price at grant represents the price used to determine the number of units granted, in line with Medibank’s methodology of granting equity awards 

at face value. Unit prices have been rounded to the nearest cent.

3.   The fair value at grant has been based on a valuation by independent external consultants in accordance with accounting standard AASB 2 Share-based 
Payments. The fair values for the 2019, 2020 and 2021 long-term incentive (LTI) grants are used for accounting purposes only as all LTI grants are made 
using the face value, as outlined in section 6.4. Unit prices have been rounded to the nearest cent.

70    Medibank 

10. Executive Leadership Team (ELT) equity awards

10.1 ELT equity award transactions

Details of 2021 ELT equity award transactions and outstanding holdings granted in previous years are set out below.

Units 

granted

Grant 

date

Vesting and 

exercise date1

Unit price  

at grant $2

Fair value  
at grant $3

2.20

2.23

-

1.91

1.90

2.20

2.23

-

1.91

1.90

2.20

2.23

-

1.91

1.90

2.20

2.23

1.91

2.20

2.23

-

1.91

1.90

2.20

2.23

-

1.91

1.90

2.20

2.23

-

1.91

1.90

2.20

2.23

-

1.91

1.90

Milosh Milisavljevic5

2021 LTI performance rights

2020 LTI performance rights

2019 LTI performance rights

Mei Ramsay

2021 LTI performance rights

110,264

26/11/2020

ELT member

Award type

David Koczkar

2021 LTI performance rights

Kylie Bishop

2021 LTI performance rights

John Goodall

2021 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

2020 LTI performance rights

2019 deferred STI performance rights

2019 LTI performance rights

2018 LTI performance rights

Mark Rogers

2021 LTI performance rights

Andrew Wilson

2021 LTI performance rights

Former ELT member

Craig Drummond6

2021 LTI performance rights

206,622

180,346

86,766

203,264

198,284

115,230

100,578

44,567

117,524

119,132

110,264

96,242

38,159

112,370

113,718

42,980

36,814

30,154

96,242

38,159

112,370

113,340

199,088

150,288

65,102

152,576

149,458

206,622

180,346

82,346

214,432

220,576

761,920

665,028

202,404

790,720

830,684

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

06/12/2018

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

26/11/2020

28/11/2019

28/11/2019

06/12/2018

27/12/2017

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

01/07/2021

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

01/07/2023

01/07/2022

18/09/2020

01/07/2021

01/07/2020

3.02

3.46

3.41

2.91

2.77

3.02

3.46

3.41

2.91

2.77

3.02

3.46

3.41

2.91

2.77

3.02

3.46

2.91

3.02

3.46

3.41

2.91

2.77

3.02

3.46

3.41

2.91

2.77

3.02

3.46

3.41

2.91

2.77

3.02

3.46

3.41

2.91

2.77

Units

-

-

86,766

-

99,142

-

-

44,567

-

59,566

-

-

38,159

-

56,859

-

-

-

-

-

38,159

-

56,670

-

-

65,102

-

74,729

-

-

82,346

-

110,288

-

-

202,404

-

415,342

Vested

Lapsed

Other changes

Unvested balance 
at 30 June 20214

%

-

-

$

-

-

100

219,518

100

112,755

Units

-

-

-

-

-

-

-

-

283,546

99,142

Units

%

-

-

-

-

50

-

-

-

-

$

-

-

-

-

283,546

-

-

-

-

170,359

59,566

50

170,359

-

-

96,542

-

-

-

-

-

-

-

-

-

-

-

-

-

162,617

56,859

50

162,617

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

162,076

56,670

50

162,076

100

96,542

100

164,708

-

-

-

-

-

-

-

-

-

-

-

-

-

213,725

74,729

50

213,725

-

-

208,335

-

-

-

-

-

-

-

-

-

-

-

-

-

315,424

110,288

50

315,424

-

-

512,082

-

-

-

-

-

-

-

-

-

-

-

-

-

1,187,878

415,342

50

1,187,878

(761,920)

(665,028)

-

(790,720)

-

-

50

-

-

-

50

-

-

100

-

50

-

-

-

-

-

-

50

-

-

-

50

-

-

100

-

50

-

-

100

-

50

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

Units

206,622

180,346

-

$

455,395

402,172

-

203,264

387,218

-

115,230

100,578

-

-

253,967

224,289

-

117,524

223,883

-

110,264

96,242

-

-

243,022

214,620

-

112,370

214,065

-

42,980

36,814

30,154

110,264

96,242

-

-

94,728

82,095

57,443

243,022

214,620

-

112,370

214,065

-

199,088

150,288

-

-

438,790

335,142

-

152,576

290,657

-

206,622

180,346

-

-

455,395

402,172

-

214,432

408,493

-

-

-

-

-

-

-

-

-

-

-

-

1.   The vesting and exercise dates represent the earliest possible date the performance rights may vest, being the end of the performance period. The actual 

4.   The unvested balance has been determined by multiplying the balance of short-term incentive (STI) performance rights at 30 June 2021 by the unit  

vesting and exercise date will be at a time and manner determined by the Board, with Medibank to notify the holder at that time. Any performance rights 

price at grant, and the balance of LTI performance rights at 30 June 2021 by the fair value at grant.

that do not vest at this point will immediately expire.

2.   The unit price at grant represents the price used to determine the number of units granted, in line with Medibank’s methodology of granting equity awards 

at face value. Unit prices have been rounded to the nearest cent.

3.   The fair value at grant has been based on a valuation by independent external consultants in accordance with accounting standard AASB 2 Share-based 

Payments. The fair values for the 2019, 2020 and 2021 long-term incentive (LTI) grants are used for accounting purposes only as all LTI grants are made 

using the face value, as outlined in section 6.4. Unit prices have been rounded to the nearest cent.

5.  Milosh Milisavljevic’s equity award transactions reflect his holdings following his commencement as a KMP on 22 June 2021. 

6.   Craig Drummond ceased to be a KMP on 17 May 2021 and therefore Craig’s unvested balance as at 30 June 2021 has been adjusted to reflect  

no further holdings as a KMP. Details of how Craig’s LTI performance rights have been treated on the basis of being a “good leaver” are detailed  
in section 2 of this report. 

Annual Report 2021    71 

Remuneration report
For the financial year ended 30 June 2021

10.2 ELT members’ ordinary shareholdings

Details of the ordinary shareholdings of ELT members and their related parties are provided in the table below.

ELT member

David Koczkar
Kylie Bishop
John Goodall
Milosh Milisavljevic3
Mei Ramsay
Mark Rogers
Andrew Wilson
Former ELT member
Craig Drummond4

Balance  
30 June 2020

Shares received 
on vesting of 
performance rights1

Net movement of 
shares due to other 
changes2

Balance  
30 June 2021

721,988
360,889
83,415
-
109,243
199,352
728,368

732,578

191,701
107,109
97,566
-
97,377
144,178
198,132

(120,000)
(44,000)
(33,040)
14,468
-
-
-

793,689
423,998
147,941
14,468
206,620
343,530
926,500

631,261

(1,363,839)

-

1.   Shares received on the vesting of deferred STI performance rights include the additional Medibank shares credited to ELT members upon the vesting of the 2019 
deferred STI performance rights as a benefit equivalent to any dividends paid during the deferral period. For further information, please refer to section 6.3.3.

2.  Net movement of shares relates to acquisition and disposal transactions by the ELT member and their related parties during the year.

3.  Milosh Milisavljevic’s ordinary shareholdings reflect his holdings and movements following his commencement as a KMP on 22 June 2021.

4.   Craig Drummond ceased to be a KMP on 17 May 2021 and therefore Craig’s balance as at 30 June 2021 has been adjusted to reflect no further holdings as a KMP.

11. Non-executive director remuneration and framework

Non-executive director fees are determined by the Board and 
reflect the role, market benchmarks and Medibank’s objective 
to attract highly skilled and experienced independent non-
executive directors. All non-executive directors are required 
to hold shares in Medibank to align with shareholder interests.

11.1 Non-executive director remuneration

Component Delivered

Description

Base fee

Cash and  
superannuation

Committee 
fees

Cash and  
superannuation

The base fee represents 
remuneration for service on 
the Medibank Board. The 
base fee for the Chairman 
represents the entire 
remuneration for that role.
Committee fees represent 
remuneration for chairing, 
or membership of, Board 
committees.

11.1.1 Non-executive director fee cap

Under Medibank’s Constitution, the total fees paid in any 
financial year to all non-executive directors for their services 
(excluding, for these purposes, the salary of any executive 
director) must not exceed, in aggregate, the amount fixed 
at Medibank’s annual general meeting in 2018 at $2,300,000  
per annum (fee cap). 

72    Medibank 

11.1.2 2021 and 2022 non-executive director 
remuneration

Under Medibank’s Constitution, the Board is responsible for 
determining the total amount paid to each non-executive director 
as remuneration for their services. In making this determination, 
the Board has taken into account the level of work required  
for the role and has regard to the median remuneration paid  
to non-executive directors of companies positioned within 
the ASX 11-100 (excluding mining and energy companies).

Following the annual benchmarking exercise and the 
position of non-executive directors against the median of the 
benchmark group, non-executive director base and committee 
fees have been maintained at their current levels for 2022. 
Based on the composition of the Board, non-executive director 
fee spend for 2022 will be $1,940,000 against the approved 
cap of $2,300,000. Non-executive director fees applicable 
throughout 2021 and 2022 are set out in the table below:

Position

Chairman

Non-executive directors

Committee chairman fees

Audit Committee

Risk Management Committee

People and Remuneration Committee

Investment and Capital Committee

Committee membership fees

Audit Committee

Risk Management Committee

People and Remuneration Committee

Investment and Capital Committee

2021 & 2022 $

445,000

165,000

40,000

40,000

40,000

40,000

20,000

20,000

20,000

20,000

11.2 Non-executive director superannuation

11.3 Shareholding policy for non-executive directors

Medibank meets its obligations under the Superannuation 
Guarantee legislation by paying superannuation contributions 
in respect of non-executive directors to their nominated 
complying superannuation funds up to the concessional 
contribution limits. Superannuation contributions for non-
executive directors are drawn from the overall fees paid 
to non-executive directors.

Medibank has a Minimum Shareholding Policy that requires 
non-executive directors to acquire shares with a value equal  
to one year’s base fee after tax over a period of five years.  
Non-executive directors do not participate in, or receive, 
any performance-based remuneration as part of their  
role and do not participate in any equity plans that operate  
within Medibank.

As permitted under the Superannuation Guarantee legislation, 
people with multiple employers can elect to be exempt from 
the superannuation guarantee where contributions are likely 
to take them over the annual concessional contribution cap. 
If a non-executive director applies and receives an exemption 
from superannuation guarantee payments, Medibank will 
make those payments in cash.

As at 30 June 2021, all non-executive directors have either  
met the minimum shareholding requirement, or are on  
track to do so, within the five-year period. Further details  
of current non-executive director shareholdings are  
provided in section 13.

12. 2021 non-executive director remuneration statutory table

Non-executive director

Mike Wilkins

Tracey Batten

Anna Bligh

Gerard Dalbosco2

David Fagan

Peter Hodgett

Linda Bardo Nicholls

Christine O’Reilly

Former non-executive director
Elizabeth Alexander3

Total non-executive director 
remuneration

Short-term 
benefits

Post-employment 
benefits

Financial 
year

Cash salary and fees  
$

Non-monetary1  
$

Superannuation  
$

Total  
$

2021
2020
2021
2020
2021
2020
2021
2020
2021
2020
2021
2020
2021
2020
2021
2020

2021
2020

2021
2020

377,228
188,655
187,935
188,655
187,934
188,654
20,882
-
206,270
207,061
206,270
207,061
187,456
198,026
225,865
217,346

107,435
427,250

3,954
3,612
2,581
2,729
3,296
3,119
-
-
2,736
2,618
3,849
3,728
3,014
2,888
2,765
2,602

9,434
-

9,352
17,922
17,854
17,923
17,854
17,922
1,984
-
19,596
19,671
19,596
19,672
18,127
8,551
-
9,385

6,112
21,174

390,534
210,189
208,370
209,307
209,084
209,695
22,866
-
228,602
229,350
229,715
230,461
208,597
209,465
228,630
229,333

122,981
448,424

1,707,275
1,822,708

31,629
21,296

110,475
132,220

1,849,379
1,976,224

1.   Non-monetary benefits may include death, total and permanent disablement insurance, salary continuance insurance, subsidised Medibank health 

insurance and fringe benefits that are on the same terms and conditions that are available to all Medibank employees.

2.  Gerard Dalbosco’s 2021 remuneration reflects his commencement date as a non-executive director of 21 May 2021.

3.  Elizabeth Alexander’s 2021 remuneration reflects her retirement date from the Medibank Board of 1 October 2020.

Annual Report 2021    73 

Remuneration report
For the financial year ended 30 June 2021

13. Non-executive director ordinary shareholdings

Non-executive director

Mike Wilkins
Tracey Batten

Anna Bligh

Gerard Dalbosco3

David Fagan

Peter Hodgett

Linda Bardo Nicholls

Christine O’Reilly

Balance  
30 June 
2020

Acquired 
during the 
year

Other 
changes 

59,013
50,000

44,623

-

47,016

67,800

45,000

69,930

40,987
-

-

-

-

-

-

-

-
-

-

24,432

-

-

-

-

Balance  
 30 June 
2021

100,000
50,000

44,623

24,432

47,016

67,800

45,000

69,930

Minimum 
shareholding 
requirement 
$1

Value of eligible 
shareholdings 
as at 30 June 
2021 $2

Minimum 
shareholding 
requirement  
timeline

222,500
82,500

82,500

82,500

82,500

82,500

82,500

82,500

316,000 Requirement satisfied
158,000 Requirement satisfied

141,009 Requirement satisfied

77,205

21 May 2026

148,571 Requirement satisfied

214,248 Requirement satisfied

142,200 Requirement satisfied

220,979 Requirement satisfied

Former non-executive director
Elizabeth Alexander4

124,786

- (124,786)

- Not applicable

-

Not applicable

1.  Minimum shareholding requirement based on annual non-executive director base fees for 2021 and an assumed tax rate of 50%.

2.   Value has been calculated with reference to the total number of eligible shares held by each non-executive director, multiplied by the closing  

price of Medibank’s shares on 30 June 2021 ($3.16).

3.   Gerard Dalbosco commenced as a non-executive director on 21 May 2021 and therefore his balance at the time of joining the Medibank Board  

is reflected in the ‘other changes’ column.

4.   Elizabeth Alexander ceased to be a KMP on 1 October 2020 and therefore Elizabeth’s balance at 30 June 2021 has been adjusted to reflect  

no further holdings as a KMP.

14. Medibank’s comparator group

As outlined throughout this report, Medibank uses a 
comparator group for the purposes of benchmarking 
executive and non-executive director remuneration and  
for the assessment of Medibank’s relative total shareholder 
return (TSR) performance under its long-term incentive 
(LTI) plan. Medibank’s comparator group is the ASX 11-100, 
excluding mining and energy companies. In any given year, 
there may be changes in the mining and energy companies 
excluded from Medibank’s comparator group due to 
companies either falling outside the ASX 11-100 or  
companies no longer being considered exclusively as  
a mining or energy company.

74    Medibank 

Financial report

Consolidated financial  
statements

Notes to the  
financial statements

Consolidated statement of comprehensive income

Consolidated statement of financial position

Consolidated statement of changes in equity

Consolidated statement of cash flows

page 76

page 77

page 78

page 79

Section 1
Basis of  
preparation
page 80

1.  Basis of  

preparation

Section 2
Operating  
performance
page 81

2.  Segment 

information

3.  Insurance  

underwriting 
result

4.  Deferred 

acquisition costs

5.  Unearned premium 

liability

6.  Shareholder  

returns

Section 3
Investment portfolio 
and capital
page 92

Section 4
Other assets  
and liabilities
page 103

Section 5
Other 

page 111

7.       Investment 
portfolio

8.       Financial risk 
management

9.       Working capital

10.   Contributed equity 
and reserves

11.   Property, plant 
and equipment

12.   Intangible assets

13.   Provisions 

and employee 
entitlements

14.  Leases

15.  Income tax

16.  Group structure

17.   Related party 

transactions

18.   Share-based 
payments

19.   Auditor’s 

remuneration

20.  Other

 Signed reports

Directors’ declaration

Auditor's independence declaration

Independent auditor’s report

page 121

page 122

page 123

Annual Report 2021    75 

Consolidated statement of comprehensive income
For the financial year ended 30 June 2021

Continuing operations

Revenue
Health Insurance premium revenue
Medibank Health revenue

Other income

Expenses
Claims expense
Medical services expense
Employee benefits expense
Office and administration expense
Marketing expense
Information technology expense
Professional service expense
Depreciation and amortisation expense
Finance expense
Share of net profit/(loss) from equity accounted investments

Note

2021 
$m

2020 
$m

2(b) 3(a)

3(a)

13(a)(ii)

16(b)

 6,691.1 
 219.3 
 6,910.4 

 6,554.7 
 214.9 
 6,769.6 

1.8

 7.4 

 (5,557.9)
 (34.0)
 (439.9)
 (79.0)
 (81.4)
 (72.3)
 (9.6)
 (122.0)
 (2.8)
 (1.0)
 (6,399.9)

 (5,486.6)
 (27.0)
 (429.0)
 (82.6)
 (94.1)
 (72.1)
 (7.5)
 (126.9)
 (3.4)
- 
 (6,329.2)

Profit before net investment income and income tax

 512.3 

 447.8 

Net investment income

Profit for the year before income tax

Income tax expense
Profit for the year from continuing operations

Discontinued operations
Profit/(loss) after tax for the year from discontinued operations

Profit for the year

Other comprehensive income, net of tax

Items that will not be reclassified to profit or loss
Actuarial gain/(loss) on retirement benefit obligation

Total comprehensive income for the year, net of tax, attributable to members  
of the parent arising from:
Continuing operations
Discontinued operations
Total operations

Basic and diluted earnings per share attributable to ordinary equity holders  
of the Company
Continuing operations
Total operations

6(b)
6(b)

The above statement should be read in conjunction with the accompanying notes. 

76    Medibank 

7(a)

 120.0 

 2.4 

 632.3 

 450.2 

15(a)

 (191.1)
 441.2 

 (134.6)
 315.6 

- 

 (0.6)

 441.2 

 315.0 

0.4
0.4

 (0.2)
 (0.2)

 441.6 
- 
 441.6 

 Cents 
 16.0 
 16.0 

 315.4 
 (0.6)
 314.8 

 Cents 
 11.5 
 11.4 

Consolidated statement of financial position
 As at 30 June 2021

Current assets
Cash and cash equivalents
Trade and other receivables
Financial assets at fair value
Deferred acquisition costs
Tax receivable
Other assets
Total current assets

Non-current assets
Property, plant and equipment
Intangible assets
Deferred acquisition costs
Deferred tax assets
Equity accounted investments
Other assets
Total non-current assets

Total assets

Current liabilities
Trade and other payables
Claims liabilities
Unearned premium liability
Tax liability
Customer give back provision
Provisions and employee entitlements
Total current liabilities

Non-current liabilities
Trade and other payables
Claims liabilities
Unearned premium liability
Provisions and employee entitlements
Total non-current liabilities

Total liabilities

Net assets

Equity
Contributed equity
Reserves
Retained earnings
Total equity

Note

9(b)
7(b)
4

11
12
4
15(c)
16(b)

9(c)
3(b)
5

13(c)
13

9(c)
3(b)
5
13

2021 
$m

2020 (restated)1 
$m

 671.7 
 215.9 
 2,311.9 
 33.6 
 6.2 
 18.8 
 3,258.1 

 101.7 
 345.3 
 47.5 
 85.9 
 77.1 
 8.2 
 665.7 

 871.4 
 207.1 
 1,994.7 
 34.5 
- 
 22.9 
 3,130.6 

 112.2 
 363.7 
 43.6 
 90.2 
- 
 7.4 
 617.1 

 3,923.8 

 3,747.7 

 338.2 
 622.4 
 697.0 
- 
 103.0 
 94.7 
 1,855.3 

 70.2 
 9.1 
 60.4 
 22.7 
 162.4 

 320.2 
 628.3 
 671.1 
 57.7 
- 
 82.9 
 1,760.2 

 84.2 
 10.9 
 75.0 
 19.6 
 189.7 

 2,017.7 

 1,949.9 

 1,906.1 

 1,797.8 

10(b)

 85.0 
 22.3 
 1,798.8 
 1,906.1 

 85.0 
 22.4 
 1,690.4 
 1,797.8 

1. Restatement reflects the change in accounting policy for Software as a Service (SaaS) intangible assets detailed in Note 20(a).

The above statement should be read in conjunction with the accompanying notes. 

Annual Report 2021    77 

Consolidated statement of changes in equity
For the financial year ended 30 June 2021

Balance at 1 July 2019
Restatement1
Balance at 1 July 2019 (restated)

Profit for the year
Other comprehensive income
Total comprehensive income for the year

Transactions with owners in their capacity as owners:
Dividends paid
Acquisition and settlement of share-based payment, net of tax
Share-based payment transactions
Balance at 30 June 2020

6(a)(i)

Profit for the year
Other comprehensive income
Total comprehensive income for the year

Transactions with owners in their capacity as owners:
Dividends paid
Acquisition and settlement of share-based payment, net of tax
Share-based payment transactions
Balance at 30 June 2021

6(a)(i)

Note

Contributed 
equity 
$m
 85.0 
- 
85.0 

 Reserves 
$m 
24.4
- 
24.4

Retained 
earnings 
$m
1,821.3
(16.1)
 1,805.2 

- 
- 
- 

- 
- 
- 
 85.0 

- 
- 
- 

- 
- 
- 
 85.0 

- 
- 
- 

 315.0 
 (0.2)
 314.8 

- 
 (3.2)
 1.2 
 22.4 

- 
- 
- 

- 
 (5.3)
 5.2 
 22.3 

 (429.6)
- 
- 
 1,690.4 

 441.2 
 0.4 
 441.6 

 (333.2)
- 
- 
 1,798.8 

Total 
equity 
$m
1,930.7
(16.1)
 1,914.6 

 315.0 
 (0.2)
 314.8 

 (429.6)
 (3.2)
 1.2 
 1,797.8 

 441.2 
 0.4 
 441.6 

 (333.2)
 (5.3)
 5.2 
 1,906.1 

1.  Restatement reflects the change in accounting policy for Software as a Service (SaaS) intangible assets detailed in Note 20(a). 

The above statement should be read in conjunction with the accompanying notes. 

78    Medibank 

Consolidated statement of cash flows
For the financial year ended 30 June 2021

Cash flows from operating activities
Premium receipts
Medibank Health receipts
Other receipts
Payments for claims and levies
Payments to suppliers and employees
Income taxes paid
Net cash inflow from operating activities

Cash flows from investing activities
Interest received
Investment expenses
Proceeds from sale of financial assets
Purchase of financial assets
Net purchase of equity accounted investments
Loan to associate
Purchase of plant and equipment
Purchase of intangible assets
Net cash inflow/(outflow) from investing activities

Cash flows from financing activities
Purchase of shares to settle share-based payment
Lease principal and interest payments
Dividends paid
Net cash outflow from financing activities

Net increase/(decrease) in cash and cash equivalents

Cash and cash equivalents at beginning of the year

Cash and cash equivalents at end of the year

The above statement should be read in conjunction with the accompanying notes.

Note

2021 
$m

2020 
$m

9(d)

16(b)
16(b)

14
6(a)(i)

 6,798.8 
 234.9 
 3.8 
 (5,542.7)
 (762.5)
 (250.1)
 482.2 

 16.0 
 (4.6)
 1,081.1 
 (1,289.6)
 (71.0)
 (2.9)
 (10.9)
 (24.2)
 (306.1)

 6,522.7 
 299.3 
 5.5 
 (5,233.2)
 (827.9)
 (194.0)
 572.4 

 27.8 
 (4.6)
 1,648.4 
 (1,533.1)
- 
- 
 (3.2)
 (26.1)
 109.2 

 (5.6)
 (37.0)
 (333.2)
 (375.8)

 (3.8)
 (33.3)
 (429.6)
 (466.7)

 (199.7)

 214.9 

 871.4 

 656.5 

 671.7 

 871.4 

Annual Report 2021    79 

Notes to the consolidated financial statements
30 June 2021

Section 1. Basis of preparation
Overview 

This section outlines the basis on which the Group’s financial statements are prepared.  
Specific accounting policies are described in the note to which they relate.

Note 1: Basis of preparation
(a) Corporate information

Medibank Private Limited (“Medibank”) is a for-profit 
company incorporated in Australia, whose shares are  
publicly traded on the Australian Securities Exchange (ASX).

The financial statements of Medibank for the financial year 
ended 30 June 2021 were authorised for issue in accordance 
with a resolution of the directors on 25 August 2021. The 
directors have the power to amend and reissue the financial 
statements.

(b) Basis of preparation

The financial statements are general purpose financial 
statements which:

•  Are for the consolidated entity (“the Group”) consisting  

of Medibank (“parent entity”) and its subsidiaries.  
Refer to Note 16(a) for the full group structure.

•  Have been prepared in accordance with Australian 

Accounting Standards, other authoritative pronouncements 
of the Australian Accounting Standards Board (AASB), 
International Financial Reporting Standards (IFRS) as 
issued by the International Accounting Standards Board 
(IASB) and the Corporations Act 2001.

•  Have been prepared under the historical cost convention, 
with the exception of financial assets measured at fair 
value and claims liabilities and lease liabilities which are 
measured at the present value of expected future payments.

•  Are presented in Australian dollars, which is Medibank’s 

functional and presentation currency.

•  Have been rounded in accordance with ASIC Corporations 

(Rounding in Financial/Directors’ Reports) Instrument 
2016/191 to the nearest hundred thousand dollars unless 
otherwise stated.

•  Include a change in accounting policy for configuration  

and customisation costs incurred in implementing 
Software-as-a-Service (SaaS) arrangements.  
Refer to Note 20(a) for further information. 

•  Adopt all new and amended accounting standards  

that are mandatory for 30 June 2021 reporting periods. 
Refer to Note 20(a) for further information.

•  Do not apply any pronouncements before their operative 
date. Refer to Note 20(b) for further information on the  
new standards and interpretations which have been issued 
but are not effective for 30 June 2021 reporting periods.

•  Include, where necessary, updates to prior year 

comparatives for changes in classification of amounts  
in the current reporting period. 

(c) Critical accounting estimates and judgements

The preparation of financial statements requires the use 
of certain critical accounting estimates. It also requires 
management to exercise judgement in the process of 
applying the Group’s accounting policies. The areas involving 
a higher degree of judgement or complexity, or areas where 
assumptions and estimates are significant to the financial 
statements, are disclosed in the following notes:

•  Note 3: Insurance underwriting result.

•  Note 4: Deferred acquisition costs.

•  Note 12: Intangible assets.

•  Note 15: Income tax.

80    Medibank 

Section 2. Operating performance 
Overview 

This section explains the operating results of the Group for the year, and provides insights into the Group’s result  
by reference to key areas, including:

•  Results by operating segment.

•  Insurance underwriting result.

•  Shareholder returns.

Note 2: Segment information

Segment Reporting Accounting Policy
Operating segments are identified based on the separate financial information that is regularly reviewed by the Chief 
Operating Decision Maker (CODM). The term CODM refers to the function performed by the Chief Executive Officer (CEO) 
in assessing performance and determining the allocation of resources across the Group. 

(a) Description of segments

Segment information is reported on the same basis as the 
Group’s internal management reporting structure at the 
reporting date. Transactions between segments are carried out 
on an arm’s length basis and are eliminated on consolidation. 
The Group is not reliant on any one major customer. 

For the financial year ended 30 June 2021, the Group was 
organised for internal management reporting purposes  
into two reportable segments, Health Insurance and 
Medibank Health. 

Health Insurance

Offers private health insurance products including 
hospital cover and ancillary cover, as stand-alone 
products or packaged products that combine the 
two. Hospital cover provides members with health 
cover for hospital treatments, whereas ancillary 
cover provides members with health cover for 
healthcare services such as dental, optical and 
physiotherapy. The segment also offers health 
insurance products to overseas visitors and 
overseas students.

Medibank Health 

Derives its revenue from a range of activities 
including contracting with government 
and corporate customers to provide health 
management and in-home care services, as well 
as providing a range of telehealth services in 
Australia. In addition, the Group distributes travel, 
life and pet insurance products on behalf of other 
insurers as part of a broader strategy to retain 
members and leverage its distribution network.

Private Health Insurance Premium Revenue Recognition 
Accounting Policy
Premium revenue is measured at the fair value of the 
consideration received or receivable and is recognised on a 
straight-line basis between the date Medibank accepts the 
insurance risk and the date the premium has been paid up to. 
Premium revenue is classified as an unearned premium liability 
in the consolidated statement of financial position when it relates 
to future financial periods.

Medibank Health Revenue Recognition Accounting Policy
Medibank Health revenue is recognised when services are 
provided to the customer and at an amount the Group will be 
entitled to receive in relation to providing the services. A contract 
liability is recognised within trade and other payables in the 
consolidated statement of financial position when the Group has 
an obligation to transfer services to a customer for which it has 
already received consideration from the customer (or an amount 
of consideration is receivable). Contract liabilities are recognised 
as Medibank Health revenue when the services are provided.

Annual Report 2021    81 

(b) Segment information provided to the CEO

The CEO measures the performance of the Group's reportable segments based on the operating profit of the segments.  
The segment information provided to the CEO for the year ended 30 June 2021 is as follows: 

Health Insurance

Medibank Health

$31.4m

$470.6m

$6,545.6m

$538.6m

$6,680.3m

$27.8m

$283.8m

$270.0m

2020

2021

2020

2021

Revenue

Operating profit

Revenue from
continuing operations

Operating profit
from continuing operations

30 June 2021
Revenues
Total segment revenue
Inter-segment revenue

Note

2(c)(iii)

Health 
Insurance 
$m

Medibank 
Health  
$m

Total  
$m

 6,680.3
- 

 283.8
 (53.7)

 6,964.1 
 (53.7)

Revenue from external customers from continuing operations

 6,680.3

 230.1 

 6,910.4 

Operating profit from continuing operations

 538.6

 31.4 

 570.0 

Items included in segment operating profit:
Depreciation and amortisation
Interest income from loans to associates
Share of profit/(loss) from equity accounted investments

30 June 2020
Revenues
Total segment revenue
Inter-segment revenue

 (104.8)
- 
- 

 (8.3)
 0.2 
 (1.0)

 (113.1)
 0.2 
 (1.0)

16(b)

Health 
Insurance 
$m

Medibank 
Health  
$m

Note

Total  
$m

 6,545.6 
- 

 270.0 
 (46.0)

 6,815.6 
 (46.0)

Revenue from external customers from continuing operations

 6,545.6 

 224.0 

 6,769.6 

Operating profit from continuing operations

 470.6 

 27.8 

 498.4 

Items included in segment operating profit:
Depreciation and amortisation

 (105.2)

 (7.9)

 (113.1)

82    Medibank 

Notes to the consolidated financial statements30 June 2021 
(c) Other segment information

(i) Segment operating profit or loss 

A reconciliation of the operating profit from continuing operations to the profit for the year before income tax from continuing 
operations of the Group is as follows:

Total segment operating profit from continuing operations

Unallocated to operating segments: 
  Corporate operating expenses

Group operating profit from continuing operations

Net investment income
Acquisition intangible amortisation
Mergers and acquisitions expenses
Other income/(expenses)

AASB 16 Leases transition adjustment

Note

2021 
$m
570.0

2020 
$m
498.6

 7(a)

 (41.7)

 (37.4)

528.3

 461.0 

 120.0 
 (4.6)
 (5.5)
 (5.9)

- 

 2.4 
 (9.0)
 (1.3)
 (6.2)

 3.3 

Profit for the year before income tax from continuing operations

 632.3 

 450.2 

(ii) Other items

(iii) Loyalty program

Segment private health insurance premium revenue is  
after $10.8 million (2020: $9.1 million) of transfers between 
the Group’s other operating segments in relation to the  
loyalty program.

(iv) Segment assets and segment liabilities

No information regarding segment assets and segment 
liabilities has been disclosed, as these amounts are not 
reported to the CEO for the purpose of making strategic 
decisions. 

(v) Geographic information

Segment revenue based on the geographical location of 
customers has not been disclosed, as the Group derives  
all of its revenues from its Australian operations. 

Segment operating profit excludes the following:

•  Corporate operating expenses of $41.7 million (2020:  

$37.4 million) relating to the Group's corporate function.

•  Net investment income, which comprises:

 – Interest and distribution income and related investment 

management expenses (refer to Note 7(a)), as this  
arises from investments which are managed by  
a central treasury function.

 – Net gains and losses on disposals of and fair value 
movements on financial assets and liabilities (refer  
to Note 7(a)), as they are not indicative of the Group's 
long-term performance.

•  Acquisition intangible amortisation of $4.6 million  

(2020: $9.0 million) not allocated to segments.

•  Expenses in relation to mergers and acquisitions  
which are not allocated to the operating activities  
of the Group’s segments.

•  Other income/(expenses) of $5.9 million (2020: $6.2 million) 
which do not relate to the current year’s trading activities  
of the Group’s segments, comprising primarily net  
sublease rent. 

Annual Report 2021    83 

Note 3: Insurance underwriting result

This note presents the Group’s insurance underwriting result and provides information on the Group’s claims liabilities,  
which comprise the outstanding claims liability, the COVID-19 claims liability and the provision for bonus entitlements.  

2021 underwriting result after expenses

$6,680.3m

100%

$(5,610.8)m

84.0%

$(531.1)m
8.0%

$538.6m
8.1%

Private health insurance premium revenue

Net claims incurred

Underwriting expenses

Underwriting result after expenses

Insurance Contracts Accounting Policy
An insurance contract arises when the Group accepts 
significant insurance risk from another party by agreeing 
to compensate them from the adverse effects of a specified 
uncertain future event. The significance of insurance risk 
depends on both the probability and magnitude of an 
insurance event.

Once insurance cover has been classified as an insurance 
contract, it remains an insurance contract for the remainder 
of its lifetime, even if the insurance risk significantly reduces 

during the period. With the exception of travel, life and pet 
insurance, for which the Group does not act as an underwriter, 
all other types of insurance cover are insurance contracts. 

A specific COVID-19 claims liability has been recorded for 
deferred claims that were a result of surgeries and other 
health services being restricted for policyholders during the 
COVID-19 pandemic period. Medibank has an obligation to 
settle these claims as they become known in future periods.

(a) Insurance underwriting result

Private health insurance premium revenue

Claims expense
  Claims incurred

(Increase)/decrease in COVID-19 claims liability

  State levies
  Net Risk Equalisation Special Account rebates/(payments)
Net claims incurred excluding claims handling costs

Movement in claims handling costs on outstanding claims liabilities
Net claims incurred

Underwriting expenses

Underwriting result after expenses

Note
(i)

(ii)
(iv)

(iii)

2021 
$m
 6,680.3 

2020 
$m
6,545.6

 (5,606.2)
 73.3 
 (53.3)
 (24.6)
 (5,610.8)

 0.2 
 (5,610.6)

 (5,190.8)
 (297.1)
 (51.6)
 7.9 
 (5,531.6)

 (0.8)
 (5,532.4)

 (531.1)

 (542.6)

 538.6 

 470.6 

(i)      Private health insurance premium revenue is after  

$10.8 million (2020: $9.1 million) of transfers between 
the Group’s other operating segments in relation to the 
loyalty program and $103.0 million (2020: nil) in relation to 
premium relief granted as part of the customer give back.

(ii)    Claims incurred are prior to elimination of transactions 

with the Group’s other operating segments of  
$52.7 million (2020: $45.8 million).

(iii)   Net claims incurred consists of amounts paid and  
payable to hospital, medical and ancillary providers 
 which consists of claims paid and payable, changes 
in claims liabilities, change in amounts receivable 
from and payable to the Risk Equalisation Special 
Account, applicable state levies, costs incurred in health 
management services and the COVID-19 claims liability. 

(iv)   This balance relates to the COVID-19 claims liability. 

Refer to Note 3(b) for further information.

84    Medibank 

Notes to the consolidated financial statements30 June 2021 
Health Insurance Premium Revenue Recognition 
Accounting Policy
Premium revenue is recognised in the consolidated 
statement of comprehensive income when the amount 
can be reliably measured and it is probable that future 
economic benefits will flow to the entity. Premium revenue 
is measured at the fair value of the consideration received 
or receivable and is recognised on a straight-line basis 
between the date Medibank accepts the risk from the 
insured under the insurance contract and the date the 
premium has been paid up to. 

Premium revenue includes the movement in the premiums 
in arrears which is assessed based on past experience of 
the likelihood of collection. Premium revenue is classified 
as an unearned premium liability in the consolidated 
statement of financial position when it relates to future 
financial periods.

The Australian Government contributes a rebate towards 
eligible policyholder’s premium and pays this directly to  
the Group. 

This rebate is recognised within premium revenue in  
the consolidated statement of comprehensive income. 
Rebates due from the government but not received at 
balance date are recognised as trade and other receivables 
in the consolidated statement of financial position.

Net Risk Equalisation Special Account Levies and  
Rebates Accounting Policy
Under legislation, all private health insurers must 
participate in the Risk Equalisation Special Account in 
which all private health insurers share the cost of the 
eligible claims of members aged 55 years and over, and 
claims meeting the high cost claim criteria.

The Australian Prudential Regulation Authority (APRA) 
determines the amount payable to or receivable from the 
Risk Equalisation Special Account after the end of each 
quarter. Estimates of amounts payable or receivable are 
provided for periods where determinations have not yet 
been made. This includes an estimate of risk equalisation 
for unpresented and outstanding claims.

(b) Gross claims liability

Current
Outstanding claims liability – central estimate
COVID-19 claims liability
Risk margin
Claims handling costs

Claims liability – provision for bonus entitlements
Gross claims liability

Non-current
Outstanding claims liability – central estimate
Risk margin
Claims handling costs

Claims liability – provision for bonus entitlements
Gross claims liability

Note

(i,ii)
(vi)
(i,iii)
(iv)

(v)
(c)

(i,ii)
(i,iii)
(iv)

(v)
(c)

2021 
$m

 347.2 
 223.8 
 33.2 
 8.5 
 612.7 

 9.7 
 622.4 

 1.8 
 0.2 
- 
 2.0 

 7.1 
 9.1 

2020 
$m

 284.4 
 297.1 
 27.1 
 8.6 
 617.2 

 11.1 
 628.3 

 2.1 
 0.2 
 0.1 
 2.4 

 8.5 
 10.9 

Claims Liability Accounting Policy
The outstanding claims liability provides for claims received 
but not assessed and claims incurred but not received. It is 
based on an actuarial assessment that considers historical 
patterns of claim incidence and processing. It is measured 
as the central estimate of the present value of expected 
future payments arising from claims incurred at the end  
of each reporting period under insurance cover issued  
by the Medibank health fund, plus a risk margin reflecting 
the inherent uncertainty in the central estimate.  

The expected future payments are discounted to present 
value using a risk-free rate.

The liability also allows for an estimate of claims handling 
costs, which comprise all direct expenses of the claims 
department and general administrative costs directly 
attributable to the claims function. These include internal 
and external costs incurred from the negotiation and 
settlement of claims.

Annual Report 2021    85 

Claims Liability Accounting Policy continued
COVID-19 Claims Liability
The COVID-19 claims liability is based on the best  
estimate, taking into account relevant risks and 
uncertainties, of expenditure required to settle claims 
deferred as a result of surgeries and other health  
services restricted for policyholders during the COVID-19 
pandemic. Medibank has an obligation to settle these 
claims as they become known in future periods. The 
liability is calculated by comparing the difference between 
the actual and expected volume of insured surgical and 

non-surgical procedures since the commencement of 
restrictions in March 2020 (the COVID-19 period). The 
expected claims level is based on the estimated underlying 
claims growth per Single Equivalent Unit per policy (PSEU) 
that would have occurred if the COVID-19 pandemic did  
not eventuate, taking into account changes in the customer 
base during the COVID-19 period. The key judgements and 
inputs to determine the expected claims level are detailed 
in Note 3(b)(vi). 

Key estimate
The outstanding claims liability estimate is based on the hospital, ancillary and overseas claim categories. 

Hospital and overseas

Calculated using statistical methods adopted for all service months but with service levels 
for the most recent service month (hospital) or two service months (overseas) being based 
on the latest forecast adjusted for any observed changes in payment patterns.

Ancillary

Calculated using statistical methods adopted for all service months.

The critical assumption in determining the outstanding claims liability is the extent to which claim incidence and 
development patterns are consistent with past experience. Adjustments are then applied to reflect any unusual or  
abnormal events that may affect the estimate of claims levels such as major variability to claims processing volumes.

The process for establishing the outstanding claims liability involves consultation with internal actuaries (including the  
Chief Actuary), claims managers and other senior management. The process includes monthly internal claims review 
meetings attended by senior management.

(i)     Outstanding 

The central estimate is an estimate of the level of the outstanding claims liability.

claims liability 
– central 
estimate

Key estimate
The central estimate is based on statistical analysis of historical experience which assumes an 
underlying pattern of claims development and payment. The final selected central estimate is based 
on a judgemental consideration of this analysis and other qualitative information, such as claims 
processing delays. The central estimate excludes the impact of the Risk Equalisation Special  
Account. A separate estimate is made of levies payable to and recoveries from the Risk Equalisation 
Special Account.

(ii)   Discounting

The outstanding claims liability central estimate is discounted to present value using the three-month 
risk-free rate of 0.03% per annum which equates to a reduction in the central estimate of less than 
$0.1 million (2020: 0.10%, less than $0.1 million).

(iii)  Risk margin

An overall risk margin considers the uncertainty surrounding the outstanding claims liability.  
The risk margin applied to the Group’s outstanding claims central estimate (net of risk equalisation)  
at 30 June 2021 is 9.4% (2020: 9.2%).

Key estimate
The risk margin is based on an analysis of past experience, including comparing the volatility  
of past payments to the adopted central estimate. The risk margin has been estimated to  
equate to the Group’s objective of achieving a probability of adequacy of at least 95% (2020: 95%).  
The risk margin is not applied to the COVID-19 claims liability. Relevant risks and uncertainties  
have been taken into account in determining the best estimate of the COVID-19 claims liability.

(iv)   Claims 

handling costs

The allowance for claims handling costs at 30 June 2021 is 2.5% of the outstanding claims liability 
(2020: 3.0%).

86    Medibank 

Notes to the consolidated financial statements30 June 2021(v)    Claims liability 
– provision 
for bonus 
entitlements

Certain private health insurance products (Package Bonus, Ultra Bonus and Membership Bonus) 
include benefits that carry forward. Package Bonus carries forward unused benefit entitlements  
in a calendar year for five calendar years. Membership Bonus carries forward unused benefit 
entitlements in a calendar year for 10 calendar years. Ultra Bonus carries forward unused benefit 
entitlements without limit. 

The Group’s claims liabilities include a provision to cover expected future utilisation of these  
benefit entitlements of the current membership.

Key estimate
The bonus provision includes the total entitlement available to members under the terms of the 
relevant insurance policies, less any amounts utilised, with a probability of utilisation based on past 
experience and current claiming patterns applied. The true cost of these entitlements cannot be 
known with certainty until any unclaimed entitlements are processed. 

 (vi)   COVID-19 
claims  
liability 

The liability relates to claims deferred as a result of surgeries and other health services restricted 
for policyholders during the COVID-19 pandemic. At 30 June 2020, this impacted health services 
for hospital, ancillary and overseas claims. At 30 June 2021, the COVID-19 liability includes hospital 
claims of $220.2 million, which includes surgical and non-surgical claims, and ancillary claims  
of $3.6 million.

Key estimate – Hospital
The liability is calculated by comparing the difference between the actual and expected volume  
of insured surgical and non-surgical procedures since the commencement of restrictions in  
March 2020 (the COVID-19 period). Utilisation of the liability has been assessed by geography  
and modality (claim type) and occurs where actual claims exceed expected claims. 

Risks and uncertainties have been taken into account in the measurement of the liability and are 
reflected in the key inputs and judgements.

The key judgements and inputs into this liability include:

•  Statistical analysis of the expected claims level at the Single Equivalent Unit per policy (PSEU) 

during the COVID-19 period.

•  The expected claims level is based on the estimated underlying claims growth per PSEU that  

would have occurred if the COVID-19 pandemic did not eventuate. It has then been applied to the 
average actual number of PSEUs during the COVID-19 period. The extent of claims deferred has 
varied by geography based on the extent of COVID-19 restrictions.

•  The expected rate at which deferred insured surgical and non-surgical procedures will be caught 
up, which is based on the analysis and expert opinion of the Chief Medical Officer and internal 
analysis. The expected claims deferral rate is analysed based on modality and is 85% (2020: 100%) 
for surgical claims and 50% (2020: 100%) for non-surgical claims.

(c) Reconciliation of movement in claims liabilities

Balance at 1 July
Claims incurred during the period
Increase/(decrease) in COVID-19 claims liability
Claims paid during the period
Amount (over)/under provided on central estimate1
Risk margin
Claims handling costs
Movement in discount rate
Balance at 30 June

Note

(i)

2021 
$m
 639.2 
 5,496.1 
 (73.3)
 (5,414.4)
 (22.0)
 6.1 
 (0.2)
- 
 631.5 

2020 
$m
 377.6 
 5,120.0 
 297.1 
 (5,180.8)
 22.3 
 1.7 
 0.8 
 0.5 
 639.2 

Note: Movement includes both current and non-current. Claims incurred and claims settled exclude levies and rebates.

1.    The over provision recognised in the current year includes $19.8 million attributable to the COVID-19 period and has been recognised within the  

COVID-19 liability as at 30 June 2021 at the applicable deferral rate. Refer to Note 3(c)(i).

Annual Report 2021    87 

(i) Reconciliation of movement in COVID-19 claims liability

The table below provides a reconciliation of the movement in the COVID-19 claims liability during the year. 

Balance at 1 July 2020
Amount over/(under) provided from central estimate
Change in expected deferral rate
Net (utilisation)/deferral during the period
Balance at 30 June 2021

(d) Impact of changes in key variables on the  
claims liabilities

Outstanding claims liability

The central estimate, discount rate, risk margin and weighted 
average term to settlement are the key outstanding claims 
variables. A 10% increase/decrease in the central estimate 
would result in a $24.4 million decrease/increase to profit after 
tax and equity (2020: $20.1 million). A 1% movement in other 
key outstanding claims variables, including discount rate, risk 
margin and weighted average term to settlement, would result in 
an insignificant decrease/increase to profit after tax and equity.

COVID-19 claims liability

The following describe the individual impacts of changes  
in the key estimate on the COVID-19 claims liability: 

•  A 4% increase/decrease in the expected claims level  
would result in a $67.0 million decrease/increase to  
profit after tax and equity (2020: $44.8 million). 

Hospital 
$m
 234.4 
 19.8 
 (73.1)
 39.1 
 220.2 

Ancillary 
$m
 62.7 
- 
- 
 (59.1)
 3.6 

Total 
$m
 297.1 
 19.8 
 (73.1)
 (20.0)
 223.8 

•  An increase/decrease of 10 percentage points in the 

adopted deferral rate for COVID-19 hospital claims would 
result in a $26.8 million decrease/increase to profit after  
tax and equity (2020: $16.4 million). The reasonable possible 
range for the hospital deferral assumption is 75-100%  
for surgical claims (2020: 90-100%) and 30%-70% for  
non-surgical claims (2020: 90-100%).

(e) Insurance risk management

The Group provides private health insurance products including 
hospital cover and ancillary cover, as stand-alone products 
or packaged products that combine the two, for Australian 
residents, overseas students studying in Australia and overseas 
visitors to Australia. These services are categorised as two 
types of contracts: hospital and/or ancillary cover. 

The table below sets out the key variables upon which the 
cash flows of the insurance contracts are dependent. 

Type of contract

Detail of contract workings

Nature of claims

Key variables that affect  
the timing and uncertainty 
of future cash flows

Hospital cover

Ancillary cover

Defined benefits paid for hospital 
treatment, including accommodation, 
medical and prostheses costs.

Hospital benefits defined  
by the insurance contract  
or relevant deed.

Claims incidence and  
claims inflation.

Defined benefits paid for ancillary 
treatment, such as dental, optical 
and physiotherapy services.

Ancillary benefits defined by 
the insurance contract  
or relevant deed.

Claims incidence and  
claims inflation.

Insurance risks and the holding of capital in excess of prudential requirements are managed through the use of claims 
management procedures, close monitoring of experience, the ability to vary premium rates, and risk equalisation. 

Mechanisms to manage risk

Claims 
management

Strict claims management ensures the timely and correct payment of claims in accordance with policy  
conditions and provider contracts. Claims are monitored monthly to track the experience of the portfolios.

Experience 
monitoring

Monthly financial and operational results, including portfolio profitability and prudential capital 
requirements, are reported to management committees and the Board. Results are also monitored 
against industry for insurance risks and experience trends as published by the regulator, APRA. 
Monitoring of claims experience during the COVID-19 period included daily and weekly dashboard reports.

88    Medibank 

Notes to the consolidated financial statements30 June 2021Prudential capital 
requirements

All private health insurers must comply with prudential capital requirements to provide a buffer 
against certain levels of adverse experience. The Board has a target level of capital which exceeds  
the regulatory requirement.

Ability to vary 
premium rates

Risk equalisation

The Group can vary future premium rates subject to the approval of the Minister for Health.

Private health insurance legislation requires resident private health insurance contracts to meet 
community rating requirements. This prohibits discrimination between people on the basis of their 
health status, gender, race, sexual orientation, religious belief, age (except as allowed under Lifetime 
Health Cover provisions), increased need for treatment or claims history. To support these restrictions, 
all private health insurers must participate in the Risk Equalisation Special Account. 

Concentration  
of health risk

The Group has health insurance contracts covering hospital and ancillary cover, and private health 
insurance for overseas students and visitors to Australia. There is no significant exposure to 
concentrations of risk because contracts cover a large volume of people across Australia.

COVID-19 claims 
liability

The Group’s Capital Management Policy requires a sufficient level of capital to be held by the Group. 
The Group also created a sub-portfolio within the Health Fund Investment Portfolio with the express 
purpose of funding the COVID-19 claims liability.

Note 4: Deferred acquisition costs

Movements in the deferred acquisition costs are as follows:

Balance at 1 July
Costs deferred during the year
Amortisation expense
Balance at 30 June

Note: Movement includes both current and non-current. 

2021 
$m
 78.1 
 42.3 
 (39.3)
 81.1 

2020 
$m
 79.6 
 36.6 
 (38.1)
 78.1 

Deferred Acquisition Costs Accounting Policy
Costs incurred in obtaining health insurance contracts 
are deferred and recognised as assets where they can be 
reliably measured and where it is probable that they will 
give rise to premium revenue that will be recognised in 
the consolidated statement of comprehensive income in 
subsequent reporting periods. 

Deferred acquisition costs are amortised systematically 
over the average expected retention period of the insurance 
contracts to which they relate. This is in accordance with 
the expected pattern of the incidence of risk under the 

insurance contracts to which they relate and corresponds 
to the earning pattern of the corresponding actual and 
expected premium revenue. The Group amortises these 
costs on a straight-line basis over a period of four years 
(2020: four years). The recoverability of deferred acquisition 
costs is considered as part of the liability adequacy test 
(refer to Note 5). Deferred acquisition costs which are 
not included in this test are separately assessed for 
recoverability in accordance with the Group’s accounting 
policy set out in Note 20(c).

Key judgement and estimate
The amortisation period of four years has been determined 
based on the average expected retention period of 
members. The actual retention period of a member can  
be longer or shorter than four years. The straight-line 
method systematically follows the initial period of customer 
tenure with some customers remaining with Medibank  

over a longer period of time. The Group maintains data 
on the retention period of all members, and performs a 
retention period analysis of those who are subject to these 
acquisition costs to ensure the period of amortisation 
remains appropriate. 

Annual Report 2021    89 

Note 5: Unearned premium liability

Movement in the unearned premium liability is as follows:

Balance at 1 July
Deferral of premium on contracts written during the year
Earnings of premiums deferred in prior years
Balance at 30 June

Note: Movement includes both current and non-current.

2021 
$m
 746.1 
 682.4 
 (671.1)
 757.4 

2020 
$m
770.6
 658.3 
 (682.8)
 746.1 

The expected cash outflows and the risk margin in the 30 June 2021 liability adequacy testing (LAT) includes the impacts  
of COVID-19. The LAT did not result in the identification of any deficiency as at 30 June 2021 and 2020. The LAT is not  
sensitive to reasonably plausible changes in key assumptions applied.

Unearned Premium Liability Accounting Policy
The proportion of premium received that has not been 
earned at the end of each reporting period is recognised 
in the consolidated statement of financial position as an 
unearned premium liability. The unearned premium liability 
is released to the consolidated statement of comprehensive 
income as revenue in accordance with Note 3(a) over the 
term of the insurance cover. 

Unexpired Risk Liability Accounting Policy
A liability adequacy test is required to be performed in 
respect of the unearned premium liability and insurance 
contracts renewable before the next pricing review 
(constructive obligation). The purpose of the test is to 
determine whether the insurance liability, net of related 
deferred acquisition costs, is adequate to cover the present 
value of expected cash outflows relating to future claims 
arising from rights and obligations under current insurance 
coverage. An additional risk margin is included in the test  
to reflect the inherent uncertainty in the central estimate. 
The liability adequacy test is performed at the level of a 
portfolio of contracts that are subject to broadly similar 
risks and that are managed together as a single portfolio. 

The unearned premium liability is deemed to be  
deficient where:

Present value of the 
expected future cash 
outflows relating to 
future claims

add

Additional risk margin 
to reflect the inherent 
uncertainty in the 
central estimate

Unearned premium 
liability 

less

greater 
than

Related intangible 
assets 

= 
Deficiency

less

Related deferred 
acquisition costs

The entire deficiency is recorded immediately in the 
statement of comprehensive income. The deficiency is 
recognised first by writing down any related intangible 
assets and then related deferred acquisition costs, with  
any excess being recorded in the consolidated statement  
of financial position as an unexpired risk liability.

Deferred acquisition costs which are not included in this 
test are separately assessed for recoverability and are 
amortised in accordance with the Group’s accounting  
policy set out in Note 4.

Note 6: Shareholder returns
(a) Dividends

(i) Dividends paid or payable 

2021
2020 final fully franked dividend
2021 interim fully franked dividend

2020
2019 final fully franked dividend
2019 final fully franked special dividend
2020 interim fully franked dividend

90    Medibank 

 Cents per fully 
paid share 

 6.30 
 5.80 

 7.40 
 2.50 
 5.70 

$m

 Payment date 

 173.5 
 159.7 

24 September 2020
25 March 2021

 203.8 
 68.9 
 157.0 

26 September 2019
26 September 2019
26 March 2020

Notes to the consolidated financial statements30 June 2021 
(ii) Dividends not recognised at the end of the reporting period

On 25 August 2021, the directors determined a final fully franked ordinary dividend for the six months ended 30 June 2021 of 
6.90 cents per share. The dividend is expected to be paid on 30 September 2021 and has not been provided for as at 30 June 2021. 

(iii) Franking account

Franking credits available at 30 June 2021 for subsequent reporting periods based on a tax rate of 30% are $324.2 million  
(2020: $215.7 million).

(iv) Calculation of dividend paid

Medibank’s target dividend payout ratio for the 2021 financial year is 75-85% (2020: 75-85%) of full year normalised net profit 
after tax (underlying NPAT). Normalised net profit after tax is calculated based on statutory net profit after tax adjusted for 
short-term outcomes that are expected to normalise over the medium to longer term, most notably in relation to the level of 
gains or losses from investments and movement in credit spreads, and for one-off items, especially those that are non-cash, 
such as impairments.

Profit for the year – after tax
Normalisation for growth asset returns
Normalisation for defensive asset returns – credit spread movement
Underlying NPAT

2021 
$m
 441.2 
 (31.2)
 (11.3)
 398.7 

2020 
$m
 315.0 
 43.2 
 8.5 
 366.7 

Dividends Accounting Policy
A liability is recorded for any dividends determined on or before the reporting date, but that have not been distributed  
at that date.

(b) Earnings per share

Attributable to ordinary equity holders of the Company
Profit for the year attributable to ordinary equity holders of the Company ($m)
Basic and diluted earnings per share attributable to ordinary equity holders of the Company (cents)

2021

2020

 441.2 
 16.0 

 315.0
 11.4

Attributable to continuing operations
Profit for the year attributable to ordinary equity holders of the Company ($m)
Basic and diluted earnings per share attributable to ordinary equity holders of the Company (cents)

 441.2 
 16.0 

 315.6 
 11.5 

Weighted average number of ordinary shares used in calculating basic and diluted earnings per share  2,754,003,240  2,754,003,240

Basic Earnings Per Share Accounting Policy
Basic earnings per share (EPS) is calculated by dividing  
the profit attributable to equity holders of Medibank, 
excluding any costs of servicing equity other than  
ordinary shares, by the weighted average number of 
ordinary shares outstanding during the reporting period, 
adjusted for bonus elements in ordinary shares issued 
during the reporting period and excluding treasury shares.

Diluted Earnings Per Share Accounting Policy
Diluted EPS adjusts the figures used in the determination  
of basic EPS to take into account:

•  The after income tax effect of any interest and other 
financing costs associated with dilutive potential  
ordinary shares.

•  The weighted average number of additional ordinary 
shares that would have been outstanding assuming  
the conversion of all dilutive potential ordinary shares.

Annual Report 2021    91 

 
Section 3. Investment portfolio and capital
Overview 

This section provides insights into the Group’s exposure to market and financial risks and outlines how these risks are 
managed. This section also describes how the Group’s capital is managed.

Note 7: Investment portfolios

This note contains information on the Group’s net investment 
income and the carrying amount of the Group’s investments. 

Medibank has established two investment portfolios for 
managing its investment assets, the Health Fund Investment 
Portfolio and the Non-Health Fund Investment Portfolio. 

The Chief Financial Officer (CFO) is responsible for the 
management of the Health Fund Investment Portfolio in 
accordance with the requirements of the Board approved 
Capital Management Policy, APRA regulatory requirements 
and the overall objective of achieving a capital base that is 
both stable and liquid. The asset allocation of Medibank’s 
Health Fund Investment Portfolio is skewed towards defensive 
assets (less risky and generally lower returning) rather than 
growth assets (riskier but potentially higher returning). The 
Board reviewed and has maintained the short-term target 
asset allocation for the Health Fund Investment Portfolio at 
20%/80% for growth and defensive assets. The long-term 
target asset allocation remains at 25%/75% for growth and 
defensive assets. During, and because of, the COVID-19 
pandemic, the Fund created a sub-portfolio of the Health 
Fund Investment Portfolio (the Short-term Operational Cash 
sub-portfolio) consisting of exclusively defensive assets with 
the express purpose of funding the COVID-19 liability and 

customer give back provision. Given its short-term nature, 
this sub-portfolio is managed separately from the Target 
Asset Allocation (TAA) framework. This portfolio is permitted 
to invest in bank deposits, short-term domestic money 
market securities with a minimum credit rating of A-1+ and 
Fixed Income securities with a minimum credit rating of AA-.

The Non-Health Fund Investment Portfolio is designed to 
provide the Group with additional liquidity and financial 
flexibility. The CFO is responsible for the management of  
the Non-Health Fund Investment Portfolio in accordance 
with the Board’s approved Investment Management Policy, 
investment strategy and delegation from the Investment  
and Capital Committee. This portfolio resides outside of 
the health fund and is not subject to the same regulatory 
requirements as the Health Fund Investment Portfolio. 
The Non-Health Fund Investment Portfolio is permitted to 
invest in bank deposits, short-term domestic money market 
securities with a minimum credit rating of A-1+ and Fixed 
Income securities with a minimum credit rating of AA-.

This note provides information on the net investment income 
and the carrying amounts of the investment assets residing  
in the Health Fund Investment Portfolio (including the  
sub-portfolio) and the Non-Health Fund Investment Portfolio.

Health Fund 
Investment 
Portfolio

Non-Health 
Fund Investment 
Portfolio

Total

 641.5 
 179.0 
 (37.3)

 1,823.4 
 (179.0)
 37.3 

 52.9 
- 
- 

 111.2 
- 
- 

- 
 164.1 

 488.5 
 2,953.4 

 588.6 
 179.0 
 (37.3)

 1,712.2 
 (179.0)
 37.3 

 488.5 
 2,789.3 

Portfolio composition 30 June 2021 ($m)

Cash portfolio
  Cash and cash equivalents (as reported in the statement of financial position)1, 2
  Cash investments with longer maturities
  Less cash allocated to the Fixed income portfolio

Fixed income portfolio
  Fixed income (as reported in the statement of financial position)3
  Less cash investments with longer maturities
  Cash allocated to the Fixed income portfolio

Growth portfolio
  Equities and investment trusts
Total investment portfolio

92    Medibank 

Notes to the consolidated financial statements30 June 2021Health Fund 
Investment 
Portfolio

Non-Health 
Fund Investment 
Portfolio

Portfolio composition 30 June 2020 ($m)

Cash portfolio

 Cash and cash equivalents (as reported in the statement of financial position)1, 2

  Cash investments with longer maturities

Fixed income portfolio
  Fixed income (as reported in the statement of financial position)3
  Less cash investments with longer maturities

Growth portfolio
  Equities and investment trusts
Total investment portfolio

 676.5 
 185.0 

 1,480.7 
 (185.0)

 466.8 
 2,624.0 

Total

 847.0 
 185.0 

 170.5 
- 

 47.2 
- 

 1,527.9 
 (185.0)

- 
 217.7 

 466.8 
 2,841.7 

1.  Cash and cash equivalents as reported in the statement of financial position also include operational cash of $30.2 million (2020: $24.4 million).

2.   Cash and cash equivalents in the Health Fund Investment Portfolio includes $178.2 million (2020: $236.5 million) in relation to the Short-term  

Operational Cash sub-portfolio.

3.   Fixed income in the Health Fund Investment Portfolio includes $148.6 million (2020: $60.6 million) relating to the Short-term Operational Cash  

sub-portfolio.

The Health Fund Investment Portfolio excluding the Short-term Operational Cash sub-portfolio comprises the following:

Growth
Australian equities
International equities
Property
Infrastructure

Defensive
Fixed income
Cash

Portfolio 
composition 
30 June 
2021

Portfolio 
composition 
30 June 
2020

Target  
asset 
allocation

4.8%
6.0%
6.9%
2.1%
19.8%

6.3%
6.5%
7.0%
0.3%
20.1%

5.0%
6.0%
7.0%
2.0%
20.0%

57.8%
22.4%
80.2%
100.0%

53.0%
26.9%
79.9%
100.0%

60.0%1
20.0%1
80.0%
100.0%

Health Fund Investment Portfolio

Australian equities
$119.3m

Cash
$552.1m

Infrastructure
$52.5m

International equities
$147.4m

Property
$169.3m

Fixed income
$1,421.9m

1.   During the period, the target Fixed Income allocation increased to 60% (2020: 52%) and the target Cash allocation reduced to 20% (2020: 28%).

Financial Assets at Fair Value Accounting Policy
Investments in listed and unlisted equity securities held 
by Medibank’s health insurance fund are accounted for 
at fair value through profit or loss (FVTPL). Fixed income 
investments held by Medibank’s health insurance fund 
are also accounted for at FVTPL, as the Group applies the 
fair value option to eliminate an accounting mismatch. 
Transaction costs relating to these financial assets are 
expensed in the consolidated statement of comprehensive 
income. These assets are subsequently carried at fair value, 
with gains and losses recognised within net investment 

income in the consolidated statement of comprehensive 
income. Financial assets at FVTPL, consist of externally 
managed equity trusts and direct mandates, and an 
internally managed fixed income portfolio.

Fixed income investments not held by Medibank’s health 
insurance fund are accounted for at fair value through  
other comprehensive income (FVOCI), as the objective  
of these assets is to collect contractual cash flows and  
to sell the assets if required, and the contractual cash  
flows are solely payments of principal and interest. 

Annual Report 2021    93 

 
Financial Assets at Fair Value Accounting Policy continued
These assets are initially and subsequently carried  
at fair value, with gains and losses recognised within  
equity in other comprehensive income until the asset  
is derecognised. When the assets are derecognised, the 
cumulative gain or loss previously recognised in other 
comprehensive income is reclassified from equity to  
profit or loss as a reclassification adjustment. Interest 
income accrues using the effective interest method 
and is included within net investment income in the 
consolidated statement of comprehensive income. 

For financial assets classified at FVOCI, the Group applies 
the general impairment approach under AASB 9, which 
requires recognition of a loss allowance based on either 
12-month expected credit losses or lifetime expected 
credit losses depending on whether there has been a 
significant increase in credit risk since initial recognition. 
Expected credit losses do not reduce the carrying amount 
of the financial asset in the statement of financial position, 
which remains at fair value. Instead, a loss allowance 
is recognised in other comprehensive income as the 
accumulated impairment amount.

Key judgement and estimate
Fair value measurement may be subjective, and investments 
are categorised into a hierarchy depending on the level of 
subjectivity involved. The hierarchy is described in Note 7(b).

The fair value of level 2 financial instruments is determined 
using a variety of valuation techniques, which make 
assumptions based on market conditions existing at the  

end of each reporting period. Valuation methods include 
quoted market prices or dealer quotes for similar 
instruments, yield curve calculations using the mid yield, 
vendor or independent developed models. 

The fair value of level 3 financial instruments is determined 
using inputs that are not based on observable market data. 

(a) Net investment income

Net investment income is presented net of investment management fees in the consolidated statement of comprehensive income. 

Interest1
Trust distributions 
Investment management expenses
Net gain/(loss) on fair value movements on financial assets
Net gain/(loss) on disposal of financial assets
Net investment income

2021 
$m
 17.7 
 38.0 
 (4.7)
47.8
 21.2 
 120.0 

2020 
$m
 29.7 
 29.5 
 (4.6)
 (53.0)
 0.8 
 2.4 

1.   Includes interest income of $0.7 million (2020: $1.7 million) relating to financial assets at fair value through other comprehensive income  

(Non-Health Fund Investments). 

Net Investment Income Accounting Policy
Gains or losses arising from changes in the fair value of 
the financial assets at FVTPL category are presented in the 
consolidated statement of comprehensive income within 
net investment income in the period in which they arise.

Trust distribution income derived from financial assets  
at FVTPL is recognised in the consolidated statement  

of comprehensive income as part of net investment income 
when the Group’s right to receive payments is established. 
Interest income from financial assets accrues using 
the effective interest method and is also included in net 
investment income.

(b) Fair value hierarchy

The fair value of the Group’s investments is measured according to the following fair value measurement hierarchy:

•  Level 1: Quoted prices (unadjusted current bid price) in active markets for identical assets or liabilities.

•  Level 2: Inputs other than quoted prices included within level 1 that are observable for the asset or liability, either directly  

(as prices) or indirectly (derived from prices).

•  Level 3: Inputs for the asset or liability that are not based on observable market data.

94    Medibank 

Notes to the consolidated financial statements30 June 2021The following tables present the Group’s financial assets measured and recognised at fair value on a recurring basis. 

30 June 2021
Financial assets at fair value through profit or loss

Australian equities1
International equities1
Property1
Infrastructure1
Fixed income

Financial assets at fair value through other  
comprehensive income – Fixed income
Balance at 30 June 2021

30 June 2020
Financial assets at fair value through profit or loss

Australian equities1
International equities1
Property1
Infrastructure1
Fixed income

Financial assets at fair value through other  
comprehensive income – Fixed income
Balance at 30 June 2020

Level 1  
$m

Level 2  
$m

Level 3  
$m

Total  
$m

- 
- 
- 
- 
82.0

 119.3 
 147.4 
- 
- 
 1,630.2 

-
 82.0 

 111.2 
 2,008.1 

- 
- 
- 
- 
 97.9 

-
 97.9

 146.8 
 151.6 
 162.5 
- 
 1,382.8 

 47.2
 1,890.9

- 
- 
 169.3 
 52.5 
- 

- 
 221.8 

- 
- 
- 
 5.9 
- 

- 
 5.9

 119.3 
 147.4 
 169.3 
 52.5 
 1,712.2 

 111.2 
 2,311.9 

 146.8 
 151.6 
 162.5 
 5.9 
 1,480.7 

 47.2 
 1,994.7

1.  Australian equities, international equities, property and infrastructure are indirectly held through unit trusts. 

The following table presents the changes in level 3  
financial instruments during the period.

Balance at 1 July 2020
Acquisitions
Net unrealised gain/(loss) 
on fair value movements
Transfer from level 21
Balance at 30 June 2021

Infrastructure 
$m
 5.9 
 44.0 

Property 
$m
- 
- 

Total 
$m
 5.9 
 44.0 

 2.6 

- 
 52.5 

1.5 

 4.1 

167.8 
169.3 

 167.8 
 221.8 

1.   During the period, $167.8 million of property financial assets were 

transferred from level 2 into level 3 due to changes in the observability 
 of inputs. 

The valuation of unlisted infrastructure and property assets  
is based on unit prices provided by investment managers. 
A 10% increase/decrease in the redemption price would 
decrease/increase the fair value of the financial asset  
by $22.2 million.

The Group’s other financial instruments, being trade and  
other receivables and trade and other payables, are not 
measured at fair value. The fair value of these instruments 
has not been disclosed, as due to their short-term nature, 
their carrying amounts are assumed to approximate their  
fair values. 

The Group did not measure any financial assets or  
financial liabilities at fair value on a non-recurring basis  
at 30 June 2021. 

The Group recognises transfers into and transfers out of  
fair value hierarchy levels from the date of effect of the 
transfer. There were no transfers between level 1 and  
level 2 during the year.

Fair value measurements using significant 
unobservable market data (level 3)

As at 30 June 2021, the Group classified $52.5 million of 
infrastructure financial assets (2020: $5.9 million) and  
$169.3 million of property financial assets (2020: nil) as  
level 3 financial instruments. These instruments are held  
in unlisted unit trusts and are valued at the redemption  
value per unit as reported by the managers of such funds. 
These investments are classified within level 3 of the fair 
value hierarchy as they are not based on observable market 
data as they trade infrequently and therefore have limited 
price transparency.

Annual Report 2021    95 

Note 8: Financial risk management

This note reflects risk management policies and procedures 
associated with financial instruments and capital and insurance 
contracts. The Group’s principal financial instruments 
comprise cash and cash equivalents, which are short-term 
money market instruments, fixed income (floating rate notes,  
asset-backed securities, syndicated loans, fixed income 
absolute return funds and hybrid investments), property, 
infrastructure, Australian equities and international equities.

other than risk management be undertaken, unless  
explicitly approved by the Investment and Capital Committee. 
The Group was in compliance with this policy during the 
current and prior financial year. 

The main risks arising from the Group’s financial instruments 
are interest rate risk, foreign currency risk, price risk, credit 
risk and liquidity risk. 

A strategic asset allocation is set and reviewed at least 
annually by the Board, which establishes the maximum and 
minimum exposures in each asset class. Transacting in 
individual instruments is subject to delegated authorities and 
an approval process which is also established and reviewed by 
the Investment and Capital Committee. At no time throughout 
the period will trading of derivative instruments for purposes 

Primary responsibility for consideration and control of 
financial risks rests with the Investment and Capital 
Committee under the authority of the Board. The Board 
reviews and agrees policies for managing each of the risks 
identified, including the setting of limits for trading in 
derivatives, foreign currency contracts and other instruments. 
Limits are also set for credit exposure and interest rate risk.

(a) Market risk

Market risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because  
of changes in market prices. 

(i) Interest rate risk

Description

The risk that the fair value or future cash flows of a financial instrument will fluctuate due to changes 
in market interest rates. 

At balance date, the Group had exposure to the risk of changes in market interest rates in respect of its  
cash and cash equivalents and fixed income investments. Both classes of financial assets have variable 
interest rates and are therefore exposed to cash flow movements if these interest rates change. 

Exposure

At balance date, the Group’s cash and cash equivalents (2021: $671.7 million, 2020: $871.4 million) and  
fixed income investments (2021: $1,823.4 million, 2020: $1,527.9 million) were exposed to Australian  
variable interest rate risk. The Group regularly analyses its interest rate exposure and resets interest  
rates on longer-term investments every 90 days on average. At balance date, the Group’s fixed income 
investments had a modified duration of 0.5 years (2020: 0.6 years).

Sensitivity

50 bps increase/decrease in interest rates for the entire reporting period, with all other variables remaining 
constant, would have resulted in a $4.4 million increase/decrease to profit after tax and equity (2020:  
$3.9 million). The sensitivity analysis has been conducted using assumptions from published economic data.

(ii) Foreign currency risk

Description

The risk that the fair value of a financial instrument will fluctuate because of changes in foreign  
exchange rates.

All of the Group’s investments with a non-AUD currency exposure are fully economically hedged,  
except for International equities which are unhedged (2020: 50% target hedge ratio).

At 30 June 2021, $147.4 million (2020: $76.0 million) of the international equities portfolio, within  
financial assets at fair value through profit or loss, had net exposure to foreign currency movements.

A 10% increase/decrease in foreign exchange rates, with all other variables remaining constant, would  
have resulted in a $11.5 million decrease/increase to profit after tax and equity (2020: $5.9 million)  
in the AUD valuation of international equities. Balance date risk exposures represent the risk exposure 
inherent in the financial instruments.

Exposure

Sensitivity

96    Medibank 

Notes to the consolidated financial statements30 June 2021(iii) Price risk

Description

The risk that the fair value of future cash flows of a financial instrument will fluctuate because of  
changes in market prices, whether those changes are caused by factors specific to the individual financial 
instrument or its issuer, or factors affecting all similar financial instruments traded in the market.

The Group is exposed to price risk in respect of its fixed income investments primarily due to movements 
in credit spreads. This risk is managed through active management of credit exposures and credit spread 
duration.

The Group’s equity price risk arises from investments in property, infrastructure, Australian equities and 
international equities. It is managed by setting and monitoring objectives and constraints on investments, 
diversification plans and limits on investments in each country, sector and market.

Sensitivity

These investments are exposed to short-term fluctuations in price with their fair value movements  
being recorded in the consolidated statement of comprehensive income. Price risk is managed by taking  
a longer-term view of the investment portfolio.

The following sensitivity analysis is based on the equity price risk exposures on average balances at  
balance date. It shows the effect on profit after tax and equity if market prices had moved, with all other 
variables held constant.

Australian equities
International equities
Property
Infrastructure

2021 
$m

2020 
$m

+10.0%
 8.7 
 10.1 
 11.6 
 2.1 

-10.0%
 (8.7)
 (10.1)
 (11.6)
 (2.1)

+10.0%
 9.5 
 11.1 
 10.9 
 1.1 

-10.0%
 (9.5)
 (11.1)
 (10.9)
 (1.1)

In relation to fixed income investments, a 25 bps increase/decrease in credit spreads, with all other 
variables remaining constant, would have resulted in a $5.9 million decrease/increase to profit after  
tax and equity (2020: $6.1 million). Balance date risk exposures represent the risk exposure inherent  
in the financial instruments.

(b) Credit risk 

(i) Cash and cash equivalents and financial assets at fair value through profit or loss

Description

The risk of potential default of a counterparty, with a maximum exposure equal to the carrying amount 
of these instruments. Credit risk arises from the financial assets of the Group and credit risk exposure 
is measured by reference to exposures by ratings bands, country, industry and instrument type.

Exposure

The Investment Management Policy limits the majority of internally managed credit exposure to A-  
or higher rated categories for long-term investments, and A2 or higher for short-term investments  
(as measured by external rating agencies such as Standard & Poor’s). Departures from this policy and  
the appointment of external managers require Board approval.

The Group does not have any financial instruments to mitigate credit risk and all investments are  
unsecured (except for covered bonds, asset-backed securities and mortgage-backed securities).  
However, the impact of counterparty default is managed through the use of Board approved limits  
by counterparty and rating and diversification of counterparties.

Sensitivity

The Group’s cash and fixed income portfolio is subject to counterparty exposure limits. These limits  
specify that no more than 50% (2020: 25%) of the cash portfolio can be invested in any one counterparty 
bank and no more than 10% (2020: 10%) in any one counterparty corporate entity. In the Group’s fixed 
income portfolio, the maximum amounts that can be invested in any one counterparty bank and any  
one counterparty corporate entity are 50% (2020: 50%) and 15% (2020: 15%) of the portfolio respectively.  
As at 30 June 2021 and 2020, the counterparty exposure of the Group was within these limits.

Annual Report 2021    97 

(ii) Trade and other receivables

Description

Due to the nature of the industry and value of individual policies, the Group does not request any collateral 
nor is it the policy to secure its premiums in arrears and trade and other receivables. The Group regularly 
monitors its premiums in arrears and trade and other receivables, with the result that exposure to bad 
debts is not significant. The credit risk in respect to premiums in arrears, incurred on non-payment  
of premiums, will only persist during the grace period of 63 days as specified in the Fund Rules when  
the policy may be terminated. The Group is not exposed to claims whilst a membership is in arrears, 
although a customer can settle their arrears up to the 63 day grace period and a claim for that arrears 
period will be paid. Trade and other receivables are monitored regularly and escalated when they fall 
outside of terms. The use of debt collection agencies may be used to obtain settlement.

Exposure

There are no significant concentrations of premium credit risk within the Group.

(iii) Counterparty credit risk ratings
The following tables outline the Group’s credit risk exposure 
at 30 June 2021 by classifying assets according to credit 
ratings of the counterparties. AAA is the highest possible 
rating. Assets that fall outside the range AAA to BBB are 
classified as non-investment grade. 

The table highlights the short-term rating as well as the 
equivalent long-term rating bands as per published Standard 
& Poor’s correlations. The Group’s maximum exposure 
to credit risk at balance date in relation to each class of 
recognised financial asset is the carrying amount of those 
assets in the consolidated statement of financial position. 

Short-term  
Long-term  
2021
Cash and cash equivalents
Premiums in arrears
Trade and other receivables
Financial assets

Australian equities
International equities
Property
Infrastructure
Fixed income
Financial assets at fair value through 
other comprehensive income

Total

2020
Cash and cash equivalents
Premiums in arrears
Trade and other receivables
Financial assets

Australian equities
International equities
Property
Infrastructure
Fixed income
Financial assets at fair value through 
other comprehensive income

Total

A-1+  
AAA  
$m
- 
- 
- 

- 
- 
- 
- 
 183.2 

A-1+  
AA  
$m
 671.7 
- 
- 

- 
- 
- 
- 
 528.4 

- 
 183.2 

111.2
 1,311.3 

- 
- 
- 

- 
- 
- 
- 
 81.1 

 836.4 
- 
- 

- 
- 
- 
- 
 483.6 

- 
 81.1 

 47.2 
 1,367.2 

A-1  
A  
$m
- 
- 
- 

- 
- 
- 
- 
 293.0 

- 
 293.0 

 35.0 
- 
- 

- 
- 
- 
- 
 328.6 

- 
 363.6 

A-2  
BBB  
$m
- 
- 
- 

B & below  
BB & below  
$m
- 
- 
- 

Not rated  
$m
- 
 8.5 
 207.4 

Total  
$m
 671.7 
 8.5 
 207.4 

- 
- 
- 
- 
 301.3 

- 
 301.3 

- 
- 
- 

- 
- 
- 
- 
 271.9 

- 
 271.9 

- 
- 
- 
- 
 7.9 

- 
 7.9 

 119.3 
 147.4 
 169.3 
 52.5 
 398.4 

 119.3 
 147.4 
 169.3 
 52.5 
 1,712.2 

- 
 1,102.8 

 111.2 
 3,199.5 

- 
- 
- 

- 
- 
- 
- 
- 

- 
- 

- 
 10.8 
 196.3 

 146.8 
 151.6 
 162.5 
 5.9 
 315.5 

 871.4 
 10.8 
 196.3 

 146.8 
 151.6 
 162.5 
 5.9 
 1,480.7 

- 
 989.4 

 47.2 
 3,073.2 

Within the not rated fixed income portfolio, $398.4 million (2020: $290.1 million) is invested in unrated unit trusts,  
of which the majority of the underlying securities held are investment grade assets and Senior Loans.

98    Medibank 

Notes to the consolidated financial statements30 June 2021Note 9: Working capital

The Group’s working capital balances are summarised in this note.

(a) Capital management

Medibank’s health insurance fund is required to maintain 
sufficient capital to comply with APRA’s solvency and capital 
adequacy standards. The solvency standard aims to ensure 
that the fund has enough cash or liquid assets to meet all 
of its liabilities as they become due, even if the cash flow is 
‘stressed’. The standard consists of a requirement to hold 
a prescribed level of cash, and also mandates a Liquidity 
Management Plan.

The capital adequacy standard aims to ensure that there  
is sufficient capital within a health insurance fund to enable 
the ongoing conduct of the business of the fund.  

(b) Trade and other receivables

The standard consists of a requirement to hold a prescribed 
level of assets to be able to withstand adverse experience, 
and also mandates a Capital Management Policy. The Capital 
Management Policy includes target capital levels, capital 
trigger points and corrective action plans.

The health insurance fund is required to comply with these 
standards on a continuous basis and report results to APRA 
on a quarterly basis. The fund has been in compliance with 
these standards throughout the year.

The Board has established a Capital Management Policy  
for the health insurance fund. Capital is managed against 
 this policy and performance is reported to the Board on  
a monthly basis. 

Premiums in arrears
Allowance for impairment loss

Trade receivables
Allowance for impairment loss

Government rebate scheme
Risk Equalisation Special Account
Accrued revenue
Other receivables

Note

(i)

(ii)

9(c)

2021 
$m
 13.2 
 (4.7)
 8.5 

 59.0 
 (2.2)
 56.8 

 133.8 
- 
 13.2 
 3.6 
 150.6 

2020 
$m
 14.9 
 (4.1)
 10.8 

 51.4 
 (3.2)
 48.2 

 124.2 
 6.5 
 14.7 
 2.7 
 148.1 

Total trade and other receivables

 215.9 

 207.1 

Note: Government rebate scheme is non-interest bearing and generally on 15-day terms.

Past due but not considered impaired

(i)   Premiums in arrears past due but not impaired at 30 June 
2021 for the Group are $8.5 million (2020: $10.8 million). 

(ii)  Trade receivables past due but not impaired at 30 June 
2021 for the Group are $8.3 million (2020: $3.7 million). 
Each business unit of the Group has reviewed their 
individual debtors and is satisfied that payment will  
be received in full. 

Trade and Other Receivables Accounting Policy
Trade and other receivables are:

Other balances within trade and other receivables do not 
contain impaired assets and are not past due. It is expected 
that these other balances will be received when due.

•  Recognised initially at fair value.
•  Subsequently measured at amortised cost using the effective interest method, less an allowance for impairment loss.
•  Presented as current assets except for those with maturities greater than 12 months after the reporting period.
•  Non-interest bearing.
•  Generally due for settlement within 7 - 30 days.

Annual Report 2021    99 

Trade and Other Receivables Accounting Policy continued
Collectability of trade receivables is reviewed on an ongoing basis. For trade receivables, the Group applies the simplified 
impairment approach under AASB 9, which requires expected lifetime losses to be recognised from initial recognition  
of the receivables. Expected lifetime losses are assessed based on historical bad and doubtful debt roll rates adjusted 
for forward looking information, where required. When a trade receivable for which an impairment allowance has been 
recognised becomes uncollectible in a subsequent period, it is written off against the allowance account. Any impairment 
loss on trade receivables is recognised within other expenses in the consolidated statement of comprehensive income. 
Subsequent recoveries of previously written off trade receivables are credited against other expenses in the consolidated 
statement of comprehensive income. Any impairment loss on premiums in arrears is offset against premium revenue.

(c) Trade and other payables

Current
Trade creditors1
Other creditors and accrued expenses2
Lease liabilities1
Risk Equalisation Special Account
Other payables3
Total current

Non-current
Lease liabilities1
Other payables3
Total non-current

Note

14
9(b)

14

2021 
$m

 239.9 
 55.6 
 28.1 
 7.7 
 6.9 
 338.2 

 65.3 
 4.9 
 70.2 

2020 
$m

 230.2 
 53.8 
 27.9 
- 
 8.3 
 320.2 

 81.3 
 2.9 
 84.2 

Terms and conditions relating to the above financial instruments:

1.  Trade creditors and lease liabilities are non-interest bearing and are normally settled up to 30 days.

2.  Other creditors and accrued expenses are non-interest bearing.

3.  Other payables include a contract liability in relation to the loyalty program. Refer to the accounting policy in Note 20(c). 

Trade and Other Payables Accounting Policy
Trade and other payables, with the exception of lease liabilities, are:
•  Recognised initially at their fair value.
•  Subsequently measured at amortised cost using the effective interest method.
•  Unsecured.
•  Presented as current liabilities unless payment is not due within 12 months from the reporting date. 

Refer to Note 14 for the accounting policy for lease liabilities.

(d) Reconciliation of profit after income tax to net cash flow from operating activities

Profit for the year

Depreciation
Depreciation of right-of-use assets
Amortisation of intangibles assets
Amortisation of deferred acquisition costs
Net realised loss/(gain) on financial assets
Net unrealised loss/(gain) on financial assets
Interest income 
Trust distribution reinvested
Investment expenses
Interest paid – leases
AASB 16 transition adjustment – recognition of finance subleases
Non-cash share-based payments expense
Share of loss/(profit) from associates and joint ventures

100    Medibank 

Note

11
11,14
12
4

14
20(a)(ii)

16(b)

2021 
$m
 441.2 

 13.3 
 27.2 
 42.2 
 39.3 
 (21.2)
 (47.8)
 (17.7)
 (38.0)
 4.7 
 2.8 
- 
 5.2 
 1.0 

2020 
$m
315.0

 13.2 
 27.0 
 48.6 
 38.1 
 (0.8)
 53.0 
 (29.7)
 (29.5)
 4.6 
 3.4 
 3.3 
 1.2 
- 

Notes to the consolidated financial statements30 June 2021 
Change in operating assets and liabilities – continuing operations:

Decrease/(increase) in trade and other receivables
Decrease/(increase) in deferred acquisition costs
Decrease/(increase) in other assets
Decrease/(increase) in net deferred tax liabilities/assets
(Decrease)/increase in trade and other payables
(Decrease)/increase in unearned premium liability
(Decrease)/increase in claims liabilities
(Decrease)/increase in income tax liability/receivable
(Decrease)/increase in provisions and employee entitlements

Change in operating assets and liabilities – discontinued operations:

Decrease/(increase) in trade and other receivables
(Decrease)/increase in trade and other payables
(Decrease)/increase in provisions and employee entitlements

Note

2021 
$m

 (8.8)
 (42.3)
 6.2 
 4.3 
 15.7 
 11.3 
 (7.7)
 (63.9)
 115.2 

- 
- 
- 

2020 
$m

 9.9 
 (36.7)
 (5.4)
 (95.5)
 (38.6)
 (23.5)
 261.6 
 36.3 
 8.6 

 66.9 
 (47.6)
 (11.0)

Net cash inflow from operating activities

 482.2 

 572.4 

Cash and Cash Equivalents Accounting Policy
Cash and cash equivalents are stated at amortised cost which approximates fair value and include cash on hand,  
short-term bank bills and term deposits, commercial paper, negotiable certificate of deposit, and other short-term  
highly liquid investments with original maturities of three months or less that are readily convertible to known amounts  
of cash and which are subject to an insignificant change in value.

For the purpose of presentation in the consolidated statement of cash flows, cash and cash equivalents include all  
cash assets, net of outstanding bank overdrafts.

(e) Liquidity risk 

Liquidity risk is the risk that an entity will encounter difficulty 
in raising funds to meet cash commitments associated with 
financial instruments. It may result from either the inability 
to sell financial assets quickly at their fair values; or a 
counterparty failing on repayment of a contractual obligation; 
or insurance liability falling due for payment earlier than 
expected; or inability to generate cash inflows as anticipated.

In order to maintain appropriate levels of liquidity, the Health 
Fund Investment Portfolio’s target asset allocation is to 
hold 20% (2020: 28%) of its total investment assets in cash/
bank deposits and highly liquid short-term money market 
instruments and fixed income securities. The Non-Health 
Fund Investment Portfolio provides the Group with additional 
liquidity and financial flexibility over and above the Fund’s 
target allocation.

Trade payables and other financial liabilities mainly originate 
from the financing of assets used in ongoing operations 
such as property, plant and equipment and investments in 
working capital. These assets are considered by the Group 
in the overall liquidity risk. To monitor existing financial 
liabilities as well as to enable an effective overall controlling 
of future risks, the Group has established comprehensive 
risk reporting that reflects expectations of management 
of expected settlement of financial liabilities.

The tables on the following page reflect all contractually 
fixed pay-offs for settlement and interest resulting from 
recognised financial liabilities as at 30 June 2021, as well as 
the respective undiscounted cash flows for the respective 
upcoming fiscal years. Cash flows for financial liabilities 
without fixed amount or timing are based on the conditions 
existing at 30 June 2021.

Annual Report 2021    101 

2021
Other trade and other payables1
Lease liabilities2
Total trade and other payables

Claims liabilities
COVID-19 claims liability3
Total claims liabilities

2020
Other trade and other payables1
Lease liabilities2
Total trade and other payables

Claims liabilities
COVID-19 claims liability3
Total claims liabilities

Under 6 
months  
$m

6 to 12 
months  
$m

 309.4 
 16.1 
 325.5 

 376.7 
 63.5 
 440.2 

 292.1 
 15.3 
 307.4 

 310.3 
 145.7 
 456.0 

 0.7 
 15.4 
 16.1 

 21.9 
 160.3 
 182.2 

 0.2 
 14.5 
 14.7 

 20.9 
 151.4 
 172.3 

1 to 2  
years  
$m

 1.1 
 29.7 
 30.8 

 5.5 
- 
 5.5 

 0.4 
 27.8 
 28.2 

 6.5 
- 
 6.5 

Over 2 
years  
$m

Total 
contractual 
cash flows  
$m

Carrying 
amount  
$m

 3.8 
 36.4 
 40.2 

 3.6 
- 
 3.6 

 2.5 
 58.2 
 60.7 

 4.4 
- 
 4.4 

 315.0 
 97.6 
 412.6 

 407.7 
 223.8 
 631.5 

 295.2 
 115.8 
 411.0 

 342.1 
 297.1 
 639.2 

 315.0 
 93.4 
 408.4 

 407.7 
 223.8 
 631.5 

 295.2 
 109.2 
 404.4 

 342.1 
 297.1 
 639.2 

1.  Contractual cash flows greater than 6 months primarily relate to the loyalty program.

2.  Refer to Note 14 for further information on lease liabilities.

3.  Refer to Note 3(b) for further information on the COVID-19 claims liability.

It is not possible for a company primarily transacting in 
insurance business to predict the requirements of funding 
with absolute certainty. The theory of probability is applied 
based on past observed practices. The amounts and 
maturities in respect of insurance liabilities are therefore, 
based on management’s best estimate which incorporates 
statistical techniques and past experience. It is not possible 
for the Group to predict the ongoing restrictions on surgeries 
and other health services due to COVID-19 which could result 
in the maturity profile of the claims liability extending beyond 
12 months.

Note 10: Contributed equity and reserves
(a) Contributed equity

Contributed equity consists of 2,754,003,240 fully paid ordinary 
shares at $0.03 per share. Ordinary shares entitle their  
holder to one vote, either in person or by proxy, at a meeting 
of Medibank, and in a winding up or reduction of capital,  
the right to repayment of the capital paid up on the shares.

Ordinary shares entitle their holders to receive dividends and, 
in the event of winding up Medibank or reduction of capital,  
entitle their holders to participate in the distribution of the 
surplus assets of Medibank.

(b) Reserves

Reserve

2021 
$m

2020 
$m

Nature and purpose of reserve

Equity reserve

17.8

17.8

During the 2009 financial year, the parent entity entered into a restructure 
of administrative arrangements, which gave rise to an equity reserve 
representing the difference between the book value of the net assets 
acquired from Medibank Health Solutions Pty Ltd (formerly Health 
Services Australia Pty Ltd) and the total purchase consideration.

Share-based 
payments reserve

4.5

4.6

The share-based payments reserve is used to record the cumulative 
expense recognised in respect of performance rights issued to key 
management personnel. Refer to Note 18 for further information.

Total

22.3

22.4

102    Medibank 

Notes to the consolidated financial statements30 June 2021Section 4. Other assets and liabilities
Overview 

This section provides insights into the operating assets used and liabilities incurred to generate the Group’s operating result.

Note 11: Property, plant and equipment
(a) Closing net book amount

Closing net book amount
Plant and equipment
Leasehold improvements
Assets under construction
Right-of-use assets
Total property, plant and equipment

Note

14

2021 
$m

10.2
23.7
4.5
63.3
101.7

(b) Reconciliation of the net book amount at the beginning and end of the period

Plant and 
equipment  
$m

Leasehold 
improvements 
$m

Assets under 
construction 
$m

2021
Gross carrying amount
Balance at 1 July 2020
Additions
Transfers in/(out)
Balance at 30 June 2021

Accumulated depreciation and impairment
Balance at 1 July 2020
Depreciation expense
Balance at 30 June 2021

2020
Gross carrying amount
Balance at 1 July 2019
Additions
Transfers in/(out)
Disposals
Balance at 30 June 2020

Accumulated depreciation and impairment
Balance at 1 July 2019
Depreciation expense
Disposals
Balance at 30 June 2020

Closing net book amount
As at 30 June 2021
As at 30 June 2020

 15.0 
 6.2 
 1.7 
22.9

 (8.9)
 (3.8)
 (12.7)

 14.3 
 0.3 
 0.4 
- 
 15.0 

 (5.5)
 (3.4)
- 
 (8.9)

10.2
6.1

 92.8 
 1.0 
 1.2 
95.0

 (61.8)
 (9.5)
 (71.3)

 90.2 
 1.3 
 1.7 
 (0.4)
 92.8 

 (52.0)
 (9.8)
- 
 (61.8)

23.7
31.0

(c) Property, plant and equipment capital expenditure commitments

Capital expenditure contracted for at the end of the reporting period but not 
recognised as liabilities

 3.0 
 4.4 
 (2.9)
4.5

-
- 
-

 2.3 
 2.8 
 (2.1)
- 
 3.0 

-
-
- 
-

4.5
3.0

2021 
$m

0.2

2020 
$m

6.1
31.0
3.0
72.1
112.2

Total 
$m

110.8
11.6
- 
122.4

 (70.7)
 (13.3)
 (84.0)

 106.8 
 4.4 
- 
 (0.4)
 110.8 

 (57.5)
 (13.2)
- 
 (70.7)

38.4
40.1

2020 
$m

-

Annual Report 2021    103 

 
 
Property, Plant and Equipment Accounting Policy
Refer to Note 14 for the accounting policy for  
right-of-use assets.

Property, plant and equipment is stated at historical cost 
less depreciation. Historical cost includes expenditure that 
is directly attributable to the acquisition of the items.

Subsequent costs are recognised as an asset when  
it is probable that future economic benefits associated  
with the item will flow to the Group and the cost of the  
item can be measured reliably. All other repairs and 
maintenance costs are charged to the consolidated 
statement of comprehensive income during the  
reporting period in which they are incurred.

Depreciation
Depreciation is calculated using the straight-line method 
over the estimated useful life or lease term as follows

Plant and equipment 
Leasehold improvements 
Assets under construction 

3 – 15 years
the lease term
not depreciated until in use

The assets’ residual values and useful lives are reviewed, and 
adjusted if appropriate, at the end of each reporting period. 

Disposal
The gain or loss on disposal of property, plant and 
equipment is calculated as the difference between the 
carrying amount of the asset at the time of disposal and  
the net proceeds on disposal (including incidental costs). 
These gains or losses are included in the consolidated 
statement of comprehensive income.

Note 12: Intangible assets

2021
Gross carrying amount
Balance at 1 July 2020
Additions
Transfers in/(out)
Balance at 30 June 2021

Accumulated amortisation and impairment
Balance at 1 July 2020
Amortisation expense
Balance at 30 June 2021

2020
Gross carrying amount
Balance at 1 July 2019
Restatement1
Balance at 1 July 2019 (restated)
Additions
Transfers in/(out)
Balance at 30 June 2020

Accumulated amortisation and impairment
Balance at 1 July 2019
Restatement1
Balance at 1 July 2019 (restated)
Amortisation expense
Balance at 30 June 2020

Closing net book amount
As at 30 June 2021
As at 30 June 2020

Customer 
contracts and 
relationships 
$m

Goodwill 
$m

Software 
$m

Assets under 
construction 
$m

282.9
- 
- 
282.9

 (78.4)
- 
 (78.4)

282.9
- 
282.9
- 
- 
282.9

 (78.4)
- 
(78.4)
- 
 (78.4)

204.5
204.5

89.7
- 
- 
89.7

(81.4)
 (4.6)
 (86.0)

89.7
- 
89.7
- 
- 
89.7

 (72.4)
- 
(72.4)
 (9.0)
 (81.4)

3.7
8.3

430.7
4.1
20.7
455.5

(306.0)
 (37.6)
 (343.6)

426.4
(34.6)
391.8
2.5
36.4
430.7

 (280.5)
 14.1 
(266.4)
 (39.6)
 (306.0)

111.9
124.7

Total 
$m

829.5
23.8
- 
853.3

26.2
19.7
 (20.7)
25.2

- 
- 
- 

 (465.8)
 (42.2)
 (508.0)

38.2
 (1.8)
36.4
26.2
(36.4)
26.2

- 
- 
- 
- 
- 

837.2
(36.4)
800.8
28.7
- 
829.5

 (431.3)
 14.1 
(417.2)
 (48.6)
 (465.8)

25.2
26.2

345.3
363.7

1.   Restatement reflects the change in accounting policy for Software as a Service (SaaS) intangible assets detailed in Note 20(a).

104    Medibank 

Notes to the consolidated financial statements30 June 2021(a) Impairment tests for goodwill – key assumptions and judgements 

Below is a cash generating unit (CGU) level summary of the Group’s goodwill allocation and the key assumptions made in 
determining the recoverable amounts. 

Health Insurance
Medibank Health Telehealth
Medibank Health Home Care

Goodwill 
allocation 
$m
 96.2 
 11.1 
 97.2 

2021

Growth 
rate 
%
 2.5 
 1.0 
 2.5 

Pre-tax 
discount 
rate %
 10.5 
 11.3 
 11.3 

Goodwill 
allocation 
$m
 96.2 
 11.1 
 97.2 

2020

Growth 
rate 
%
 2.5 
 2.5 
 2.5 

Pre-tax 
discount 
rate %
 10.7 
 11.3 
 11.3 

Growth rates 
and discount 
rates

The growth rate disclosed above represents the weighted average growth rate used to extrapolate cash 
flows beyond the budget period. The growth rate does not exceed the long-term average growth rate for the 
business in which the CGU operates as per industry forecasts.

In performing the recoverable amount calculations for each CGU, the Group has applied post-tax discount 
rates to discount the forecast future attributable post-tax cash flows. The equivalent pre-tax discount rates 
are disclosed above. The discount rates used reflect specific risks relating to the relevant CGU. 

Health 
Insurance 
CGU

The recoverable amount is based on a value-in-use calculation, which uses a three year cash flow projection 
per the Group’s Corporate Plan approved by the Board. Cash flows beyond the Corporate Plan period are 
extrapolated using the estimated growth rates, with a terminal value assumed in the calculations.

Key assumptions
•  Forecast revenue comprising estimated change in the number of members and future premium  

revenue rate rises.

•  Forecast claims and operating expenses. 

Medibank 
Health 
Telehealth 
CGU

The recoverable amount is based on a value-in-use calculation, which uses a three year cash flow 
projection per the Group’s Corporate Plan approved by the Board. Cash flows that are beyond this  
period, but within the period that management can reliably estimate, are extrapolated using the  
estimated growth rates. No terminal value has been assumed in the calculations.

Key assumptions
•  Forecast revenue for the market sector and specific forecasts for key customer contracts.
•  Forecast direct expenses and allocated corporate costs.
•  Period over which to assess the forecasts.

The key assumption in the Medibank Health Telehealth CGU is the cash flow forecast. The ability to meet 
these cash flows, which are based on the Group’s Corporate Plan, could impact the recoverability of the 
CGU. The business model of the CGU is contract based by nature and the forecast cash flows contain 
assumptions around expected contract renewals, new wins and losses. This cash flow estimate assumes 
that current contract renewal options will be exercised by the customers. This assumption is based on 
management’s past experience and knowledge of the market in which the CGU operates.

Medibank 
Health Home 
Care group 
of CGUs

Home Care comprises acquired and internally developed in-home care businesses. Goodwill has been allocated 
to the Home Care CGUs as the Group derives strategic and operational synergies, and the Group monitors 
business performance at the combined Home Care level. The recoverable amount is based on a value-in-use 
calculation, which uses a three year cash flow projection per the Group’s Corporate Plan approved by the 
Board. Cash flows that are beyond this period, but within the period that management can reliably estimate, 
are extrapolated using the estimated growth rates with a terminal value assumed in the calculations.

Key assumptions
•  Forecast revenue based on market sector growth, customer contracts and specific volume forecasts  

for geographic areas. 

•  Forecast direct expenses and allocated corporate costs.
•  Continued synergies from:

 – Single go-to-market approach.
 – Integration of the chronic diseases management and rehab at home programs.
 – Workforce management.

Annual Report 2021    105 

Medibank 
Health Home 
Care group 
of CGUs 
continued

The key assumption in the Medibank Health Home Care group of CGUs is the cash flow forecast. The ability 
to meet these cash flows, which are based on the Group’s Corporate Plan, could impact the recoverability 
of the CGUs. The business model of the Home Care group of CGUs is volume and contract based and the 
forecast cash flows contain assumptions including volumes of services performed across geographic areas 
and expected contract renewals, new wins and losses. The cash flow forecast assumes that service volumes 
will increase based on geographic growth and new contracts. This assumption is based on management’s 
past experience and knowledge of the market in which the CGUs operate.

There are no reasonably possible changes in key assumptions that could have resulted in an impairment loss for the Health 
Insurance CGU, Medibank Health Telehealth CGU or the Medibank Health Home Care group of CGUs in the current or prior 
financial year.

Impairment Accounting Policy
Goodwill and intangible assets that have an indefinite  
useful life are not subject to amortisation and are tested 
annually for impairment, or more frequently if events 
or changes in circumstances indicate that they might 
be impaired. An impairment loss is recognised for the 
amount by which the asset’s carrying amount exceeds its 
recoverable amount. The recoverable amount is the higher 
of an asset’s fair value less costs of disposal and its value-
in-use. In assessing value-in-use, the estimated future 
cash flows are discounted to their present value using  

a discount rate that reflects current market assessments of 
the time value of money and the risks specific to the asset. 

For the purposes of assessing impairment, assets are 
grouped at the lowest levels for which there are separately 
identifiable cash inflows which are largely independent of the 
cash inflows from other assets or groups of assets called 
cash-generating units (CGUs). Goodwill is allocated to the 
CGU, or group of CGUs, at which the goodwill is monitored 
and where the synergies of the combination are expected. 

(b) Intangible assets capital expenditure commitments

Capital expenditure contracted for at the end of the reporting period  
but not recognised as liabilities

Intangible Assets Accounting Policy

2021 
$m

2020 
$m

 1.9

 1.7

Accounting policy

Key estimates

Goodwill is not amortised but it is tested for impairment 
annually, or more frequently if events or changes in 
circumstances indicate that it might be impaired, and is 
carried at cost less accumulated impairment losses. 

Refer to Note 12(a) above for further 
information on the assumptions used in  
the recoverable amount calculations.

The estimated useful lives are based on  
projected product lifecycles and could  
change significantly as a result of technical 
innovations and competitor actions. 

Software intangibles are carried at cost less 
accumulated amortisation and impairment losses. 
Costs incurred in acquiring software and licences 
(including external direct costs of materials and service 
and direct payroll-related costs of employees’ time spent 
on the project) are capitalised where there is control 
of the underlying software asset and where they will 
contribute to future financial benefits, through revenue 
generation and/or cost reduction.

Amortisation is calculated on a straight-line basis  
over the expected useful lives of the software  
(1.5 to 10 years) and is recognised in depreciation  
and amortisation expense in the consolidated 
statement of comprehensive income.

Goodwill

Software

106    Medibank 

Notes to the consolidated financial statements30 June 2021 
Customer 
contracts and 
relationships

Customer contracts and relationships acquired as 
part of a business combination are carried at their 
fair value at the date of acquisition less accumulated 
amortisation and impairment losses. 

Amortisation is calculated on a straight-line basis 
over the expected useful lives (5 to 12 years) and is 
recognised in depreciation and amortisation expense in 
the consolidated statement of comprehensive income.

Customer contracts and relationships are 
assessed for indicators of impairment 
whenever events or changes in circumstances 
indicate that the carrying amount may not be 
recoverable.

A key assumption in assessing customer 
contracts and relationships for impairment 
is the retention of the underlying contracts. 
Assumptions are made around renewal of 
these contracts, associated cash flows based 
on contracted renewal options and the Group’s 
commercial and strategic long-term plans.

Note 13: Provisions and employee entitlements

Note

13(c)
13(a)
13(b)

13(a)
13(b)

Current
Customer give back provision
Employee entitlements 
Provisions
Total current

Non-current
Employee entitlements 
Provisions
Total non-current

(a) Employee entitlements

(i) Employee entitlements provision

Employee entitlements 
Current
Non-current
Total employee entitlements

This provision incorporates annual leave, long service leave, termination payments and bonus plans. 

(ii) Employee benefits expense 

Included in the Group’s employee benefits expense are the following:

Superannuation expense
Other long-term benefits expense
Termination benefits expense
Share-based payment expense

2021 
$m

 103.0 
 69.7 
 25.0 
 197.7 

 13.0 
 9.7 
 22.7 

2021 
$m

 69.7 
 13.0 
 82.7 

2021 
$m
 30.4 
 5.4 
 3.7 
 5.2 

2020 
$m

- 
 52.5 
 30.4 
 82.9 

 12.6 
 7.0 
 19.6 

2020 
$m

 52.5 
 12.6 
 65.1 

2020 
$m
 29.7 
 5.0 
 2.7 
 1.2 

Annual Report 2021    107 

Employee Entitlements Accounting Policy

Short-term 
obligations

Liabilities for wages and salaries, including non-monetary benefits, are recognised in respect  
of employees’ services up to the end of the reporting period and are measured at the amounts 
expected to be paid when the liabilities are settled. 

Other long-term 
employee benefit 
obligations

Liabilities for employee entitlements includes long service leave and annual leave which are not 
expected to be settled wholly within 12 months after the end of the period. The liabilities  
are measured at the present value of expected future payments using the projected unit credit  
method, taking into account:

•  Expected future wage and salary levels.
•  Experience of employee departures. 
•  Periods of service.

Expected future payments are discounted using market yields at the end of the reporting period, 
using corporate bonds with terms to maturity that closely match the estimated future cash outflows. 
The obligations are presented as current liabilities in the consolidated statement of financial position 
if the Group does not have an unconditional right to defer settlement for at least 12 months after the 
reporting date, regardless of when the actual settlement is expected to occur.

Bonus plans

Liabilities for bonuses are based on a formula that takes into consideration the performance of the 
employee against targeted and stretch objectives, the profit of the Group and other financial and 
non-financial key performance indicators. The Group recognises a provision when it is contractually 
obliged or where there is a past practice that has created a constructive obligation. 

Termination 
benefits

Termination benefits are payable when employment is terminated by the Group before the normal 
retirement date, or when an employee accepts voluntary redundancy in exchange for these benefits. 
The Group recognises termination benefits at the earlier of the following dates:

•  When the Group can no longer withdraw the offer of those benefits.

•  When the Group recognises costs for a restructuring that is within the scope of  

AASB 137 Provisions, Contingent Liabilities and Contingent Assets and involves the payment  
of termination benefits. 

In the case of an offer made to encourage voluntary redundancy, the termination benefits are 
measured based on the number of employees expected to accept the offer. Benefits falling due  
more than 12 months after the end of the reporting period are discounted to present value.

(b) Provisions

Balance at 1 July 2020
Additional provision
Amounts utilised during the year
Reversal of unused provision
Balance at 30 June 2021

Balance comprised of:
Current
Non-current

Commissions 
$m
 8.1 
 7.5 
 (6.7)
- 
 8.9 

Make good 
$m 
 4.5 
 0.5 
- 
- 
 5.0 

Workers 
compensation 
$m 
 4.8 
 1.6 
 (1.1)
- 
 5.3 

Corporate 
loyalty benefits 
$m
 6.7 
 3.2 
 (2.0)
 (0.9)
 7.0 

Other 
$m 
 13.1 
 3.2 
 (7.7)
 (0.1)
 8.5 

Total 
$m 
 37.2 
 16.0 
 (17.5)
 (1.0)
 34.7 

 8.9 
- 

 2.2 
 2.8 

 1.4 
 3.9 

 7.0 
- 

 5.5 
 3.0 

 25.0 
 9.7 

108    Medibank 

Notes to the consolidated financial statements30 June 2021(i) Commissions provision

This provision relates to estimated commissions payable  
to third parties in relation to the acquisition of health 
insurance contracts.

(ii) Make good provision

In accordance with certain lease agreements, the Group 
is obligated to restore leased premises to their original 
condition at the end of the lease term. Due to the long-term 
nature of the liability, there is uncertainty in estimating the 
ultimate amount of these costs. The provision has been 
discounted to take into account the time value of money 
throughout the remaining term of the lease.

(iii) Workers compensation provision

The Group is self-insured for workers’ compensation claims. 
Provisions are recognised based on claims reported and 
an estimate of claims incurred but not reported. These 
provisions are determined on a discounted basis, using  
an actuarial valuation performed at each reporting date. 
The Group has entered into $10.0 million (2020: $8.8 million) 
of bank guarantees in relation to its self-insured workers 
compensation obligations.

(iv) Corporate loyalty benefits provision

This provision relates to estimated incentives payable  
to third parties in relation to the acquisition of Corporate 
health insurance contracts.

(c) Customer give back provision

A customer give back provision of $103.0 million has been 
recognised at 30 June 2021 (2020: nil). This provision relates 
to the return of permanent COVID-19 savings to customers 
through premium relief announced by the Group on 29 June 
2021. The provision has been recognised within Health 
Insurance premium revenue in the consolidated statement 
of comprehensive income and is expected to be utilised via 
a one-time cash payment to former eligible policyholders or 
a one-time reduction in future premiums payable by active 
eligible policyholders within the next 12 months. 

Note 14: Leases
(a) Group as a lessee

Leases are entered into as a means of acquiring access 
to corporate and retail property. Rental payments are 
generally fixed, with differing clauses to adjust the rental 
to reflect increases in market rates. These clauses include 
fixed incremental increases, market reviews and inflation 
escalation clauses during a lease on which contingent  
rentals are determined. No operating leases contain 
restrictions on financing or other leasing activities. 

Provisions Accounting Policy
Provisions are recognised when:

•  The Group has a present legal or constructive 

obligation as a result of past events.

•  It is probable that an outflow of resources will be 

required to settle the obligation. 

•  The amount has been reliably estimated. 

Provisions are not recognised for future operating losses.

Where there are a number of similar obligations, the 
likelihood that an outflow will be required in settlement 
is determined by considering the class of obligations as 
a whole. A provision is recognised even if the likelihood 
of an outflow with respect to any one item included in the 
same class of obligations may be small.

Provisions are measured at the present value of 
management’s best estimate of the expenditure required 
to settle the present obligation at the end of the reporting 
period. Expected future payments are discounted using 
market yields at the end of the reporting period using 
corporate bonds with terms to maturity that match, as 
closely as possible, the estimated future cash outflows. 
The increase in the provision due to the passage of time 
is recognised as interest expense.

(d) Contingent liabilities

From time to time, the Group is exposed to contingent 
liabilities which arise from the ordinary course of business, 
including:

•  Losses which might arise from litigation.

•  Investigations from internal reviews and by regulatory 

bodies such as the ACCC, ASIC or APRA into past conduct 
on either industry-wide or Medibank specific matters.

It is anticipated that the likelihood of any unprovided  
liabilities arising is either remote or not material.

The Group leases unused office space under non-cancellable 
leases agreements. The leases have varying terms, escalation 
clauses and renewal rights.

As at 30 June 2021, management have determined it is not 
reasonably certain that any of its leases will be extended  
or terminated. 

Annual Report 2021    109 

The table below sets out the carrying amounts of the right-of-use asset and the movements during the year.

Balance at 1 July
Net additions
Depreciation expense
Balance at 30 June

The table below sets out the carrying amounts of the lease liabilities and the movements during the year.

Balance at 1 July
Additions
Accretion of interest
Lease payments
Balance at 30 June

Balance comprised of:

Current
Non-current

2021 
$m
72.1
18.4
(27.2)
63.3

2021 
$m
 109.2 
 18.4 
 2.8 
 (37.0)
 93.4 

2020 
$m
88.0
11.1
(27.0)
72.1

2020 
$m
 132.5 
 6.6 
 3.4 
 (33.3)
 109.2 

 28.1 
 65.3 

 27.9 
 81.3 

The maturity profile of the Group's lease liabilities based on contractual undiscounted payments is provided in Note 9(e).

Leases Accounting Policy
As a lessee
At inception of a contract, the Group assesses whether a 
contract is, or contains, a lease by determining whether:
•  The contract involves the use of an identified asset.
•  The Group has the right to direct the use of the asset

The Group recognises a right-of-use asset and a lease 
liability at the lease commencement date. The right-of-use 
asset is initially measured at cost, which comprises the initial 
amount of the lease liability adjusted for any lease payments 
made at or before the commencement date, plus any initial 
direct costs incurred and an estimate of costs to restore the 
underlying asset less any lease incentives received.

The right-of-use asset is subsequently depreciated using 
the straight-line method from the commencement date to 
the earlier of the end of the useful life of the right-of-use 
or the end of the lease term. In addition, the right-of-use 
is periodically reduced by impairment losses, if any, and 
adjusted for certain remeasurements of the lease liability.

The lease liability is initially measured at the present 
value of the lease payments that are not paid at the 
commencement date, discounted using the Group’s 
incremental borrowing rate. In determining the incremental 
borrowing rate, the following components are considered:
•  Reference rate (incorporating currency, environment, term).
•  Financing spread adjustment (incorporating term, 

indebtedness, entity, environment).

•  Lease specific adjustment (incorporating asset type).

The interest expense recognised on the lease liability is 
measured at amortised cost using the effective interest 
method. The lease liability is remeasured when there is 
a change in future lease payments, with a corresponding 
adjustment made to the carrying amount of the right-of-use 
asset (or profit or loss if the carrying amount of the right-
of-use asset has been reduced to zero).

The Group has elected not to recognise right-of-use assets 
and lease liabilities for leases of low value assets. The Group 
recognises the lease payments associated with these leases 
as an expense on a straight-line basis over the lease term.

b) Group as a Lessor

Finance lease receivables of $7.0 million have been 
recognised by the Group at 30 June 2021 (2020: $8.9 million).  
These are presented within other assets in the consolidated 
statement of financial position. The Group recognised income  
of $1.1 million (2020: $2.3 million) for the year with respect  
to subleasing of its right-of-use assets.

Leases Accounting Policy
As a lessor
The Group acts as an intermediate lessor for two of its  
four subleases. The Group’s interest in the head lease  
and sublease are accounted for separately. At the sublease 
commencement, the Group determines whether it is a finance 
or operating lease by assessing whether the lease transfers 
substantially all of the risks and rewards of ownership to the 
lessee, with reference to the right-of-use asset arising from 
the head lease, not with reference to the underlying asset.

110    Medibank 

Notes to the consolidated financial statements30 June 2021Section 5. Other
Overview 

This section includes additional information that must be disclosed to comply with Australian Accounting Standards,  
the Corporations Act 2001 and the Corporations Regulations.

Note 15: Income tax

Tax consolidation legislation
Medibank and its wholly-owned Australian controlled 
entities are members of a tax consolidated group. As a 
consequence, these entities are taxed as a single entity  
and the deferred tax assets and liabilities of these entities 
are offset in the consolidated financial statements. 

The entities in the tax consolidated group entered into a 
tax sharing agreement which limits the joint and several 

(a) Income tax expense

liability of the wholly-owned entities in the case of a default 
by the head entity, Medibank.

The entities have also entered into a tax funding agreement 
under which the wholly-owned entities fully compensate 
Medibank for any current tax payable and are compensated 
by Medibank for any current tax receivable.

Continuing operations
Current tax
Deferred tax1
Adjustment for tax of prior period
Income tax expense reported in the statement of comprehensive income

2021 
$m

182.2
8.6
0.3
191.1

2020 
$m

226.8
 (93.9)
 1.7 
 134.6 

1.   Prior period includes deferred tax of $89.1 million in relation to the COVID-19 claims liability. Refer to Note 3(b) for further information on the COVID-19 

claims liability.

(b) Numerical reconciliation of income tax expense to prima facie tax payable

Profit for the year from continuing operations before income tax expense

Tax at the Australian tax rate of 30%
Tax effect of amounts which are not deductible (taxable) in calculating taxable income:
Non-deductible expenses
Tax offset for franked dividends
Other items

Adjustment for tax of prior period 
Income tax expense reported in the statement of comprehensive income

2021 
$m
 632.3 

2020 
$m
 450.2 

 189.7 

 135.1 

 2.8 
 (1.2)
 (0.5)
 190.8 

 0.3 
 191.1 

- 
 (1.8)
 (0.4)
 132.9 

 1.7 
 134.6 

Annual Report 2021    111 

 
(c) Deferred tax assets and liabilities

Deferred tax balances comprise temporary differences attributable to items:
Recognised in the income statement
Trade and other receivables
Financial assets at fair value through profit or loss
Deferred acquisition costs
Property, plant and equipment
Intangible assets
Trade and other payables
Employee entitlements
Claims liabilities1
Provisions2
Business capital costs
Other (liabilities)/assets
Recognised in the income statement

Recognised directly in other comprehensive income
Actuarial loss on retirement benefit obligation
Recognised directly in other comprehensive income

Net deferred tax (liabilities)/assets

2021 
$m

2020 (restated)3 
$m

2.0
(28.4)
(24.3)
(19.6)
 (13.0)
30.6
24.8
72.2
40.6
0.3
0.3
85.5

0.4
0.4

85.9

 2.1 
(16.0)
 (23.4)
 (22.8)
10.6
 34.5 
 19.5 
 95.0 
 11.4 
 0.5 
 (0.6)
89.6

 0.6 
 0.6 

90.2

1.    Includes deferred tax of $67.1 million (2020: $89.1 million) in relation to the COVID-19 claims liability. Refer to Note 3(b) for further information on the 

COVID-19 claims liability.

2.   Includes deferred tax of $30.9 million (2020: nil) in relation to the customer give back provision. Refer to Note 13(c) for further information.

3.   Restatement reflects the change in accounting policy for Software as a Service (SaaS) intangible assets detailed in Note 20(a).

Income Tax Accounting Policy
Current Taxes Accounting Policy
The current income tax charge is calculated on the basis 
of the tax laws enacted or substantively enacted at the end 
of the reporting period. Management periodically evaluates 
positions taken in tax returns with respect to situations in 
which applicable tax regulation is subject to interpretation, 
and establishes provisions where appropriate.

Deferred Taxes Accounting Policy
Deferred income tax is determined using tax rates (and laws) 
that have been enacted or substantially enacted at the end 
of each reporting period and are expected to apply when the 
related deferred income tax asset is realised or the deferred 
income tax liability is settled. Deferred income tax is provided 
on temporary differences arising between the tax bases 
of assets and liabilities and their carrying amounts in the 
consolidated financial statements, other than for the following:
•  Where they arise from the initial recognition of goodwill.
•  Where they arise from the initial recognition of an 

asset or liability in a transaction other than a business 
combination that at the time of the transaction affects 
neither accounting nor taxable profit or loss.

•  For temporary differences between the carrying amount 
and tax bases of investments in controlled entities where 
the parent entity is able to control the timing of the 
reversal of temporary differences and it is probable that 
the differences will not reverse in the foreseeable future.

Deferred tax assets are recognised for deductible 
temporary differences and unused tax losses only if it is 
probable that future taxable amounts will be available to 
utilise those temporary differences and losses. 

Current and deferred tax is recognised in the profit or loss, 
except to the extent that it relates to items recognised in 
other comprehensive income or directly in equity. In this 
case, the tax is also recognised in other comprehensive 
income or directly in equity, respectively.

Offsetting balances
Current tax assets and tax liabilities are offset where the 
entity has a legally enforceable right to offset and intends 
either to settle on a net basis, or to realise the asset and 
settle the liability simultaneously. Deferred tax assets and 
liabilities are offset when there is a legally enforceable right 
to offset current tax assets and liabilities and when the 
deferred tax balances relate to the same taxation authority.

Key judgement
The deferred tax asset in relation to the COVID-19 claims liability has been recognised in the consolidated statement  
of financial position. Recognition is on the basis that the Group can demonstrate that:
•  The temporary difference will reverse when the expected deferred claims are incurred.
•  Sufficient profits are forecast to exist to utilise the tax asset in the future.

112    Medibank 

Notes to the consolidated financial statements30 June 2021Note 16: Group structure
(a) Group structure

The consolidated financial statements incorporate the following entities. All entities, unless otherwise stated,  
are 100% controlled.

Medibank Private Limited 

Australian Health 
Management Group  
Pty Ltd

Medibank Health 
Solutions 
Pty Ltd

Medibank Private 
Employee Share  
Plan Trust1

Medibank 
Health Solutions 
Telehealth  
Pty Ltd

Integrated Care 
Services 
Pty Ltd

Medi Financial 
Services 
Pty Ltd

Live Better 
Management 
Pty Ltd

MH Investment 
Holdings 
Pty Ltd

MH Solutions 
Investments 
Pty Ltd

HealthStrong 
Pty Ltd

Home Support 
Services 
Pty Ltd

Calvary MHIH JV 
Pty Ltd  
(50%)

East Sydney Day 
Hospital Pty Ltd  
(49%)

Adeney Private 
Hospital Pty Ltd  
(49%)

Myhealth Medical 
Holdings Pty Ltd  
(49%)

   These subsidiaries are wholly owned by Medibank Health Solutions Pty Ltd and have been granted relief from the necessity to prepare financial reports  

in accordance with the ASIC Corporations (Wholly-owned Companies) Instrument 2016/785. 

  These entities are equity accounted investments. Refer to Note 16(b) for further information.

1.  Refer to Note 18(a) for further information on the Employee Share Plan Trust.

Consolidation Accounting Policy
Subsidiaries are all those entities over which the Group has 
control. The Group controls an entity when it is exposed to, 
or has rights to, variable returns from its involvement with 
the entity and has the ability to affect those returns through 
its power over the entity. Subsidiaries are fully consolidated 
from the date on which control is transferred to the Group. 
They are deconsolidated from the date that control ceases.

and contingent liabilities assumed in a business 
combination are, with limited exceptions, measured initially 
at their fair values at the acquisition date. The excess  
of the consideration transferred and the amount of any 
non-controlling interest in the acquiree over the fair value 
of the Group’s share of the net identifiable assets acquired, 
is recorded as goodwill.

The acquisition method of accounting is used to account 
for the acquisition of subsidiaries. The consideration 
transferred for the acquisition of a subsidiary comprises 
the fair value of the assets transferred and the liabilities 
incurred. Acquisition-related costs are expensed as 
incurred. Identifiable assets acquired and liabilities  

Intercompany transactions, balances and unrealised 
gains on transactions between Group companies are 
eliminated. Unrealised losses are also eliminated unless 
the transaction provides evidence of the impairment of  
the asset transferred. Accounting policies of subsidiaries 
are consistent with the policies adopted by the Group.

Annual Report 2021    113 

 
 
 
 
(b) Equity accounted investments

As at 30 June 2021 the Group held the following investments in associates and joint ventures:

Name of company
East Sydney Day Hospital Pty Ltd(i)
Calvary MHIH JV Pty Ltd(ii)
Myhealth Medical Holdings Pty Ltd(iii)
Adeney Private Hospital Pty Ltd(iv)

Principal  
activity
Short-stay hospital
Medical services
Medical services
Short-stay hospital 

Place of 
incorporation
Australia
Australia
Australia
Australia

Type
Associate
Joint Venture
Associate
Associate

The following table shows the Group’s aggregated interests in equity accounted investments.

Balance at 1 July 
Net additions1
Share of net profit/(loss) for the year
Balance at 30 June

Ownership interest %

2021
49%
50%
49%
49%

2021 
$m
- 
 78.1 
 (1.0)
 77.1 

2020
-
-
-
-

2020 
$m
- 
- 
- 
- 

1.   Net additions during the period include purchases of equity accounted investments ($82.6 million) and proceeds from sale of equity accounted 

investments ($11.6 million).

(i) East Sydney Day Hospital Pty Ltd – Associate

(iii) Myhealth Medical Holdings Pty Ltd – Associate

On 6 August 2020, MH Solutions Investments Pty Ltd acquired 
a 49% shareholding in East Sydney Day Hospital Pty Ltd 
(ESPH) for $8.8 million, of which $4.4 million is recognised  
as a current payable and due 12 months following completion. 
The purchase agreement contains an additional $10.8 million 
contingent consideration that is subject to ESPH achieving 
certain earnings targets over three years. The fair value of 
this contingent consideration is $2.7 million at 30 June 2021 
and has been recorded as a non-current provision in the 
consolidated statement of financial position. 

An interest-bearing three-year loan of $2.9 million was  
also advanced to ESPH on acquisition.

(ii) Joint venture with Calvary Hospital 

On 29 September 2020, MH Investment Holdings Pty Limited 
acquired a 50% shareholding in Calvary MHIH JV Pty Ltd 
for $2.7 million. This joint venture was determined to be 
the successful bidder on a tender for the South Australian 
Government’s “My Home Hospital” program during the period.

On 31 March 2021, MH Solutions Investments Pty Ltd 
acquired a 49% shareholding in Myhealth Medical Holdings 
Pty Ltd for $68.6 million. The Group subsequently reduced 
its shareholding to 43% on the same day for proceeds of 
$11.6 million, before increasing its shareholding again to 
49% on 1 April for consideration of $5.9 million. The net 
consideration paid for the 49% investment is $62.9 million. 

(iv) Adeney Private Hospital Pty Ltd – Associate

On 9 March 2021, MH Solutions Investments Pty Ltd acquired 
a 49% shareholding in Adeney Private Hospital Pty Ltd 
(APH) for $1.0 million, to develop a hospital in Victoria for 
short-stay surgical procedures. As part of the purchase 
agreement, the Group may make future equity purchases 
in APH up to $8.0 million over the next 3 years. These future 
equity purchases are contingent on APH achieving certain 
milestones in the development of the hospital and therefore 
will only be recognised when the milestones are achieved.

Parent Entity Financial Information Accounting Policy
The Group’s associates and joint ventures, which are  
entities over which the Group has significant influence or 
joint control, are accounted for using the equity method. 
Under this method, the investment associate or joint 
venture is initially recognised at cost and is increased or 
decreased to recognise the Group’s share of profit or loss.  

Equity accounting of losses is restricted to the Group’s 
interest in the associate or joint venture. The Group’s 
share of profit or loss for the period is reflected in the 
consolidated statement of comprehensive income. 
Investments in associates and joint ventures are tested for 
impairment if an event occurs that has an impact on the 
estimated future cash flows from the net investment.

114    Medibank 

Notes to the consolidated financial statements30 June 2021(c) Parent entity financial information

(i) Summary financial information

The individual financial statements for the parent entity show the following aggregate amounts:

Statement of financial position
Current assets

Total assets

Current liabilities

Total liabilities

Shareholders' equity
Issued capital
Reserves

Equity reserve
Share-based payment reserve

Retained earnings
Total shareholders' equity

Profit for the year

Total comprehensive income

2021 
$m

2020 (restated)1 
$m

 3,186.5 

 3,794.7 

 1,832.2 

 1,980.2 

 3,053.3 

 3,632.6 

 1,731.7 

 1,917.6 

 85.0 

 85.0 

 6.3 
 4.5 
 1,718.7 
 1,814.5 

 432.7 

 432.7 

 6.3 
 4.5 
 1,619.2 
 1,715.0 

 311.4 

 311.4 

1.  Restatement reflects the change in accounting policy for Software as a Service (SaaS) intangible assets detailed in Note 20(a).

(ii) Guarantees entered into by parent entity

(iii) Contingent liabilities of the parent entity

Refer to Note 13(d) for details of the contingent liability  
of the parent entity.

The parent entity has entered into $10.0 million  
(2020: $8.5 million) of bank guarantees in relation to its  
self-insured workers compensation obligations. Refer to  
Note 13(b)(iii) for further information on the provision for 
workers compensation. The parent entity also provided 
guarantees in respect of service obligations assumed by 
members of the Group. No liability has been recognised  
in relation to these guarantees by the parent entity or the 
Group as the fair value of the guarantees is not material.

(iv) Parent entity capital expenditure commitments

Capital expenditure contracted for at the end of the reporting period  
but not recognised as liabilities
Property, plant and equipment
Intangible assets

2021 
$m

2020 
$m

 0.2 
 1.6 

- 
 1.5 

Parent Entity Financial Information Accounting Policy
The financial information for the parent entity, Medibank, has been prepared on the same basis as the consolidated 
financial statements, except as set out below:

•  Investments in subsidiaries are accounted for at cost less accumulated impairment losses in the financial  

statements of Medibank.

•  Assets or liabilities arising under tax funding arrangements with the tax consolidated entities are recognised  

by Medibank as current assets or current liabilities.

Annual Report 2021    115 

Note 17: Related party transactions
(a) Transactions with equity accounted investments

Transactions with equity accounted investments
Claims incurred
Services provided
Interest received

Outstanding balances with related parties
Amounts payable
Amounts receivable
Loan receivable

2021 
$m

 (2.9)
 1.7 
 0.2 

- 
 1.5 
 2.9 

2020 
$m

- 
- 
- 

- 
- 
- 

The Group has entered into the following transactions with its equity accounted investments during the year:

•  Payment of policyholder claims. These transactions are under normal commercial terms. 

•  Interest-bearing three-year loan of $2.9 million advanced to ESPH on acquisition. 

•  Reimbursement of costs incurred. 

(b) Key management personnel remuneration

Total remuneration for key management personnel of the Group during the financial year are set out below:

Short-term benefits
Post-employment benefits
Long-term benefits
Share-based payments
Total key management personnel

2021 
$
 10,300,436 
 281,954 
 1,420,495 
 3,515,299 
 15,518,184 

2020 
$
 7,722,918 
 300,528 
 323,044 
 1,641,366 
 9,987,856 

(c) Transactions with other related parties 

Certain key management personnel hold director positions in other entities, some of which transacted with the Group  
during the 2021 financial year. All transactions that occurred were in the normal course of business on terms and conditions  
no more favourable than those available on an arm’s length basis.

116    Medibank 

Notes to the consolidated financial statements30 June 2021Note 18: Share-based payments
(a) Share-based payments arrangements 

Performance rights to acquire shares in Medibank are 
granted to Executive Leadership Team (ELT) and Senior 
Executive Group (SEG) members as part of Medibank’s  
short-term incentive (STI) and long-term incentive (LTI)  
plans. The plans are designed to:

•  Align the interests of employees participating in the 

plan more closely with the interests of customers and 
shareholders by providing an opportunity for those 
employees to receive an equity interest in Medibank 
through the granting of performance rights.

•  Assist in the motivation, retention and reward of ELT  

and SEG members.

Performance rights granted do not carry any voting rights. 

Medibank has an Employee Share Plan Trust to manage  
its share-based payments arrangements. Shares allocated  
by the trust to the employees are acquired on-market prior  
to allocation. The Trust held nil shares at 30 June 2021.

(i) LTI offer

Under the LTI Plan, performance rights were granted to 
members of the ELT and SEG as part of their remuneration. 
Performance rights granted under the LTI Plan are subject  
to the following performance hurdles: 

•  35% of the performance rights will be subject to  

a vesting condition based on Medibank’s earnings  
per share compound annual growth rate (EPS CAGR)  
over the performance period.

•  35% of the performance rights will be subject to a relative 
total shareholder return (TSR) vesting condition, measured 
over the performance period against a comparator group  
of companies. 

•  30% of the performance rights will be subject to a 

performance hurdle based on the growth of Medibank’s 
private health insurance market share (as reported  
by APRA) over the performance period.

Each performance hurdle under the LTI Plan has a threshold 
level of performance which needs to be achieved before 
vesting commences. Details of these thresholds are outlined 
in the remuneration report. The vesting conditions for 
performance rights in grants will be tested over a three-year 
performance period commencing on 1 July of the relevant 
period. The vesting conditions must be satisfied for the 
performance rights to vest. On satisfaction of the vesting 
conditions, each performance right will convert into a fully 
paid ordinary share on a one-for-one basis.

The number of rights granted in the 2021 grants were 
determined based on the monetary value of the LTI award, 
divided by the volume-weighted average share price of 
Medibank shares on the ASX during the 10 trading days up  
to and including 30 June 2020. This average price was $3.02.

(ii) Annual STI offer

Under the Group’s STI Plan, 50% of STI awarded to ELT 
members is paid in cash after the announcement of financial 
results. The remaining 50% is deferred for 12 months in the 
form of performance rights granted under the Performance 
Rights Plan. Vesting of deferred performance rights is 
conditional on the participant remaining employed by 
Medibank until the end of the 12-month deferral period.

On vesting of the performance rights, each performance right 
will convert into a share on a one-for-one basis, subject to any 
adjustment required to ensure that the participant receives  
a benefit equivalent to any dividends paid by Medibank during 
the deferral period.

The number of rights to be granted will be determined  
based on the monetary value of the STI award, divided by  
the volume-weighted average share price over the 10 trading 
days up to and including the payment date of cash STI.

Share-based Payment Accounting Policy
The fair value of the performance rights is recognised as an 
employee benefits expense, with a corresponding increase 
in equity. The total amount to be expensed is determined 
by reference to the fair value of the performance rights 
granted, which includes any market performance conditions 
and the impact of any non-vesting conditions, but excludes 
the impact of any service and non-market performance 
vesting conditions. Non-market vesting conditions are 
included in assumptions about the number of performance 
rights that are expected to vest.

The total expense is recognised over the period in which the 
performance and/or service conditions are fulfilled (the vesting 
period), ending on the date on which the relevant employees 
become fully entitled to the award (the vesting date).

At the end of each reporting period, the Group revises its 
estimates of the number of awards that are expected to vest 
based on the non-market vesting conditions. The impact 
of the revision to original estimates, if any, is recognised in 
profit or loss, with a corresponding adjustment to equity.

Annual Report 2021    117 

(b) Performance rights – Group

Outstanding at 1 July
Granted
Forfeited
Exercised
Lapsed
Outstanding at 30 June
Exercisable at 30 June

Note

(i)
(ii)
(iii)

Number of equity 
instruments
2020
 8,430,879 
 3,338,273 
 (594,482)
 (1,068,721)
 (1,167,876)
 8,938,073 
- 

2021
 8,938,073 
 3,168,794 
 (624,784)
 (1,980,272)
 (1,422,769)
 8,079,042 
- 

(i)  Forfeited relates to instruments that lapsed on cessation of employment.

(ii)  Performance rights are exercised as soon as they vest.

(iii) Lapsed relates to instruments that lapsed on failure to meet the performance hurdles.

(c) Fair value of performance rights granted

Below is a summary of the fair values of the 2020 and 2021 
LTI plans and the key assumptions used in determining  
the valuation. The fair value was determined in consultation  
with the Group’s professional service advisors, KPMG 
including key inputs and the valuation methodology for  

the performance rights granted. The fair value at grant date 
differs for each grant primarily due to the Medibank share 
price on that grant date and for the TSR performance rights, 
the Medibank share price relative to the comparator group.

Grant date

Date of commencement of  
service and performance period

Expected vesting date
Fair value at grant date

TSR 
performance rights

EPS  
performance rights

Market share  
performance rights

2021
1 July 2020

2020
1 July 2019

2021
1 July 2020

2020
1 July 2019

2021
1 July 2020

2020
1 July 2019

1 July 2020

1 July 2019

1 July 2020

1 July 2019

1 July 2020

1 July 2019

30 June 2023 30 June 2022 30 June 2023 30 June 2022 30 June 2023 30 June 2022
$2.80 

$1.58 

$2.80 

$2.54 

$2.54 

$1.09 

Share price at grant date
Dividend yield (per annum effective)
Franking rate
Risk free discount rate (per annum)

$2.97 
4.0%
100.0%
0.3%

$3.21 
4.0%
100.0%
0.6%

$2.97 
4.0%
100.0%
n/a

$3.21 
4.0%
100.0%
n/a

$2.97 
4.0%
100.0%
n/a

$3.21 
4.0%
100.0%
n/a

Valuation method 

Monte Carlo 
simulation 
model

Monte Carlo 
simulation 
model

Black-Scholes 
option pricing 
methodology

Black-Scholes 
option pricing 
methodology

Black-Scholes 
option pricing 
methodology

Black-Scholes 
option pricing 
methodology

Volatility assumptions (per annum)
Medibank
Comparator group average

Correlation between  
comparator companies' TSR

28%
35%

25%

20%
23%

25%

n/a
n/a

n/a

n/a
n/a

n/a

n/a
n/a

n/a

n/a
n/a

n/a

118    Medibank 

Notes to the consolidated financial statements30 June 2021Note 19: Auditor's remuneration

During the year the following fees were paid or payable for services provided by the auditor of Medibank, its related practices and 
non-related audit firms:

PricewaterhouseCoopers Australia (PwC):
Amounts received or due and receivable by the Company's auditor for:
 –  An audit or review of the financial report of the Company and any other entity 

within the Group

Other assurance services in relation to the Company and any other entity within the Group:
 – Audit of regulatory compliance returns
 – Accounting and other assurance services

Other services in relation to the Company and any other entity within the Group:
 – Other non-audit services

Total remuneration of PwC

2021 
$

2020 
$

 1,570,108 

 1,581,094 

 231,830 
 15,530 

 342,264 
 64,260 

 199,517 

-

 2,016,985 

 1,987,618 

Note 20: Other
(a) New and amended standards adopted

(i) Adopted in the current period

During the period, the IFRS Interpretations Committee 
(IFRIC) issued a final agenda decision, ‘Configuration or 
Customisation Costs in a Cloud Computing Arrangement 
(IAS 38 Intangible Assets)’. The agenda decision clarifies 
when configuration and customisation costs incurred in 
implementing a Software as a Service (‘SaaS’) arrangement 
can be recognised as an intangible asset and if not, over  
what time period the expenditure is expensed. 

Medibank has implemented this guidance retrospectively  
as a change in accounting policy and has recognised the 
following adjustments in the prior year financial statements  
of the Group and Parent Entity as follows:

•  A decrease in intangible assets as at 1 July 2019  
of $22.3 million (Parent Entity: $20.1 million).

•  An increase in deferred tax assets as at 1 July 2019  

$6.2 million (Parent Entity: $5.9 million).

•  A decrease in retained earnings as at 1 July 2019  

of $16.1 million (Parent Entity: $14.2 million).

There are no other material impacts as a result of this change 
in accounting policy.

The following standards became effective for the annual 
reporting period commencing on 1 July 2020 but did not  
have a material impact on the Group’s accounting policies  
or on the consolidated interim financial report.

•  AASB 2018-7 Amendments to Australian Accounting 

Standards – Definition of Material

•  Amendments to References to the Conceptual Framework 

in IFRS Standards

•  AASB 2020-4 Amendments to Australian Accounting 

Standards – Covid-19-Related Rent Concessions

(ii) Adopted in the previous period

The Group adopted AASB 16 Leases on 1 July 2019 using the 
modified retrospective approach. The net impact after tax  
of initially applying AASB 16 was recognised as a decrease  
of $4.7 million to the opening balance of retained earnings  
at 1 July 2019.

(b) New accounting standards and interpretations  
not yet adopted

Certain new accounting standards have been published  
that are not mandatory for 30 June 2021 reporting periods, 
but will be applicable to the Group in future reporting periods. 
The Group’s assessment of the impact of these new standards 
is set out below.

(i) AASB 17: Insurance Contracts

AASB 17 Insurance Contracts is effective for reporting periods 
beginning on or after 1 January 2023 and will replace AASB 4 
Insurance Contracts, AASB 1023 General Insurance Contracts 
and AASB 1038 Life Insurance Contracts. The Group will apply 
AASB 17 for the annual period beginning 1 July 2023.

The standard introduces a new general measurement model 
for accounting for insurance contracts. However, a simplified 
premium allocation approach, similar in nature to the Group’s 
existing measurement basis under AASB 1023 is permitted in 
certain circumstances (such as for short-duration contracts).

The Group has a comprehensive project underway to assess 
the potential impact on its consolidated financial statements. 
This includes identifying changes to the Group’s accounting 
policies, reporting requirements, systems, processes and 
controls and consideration of industry interpretations and 
regulatory responses. 

Annual Report 2021    119 

The final impact of AASB 17 is currently being evaluated 
by the Group. The Group expects to apply the simplified 
premium allocation approach to all of its insurance contracts 
and therefore the measurement basis is not expected to 
significantly change. The key estimates and judgements in 
relation to the measurement of the Group’s claim liabilities are 
expected to remain largely the same under the new standard, 
albeit with some differences in their application. However, it is 
expected that under AASB 17 there will be substantial changes 
in presentation of the financial statements and disclosures.

(c) Other accounting policies

(ii) Other accounting standards or amendments that 
will become applicable in future reporting periods

Other accounting standards or amendments that will  
become applicable in future reporting periods are not 
expected to have a material impact on the Group’s  
accounting policies or on the consolidated financial report.

Impairment of Tangible and Intangible Assets (other than Goodwill) Accounting Policy
Assets other than goodwill and financial assets classified at fair value through other comprehensive income, are tested  
for impairment whenever events or changes in circumstances indicate that the carrying amount may not be recoverable.  
An impairment loss is recognised for the amount by which the asset’s carrying amount exceeds its recoverable amount.  
The recoverable amount is the higher of an asset’s fair value less costs of disposal and its value-in-use. In assessing 
value-in-use, the estimated future cash flows are discounted to their present value using a discount rate that reflects 
current market assessments of the time value of money and the risks specific to the asset. For the purposes of assessing 
impairment, assets are grouped at the lowest levels for which there are separately identifiable cash inflows which are  
largely independent of the cash inflows from other assets or groups of assets (CGUs). 

Financial Assets and Financial Liabilities Accounting Policy
The Group’s financial assets consist of cash and cash equivalents, financial assets at fair value and trade and other 
receivables. Management determines the classification of its financial assets at initial recognition based on the business 
model test and cash flow characteristics. Purchases and sales of financial assets are recognised on trade-date – the date 
on which the Group commits to purchase or sell the asset. Financial assets are derecognised when the rights to receive 
cash flows from the financial assets have expired or have been transferred. The Group’s financial liabilities comprise  
trade and other payables. Financial liabilities are classified and measured at amortised cost and derecognised when  
the Group’s contractual obligations are discharged, cancelled or expired.

Goods and Services Tax (GST) Accounting Policy
Revenues, expenses and assets are recognised net of the amount of associated GST, unless the GST incurred is not 
recoverable from the taxation authority. In this case it is recognised as part of the cost of acquisition of the asset or  
as part of the expense.

Receivables and payables are stated inclusive of the amount of GST receivable or payable. The net amount of GST 
recoverable from, or payable to, the taxation authority is included with other receivables or payables in the consolidated 
statement of financial position.

Cash flows are presented on a gross basis. The GST component of cash flows arising from investing or financing activities 
which are recoverable from, or payable to, the taxation authority, are presented as operating cash flows. Commitments  
and contingencies are disclosed net of the amount of GST recoverable from, or payable to, the taxation authority.

Loyalty Program Accounting Policy
Where the amount of health insurance premium revenue includes a loyalty component, revenue is allocated to this 
component based on the relative estimated stand-alone selling price. The component of loyalty revenue is initially deferred 
as a liability on the consolidated statement of financial position, and subsequently recognised in the consolidated statement 
of comprehensive income upon redemption when Medibank is obliged to provide the specified goods or services itself.

(d) Events occurring after the reporting period 

There have been no events occurring after the reporting period which would have a material effect on the Group’s  
financial statements at 30 June 2021.

120    Medibank 

Notes to the consolidated financial statements30 June 2021Directors' declaration

The directors declare that, in the opinion of the directors:

(a)    the financial statements and notes set out on pages 75 
to 120 are in accordance with the Corporations Act 2001, 
including:

   (i)  

   (ii) 

 giving a true and fair view of the Group’s financial 
position as at 30 June 2021 and of its performance 
for the financial year ended on that date; and

 complying with Australian Accounting Standards, the 
Corporations Regulations 2001 and other mandatory 
professional reporting requirements; and

Note 1(b) confirms that the financial statements also  
comply with International Financial Reporting Standards  
as issued by the International Accounting Standards Board.

This declaration has been made after receiving the 
declarations required to be made to the directors by the  
Chief Executive Officer and Chief Financial Officer in 
accordance with section 295A of the Corporations Act 2001  
for the year ended 30 June 2021.

This declaration is made in accordance with a resolution  
of the directors.

(b)    there are reasonable grounds to believe that the 

Company will be able to pay its debts as and when  
they become due and payable.

On behalf of the Board,

Mike Wilkins AO   
Chairman 

25 August 2021 
Melbourne

David Koczkar 
Chief Executive Officer

Annual Report 2021    121 

 
 
 
 
 
Auditor's independence declaration

Auditor’s Independence Declaration 
As lead auditor for the audit of Medibank Private Limited for the year ended 30 June 2021, I declare 
that to the best of my knowledge and belief, there have been:  

(a) no contraventions of the auditor independence requirements of the Corporations Act 2001 in

relation to the audit; and

(b) no contraventions of any applicable code of professional conduct in relation to the audit.

This declaration is in respect of Medibank Private Limited and the entities it controlled during the 
period. 

CJ Heath 
Partner 
PricewaterhouseCoopers 

Melbourne 
25 August 2021 

PricewaterhouseCoopers, ABN 52 780 433 757 
2 Riverside Quay, SOUTHBANK  VIC  3006, GPO Box 1331, MELBOURNE  VIC  3001 
T: 61 3 8603 1000, F: 61 3 8603 1999, www.pwc.com.au 

Liability limited by a scheme approved under Professional Standards Legislation. 

122    Medibank 

Independent auditor’s report 

To the members of Medibank Private Limited 

Report on the audit of the financial report 

Our opinion 

In our opinion: 

The accompanying financial report of Medibank Private Limited (the Company) and its controlled 
entities (together the Group) is in accordance with the Corporations Act 2001, including: 

(a)  giving a true and fair view of the Group's financial position as at 30 June 2021 and of its 

financial performance for the year then ended  

(b)  complying with Australian Accounting Standards and the Corporations Regulations 2001. 

What we have audited 
The Group financial report comprises: 

● 
● 
● 
● 
● 

● 

the consolidated statement of financial position as at 30 June 2021 
the consolidated statement of comprehensive income for the year then ended 
the consolidated statement of changes in equity for the year then ended 
the consolidated statement of cash flows for the year then ended 
the notes to the consolidated financial statements, which include significant accounting policies 
and other explanatory information 
the directors’ declaration. 

Basis for opinion 

We conducted our audit in accordance with Australian Auditing Standards. Our responsibilities under 
those standards are further described in the Auditor’s responsibilities for the audit of the financial 
report section of our report. 

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for 
our opinion. 

Independence 
We are independent of the Group in accordance with the auditor independence requirements of the 
Corporations Act 2001 and the ethical requirements of the Accounting Professional & Ethical 
Standards Board’s APES 110 Code of Ethics for Professional Accountants (including Independence 
Standards) (the Code) that are relevant to our audit of the financial report in Australia. We have also 
fulfilled our other ethical responsibilities in accordance with the Code. 

PricewaterhouseCoopers, ABN 52 780 433 757 
2 Riverside Quay, SOUTHBANK  VIC  3006, GPO Box 1331, MELBOURNE  VIC  3001 
T: 61 3 8603 1000, F: 61 3 8603 1999, www.pwc.com.au 

Liability limited by a scheme approved under Professional Standards Legislation. 

Annual Report 2021    123 

 
 
  
  
 
Independent auditor’s report

Our audit approach 

An audit is designed to provide reasonable assurance about whether the financial report is free from 
material misstatement. Misstatements may arise due to fraud or error. They are considered material if 
individually or in aggregate, they could reasonably be expected to influence the economic decisions of 
users taken on the basis of the financial report. 

We tailored the scope of our audit to ensure that we performed enough work to be able to give an 
opinion on the financial report as a whole, taking into account the geographic and management 
structure of the Group, its accounting processes and controls and the industry in which it operates. 

Materiality 

Audit scope 

Key audit matters 

Our audit focused on where the 
Group made subjective 
judgements; for example, 
significant accounting estimates 
involving assumptions and 
inherently uncertain future 
events. 

We performed: 

•  An audit of the financially 

Amongst other relevant topics, we 
communicated the following key 
audit matters to the Audit 
Committee: 

•  Estimation of the COVID-19 

claims liability  

•  Estimation of the outstanding 

claims liability 

significant component of the 
Group, being the Health 
Insurance segment.  

• 

• 

Specific audit procedures 
over significant risks and 
financially significant 
balances of the Medibank 
Health segment. 

Impairment test of goodwill 
allocated to the Home Care 
Cash Generating Unit (CGU)  

•  Reliance on automated 
processes and controls 

These are further described in the 
Key audit matters section of our 
report. 

For the purpose of our audit we 
used overall Group materiality of 
$27 million, which represents 
approximately 5% of the Group’s 
profit before tax. 

We applied this threshold, 
together with qualitative 
considerations, to determine the 
scope of our audit and the nature, 
timing and extent of our audit 
procedures and to evaluate the 
effect of misstatements on the 
financial report as a whole. 

We chose Group profit before tax 
because, in our view, it is the 
benchmark against which the 
performance of the Group is most 
commonly measured.    

We utilised a 5% threshold based 
on our professional judgement, 
noting it is within the range of 
commonly acceptable thresholds.  

124    Medibank 

 
      
 
Key audit matters 

Key audit matters are those matters that, in our professional judgement, were of most significance in 
our audit of the financial report for the current period. The key audit matters were addressed in the 
context of our audit of the financial report as a whole, and in forming our opinion thereon, and we do 
not provide a separate opinion on these matters. Further, any commentary on the outcomes of a 
particular audit procedure is made in that context.  

Key audit matter 

How our audit addressed the key audit matter 

Estimation of the COVID-19 claims liability 
(Refer to Note 3) $223.8m 

The COVID-19 claims liability relates to a 
constructive obligation arising from the Group’s 
commitments to pass back to customers unforeseen 
financial gains arising from the temporary closure of 
elective surgery and reduced access to ancillary 
services as a result of restrictions imposed in 
response to the Coronavirus pandemic (COVID-19).  
The COVID-19 claims liability is calculated by 
comparing the difference between the actual and 
expected volume of insured surgical and non-surgical 
procedures since the commencement of restrictions 
in March 2020 (the COVID-19 period). Utilisation of 
the COVID-19 claims liability is assessed by 
geography and modality (claim type) and occurs 
where actual claims exceed expected claims.  

The COVID-19 claims liability is included in the 
financial statement line item titled ‘Claims liabilities’ 
recognised on the consolidated statement of financial 
position but does not form part of the outstanding 
claims liability (refer to the Key Audit Matters titled 
‘Estimation of outstanding claims liability’). 

We considered this a key audit matter due to the: 

● significant uncertainties impacting the Group’s

estimate of the liability, including:

o the impact and variability of disruptions to

planned insured surgeries and other insured
procedures arising from COVID-19
restrictions and lock-downs

o an absence of historical precedent on which

to analyse data due to the impact of
COVID-19 on claims patterns in the current
and future periods

o determining the proportion of claims not
incurred due to COVID-19 restrictions

o determining expected future claims

utilisation patterns.

We performed the following audit procedures, amongst 
others: 

●

Evaluated the design of the Group’s relevant
key controls over the COVID-19 provisioning
process.

● Developed an understanding of the Group’s
public announcements and commitments to
financial analysts, shareholders and
policyholders during the year.

●

●

●

●

Evaluated the Group’s accounting policy for
the deferral of claims due to the COVID-19
pandemic against applicable Australian
Accounting Standard requirements and
private health insurance industry practices.

Assessed, on a sample basis, significant data
inputs used in the Group’s modelling and
estimation of the COVID-19 claims liability
(including relevance and reliability of data,
appropriateness of data in the context of the
applicable financial reporting framework, and
potential indicators of management bias).

Analysed claims patterns across key claims
attributes (e.g. hospital versus ancillary claims
and surgical versus non-surgical).

Together with PwC actuarial experts, we:
o Assessed significant assumptions applied
by the Group in determining the impact of
continued COVID-19 restrictions on claims
deferred to future periods, including
consideration of practices adopted across
the private health insurance industry.

o

Considered the appropriateness of the
Group’s methodologies used to determine
claims deferred to future periods.

o On a sample basis, performed

recalculations over the mathematical
accuracy of the Group’s COVID-19 claims
liability model.

Annual Report 2021    125 

Independent auditor’s report

Key audit matter 

How our audit addressed the key audit matter 

•

reasonableness of disclosure of the COVID-19
claims liability within the financial report.

o Assessed the reasonableness of disclosure
of the COVID-19 claims liability in the
financial report against the requirements
of the applicable Australian Accounting
Standards.

Estimation of the outstanding claims liability 
(Refer to Note 3) $390.9m 

We performed the following audit procedures, amongst 
others: 

The liability for outstanding claims relates to claims 
incurred during the financial year or prior periods but 
either not assessed or received by the Group at year 
end.  

The liability for outstanding claims is estimated by the 
Group as a central estimate but, as is the case with 
any accounting estimate, there is a risk that the 
ultimate claims paid will differ from the initial 
estimates. There is also additional uncertainty 
relating to the continued impact of the COVID-19 
pandemic on claims patterns.  

A risk margin is applied by the Group to reflect the 
uncertainty in the estimate. The central estimate and 
risk margin combined, which are estimated based on 
judgements and actuarial expertise, are intended to 
achieve an actuarially defined probability of adequacy 
(PoA) of 95% (2020: 95%). 

The estimation of the outstanding claims liability 
involves complex and subjective judgements about 
future events, both internal and external to the 
business.  Primarily, judgement is required by the 
Group in order to estimate the: 

●

●

●

●

type and amount of claims incurred during the
last two months of financial year but not
received or processed by year end

speed of processing claims by providers issuing
claims on behalf of policyholders

claims cost inflation and medical trends
impacting utilisation of benefits by members

impact of the COVID-19 pandemic on claims
patterns.

Controls design and operating effectiveness 

● We evaluated the design of the Group’s

relevant key controls over the claims reserving
process (including data reconciliation, data
inputs, data quality, and the Group’s review of
the estimate) and assessed whether these
controls were operating effectively throughout
the year.

The use of actuarial expertise 

Together with PwC actuarial experts, we: 

●

●

Assessed, on a sample basis, significant data
inputs used in the Group’s modelling and
measurement of the central estimate
(including relevance and reliability of data,
appropriateness of data in the context of the
applicable financial reporting framework, and
potential indicators of management bias).

Considered whether the Group’s actuarial
methodologies were consistent with actuarial
practices and those used in the industry.

● On a sample basis, performed recalculations

over the mathematical accuracy of the Group’s
actuarial models.

●

•

Assessed the significant actuarial assumptions
used by the Group in forecasting expected
claims particularly those relating to the two
months prior to the year end. This included
comparing the significant actuarial
assumptions to the Group’s historical
experience, observable market trends,
environmental factors, estimated payment
patterns, member claiming patterns, and our
industry knowledge.

Considered the impact on the estimate of
reasonably plausible alternative assumptions
such as changes in service levels, payment
history, recent claims trends, and COVID-19
environmental factors.

126    Medibank 

Key audit matter 

How our audit addressed the key audit matter 

We considered this a key audit matter because of the 
significant judgement required by the Group in 
estimating claims liabilities, including continued 
uncertainty on member claiming patterns due to 
impact of the COVID-19 pandemic, and because a 
small change in assumptions can result in a material 
change in the estimated liability and corresponding 
charge to profit for the year. 

Impairment test of goodwill allocated to 
Home Care Group of Cash Generating Unit 
(CGU)  
(Refer to Note 12) $97.2m 

The Group recognised goodwill of $97.2 million in 
respect of the acquisition of a number of in-home care 
businesses. This goodwill has been allocated to a Cash 
Generating Unit (CGU) referred to as the Home Care 
CGU (Home Care). 

An impairment test of Home Care is performed 
annually by the Group by comparing the carrying 
value of Home Care to the recoverable amount.  

We considered this to be a key audit matter due to 
the: 

●

●

●

financial significance of the goodwill allocated
to Home Care which accounts for 48% of the
goodwill balance recognised by the Group

recoverable amount of Home Care is
determined using a value-in-use model that
requires significant judgement by the Group to
estimate future cash flows based on a number of
key assumptions, including revenue forecasts
and expected synergies

judgements and assumptions applied by the
Group in performing the impairment test,
including cash flows forecasts related to the
realisation of planned strategic objectives for
Home Care over the next three years, discount
rates and growth rates.

●

●

Assessed the Group’s approach to setting the
risk margin in accordance with the
requirements of Australian Accounting
Standards, including an assessment of the
reasonableness of the Group’s actuarial
calculation of the PoA.

Assessed the reasonableness of disclosure of
the outstanding claims liability in the financial
report against the requirements of the
applicable Australian Accounting Standards.

Claims received after the year end 

● We considered whether actual claiming
activity after year end supported the key
assumptions used by the Group to estimate the
outstanding claims liability at year end.

We performed the following procedures, amongst 
others: 

● Developed an understanding of the process by
which the projected future cash flows of Home
Care were developed, including consideration of
expected operational, productivity and financial
synergies, and realisation of planned strategic
objectives.

●

●

●

●

●

Considered the level of business performance
monitoring by the Group and assessed whether
the monitoring was performed at the Home Care
level.

Compared the cash flows included in the
impairment assessment with the three-year
business plan presented to and approved by the
Board.

Considered whether the cash flow forecasts were
reasonable and were based on supportable
assumptions, by comparing the forecasts to actual
cash flows from previous years.

Considered the impact on the impairment test of
reasonably plausible alternative assumptions such
as achieving cash flow forecasts and changes in
the discount rate.

Compared the growth rate assumed in the cash
flow projections extrapolated beyond three years
to industry research.

Annual Report 2021    127 

Independent auditor’s report

Key audit matter 

How our audit addressed the key audit matter 

●

Assessed the reasonableness of disclosure of the
impairment test for Home Care goodwill in the
Group financial report against the requirements
of the applicable Australian Accounting
Standards.

Together with PwC valuation experts, we: 

● Developed an understanding of the Group’s

impairment test methodology, including testing
judgements and assumptions.

●

●

●

Evaluated the valuation methodology supporting
the Group’s impairment analysis against
applicable Australian Accounting Standards.

Evaluated the Group’s discount rate assumptions
to market data, comparable data, and industry
research.

Tested the mathematical accuracy of the
value-in-use model.

Reliance on automated processes and 
controls 

We developed an understanding of the Group’s IT 
governance framework as well as the internal controls 
designed to mitigate the risk of fraud or error over: 

The Group utilises a number of complex and 
interdependent Information Technology (IT) systems 
to capture, process and report a high volume of 
transactions. 

We considered this a key audit matter because the: 

●

●

●

●

program development and changes

access to programs and data

computer operations

business process.

•

•

•

operations and financial reporting processes of
the Group are heavily reliant on IT systems

Together with PwC IT specialists, we performed the 
following procedures, amongst others: 

underlying IT controls over business processes
are significant to the financial reporting process

data migration activities which occurred during
the year impacted the key IT processes, systems,
and controls relevant to the financial reporting
process.

● Evaluated the design and tested the operating

effectiveness of a sample of key IT controls that
are relevant to the financial reporting process and
our audit

● Considered the risks of the system

implementation and data centre migration
activities applicable to the financial reporting
process and tested controls, where relevant.

128    Medibank 

Other information 

The directors are responsible for the other information. The other information comprises the 
information included in the annual report for the year ended 30 June 2021, but does not include the 
financial report and our auditor’s report thereon. Prior to the date of this auditor's report, the other 
information we obtained included the Operating and Financial Review and the Directors' Report. We 
expect the remaining other information to be made available to us after the date of this auditor's 
report.  

Our opinion on the financial report does not cover the other information and we do not and will not 
express an opinion or any form of assurance conclusion thereon. 

In connection with our audit of the financial report, our responsibility is to read the other information 
and, in doing so, consider whether the other information is materially inconsistent with the financial 
report or our knowledge obtained in the audit, or otherwise appears to be materially misstated. 

If, based on the work we have performed on the other information that we obtained prior to the date of 
this auditor’s report, we conclude that there is a material misstatement of this other information, we 
are required to report that fact. We have nothing to report in this regard. 

When we read the other information not yet received, if we conclude that there is a material 
misstatement therein, we are required to communicate the matter to the directors and use our 
professional judgement to determine the appropriate action to take. 

Responsibilities of the directors for the financial report 

The directors of the Company are responsible for the preparation of the financial report that gives a 
true and fair view in accordance with Australian Accounting Standards and the Corporations Act 2001 
and for such internal control as the directors determine is necessary to enable the preparation of the 
financial report that gives a true and fair view and is free from material misstatement, whether due to 
fraud or error. 

In preparing the financial report, the directors are responsible for assessing the ability of the Group to 
continue as a going concern, disclosing, as applicable, matters related to going concern and using the 
going concern basis of accounting unless the directors either intend to liquidate the Group or to cease 
operations, or have no realistic alternative but to do so. 

Auditor’s responsibilities for the audit of the financial report 

Our objectives are to obtain reasonable assurance about whether the financial report as a whole is free 
from material misstatement, whether due to fraud or error, and to issue an auditor’s report that 
includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an 
audit conducted in accordance with the Australian Auditing Standards will always detect a material 
misstatement when it exists. Misstatements can arise from fraud or error and are considered material 
if, individually or in the aggregate, they could reasonably be expected to influence the economic 
decisions of users taken on the basis of the financial report. 

Annual Report 2021    129 

Independent auditor’s report

A further description of our responsibilities for the audit of the financial report is located at the 
Auditing and Assurance Standards Board website at: 
https://www.auasb.gov.au/admin/file/content102/c3/ar1_2020.pdf. This description forms part of 
our auditor's report. 

Report on the remuneration report 

Our opinion on the remuneration report 

We have audited the remuneration report included in pages 50 to 74 of the directors’ report for the 
year ended 30 June 2021. 

In our opinion, the remuneration report of Medibank Private Limited for the year ended 30 June 2021 
complies with section 300A of the Corporations Act 2001. 

Responsibilities 

The directors of the Company are responsible for the preparation and presentation of the 
remuneration report in accordance with section 300A of the Corporations Act 2001. Our 
responsibility is to express an opinion on the remuneration report, based on our audit conducted in 
accordance with Australian Auditing Standards.  

PricewaterhouseCoopers 

CJ Heath 
Partner 

Melbourne 
25 August 2021 

130    Medibank 

Shareholder information

The shareholder information below is current as at 25 August 2021.

Distribution of equity securities

Size of shareholding

1 – 1,000
1,001 – 5,000
5,001 – 10,000
10,001 – 100,000
100,001 & over
Total

Unmarketable parcels 

Number of 
shareholders

44,044
140,796
14,750
6,919
192
206,701

Number of 
shares

39,603,488
396,285,686
101,734,221
147,081,574
2,069,298,271
2,754,003,240

There were 874 holdings of less than a marketable parcel ($500) of shares (142 shares based on a market price  
of $3.53 per share) and such holders held a total of 23,944 shares.

20 largest shareholdings

Number of 
shares

% of 
issued capital

CITICORP NOMINEES PTY LIMITED  

1 HSBC CUSTODY NOMINEES (AUSTRALIA) LIMITED
J P MORGAN NOMINEES AUSTRALIA PTY LIMITED
2
3
CITICORP NOMINEES PTY LIMITED
4 NATIONAL NOMINEES LIMITED
5 BNP PARIBAS NOMINEES PTY LTD 
6 BNP PARIBAS NOMS PTY LTD 
7 HSBC CUSTODY NOMINEES (AUSTRALIA) LIMITED 
8 BNP PARIBAS NOMINEES PTY LTD SIX SIS LTD 
9
10 NETWEALTH INVESTMENTS LIMITED 
11 THE SENIOR MASTER OF THE SUPREME COURT 
12 NAVIGATOR AUSTRALIA LTD  
13 AUSTRALIAN EXECUTOR TRUSTEES LIMITED 
14 BNP PARIBAS NOMINEES PTY LTD ACF CLEARSTREAM
15 BNP PARIBAS NOMINEES PTY LTD HUB24 CUSTODIAL SERV LTD 
16 NETWEALTH INVESTMENTS LIMITED 
17 BNP PARIBAS NOMS PTY LTD 
18 NATIONAL NOMINEES LIMITED 
19 NEWECONOMY COM AU NOMINEES PTY LIMITED <900 ACCOUNT>
20 AMP LIFE LIMITED
Total

844,196,960
515,398,135
269,831,924
144,394,624
64,160,779
52,703,501
23,213,664
20,179,643
13,969,892
6,541,236
6,500,000
6,150,413
6,054,833
5,412,538
5,267,074
3,609,344
3,433,369
3,413,056
3,322,276
3,013,952
2,000,767,213

30.65
18.71
9.80
5.24
2.33
1.91
0.84
0.73
0.51
0.24
0.24
0.22
0.22
0.20
0.19
0.13
0.12
0.12
0.12
0.11
72.65

Annual Report 2021    131 

Shareholder information

Substantial shareholders

As at 25 August 2021, the following holders had provided a substantial shareholding notice:

Number of shares % of issued capital

224,049,642
165,843,215

8.13
6.02

Name of holder

BlackRock Group
The Vanguard Group

Voting rights

At a general meeting of the Company, every shareholder 
present (including virtually present) or by proxy, attorney  
or representative has one vote on a show of hands and,  
on a poll, one vote for each share held.

On-market purchases of shares

During the financial year ended 30 June 2021, 2,017,497 
Medibank ordinary shares were purchased on market at 
an average price of $2.76 for the purposes of Medibank’s 
employee incentive schemes.

On-market share buy-back

There is no current on-market share buy-back.

132    Medibank 

Contents

About Medibank  

2021 highlights  

Chairman’s message  

CEO’s message  

Our strategy 

Creating value for our stakeholders 

Better for customers 

Better for health 

Better for people and communities 

Our sustainability highlights 

Operating and financial review  

Directors  

Executive leadership team  

Corporate governance statement  

Directors’ report  

  Remuneration report 

Financial report 

  Consolidated statement of comprehensive income  

  Consolidated statement of financial position  

  Consolidated statement of changes in equity  

  Consolidated statement of cash flows  

  Notes to the consolidated financial statements  

  Directors’ declaration  

  Auditor’s independence declaration  

Independent auditor’s report  

Shareholder information  

Financial calendar 

Corporate directory 

1

2

4

5

6

7

8

12

16

20

22

30

33

35

47

50

75

76 

77

78

79

80 

121

122 

123

131

133

133

Financial calendar

Key dates

Full year results announcement 

25 August 2021

Ex-dividend share trading commences 

8 September 2021

Record date for final dividend 

9 September 2021

Payment date for final dividend 

30 September 2021

Annual general meeting 

18 November 2021

Half year results announcement 

February 2022

Payment date for interim dividend 

March 2022

The above dates and payments are subject to confirmation.
Any change will be notified to the Australian Securities Exchange (ASX).

Corporate directory

Company

Share registry

Medibank Private Limited 

Registered Office  
720 Bourke Street  
Docklands Vic 3008

GPO Box 9999  
Melbourne VIC 3001 

Telephone:  
132 331 (within Australia)  
+61 3 8622 5780 (outside Australia)

medibank.com.au

Computershare Investor Services  
Pty Limited 

GPO Box 2975  
Melbourne VIC 3001

Telephone:  
1800 998 778 (within Australia)  
+61 3 9415 4011 (outside Australia) 

computershare.com.au

Annual Report 2021    133

 
no overlap of red spine allowed for fold crease

spine set up as 7 mm

Annual Report 2021

Better health

for better lives

Medibank Private Limited
ABN  47 080 890 259