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Medibank Private Ltd

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FY2022 Annual Report · Medibank Private Ltd
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Annual Report 2022

Doing more for
better health

Contents

Medibank Group – our story  
2022 highlights  
Chair’s message  
CEO’s message  

Delivering value to stakeholders through our strategy 
Deliver leading experiences 
Differentiate our insurance business 
Expand in health 
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 
8 
12 
16 
20

22

30 
33 
35 
48 
51

73
74 
75 
76 
77 
78 
120 
121 
122

131

133

133

Sustainability Report 2022

For healthy futures 

2022 full year 
results  

Investor presentation
18 August 2022

David Koczkar – Chief Executive Officer   

Mark Rogers – Group Executive 
Chief Financial Officer & Group Strategy

Medibank Private Limited
ABN  47 080 890 259

Annual Report 2022

Doing more for
better health

This report is part of our suite of reporting for the 2022 financial 
year. You can find more information about our performance in our 
Full Year Results Investor Presentation and Sustainability Report

Cover – Medibank employee and Live Better member, Ella at Half Moon Bay, Victoria. Ella is an active Live Better member who 
enjoys weight training, meditating through the Smiling Minds app, walking her dog and spending time with her young family.

 
 
Medibank Group – our story

We’re a health company working to create Better Health 
for Better Lives by providing the best health and wellbeing 
experience for people across Australia. Building upon our  
46-year history as one of Australia’s leading health insurers, 
our Medibank and ahm brands now support millions of 
customers to manage their health and wellbeing through 
personalised products and services. 

We’re investing in preventative health and reimagining 
healthcare to give people greater choice, better access and 
more control over their care. We’re partnering with doctors, 
hospitals and governments to deliver care in new ways –  
and growing and developing new health services through  
our Amplar Health business. We’re also working together  
to drive the change within Australia’s healthcare system to 
help ensure it can support our generation and those to come.  

Purpose

Vision

Better Health for Better Lives

The best health and wellbeing for Australia

Values

Customer obsessed

Show heart

Brilliance together

Break boundaries

Strategy

Growing as a health company

Deliver leading  
experiences

Differentiate our  
insurance business

Expand in health

Our brands

Health insurance

Diversified insurance

Travel

Pet

Life

Car and home

Health services

Health and wellbeing including Live Better

Preventative programs

Clinical homecare and virtual care

Investments in primary care, virtual care and  
health system navigation support

Investments in no gap healthcare programs

Sustainability focus areas

Customer 
health

Employee 
health

Community 
health 

Environmental 
health

Governance

Annual Report 2022    1 

 
 
2022 highlights

Customer

3.96m

total customers 
at 30 June 2022

27.45%

market share 
(+14 bps since FY21)  

$5.4b

total claims paid

c. $682m

total COVID financial support  
to date – includes c. $368m customer  
give backs

60.9k  (+3.2%)

reported net resident  
policyholder growth

45.345.3 (+8.2)  Medibank 
42.442.4 (-0.6)  ahm 
customer advocacy  
(average Service NPS) 

c. 568k

customers engaged  
with Live Better and 
preventative programs 

Services supported

1.21.2m+m+

24.724.7m+m+

476476k+k+

hospital admissions

extras services

surgical procedures

Health services

 10,086 (+40%)

customers engaged  
with preventative  
health programs

7,239 (-5%)  
c. 7,239

customers used 
Medibank at Home

$10m

investment in 
health tech 
company  
Medinet

c. 3.53.5mm

3,245
3,245

virtual 
health 
interactions 

patients used  
My Home Hospital 
since Jan 2021 launch

2    Medibank 

 
Our performance

$393.9m (-10.7%)

Group net profit after tax 

7.3 cps (+5.8%) 

 final ordinary dividend
fully franked

 13.4 cps (+5.5%)

 total ordinary dividend
fully franked

$6,859.8m 

Health Insurance  
segment revenue 

$321.8m 

Medibank Health  
segment revenue 

-$24.8m 

net investment 
income / loss

Composition of  
2022 segment 
operating profit

92.992.9%  
$592.6m
Health Insurance

7.17.1%  
$45.5m
Medibank Health

  c. $15m

in productivity 
savings

7.97.9⁄⁄ 1010

employee engagement 

All data is presented on a statutory basis

33,768768

including around

11,300300

employees

health professionals

Headcount at 30 June 2022

Annual Report 2022    3 

Chair’s message

Mike Wilkins  AO 

4    Medibank 

Creating greater value for our customers, community and shareholders has always 
been important to Medibank and we have sought to again deliver this over the past 12 
months – guided by our purpose of Better Health for Better Lives and our commitment 
to being a responsible and sustainable business that is contributing to our society.

As a result of this focus, we have grown 
policyholder numbers, achieved record levels 
of customer advocacy and created double-
digit growth in Medibank Health, to deliver 
another strong result. We have done this while 
maintaining a focus on productivity and costs 
as part of our ongoing disciplined approach  
to growing and running our business. 

While Health Insurance operating profit 
and Medibank Health segment profit both 
increased, our net profit after tax of $393.9 
million was down 10.7% on last year. This 
was as a result of financial market volatility, 
which led to a $24.8 million loss in net 
investment income. Our capital position 
remains strong and the Board determined 
a final fully franked ordinary dividend of 7.3 
cents per share, bringing the total full year 
dividend to 13.4 cents per share fully franked.

Throughout the pandemic we have committed 
to, and continued to, support our customers 
and the community. Through the COVID Care 
at Home program we deliver with Calvary, 
we have now helped around 165,000 people 
and we continue to support the broader 
public health response to COVID. Part of 
this support for our customers has been our 
commitment to return known permanent net 
claims savings due to COVID to them. Our 
total COVID support now stands at around 
$682 million including our recent premium 
give back and the deferral of our most recent 
premium increases for seven months. 

At Medibank we are working to drive real 
change in our communities as we seek to 
achieve our 2030 Vision to create the best health 
and wellbeing for Australia. A key component 
of this is our focus on environmental, social 
and governance issues (ESG). This year we 
refreshed our ESG materiality assessment, to 
ensure we were focusing on the sustainability 
issues that our customers, employees, 
shareholders and the wider community 
believe are most important for us to address.

Chief among these is the ongoing need for 
affordable, innovative and personalised 
healthcare. This is underlying the work we 
are doing to give people greater access, 
choice and control of their healthcare,  
such as expanding our no gap program  
and growing our Live Better and preventative 

health programs, developing new extras 
products and building partnerships with 
health professionals to provide new care 
settings and models of delivery. 

How we work, and the culture that we 
cultivate is paramount to delivering for our 
customers and for you, our owners. To this 
end we continue to champion diversity and 
inclusion across our business, through 
our Future Fit way of working, our focus 
on employee health and wellbeing, and 
our values-based culture in support of our 
continuing desire to be an employer of choice. 
It’s pleasing to report that women hold 44% of 
both Board and senior leadership roles and we 
further enhanced our parental leave policy this 
year. In addition to launching our first Human 
Rights Policy, we reinforced our commitment 
to improving prosperity and addressing 
health equity for First Nations People 
through our fifth Reconciliation Action Plan. 
We also released our second Accessibility 
and Inclusion Plan outlining our approach to 
supporting people living with a disability. 

We accelerated our commitment to Net 
Zero that we first announced in September 
2021, bringing forward our timelines and 
setting a pathway to achieve Net Zero by 
2040 (including Net Zero against our Scope 
1 and 2 emissions by 2025) on our current 
business as usual operations. We have also 
begun exploring our investment portfolio’s 
greenhouse gas emissions exposure so we 
can work towards setting science-based 
targets to create a pathway to Net Zero across 
our investment portfolio. You can find more 
detail on this in our Sustainability Report 2022.

I’m proud of Medibank and the role that 
it plays in our community. David Koczkar 
and the executive team have shown 
great leadership throughout another 
challenging year and I would like to thank 
and congratulate them, along with everyone 
at Medibank, for all that they have done and 
achieved in 2022. I would also like to express 
my gratitude to my fellow directors for their 
wise counsel and to all our shareholders for 
your ongoing support. Together, we continue 
working to make a difference to the health 
and wellbeing of our customers, our people 
and our community.

CEO's message

2022 has seen Medibank deliver another strong result, reflecting 
the work of our amazing team and their unwavering focus on our 
customers. It is a year that our company can be truly proud of. 

We saw standout customer growth of 3.2%, 
increasing our resident policyholders by 
nearly 61,000. Most of our new customers 
were younger people and those taking out 
cover for the first time. We also saw strong 
growth in Medibank Health as we focused 
on supporting the health and wellbeing 
needs of our customers and community. 

Differentiating our core insurance  
business is central to our strategy. Our  
two brands, combined with one of the  
most extensive provider networks in the 
industry, continues to set us apart from 
others as we offer leading products and 
services across the full spectrum of our 
customers' needs in health.

Customer retention over the past two 
years across the Medibank Group has been 
stronger than at any point in the decade 
previously, and high levels of customer 
advocacy and brand leadership among the 
top health insurers show our customers 
are valuing the support we provide. 

We have managed to achieve this growth 
despite the fact that this year has been 
tough for many people as the impacts 
of COVID continue to be felt and costs of 
living rise. What is clear is that health 
has remained top of mind with a record 
number of people wanting greater choice 
and control and electing to participate  
in the private health system. 

Our strategy to grow as a 
health company is enabling 
us to deliver for our 
customers not only today, 
but is also setting us up to 
do the same into the future. 

Delivering leading experiences continues 
to be key. For our customers, we’re 
focused on making things better for them. 
Our digital and analytics capabilities are 
supporting more self-service interactions 
as customer preference increasingly 
shifts towards technology. These same 
capabilities are enabling more personalised 
conversations with customers to better 
support their health and wellbeing.

Of course, none of this would be possible 
without our team. I am pleased to report 
that our people remain highly engaged, 
driven in part by the launch of our 
2030 Vision to deliver the best health 
and wellbeing for Australia, including 
progressing our sustainability agenda.

The growing number of customers engaging 
with our Live Better and preventative 
programs reflects the unmet need in  
the community and the role we can play  
to provide support to fill this gap. As  
we expand in health, our focus in areas 
such as virtual health, mental health  
and integrated care offers tremendous 
benefits for our customers, community 
and the health system at large. The same 
can be said of our investments in new care 
settings including our no gap network, 
which we more than doubled over the year. 

Our rebranded Health Services business, 
Amplar Health, is focused on these 
opportunities as we look to meet the  
needs of our customers and our 
government and community partners.

We are also seeking to drive change across 
the health system so it is fit and sustainable 
for the future. For health insurers these 
changes will help keep premium increases 
low for our customers, improve access 
to private health, and in turn alleviate 
pressure on the stretched public system. 
Some challenges require a rethink of 
the status quo. Other challenges require 
reform. Prostheses reform is a prime 
example of this, with a chance to deliver up 
to $900 million of savings to consumers in 
the private system over the next four years.  

With challenges, come opportunity, and I 
want to thank our people for managing both 
incredibly well throughout the year. Their 
commitment and focus continue to be the 
driving force as we support our customers, 
and take our next steps to deliver the best 
health and wellbeing for Australia. I also 
want to thank Mike and the Board, and of 
course all our shareholders whose ongoing 
support enables these steps to be made.

David Koczkar

Annual Report 2022    5 

 
Delivering value to stakeholders through our strategy

Impacts and trends influencing our stakeholders

Customers

Employees

Community 

Shareholders

Government / 
health system

Impacts of  
COVID 

Flexibility and  
health and  
wellbeing  

  Highly competitive 
talent market

Pressure on 
household  
budgets

Health and  
wellbeing 

Higher customer 
experience 
expectations 

Simple,  
personalised  
digital service

Impacts of  
COVID 

Sustainable  
financial returns 

Pressure on  
health system 

Climate change 

Equality, diversity  
and inclusion

Expectation of 
businesses to 
contribute to  
society

Transparency  
in reporting

Growing chronic 
disease and ageing

Environmental, social 
and governance  
(ESG) issues – 
Net Zero, diversity  
and inclusion and  
data privacy and 
technology

Healthcare  
worker shortages  
and burnout

Acceleration of  
new care settings  
– telehealth and 
virtual care 

How we’re responding to deliver value through our strategy

We’re supporting  
our customers’  
health and wellbeing, 
offering greater 
healthcare access, 
choice and control 
and creating a more 
connected experience

We’re empowering 
our people to  
achieve their best  
through flexible 
working, health and 
wellbeing support, 
with a culture that 
celebrates diversity 
and inclusion

We’re addressing 
some of Australia’s 
biggest health and 
community concerns 
such as loneliness, 
mental health, 
reconciliation,  
climate change, and 
diversity and inclusion

We’re delivering 
sustainable returns 
to our shareholders 
while meeting 
the expectations 
of our customers 
and community by 
embedding ESG 
practices in our 
strategy

We’re driving change 
to reshape Australia’s 
health system, 
investing in prevention 
and partnering with 
doctors, hospitals 
and governments on 
new care models to 
support the long-term 
sustainability of our 
health system

6    Medibank 

 
 
The material issues our stakeholders care most about

Affordable, 
innovative 
and 
personalised 
healthcare

Engaged, purpose-
led culture, attract 
and retain talent

Diverse and  
inclusive 
workforce

Support healthy 
communities

Work together to  
build a stronger and 
more sustainable 
health system

Environmental 
health and 
climate change

Ethical and 
sustainable  
business 

Our strategy – growing as a health company

Deliver leading  
experiences

Differentiate our  
insurance business

Expand in health

Create personalised  
and connected 
customer experiences 

Empower our people

Collaborate with  
our communities to 
make a difference

Deliver more value, choice 
and control for customers

Offer products and services 
to meet all customer needs

Leverage our dual brands  
and provider networks

Focus growth on  
prevention and  
integrated care models

Scale and connect  
our health businesses

Bring benefits back  
to our core

Better Health for Better Lives

Annual Report 2022    7 

Deliver leading 
experiences

Our goals:

Our FY22 milestones

>  Create personalised and  

connected customer experiences 

>  Empower our people 

>  Collaborate with our communities 

to make a difference

Target

Achieved

Customer advocacy Service NPS (average)
>35
Medibank
>35
ahm

45.3 (+8.2)
42.4 (-0.6)

Employee advocacy (eNPS)
Place to work
Products and services

≥+24
≥+19

+27
+29

8    Medibank 

We’re working to deliver a brilliant experience every time for our 
customers, by investing in our digital capabilities, engaging our people 
in our purpose and vision, and helping improve the communities we are 
part of. The strong technology foundations we’ve built are enabling us to 
have deeper, more meaningful relationships with our customers that are 
helping them better manage their health and wellbeing.

A better experience across every channel

We’ve risen to meet our customers’ changing 
expectactions – delivering information 
personalised to their own needs, the benefits 
that come from connected experiences and  
the control and ease offered by self-service 
tools and support. 

This year, we’ve achieved our highest ever 
customer advocacy service NPS scores for 
Medibank and were above target for ahm. We are 
also leading our health insurer peers on brand 
advocacy. Like most companies, we experienced 
workforce challenges throughout the year, which 
we managed by enabling our customer channels 
and Amplar Health team members to work 
across multiple channels and by improving the 
effectiveness of our digital self-service channels 
to provide the support our customers expect 
of us. Our Amplar Health team undertook over 
440,000 digital COVID Care assessments this 
year, assisted by other team members. 

We checked in with more than half a million 
customers to make sure their health cover 
was delivering to their needs. We’ve invested 
in our analytics capabilities to help us tailor 
the information and support we offer to our 
customers, so it is personalised to deliver greater 
value. We’ve also been piloting health clinicians 
working in a number of our retail stores to enable 
more detailed conversations about healthcare  
and support programs available. 

We’ve continued enhancing our digital customer 
experience. We’ve expanded the range of claims 

and payments that can be done through the  
My Medibank app and introduced authenticated 
messaging to make it quicker for people to 
access support. We continued integrating more 
Live Better functionality, making it easier for 
customers to manage their health and wellbeing 
in a single digital experience. Around 70% of ahm 
customers have logged in to the app or website 
this year, as we made it easier to pay digitally, 
revamped the claims experience and introduced 
on-the-spot orthodontics claims. We’ve also seen 
more people take up digital membership cards 
with both Medibank and ahm cards available on 
both iOS and Android platforms.

The convenience and simplicity of our self-
service channels has seen them continue to 
grow and increasingly become the support 
channel of choice, managing more than 40%  
of all Medibank service queries this year.  
We’ve added new functionality to our online 
messaging service to guide people through 
payments and claims queries. We’ve also 
strengthened our privacy and data security 
capabilities and requirements to ensure  
our customers are better protected. 

We’re bringing Medibank to our customers 
through VANgo – our mobile store on wheels that 
has been travelling throughout regional and rural 
Queensland to provide a face-to-face experience 
for customers in areas where stores aren’t close 
by. VANgo has been so popular, we will soon 
have two more vans travelling through WA and 
northern Victoria/southern New South Wales.  

c. 504504kk

customer check ins 

c. 1.41.4mm

c.  4040%

customers registered 
for My Medibank app

of Medibank service interactions 
through self-service channels

 1.5m+

people have engaged 
in free Live Better 
events and activities 
since 2017 

Annual Report 2022    9 

Deliver leading experiences

Inspiring our people to deliver 

It is the passion and commitment of our people 
that enables us to deliver for our customers 
– they are the heart and soul of who we are 
and what we do. Already strongly committed 
to our purpose and values-based culture, the 
launch of our bold new 2030 Vision this year 
– to create the best health and wellbeing for 
Australia – has inspired and motivated our 
people even further.

Our people are also empowered by our Future 
Fit ways of working, which we’ve continued to 
evolve, drawing on the lessons learnt through 
the pandemic. They choose where they work, 
based on what they are doing and where it’s best 
to get that work done. This is one of the reasons 
our people continue to be so highly engaged. 
Our employee survey this year highlighted how 
much our team value the approach to flexibility 
we offer and feel well supported in their health 
and wellbeing and opportunities for professional 
development. In a highly competitive market for 
talent, people are attracted to our purpose, our 
progressive way of working, and our caring and 
inclusive workplace.

We remain strongly committed to showing 
leadership on diversity and inclusion. We 
continued to champion gender equality with 
more than 40% of women in both senior 
leadership and Board positions and maintained 
a genderpay equity of less than 1% this year. 
We’ve strengthened cultural awareness and 
understanding among our people, launching 
our 5th Reconciliation Action Plan (RAP) this 
year and working with the Australian Indigenous 
Doctors’ Association (AIDA) and members of the 
Health RING (a network of health organisations) 
to support a more culturally safe health sector. 
We’ve also set ourselves a new target of $1 million 
(inc GST) in Aboriginal and Torres Strait Islander 
business procurement spend each year by 2025. 

The launch of our 2nd Accessibility and Inclusion 
Plan built upon our work to create an inclusive, 
safe and disability confident workplace. We 
introduced accessible membership cards for 
Medibank customers, launched our 1st disability 
awareness training module, and began piloting 
a support program for employees caring for 
ageing parents or someone with a disability  
or chronic illness.   

4444%

of Board roles  
held by women

4444%

 1 1,674,674 

 163 163

of senior leadership  
roles held by women

employees participated in 
cultural awareness training 

employees self-identify  
as living with disability

10    Medibank 

Building better communities 

We’re committed to supporting the health of our 
community and making a positive contribution 
to help address the issues we face as a society.

We reached our goal of engaging 1.5 million 
people in our free Live Better events and 
activities, 10 months ahead of schedule. The 
many free activities we supported included 
online dance classes in collaboration with the 
Sydney Dance Company, family mindfulness 
activities through our partnership with Smiling 
Mind, and health and wellbeing classes as part 
of the Medibank Feel Good program in Brisbane.

Since 2016, we've been partnering with parkrun 
Australia to make exercise and community 
engagement something everyone could enjoy. 
More than 750,000 people have participated in 
parkrun's free weekly events since 2011. We 
know the positive social impact parkrun has on 
communities, particularly so in terms of tackling 
loneliness, and this year we extended our 
partnership to 2025. 

We raised the public conversation about 
loneliness as part of our 10-year commitment 
to helping address an issue that our research 
showed is impacting more than half the people 
in Australia, based on our latest survey results. 
We launched the podcast series We Are Lonely 
to explore the theme of loneliness and drive 
positive conversations around mental health and 
wellbeing. Featuring interviews with the likes of 
actor Hugo Weaving and musician Darren Hayes, 
the podcast has been listened to by more than 
55,000 people to date. 

We launched our Better Minds hub to provide  
a range of resources about mental health  
and wellbeing, as well as an app featuring 
wellbeing checks, mental fitness training  
and one-on-one coaching sessions.  

We also undertook research to better understand 
the longer-term implications COVID is having 
on the mental health and wellbeing of young 
people. We continued to drive health research 
and patient advocacy initiatives; partnering with 
universities and research leaders, industry and 
advocacy groups. We supported 25 projects this 
year, including a University of Sydney program 
assessing the use of digital health services to 
help people in rural and remote communities 
manage musculoskeletal pain.  

In addition to supporting our customers 
through our COVID financial support package 
and give back program, we helped customers 
impacted by the floods in New South Wales and 
Queensland with assistance packages including 
policy suspensions and financial support to 
cover premiums for up to three months.

We know we have a role to play in fighting 
climate change, which is why we’ve brought 
forward our Net Zero commitment to 2040 
and set science-based targets to achieve Net 
Zero on Scope 1 and 2 emissions by 2025 and 
a 50% reduction in Scope 3 emissions by 2030. 
Our pathway is based on Medibank Group’s 
current business-as-usual operations and does 
not account for any future partnership and 
investment activity. Our investment portfolio is 
also currently out of scope, but we are working 
to create a pathway to Net Zero for this. We’re 
actively working to protect human rights and 
help prevent modern slavery. This year we 
strengthened our commitment to ensuring 
respect and equality for our customers, 
employees, communities and suppliers with 
the launch of our 1st Human Rights Policy. 
We also published our 2nd Modern Slavery 
Statement, which detailed the extension of  
our risk assessments to our hospital partners 
and overseas agents that distribute products  
on our behalf.

c. $$1.11.1mm

invested in research
1 July 2021 to 30 June 2022

More than

  5555k+ k+ 

people have 
listened to the  
We Are Lonely  
podcast to date

For more information  
about the work we’re  
doing in the community  
and our commitments  
to sustainability, see our  
Sustainability Report 2022

Annual Report 2022    11 

Differentiate our 
insurance business

Our goals:

Our FY22 milestones

>  Deliver more value, choice  
and control for customers 

>  Offer products and services  
to meet all customer needs 

>  Leverage our dual brands  

and provider networks

Net policyholder growth

Market share –  
FY24 aspiration

Target

3.1-3.3%

Up 25-75bps

Health Insurance  
productivity delivered

$40m including 
$15m in FY22

Achieved

+3.2% 

27.45%  
(+14bps since FY21)

c. $15m 

12    Medibank 

As the impacts of the pandemic persist in our health system and the broader 
community, people are continuing to prioritise their health, even though  
cost of living pressures are increasing. They are looking to us to provide  
real value and support for their health and wellbeing, and we are delivering  
– with products and services that do more for our customers and growing 
our network of partners and providers to better meet their needs. 

 70%

of our new customers 
are younger people  
and those new  
to industry

People have responded to the choice we are 
providing through our two distinct brands and  
we increased our market share by 14 basis 
points. Younger people and those new to industry 
made up around 70% of our new customers  
this year. Together our Medibank and ahm 
brands now represent 27.45% of people with 
private health insurance.

Ongoing COVID support  
for our customers

As COVID continued to impact our customers’ 
ability to access healthcare services, we 
returned around $368 million in COVID 
permanent net claims savings to customers 
through cash give backs and deferring premium 
increases. We also rolled over extras annual 
limits for ahm customers. In total we’ve  
now provided around $682 million in COVID 
customer support since the pandemic first 
began and we continue to assess known 
permanent net claims savings due to COVID  
to return to our customers in the future. 

Products and services  
built for better 

We’ve listened to our customers and refined our 
products and services to offer greater value. We 
launched a new suite of extras cover products to 
give customers the flexibility to be able to choose 
and pay for the services they want. In doing so 
we've introduced a new, intuitive way for new 
customers to buy the health insurance that best 
meets their needs, and have seen increased 
levels of satisfaction for these products. 

We partnered with doctors and hospitals to 
expand our short stay network, forming a new 
partnership with Healthe Care to grow our no 
gap program. By October 2022, we will have 24 
hospitals across seven states and territories 
participating in our no gap program, which 
covers selected procedures such as hip and knee 
replacements and endoscopies with no medical 
out-of-pocket costs and the opportunity to 
recuperate at home, where clinically appropriate. 

Almost two thirds of Medibank customers will 
live within 25km of a no gap site by October 2022 
and we’re now expanding the program to new 
procedures, including some general surgery 
procedures. We were also the first major health 
insurer to adopt the Federal Government’s 
voluntary age dependent reforms, extending the 
age that young adults can stay on their parents’ 
policy from 24 years old until their 31st birthday.  

3.963.96mm 

customers 
at 30 June 2022

c.  6464% 

of Medibank 
customers to live 
within 25km of a  
no gap hospital  
by October 2022 

24 hospitals 
in 7 states in our  

no gap network
by October 2022  

1,200  
$$1,200

average out-of-pocket 
cost savings for patients 
in our no gap joint 
replacement program 

Annual Report 2022    13 

 
 
Differentiate our insurance business

As borders began to reopen, we saw strong 
growth in the number of overseas students, 
workers and visitors choosing our health 
insurance options. We enhanced our Overseas 
Student Health Cover products to provide  
greater support for international students, 
introducing an online GP service within the 
app and launching a student rewards program 
to help students to save money, find work and 
enhance their skills and knowledge. This year, 
Canstar named Medibank and ahm joint  
winners of its Outstanding Value Award for 
overseas health cover. 

Better value 

Our Members’ Choice Advantage network  
has delivered around $31.2 million in  
out-of-pocket savings this year, providing  
better value, more cost transparency and  
a wider range of services to our customers. 

In July this year, we expanded this network to 
include physiotherapy, chiropractic, podiatry, 
acupuncture and remedial massage and we  
now cover more types of services than any  
other health insurer. Through our Live Better 
Rewards program, we’re rewarding our 
customers for looking after their health by 
visiting one of our Members’ Choice Advantage 
dentists or optical providers or shopping with 
our partners like Fitbit, Brooks, Amcal Pharmacy 
or HelloFresh. Customers have also been able 
to redeem points on products and services from 
our growing range of partners including adidas, 
Apple and more. 

c. $$31.231.2mm  

out-of-pocket savings 
through Members’ Choice 
Advantage network 

14    Medibank 

The program is helping us improve customer 
engagement and retention, with our data 
showing customers participating in Live  
Better are more likely to stay with us.

We were one of the first insurers to introduce 
COVID benefits to our travel insurance cover 
when travel restrictions lifted this year.  
We also supported customers to better protect 
their pets, simplifying access to pet insurance 
by integrating it into the My Medibank app  
and improving our cover options – for which  
we were recognised by the Canstar Award  
for outstanding value pet insurance.  

We’ve paid $5.4 billion in claims and this  
year’s annual health insurance premium 
increase, which we postponed for seven  
months, was our lowest in 21 years. We also 
continued to manage our own costs, delivering 
around $15 million in cost savings this year  
as part of our target to deliver $40 million in  
productivity savings between FY22 and FY24.

Advocating for reform

We’ve worked to encourage healthcare 
reforms that could reduce costs and improve 
sustainability across the system, increase  
care options where clinically appropriate  
and make private health insurance more 
affordable through improved incentives. 

We’ve continued to strongly advocate for 
prostheses reform, which presents an 
opportunity to deliver around $900 million in 
cumulative savings over four years to private 
health consumers. While we anticipate the 
Federal Government’s agreement with medical 
device manufacturers will see real price 
reductions flow through the health system over 
the next four years, more needs to be done as 
Australians continue to pay some of the highest 
prices for medical devices in the world. We 
remain committed to returning the prostheses 
reform savings realised to our customers 
through lower premium increases.

Prostheses  
costs are around 

3030%

 higher 

than in NZ, France 
or the UK

Private Healthcare Australia

$$5.45.4bb   

total claims paid

Lowest average premium 
increase in 21 years
years

deferred for 7 months until

1 Nov 
2022

c. $$1515mm  

in productivity savings

Annual Report 2022    15 

Expand in health 

Our goals:

>  Focus growth on prevention 
and integrated care models 

>  Scale and connect our  

health businesses 

>  Bring benefits back to our core

 10,086  
 10,086

people enrolled  
in preventative  
health programs 

 1  1 in 

in 44  

Medibank joint 
replacement patients 
are having rehab 
at home  

16    Medibank 

Together with doctors, hospitals and governments, we’re creating  
new models of care that are better for patients and better for Australia’s 
health system. We’re working to drive down costs, offer more choice and 
improve the healthcare experience for our customers and for patients 
across the country. 

We’re supporting healthcare innovation, building partnerships with others 
in the healthcare system and investing in companies that are utilising 
technology to make healthcare simpler, easier and more accessible. 

c. 27%

of Medibank customers 
going to hospital  
were supported by  
Health Concierge

Helping our customers be better 

The latest census data highlighted one of  
the biggest challenges facing our health 
system – Australia’s ageing population and  
the growing number of people with one or 
more chronic health conditions. This is why 
we are so invested in preventative healthcare, 
helping our customers and our communities  
to stay healthy and avoid unnecessary  
hospital treatments.

More than half a million people have joined 
our Live Better program which is designed 
to encourage and reward people for healthy 
actions. Through the Live Better app we have 
been running preventative health campaigns, 
rewarding customers for getting flu and COVID 
vaccinations, taking their blood pressure 
or having skin checks. We also developed a 
children’s eye check challenge after research 
highlighted the increased use of screens during 
the pandemic was leading to an increase in 
childhood myopia.  

Our preventative health programs continue 
to grow with enrolments increasing by more 
than 40% across our eight programs this 
year. Results from our Better Knee, Better Me 
program demonstrate up to four out of five 
participants experienced clinically significant 

improvements in knee pain, and the program – 
developed with the University of Melbourne  
– received the inaugural Australian Clinical Trials 
Alliance (ACTA) Industry Partnership Award this 
year. We have now launched a new pilot that 
aims to help people manage osteoarthritis hip 
pain that utilises the same successful approach.  
Our Medibank Type 2 Diabetes program has  
also seen promising early results and feedback 
from participants. 

Our Health Concierge team supported almost 
27% of Medibank customers going to hospital 
this year and launched two new pilots. Our 
Dietician Support service is designed to help 
elderly people going to hospital who are at risk 
of malnutrition. In July 2022 we also launched 
our Mental Health Concierge that prepares 
customers and their family for a psychiatric 
admission and supports them throughout  
their experience. 

As well, many of our corporate customers 
are looking to us for support with developing 
health and wellbeing programs tailored to the 
needs of their employees. From customised 
preventative programs and virtual health 
solutions, to specialised mental health support, 
we are helping businesses, organisations and 
universities to better support their people.

Our FY22 milestones

Customers engaged with Live Better*

Medibank Health segment profit

Target

c. 480k

Replace the reported FY18 $30m 
operating profit of Garrison by FY22**

Achieved

c. 568k (+55%)

 $45.5m 
(FY18: $47.3m)

*   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

** Milestone updated to align with Medibank Health segment profit and to reflect FY21 statements that the temporary 

travel insurance earnings impact is expected to be largely offset by the contribution from investments in FY22

Annual Report 2022    17 

Making healthcare personal 

As we work to create more options that give 
people greater access, choice and control 
over their healthcare, we reshaped our health 
services business this year under the new name, 
Amplar Health. Through Amplar, we’ve continued 
to support patients in both the private and public 
health systems by growing and developing the 
health services we deliver and invest in – virtual 
health, homecare, short stay hospitals, primary 
care and allied health. The Amplar team is also 
focusing on ways to improve health system 
navigation and create a more digitally connected 
healthcare experience for our customers. 

Central to this work is the partnerships we have 
built across the business with doctors, hospitals 
and health stakeholders. During the year we 
invested $10 million in leading health technology 
company Medinet, expanded the My Home 
Hospital program we deliver for Wellbeing SA 
in a joint venture with Calvary, and assisted the 
Myhealth GP network to expand their network of 
local GP practices, as well as helping strengthen 
their clinical operations and core business 
processes. We also continued working with a 
group of more than 40 doctors to develop a  
new short stay hospital in Melbourne which  
we expect to open in 2024. 

7,239
7,239

customers used 
Medibank at Home

3,245
3,245

patients used  
My Home Hospital 

since Jan 2021

c. 7979kk  

Better Minds hub 
users and app 
downloads 

18    Medibank 

Expand in healthRedesigning healthcare  
for our customers 

We partnered with Myhealth and Medinet to 
launch a new telepsychology clinic pilot designed 
to reduce the wait time to access a psychologist 
from three months to two weeks, that utilises 
video consultations supported by an innovative 
phone and digital concierge support program.

We’ve continued to invest in our telehealth 
capabilities and expand our virtual care 
technology. Through our joint venture with 
Calvary we created a COVID Care at Home 
program that utilised remote monitoring and 
artificial intelligence to assist local health 
authorities to support around 165,000 COVID 
patients across New South Wales, Victoria, 
Queensland and Western Australia this year.  
We also helped take the pressure off emergency 
departments and support local hospitals through 
the Nurse Triage and After Hours GP programs 
that we deliver on behalf of healthdirect.   

We worked closely with one of our largest 
corporate clients to implement virtual GP 
services, health management programs and 
provide 24/7 care to support their fly in fly out 
and regional and rural employees in remote 
parts of Australia.

In addition to providing our own 24/7 general 
health and mental health phone support lines 
for our customers, we have continued to deliver 
the NSW Mental Health Line, and after a decade 
of delivering 1800RESPECT and Beyond Blue, 
our contracts came to an end this year.   

Community support for homecare has continued 
to increase, despite services being impacted by 
COVID restrictions on elective surgery. We cared 
for more than 7,000 people in the comfort of 
their home this year, and our My Home Hospital 
service, delivered on behalf of Wellbeing SA 
through a joint venture with Calvary, expanded to 
provide a broader range of treatments and care 
to patients in additional areas near Adelaide.

$$1010mm  

investment in health tech 
company Medinet

c. 3.53.5mm  

virtual health interactions

c. 165165kk  

patients supported 
through joint 
Calvary-Medibank 
COVID Care at Home

Annual Report 2022    19 

Our sustainability highlights

FY22 highlights

Giving back to customers c. $368m in 
COVID permanent net claims savings 
through cash give backs and postponing  
premium increases for 7 months

c. $682m total COVID financial 
support package to date

Rolling over unclaimed ahm FY22  
extras annual limits for another year 

More than doubled our no gap network 
(including short stay) across 7 states  
and territories

c. 568k customers engaged with Live 
Better and preventative programs 

c.7.2k customers used Medibank at Home

c. $31.2m out-of-pocket savings through 
Members’ Choice Advantage network

Managed c.3.5m virtual health interactions

Supported c.165k patients through  
COVID Care at Home program  
delivered with Calvary

Lowest average premium increase  
in 21 years

Invested $10m in health  
technology company, Medinet

c.79k Better Minds hub users  
and app downloads

c.100k+ people engaged with the  
Smiling Mind Families program 

Launched We Are Lonely podcast series  
to raise awareness of loneliness

Rewarded 70k+ Live Better members  
for getting COVID vaccinations

40k+ customers accessed  
free flu vax vouchers

Women represent 44%  
of Group and senior leaders

44% of our Board are women 

Maintained gender pay equity  
of less than 1% 

24% of parental leave taken by men

11th globally in Equileap  
Gender Equality Index

Employer of choice by WGEA,  
7th year in a row

Certified as a Family Friendly  
Workplace by UNICEF

Published 1st  
Human Rights Policy

Published 2nd  
Modern Slavery Statement 

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

Extended modern slavery risk  
assessments of suppliers 

Sought independent limited  
assurance of selected ESG metrics 

c. 85% of employees worked flexibly

COVID care and pregnancy support 
programs extended to employees

In the top 25% of companies  
globally for employee health  
and wellbeing engagement  
(Q1 2022 Peakon global benchmark)

Extended commitments to partner  
with Aboriginal and Torres Strait  
Islander businesses in RAP

c. $596k (inc GST) spend with Aboriginal 
and Torres Strait Islander businesses

Ensure healthy lives and 
promote wellbeing  
for all ages

Material topics 

Affordable, innovative and 
personalised healthcare

Support healthy communities

Achieve gender equality and 
empower all women and girls 

Material topics 

Diverse and inclusive 
workforce 

Engaged, purpose-led culture, 
attract and retain talent

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

Material topics 

Engaged, purpose-led culture, 
attract and retain talent

Ethical and sustainable 
business

20    Medibank 

FY22 highlights

Increased employee engagement  
among Aboriginal and Torres  
Strait Islander employees 

163 employees identified  
as having a disability

Piloted a carers support program  
for employees

Published 2nd Accessibility  
and Inclusion Plan

Reduce inequality within  
and among countries

Material topics 

Diverse and inclusive 
workforce

Ethical and sustainable 
business

Ranked 11 on the Australian Network  
on Disability Access & Inclusion index

Published 5th RAP 

11 years partnering with the  
Wadeye community in NT 

1,674 employees participated  
in cultural awareness training

Take urgent action to combat 
climate change and its impacts

Material topic 

Environmental health  
and climate change

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

Material topics 

Ethical and sustainable 
business

Work together to build 
a stronger and more 
sustainable health system

Support healthy communities

Accelerated commitment to achieving 
Net Zero by 2040 including Net Zero 
against our Scope 1 and 2 emissions  
by 2025

c.$15m invested in green bonds

Begun analysis to understand  
the sustainability profile of our  
investment portfolio

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

Ongoing commitment to low carbon 
domestic and international equity  
investments

Further integration of ESG into 
enterprise risk management

c. $1.1m invested in  
25 health research projects 

Advocated for healthcare  
system reform

Partnered with La Trobe University  
to research impacts of COVID and  
health delivery services

6 years partnering with the  
Grattan Institute

3 years partnering with the  
Australian Patients Association 

Community partnerships 

•  parkrun Australia

•  Smiling Mind 

•  Feel Good Program, Brisbane

•  Sydney Dance Company

•  Dr Michael Mosley and  
The Fast 800 Program 

Aboriginal and Torres Strait Islander 
partnerships

•  Australian Indigenous Doctors’ 

Association 

•  Thamarrurr Indigenous Youth 

Corporation 

•  Wadeye community, Northern Territory

•  Indigenous Defence and Infrastructure 

Consortium (iDiC) 

•  Supply Nation

•  Dhiira

For more detail see our Sustainability Report 2022

Annual Report 2022    21 

Operating and financial review

1. About Medibank

Medibank Private Limited (Medibank) is a health company 
providing health insurance and health services to more 
than 4 million people 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 providing a number of services: our 
health services business, which is being rebranded as Amplar 
Health, supports the healthcare needs of our core Medibank 
and ahm customers and the broader community; our Live 
Better program supports customers and the community to 
make better choices for their health and wellbeing; and we 
offer a range of diversified insurance products such as travel, 
life and pet insurance. Additionally, as we maintain assets 
to satisfy our regulatory reserves, we 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. 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 2022, we had 
3,291 full-time equivalent (FTE) employees, including 970 
health professionals (excluding employees in associates  
and joint ventures). 

2.1 Group summary income statement

Year ended 30 June ($m)
Group revenue from external customers 
Health Insurance operating profit
Medibank Health segment profit
Segment operating profit
Corporate overheads
Group operating profit 
Net investment income/(expense)
Amortisation of intangibles
Other income/(expenses)
Profit before tax
Income tax expense
Group net profit after tax (NPAT) 
Effective tax rate
Earnings per share (EPS) (cents) 
Normalisation of growth asset returns
Normalisation of defensive asset returns
Underlying NPAT1
Underlying EPS (cents)1
Dividend per share (cents)
Dividend payout ratio1

2. Financial and operating performance

References to “2021”, “2022” and “2023” are to the financial 
years ended on 30 June 2021, 30 June 2022 and 30 June 2023 
respectively, unless otherwise stated. The “Group” refers 
to the consolidated entity, consisting of Medibank and its 
subsidiaries. 

Despite the challenging environment over the last year, our 
results show continuing momentum in our Health Insurance 
business and strong growth in Medibank Health, including 
a meaningful uplift in the contribution from our healthcare 
partnerships. 

2022
7,128.5
592.6
45.5
638.1
(44.0)
594.1
(24.8)
(2.0)
(7.3)
560.0
(166.1)
393.9
29.7%
14.3
22.7
18.5
435.1
15.8
13.4
84.8%

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
(31.2)
(11.3)
398.7
14.5
12.7
87.7%

Change
3.2%
10.0%
44.9%
11.9%
5.5%
12.5%
n.m.
(56.5%)
(36.0%)
(11.4%)
(13.1%)
(10.7%)
(50bps)
(10.7%)
n.m.
n.m.
9.1%
9.1%
5.5%
(3.3%)

1.   Underlying NPAT is statutory NPAT normalised for growth asset returns to historical long-term expectations, credit spread movements and one-off items. 

Dividend payout ratio based on underlying NPAT

22    Medibank 

 
Group operating profit increased by $65.8 million or 12.5%, 
with $54.0 million or 10.0% growth in Health Insurance 
operating profit, and $14.1 million or 44.9% growth in 
Medibank Health segment profit. However, continued volatility 
within financial markets drove a $24.8 million loss in net 
investment income compared to a $120.0 million gain in 
2021, and as a consequence Group NPAT was down 10.7%. 

Underlying NPAT, which adjusts for the normalisation of 
investment returns, increased $36.4 million or 9.1% to  
$435.1 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

2022
6,859.8
(5,731.1)
1,128.7
(536.1)
592.6
16.5%
7.8%
8.6%

2021
6,680.3
(5,610.8)
1,069.5
(530.9)
538.6
16.0%
7.9%
8.1%

Change
2.7%
2.1%
5.5%
1.0%
10.0%
50bps
(10bps)
50bps

Strong Health Insurance performance was driven by 
continued policyholder growth, a subdued level of cover 
downgrading and ongoing cost control, and was achieved 
despite the impact of border closures on the non-resident 
health insurance business.

Health Insurance revenue grew 2.7% to $6,859.8 million with 
strong policyholder growth and improved downgrading. When 
adjusted for our COVID-19 customer support measures of 
$369.4 million in 2022 and $226.0 million in 2021, underlying 
revenue grew 4.7%.

The resident Health Insurance market remains buoyant 
with the trend of high quality industry policyholder growth 
continuing, including new to industry and younger customers.

Our reported net resident policyholders increased by more 
than 60,000 or 3.2% with the Medibank and ahm brands 
growing 1.9% and 7.3% respectively. The Medibank brand 
acquisition rate increased 30 basis points, reflecting strong 
growth in the corporate segment and through digital channels. 
ahm continued its strong growth trajectory and now has more 
than 500,000 policyholders, although the acquisition rate was 
lower than the prior period due to declining sales through 
aggregator platforms and increased policyholder numbers. 

Reported net resident policyholder growth

FY22

FY21

FY20

FY19

3.2%

4.6%

0.6%

0.8%

0

1

2

3

4

5

The lapse rate for Medibank was stable, while an increase 
in ahm’s lapse rate in part reflects the benefit of the extras 
annual limit rollover last year. Despite deteriorating economic 
conditions, the lapse rate in the second half for both 
brands improved compared to the second half of 2021, and 
throughout the year there was no notable increase in policy 
suspensions.

Gross claims expense increased 1.9% and net claims, 
which includes risk equalisation, increased 2.1%.  The risk 
equalisation payment increased $11.5 million, reflecting our 
claims growth continuing to be below industry growth and 
strong policyholder growth in ahm which has a younger and 
lower claiming customer demographic. There was also a 
$368.8 million reduction in claims expense with lower than 
expected claims as a result of COVID-19 and an increase in 
the deferred claims liability.

Underlying resident claims growth per policy unit (which 
excludes COVID-19 impacts) was 2.3% with the increase in 
hospital claims more than offset by the reduction in extras 
claims. Extras claims growth in the prior period was elevated 
due to investment in additional product benefits, and the 
modest increase in hospital claims this period reflects sales 
mix and the benefits of claims initiatives in the prior period. 

The COVID-19 deferred claims liability, which is in 
recognition of claims that have likely been deferred since the 
commencement of COVID-19 restrictions, increased $224.5 
million to $448.3 million with lower hospital volumes due to 
elective surgery restrictions and staff shortages resulting 
from COVID-19 isolation periods. Overall, COVID-19 had a 
modest impact of $0.6 million on operating profit with the 
cost of our customer give back program offset by further 
permanent claims savings. Removing these COVID-19 
impacts, underlying gross profit increased 5.3%.

Annual Report 2022    23 

Operating and financial review

Reported gross profit increased 5.5% to $1,128.7 million with 
improving revenue and lower claims growth per policy unit 
in the resident portfolio more than offsetting a decline in 
the non-resident portfolio. The second half saw a material 
improvement in gross profit for the non-resident portfolio 
as the opening of international borders led to an increased 
student intake. 

Management expenses were up 1.0% to $536.1 million 
with approximately $15 million of productivity savings and 
lower non-cash costs largely offsetting cost inflation of 
approximately 2.5%, additional statutory costs and growth 
in non-resident commissions. The growth in non-resident 
commissions reflects the reopening of borders in the 
second half. While we expect cost inflation to increase to 
approximately 3.5% to 4.0% in 2023, this will largely be offset 
by further productivity savings. Despite this modest increase 
in management expenses, the increase was lower than the 
increase in revenue resulting in an improved management 
expense ratio of 7.8%, or 7.4% on an underlying basis.  
Going forward we will continue to leverage the benefits of 
growth and scale to target further modest improvement in 
the management expense ratio. While we will remain 
disciplined, we will continue to focus on balancing this 
objective with our medium-term growth aspirations.

Health Insurance management expense ratio

2022

2021

2020

2019

7.8%

7.9%

8.3%

8.7%

0

2

4

6

8

10

Our Health Insurance operating profit of $592.6 million 
increased 10.0% this year, or 9.5% on an underlying basis, 
with continued cost discipline and the benefit of increasing 
scale contributing to a 50 basis point improvement in 
operating margin. On an underlying basis, operating margin 
improved 40 basis points to 8.2% due to the 30 basis point 
improvement in underlying management expense ratio. 

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. It includes the provision of health 
management, telehealth services for government and 
corporate customers, hospital care in the home, preventative 
health and wellbeing programs, and diversified insurance 
products. Our investments in associates and joint ventures 
also form part of this segment. This includes our non-
controlling investments in East Sydney Private Hospital  

24    Medibank 

and Myhealth, a leading operator of primary care clinics, and 
our joint venture with Calvary to deliver My Home Hospital, a 
Wellbeing SA service, and COVID Care at Home services.

During 2022 there were a number of largely offsetting 
COVID-19 impacts to Medibank Health. Closed borders 
continued to impact travel insurance sales, and lockdowns 
impacted homecare patient numbers and margins, although 
this was largely offset by the provision of COVID-related 
services. Revenue increased 13.4% to $321.8 million with 
strong growth in telehealth and health and wellbeing services, 
and a strong second half of travel insurance sales, offset by 
lower homecare revenue due to elective surgery restrictions.

Gross margin was down 110 basis points to 40.1% with 
constrained labour availability impacting labour costs and 
the ability to deliver services in homecare, and the impact of 
transitioning out of telehealth contracts.

Management expenses increased $3.6 million, including 
$2 million due to contract exits and other one-off costs, 
however the management expense ratio improved 240 basis 
points to 27.5% due to strong revenue growth, reinforcing the 
opportunity to create scale in this business.

With the strong momentum in the remainder of the Medibank 
Health business and growth opportunity around the needs of 
the Medibank customer, we expect on average at least 15% 
organic segment profit growth per annum over the next three 
years, with the potential for further growth from M&A activity. 

While revenue and costs will be lower in 2023 as a result 
of the exit of 1800RESPECT and Beyond Blue telehealth 
contracts, these contracts did not make a material 
contribution to 2022 operating profit, which increased  
26.7% to $40.8 million and excludes our share of the results 
of Myhealth and other investments. Medibank Health 
segment profit improved 44.9% to $45.5 million.  

Net investment income/(expense)

Medibank’s investment portfolio was $3.4 billion as at  
30 June 2022. This investment portfolio, which includes 
$3.2 billion relating to the health fund, 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 additional assets, largely in 
cash to fund claims deferred due to COVID-19 and customer 
give back programs, and sits outside our target allocation of 
growth and defensive assets of 20% and 80% respectively.

Volatile investment markets significantly impacted net 
investment income in both years with a $24.8 million expense 
in 2022 compared to income of $120.0 million in 2021. The 
decreased income was driven by the significant correction 
across equity markets within the growth portfolio assets, and 
a reduction in income from the defensive portfolio including 
a $26.5 million loss due to widening of credit spreads, 
compared to a gain of $16.1 million last year. 

 
 
 
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 decreased by $39.5 million  
or 2.1% to $1,945.6 million as at 30 June 2022.

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

•  An increase in financial assets at fair value to fund our 

commitment to return permanent net claims savings due  
to COVID-19 to customers (customer give back programs) 
and COVID-19 deferred claims liability. 

•  An increase in claims liabilities due to the ongoing 

recognition of the COVID-19 deferred claims liability.

•  An increase in unearned premium liability and provisions due 
to the recognition of customer give back provision relating to 
the return of permanent net claims savings due to COVID-19 
to customers through premium relief and cash returns.

As at 30 June 2022, 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 2022:

•  Our total Health Insurance business-related capital was 
$983.7 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 $187.2 million.

•  Unallocated capital surplus was $148.0 million.

In November 2018, the Australian Prudential Regulation 
Authority (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 
Quantitative Impact Study (QIS). Draft capital standards 
were released in December 2021 with the intention 
to release the final standards in September 2022 for 
implementation on 1 July 2023. We are well placed to 
implement this framework as our Capital Management 
Policy is already closely aligned with LAGIC and do not 
expect it will negatively impact our capital position. 

Dividends paid or payable in respect of profits from the 
financial year totalled 13.40 cents per share fully franked, 
amounting to $369.0 million comprising:

•  An interim ordinary dividend of 6.1 cents per share fully 

franked, amounting to $168.0 million paid on 24 March 2022 
in respect of the six-month period ended 31 December 2021.

•  A final ordinary dividend of 7.30 cents per share fully franked, 
amounting to $201.0 million to be paid on 29 September 2022 
in respect of the six-month period ended 30 June 2022.

The full year 2022 ordinary dividend represents an 84.8% 
payout ratio of underlying NPAT, normalising for investment 
market returns. This is at the top end of our dividend target 
payout ratio range of between 75% and 85% of underlying 
NPAT, and reflects our strong capital position.

2.4 Management changes

There have been no changes to Medibank’s Executive 
Leadership Team this year.

3. Strategy and future prospects

Medibank’s purpose is Better Health for Better Lives.  
Our 2030 vision is to create the best health and wellbeing  
for Australia. By working to provide affordable and quality 
health outcomes, we seek to sustainably build our customer 
base and grow shareholder value. Our strategy puts our 
customers and people at the centre of everything we do. 

Our strategy – growing as a health company 

Deliver leading  
experiences

Differentiate our  
insurance business

Expand in health

Create personalised and connected 
customer experiences 

Empower our people

Collaborate with our communities 
to make a difference

Deliver more value, choice  
and control for customers

Offer products and services  
to meet all customer needs

Leverage our dual brands  
and provider networks

Focus growth on prevention  
and integrated care models

Scale and connect  
our health businesses

Bring benefits back  
to our core

Better Health for Better Lives

Annual Report 2022    25 

Operating and financial review

Our employees are our most valuable asset. It is only by 
empowering our people that we can deliver on our vision, so 
we’ve built a culture anchored by the three pillars of purpose, 
people and performance so they can make the greatest impact 
on our customers and communities. We are committed 
to ensuring Medibank remains a great place to work, 
differentiating ourselves in the market through our approach 
to flexibility and health and wellbeing. We’re embedding our 
purpose and values throughout our business, and building a 
highly engaged, skilled team. We’re also committed to driving 
a culture of wellbeing and supporting the diverse physical, 
emotional and mental health needs of our people. 

Since the start of the COVID-19 pandemic we have seen 
a shift of people in Australia prioritising their health and 
wellbeing. Combined with heightened pressure on the public 
health system, this has resulted in private health insurance 
becoming more compelling for many people including those 
who were previously uninsured. We have continued to focus 
on differentiating and growing our health insurance business 
by leveraging our dual brand strategy to create a competitive 
advantage. The pandemic has also resulted in an increased 
awareness and acceptance of integrated care models. We’re 
partnering with doctors, hospitals and governments to deliver 
care in new ways – and growing and developing new health 
services through our Amplar Health business. 

We have worked hard to deliver our lowest premium increase 
in 21 years, with premiums scheduled to rise by an average 
of 3.10% from 1 April 2022. Due to our commitment to return 
all COVID-19 permanent net claims savings, we deferred this 
premium increase for seven months to 1 November 2022 for 
eligible policyholders. Additionally, we have announced a cash 
give back to eligible customers, which they will receive in 
September 2022. To date, our total COVID-19 support for our 
customers stands at around $682 million and has included two 
rounds of premium deferrals, give backs to customers through 
premium relief and cash give backs, ancillary limit rollovers 
for ahm customers, and financial hardship support. We are 
committed to returning all permanent net claims savings  
due to COVID-19 to our customers once they are known.

We have focused 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 $55 million of productivity savings 
over the past three years, including approximately $15 million 
in 2022, and will continue to target further productivity. 

Customers are at the heart of what we do and we are working 
to better support their healthcare needs by providing greater 
choice and more personalised advice, while helping to reduce 
out-of-pocket medical costs. We’ve expanded the no gap 
program to more participating providers across the country  
to provide eligible customers with the option of paying no  
out-of-pocket medical costs for a range of selected 
procedures including hip and knee replacements, 
endoscopies, and some general surgery procedures. 

26    Medibank 

Our no gap network, which includes a short stay care model, 
has continued to grow with 64% of Medibank customers 
to live within 25km of a no gap site by October 2022. The 
network includes East Sydney Private Hospital, which we have 
a 49% interest in. We also continue to work with a group of 
more than 40 doctors on the development of Adeney Private 
Hospital – a short stay surgical facility in Melbourne due to 
open in 2024. 

The My Home Hospital service delivers hospital level care to 
patients in their homes in Adelaide and surrounding areas. 
This year the service expanded to provide a broader range of 
treatments and operate in additional areas in South Australia. 
A Wellbeing SA service delivered by a joint venture between 
Calvary and Medibank, My Home Hospital utilises remote 
monitoring technology to enable clinicians to track the clinical 
status of admitted patients and allows the care team to stay 
in touch 24/7. More than 3,200 patients have used the service 
since launch in January 2021. In the future, opportunities exist 
to use market leading technology platforms, like those used 
for My Home Hospital, across public and private settings.

We continue to work with GPs given the vital role they play 
in primary health. Our investment in the Myhealth Medical 
Group supports 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 also gives the GPs access to additional capabilities 
to improve data analytics and information management and 
enables Myhealth to continue its rapid growth. There were 
106 Myhealth clinics at the end of 2022 and further growth 
will be supported by investment in greenfield practices and 
acquisition of existing practices. Our investment in digital 
health services company Medinet to support the virtual 
capability and connectivity of GPs and their patients also 
reflects our support for primary care in the community.

We have deepened relationships with our customers through 
other avenues and we have seen substantial growth in 
members supported in navigating and managing their health. 
More than 40,000 customers, equating to approximately 
27% of customers going to hospital, were supported by our 
telephone and digital Health Concierge, and we’re trialling the 
introduction of specialist health concierge clinicians across five 
Victorian stores to engage with customers on the many health 
and wellbeing support options available to access. We’ve made 
progress in mental health solutions with the Better Minds 
hub and app attracting approximately 79,000 users and app 
downloads. We also launched a telepsych clinic pilot this year 
in partnership with Myhealth and Medinet, and partnered to 
deliver out-of-hospital care models for mental health. 

Our Members’ Choice network is one of the largest health 
provider networks in Australia, and offers better value,  
more cost transparency and a wider range of services to  
our customers. Customers using our Members’ Choice 
Advantage for their dental and optical needs saved 
approximately $31.2 million in out-of-pocket costs in 2022. 

We have now expanded the network to also include physio, 
chiro, podiatry, acupuncture, and remedial massage, covering 
more types of services than any other health insurer. 

Our Live Better program continues to scale, with more than 
522,000 Live Better Rewards participants, and we are targeting 
more than 800,000 participants in FY25. We are continuing 
to integrate the Live Better app into the My Medibank app 
to provide a single digital health experience across health 
insurance and health and wellbeing. We are also integrating 
Live Better into preventative health, acquisition and retention 
journeys to evolve the way we inform and inspire customers 
about health and wellbeing, making it even more relevant, 
accessible and easy to use. 

We’ve invested in growing our suite of preventative healthcare 
programs designed to support our customers stay healthy 
and avoid unnecessary treatments, and have seen more than 
10,000 enrolments in our programs, an increase of more 
than 40% over the past 12 months. Our national Better Knee, 
Better Me program was awarded the Australian Clinical Trials 
Alliance (ACTA) inaugural Industry Partnership Award this year.  
Following the success of Better Knee, Better Me, we recently 
launched a Better Hip pilot that aims to help people manage 
osteoarthritis hip pain. 

The macroeconomic environment and ongoing impacts of 
COVID-19 cannot be predicted with any certainty in 2023. 
Although we are seeing rising inflation impacting the cost 

of items such as groceries and fuel, and households 
navigating a higher interest rate environment, Medibank 
remains positioned for growth with strong customer 
advocacy, positive policyholder growth outlook, a continued 
focus on cost discipline, and a strong balance sheet to 
support our growth ambitions. 

In the year ahead we will build on further understanding 
our customers’ needs to develop a broader and deeper 
relationship with them and their health. We will continue 
to differentiate and add value to the core health insurance 
proposition by strengthening our product range, and 
leveraging our technology and data capabilities to deliver 
increasingly personalised propositions. We will work with 
partners and providers to deliver more proactive and 
preventative healthcare to support affordability, drive down 
costs, and improve the choice and experiences for our 
customers. We will embed and scale our existing health 
assets to deliver earnings growth in their own right, utilising 
the synergies between the individual assets as well as the 
core Health Insurance business and expedite health system 
change. Connection between our various health assets will 
be key to delivering a better and more customer/patient-
centric health experience.

Our strategy is the right strategy for our business and will 
continue to inform our decisions. Aligned with our strategy, 
our milestones are detailed below. 

FY23 – FY25 milestones

Pillars

Milestones

Deliver leading 
experiences

Customer advocacy: Service NPS (average)

Employee advocacy: eNPS

FY22
Medibank 45.3
42.4
ahm

FY23 benchmark1
>35
>35

Place to work
Products and services

FY22
+27
+29

FY23 benchmark2
≥+24
≥+26

Differentiate our 
insurance business 

Market share3 – updated for FY23
Q3FY22
27.35% 
(+4bps since FY21)

FY25 aspiration
Up 25-75 bps 
on FY22

Health Insurance productivity delivered

FY22
c. $15m

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

Expand in health 

Health and wellbeing 

Medibank Health segment profit

Live Better Rewards 
participants
Preventative program 
participants4

FY22

FY25 target

c. 522k  > 800k 

FY22
$45.5m 

c. 10k  > 50k 

FY23-FY25 target
Average at least 15% p.a. organic segment 
profit growth 
Aim to invest $150 - $250m in total to grow 
Medibank Health inorganically as suitable 
opportunities arise over the next 3 years

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

2.   FY23 benchmark has been corrected from originally reported in operating and financial review in FY22 Appendix 4E and Financial Report issued  
on 18 August 2022 and includes the global average benchmark for Place to Work eNPS and the historical trend for Products and Services eNPS.

3.  APRA PHI quarterly data to March-22

4.   Includes total customers who have engaged with eitght preventative health programs (e.g. Better Knee, Better Me, Better Hip) and any new offerings 

developed

Annual Report 2022    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 2023, 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. 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

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 (including regulatory 
compliance) 

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

Mitigations

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

Material sustainability 
categories

Customer health 
Community health

Employeer health 
Environmental 
health 
Governace

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.

Governace

Governace

28    Medibank 

 
 
Risk

Mitigations

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

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.

Material sustainability 
categories

Governace

Governace

Customer health 
Community health

Customer 
health

Employee 
health

Community 
health 

Environmental 
health

Governance

For further information about our material categories please see our Sustainability Report 2022. 

This Operating and Financial Review is dated as at 18 August 2022.

Annual Report 2022    29 

 
 
 
Directors

 44%*

are women

11%*

were born 
overseas

100%*

identify primarily  
as Australian
(non-Aboriginal and  
Torres Strait Islander)

*Including CEO

Top L to R: Mike Wilkins, David Koczkar, Tracey Batten. Middle L to R: Anna Bligh, Gerard Dalbosco, Peter Everingham. 
Bottom L to R: David Fagan, Kathryn Fagg, Linda Bardo Nicholls.

Name and title

Biography

Mike Wilkins AO

Chair and Independent  
Non-executive Director

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

BCom, MBA, FAICD, FCA

Age: 65

Mike is the Chair (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: 49

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 financial 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 commercial businesses, sales and marketing and customer 
channels and served as a director of Jetstar Pacific (Vietnam), Jetstar Hong Kong and NewStar 
(Singapore) JV airlines.

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

30    Medibank 

 
Name and title

Biography

Dr Tracey Batten

Independent  
Non-executive Director

MBBS, MHA, MBA,  
FAICD, FRACMA

Age: 56

Tracey was appointed a director in August 2017. She is Chair of the People and Remuneration 
Committee and a member of the Risk Management Committee and the Nomination 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: 62

Gerard Dalbosco

Independent  
Non-executive Director

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

Age: 59

Peter Everingham

Independent 
Non-executive Director

BEc, MBA, GAICD

Age: 53

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 Risk Management 
Committee and the Investment and Capital 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 Chair of the Audit Committee and a member 
of the Risk Management Committee and the Nomination 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. 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 director and  
Co-Deputy Chair of the Committee for Melbourne.

Peter was appointed a director in March 2022. He is a member of the Audit Committee and the  
People and Remuneration Committee. 

Peter has over 25 years of corporate experience and is highly respected in the digital sector, having 
held senior executive roles in that sector for 18 years. His senior leadership experience includes  
key roles at companies with a strong consumer and technology focus.

Peter is currently a director of Super Retail Group Limited (since December 2017), the owner of  
several notable Australian brands including BCF, Macpac, Rebel and Supercheap Auto. He is also  
a director of WWF Australia. 

He was previously a director of iCar Asia Limited (July 2017 to May 2022), Managing Director of the 
international division of Seek Limited (and concurrently Chair of Seek’s subsidiary, Zhaopin), a director 
of ME Bank and IDP Education Ltd, and a senior executive for Yahoo! in Australia and Southeast Asia.  

Annual Report 2022    31 

Directors

Name and title

Biography

David Fagan

Independent 
Non-executive Director

LLB, LLM, GAICD

Age: 65

Kathryn Fagg AO

Independent 
Non-executive Director

FTSE, BE (Hons), MCom (Hons), 
Hon.DBus, Hon.DChemEng, 
GAICD

Age: 61

David was appointed a director in March 2014. He is Chair of the Risk Management Committee and  
a member of the Audit Committee and the Nomination Committee.

David was a commercial lawyer for over 40 years. 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.

Kathryn was appointed a director in March 2022. She is a member of the Audit Committee and  
the People and Remuneration Committee.  

Kathryn is a highly respected director and Chair with significant, wide-ranging senior commercial and 
operational experience. She is currently a director of National Australia Bank Ltd (since December 
2019), Djerriwarrh Investments Ltd (since May 2014) and she is the Chair of CSIRO. In the non-for-
profit sector, she is Chair of Watertrust Australia Ltd and Breast Cancer Network Australia, a director 
of The Myer Foundation, the Grattan Institute and the Champions of Change Coalition.

Kathryn was a non-executive director of Boral Limited from September 2014 to July 2021 
including as Chair from July 2018, a non-executive director of Incitec Pivot Limited from April 2014 
to December 2019, and a member of the board of the Reserve Bank of Australia from 2013  
to 2018. She is a former President of Chief Executive Women (CEW), a former Chair of Parks 
Victoria and the Melbourne Recital Centre and a former board member of the Australian Centre 
for Innovation, and has held senior executive roles at Linfox, Bluescope Steel and ANZ. 

Linda Bardo Nicholls 
AO

Linda was appointed a director in March 2014. She is Chair of the Investment and Capital 
Committee and a member of the Risk Management Committee and the Nomination Committee.

Independent  
Non-executive Director

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.

BA, MBA (Harvard), FAICD

Age: 74

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

Linda’s previous directorships include Japara Healthcare Limited as Chair (March 2014 to 
November 2021), Fairfax Media Limited and Sigma Pharmaceuticals Limited. 

Company Secretary

Name and title

Biography

Mei Ramsay

Group Executive –  
Legal, Governance  
& Compliance and  
Company Secretary

BA, LLB, LLM

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 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.

32    Medibank 

Executive 
Leadership  
Team

 25%*

are women

50%*

were born overseas

75%*

identify primarily as Australian 
(non-Aboriginal and Torres Strait Islander)

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.

*Including CEO

Name and title

Biography

Kylie Bishop 

Group Executive –  
People, Culture & 
Sustainability

Kylie has held the position of Group Executive – People, Culture & Sustainability (previously 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 across Medibank. This includes culture, talent and capability, performance and 
rewards, shared services, talent acquisition, diversity and inclusion, 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 and 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 2022    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.

Dr Andrew Wilson

Group Executive –  
CEO Amplar Health

Andrew was appointed Group Executive – CEO Health Services (now Amplar Health) 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 Medibank JV Pty Ltd, Myhealth Medical Group and Medinet Australia 
Pty Ltd. He is also a director of a joint venture between Medibank and specialists  
to develop a private hospital facility in Kew, Melbourne.

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 the CPS 510 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 40 to 41.

Annual Report 2022    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 2022
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.

 – Ensuring we don’t profit from COVID-19 by returning  

any permanent net claims savings via customer  
give backs and hardship policies.

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

 – Business continuity management.

 – Continuing to ensure safe workplaces and practices in 

our retail stores, offices and while delivering health care 
in customer homes and residential aged care facilities. 

•  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.

•  Setting environmental, social and governance (ESG) 

strategy, including net zero pathway.

•  Oversight of our people frameworks, ensuring we provide 
a safe environment for our people focused on health and 
wellbeing and diversity and inclusion.

•  Oversight of talent attraction, development and retention, 

including succession planning for the executive leadership team.

•  Review of remuneration framework and reward governance 
practices in preparation for the implementation of APRA 
Prudential Standard CPS 511 in FY24.

Structure and composition of the Board

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

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

The current Chair is Mike Wilkins AO, an independent non-
executive director who has served as Chair since October 
2020 and on the Board since May 2017. The current CEO is 
David Koczkar, who commenced in the role in 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 2022. Details of directors’ attendance at Board 
and committee meetings during the year ended 30 June 2022 are 
on page 49. The length of service of the non-executive directors 
ranges from four months to nine years and eight months.

Non-executive director tenure profile

Strategy and execution

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

>9 years 
(1 director)

•  Oversight of investments, partnerships and organic growth 

initiatives to support execution of the strategy.

6-9 years 
(2 directors)

•  Oversight of the group’s capital management policies and 
level of capital, including review and implementation of 
APRA’s new capital standards (expected to apply 1 July 2023).

<3 years
(3 directors)

3-6 years
(2 directors)

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

People, remuneration and culture

•  Oversight of Medibank’s 2030 Vision, values, strategy  

and culture. 

•  Oversight of new CEO transition and alignment of  

executive leadership team (ELT) roles.

•  Review of Board composition and consideration  

of succession planning, including selection of new  
non-executive directors.

36    Medibank 

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. It has determined that all non-
executive directors are independent in accordance with the 
principles outlined by the ASX Corporate Governance Council 
and APRA and as set out in Medibank’s Board Charter.

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. David Fagan 
and Linda Bardo Nicholls will retire and offer themselves for 
re-election at the upcoming AGM on 16 November 2022, while 
Kathryn Fagg and Peter Everingham will stand for election at 
the upcoming AGM, having been appointed on 31 March 2022. 
Further information about these directors is set out on pages 
30 to 32 of the Annual Report 2022, 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.

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 
Chair, 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 Chair, 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 directly accountable to the Board through the Chair, and 
advises the Board and the Chair 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.  

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. 

Annual Report 2022    37 

Corporate governance statement

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 Ms Kathryn Fagg and  
Mr Peter Everingham to the Board effective 31 March 2022. 
Ms Fagg and Mr Everingham have significant experience and 
a proven track record of delivery, and strengthen the Board’s 
collective skills and expertise.

Board skills matrix

Skills and experience

  Collective strength1

Strategy
Experience in developing and implementing 
organisational strategies, and appropriately 
challenging management on delivery of 
strategic objectives

Financial acumen and capital management
Strong financial acumen and proficiency 
in corporate finance and internal financial 
controls and/or experience in overseeing 
corporate funding, capital management and 
investments

Corporate transactions and major projects 
Experience in overseeing complex business 
transactions and major projects, including 
mergers and acquisitions (and integration  
of those acquisitions)

Risk and compliance management
Experience in establishing risk and 
compliance management frameworks, 
setting the risk appetite, and overseeing 
organisational risk culture

Governance 
Experience in establishing and overseeing 
operations in a complex regulated 
environment, and demonstrated commitment 
to the highest governance standards

Insurance and healthcare industry 
experience 
Experience in the insurance and/or  
healthcare industry 

Customer
Experience in developing product and/or 
customer management strategies, marketing 
and/or digitised customer initiatives

Moderate

Strong

Very Strong

Moderate

Strong

Very Strong

Moderate

Strong

Very Strong

Moderate

Strong

Very Strong

Moderate

Strong

Very Strong

Moderate

Strong

Very Strong

Moderate

Strong

Very Strong

38    Medibank 

Skills and experience

  Collective strength1

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

Government relations and public policy
Interacting with government and/or regulators 
and/or involvement in public policy decisions

Technology
Understanding technology and innovation 
(including associated risks), and experience 
with businesses that have developed and 
implemented technology based initiatives 
to enhance productivity and/or customer 
experiences

Moderate

Strong

Very Strong

Moderate

Strong

Very Strong

Moderate

Strong

Very Strong

1.   This represents the collective strength of the Board including David Koczkar, CEO.

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 2022. The number of 
meetings of each committee, and the individual attendance  
of their members, are provided on page 49. 

Board performance evaluation

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

In 2022, the Chair of the Nomination Committee led an 
internal Board evaluation by way of a detailed directors’ 
survey seeking feedback in the areas of the role of the 
Board, people on the Board, procedures and practices, and 
behaviours. The internal Board evaluation in 2022 followed the 
external Board evaluation that was undertaken in 2021.  

Following the survey, the Board discussed and evaluated 
the outcomes and committed to relevant action items.  The 
performance evaluation of the Board included assessment 
of the handling by committees of the issues and challenges 
which arose during the year.

The Chair continues to be responsible for the assessment 
of each individual non-executive director’s performance and 
contribution. The Chair met with each of the non- executive 
directors in 2022 to review their performance and professional 
development needs.

Annual Report 2022    39 

Corporate governance statement

Committee 
membership as at  
18 August 2022

Audit Committee1 

•  Gerard Dalbosco 

(Chair)

•  Peter Everingham

•  David Fagan

•  Kathryn Fagg

Composition

Key roles and responsibilities

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

•  Overseeing and reviewing the integrity of external 

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 internal control framework.

Risk Management 
Committee2 

•  David Fagan (Chair)

•  Tracey Batten

•  Anna Bligh

•  Gerard Dalbosco 

•  Linda Bardo Nicholls

•  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 chair must be an independent non-
executive director and must not be the 
chair of the Board (but the chair 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 Committee3

•  At least three members, all of whom are 

•  Assisting and advising the Board on capital and 

non-executive directors.

investment related matters.

•  Linda Bardo Nicholls 

•  The chair must be an independent non-

•  Overseeing the investment strategy and Capital 

(Chair)

•  Anna Bligh

•  Mike Wilkins

executive director, appointed by the Board.

Management Policy.

•  Monitoring the effectiveness of the investment 

process.

•  Authorising delegated investment decisions.

1.   Gerard Dalbosco was appointed Chair of the Audit Committee effective 18 November 2021, following Christine O’Reilly’s retirement from the Board.  
Peter Everingham and Kathryn Fagg were appointed members of the Audit Committee effective 31 March 2022. Mike Wilkins was a member of the  
Audit Committee during the period from 18 November 2021 until his retirement from the Committee effective 31 March 2022. 

2.   Anna Bligh was appointed to the Risk Management Committee effective 31 March 2022. Linda Bardo Nicholls was appointed to the Committee  
effective 1 June 2022. Christine O’Reilly was a member of the Committee until her retirement from the Board effective 18 November 2021.

3.   Linda Bardo Nicholls was appointed to the Investment and Capital Committee as Chair effective 1 June 2022. David Fagan was a member of the 

Committee until his retirement from the Committee effective 1 June 2022. Peter Hodgett was Chair of the Committee until his retirement effective  
18 November 2021.  

40    Medibank 

 
 
 
 
Composition

Key roles and responsibilities

Committee 
membership as at  
18 August 2022

People and 
Remuneration 
Committee4

•  Tracey Batten (Chair)

•  Peter Everingham

•  Kathryn Fagg

•  Mike Wilkins 

•  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 
Risk Management Committee.

•  The chair must be an independent non-

executive director, appointed by the Board.

•  Reviewing and overseeing people and 

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

•  Reviewing and making recommendations to 
the Board on the remuneration framework, 
policy and arrangements for the non-executive 
directors, CEO, ELT and certain nominated 
personnel.

•  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.

•  Director selection and appointment.

•  Director induction and professional development.

•  Board composition.

•  Board succession planning and renewal.

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

Nomination 
Committee5 

•  Mike Wilkins (Chair)

•  Tracey Batten

•  Gerard Dalbosco

•  David Fagan

•  At least three members, comprising the 
chair of the Board and the chair of each 
standing Board committee (unless the 
Board resolves otherwise).

•  All members of the committee must be 

independent directors.

•  The chair of the Board will be the chair of 

•  Linda Bardo Nicholls

the committee.

4.   Tracey Batten was appointed Chair of the People and Remuneration Committee effective 31 March 2022.  Peter Everingham and Kathryn Fagg were 
appointed to the Committee effective 31 March 2022. Linda Bardo Nicholls was Chair of the Committee until 31 March 2022, and a member of the 
Committee until her retirement from the Committee effective 1 June 2022.  Anna Bligh was a member of the Committee until her retirement from the 
Committee effective 31 March 2022.  

5.   Gerard Dalbosco was appointed to the Nomination Committee effective 18 November 2021. Tracey Batten was appointed to the Committee effective 31 
March 2022. Linda Bardo Nicholls was a member of the Committee until her retirement from the Committee effective 31 March 2022, and rejoined the 
Committee effective 1 June 2022.   

Executive Leadership Team

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 51.

The remuneration report from page 51 contains the 
performance measures applied to Executive KMP  
members and the process for the annual evaluation of  
their performance. The same process is also undertaken  

for the annual performance of each other ELT member.  
A performance evaluation was undertaken during 2022  
in accordance with that process for each ELT member.

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: Customer Obsessed; Show Heart; Brilliance Together; 
and Break Boundaries. 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 the 
Sustainability Report 2022. 

Annual Report 2022    41 

 
 
 
 
Corporate governance statement

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

Whistleblower 
Policy

Anti-Bribery 
and  
Corruption 
Policy

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.

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.  

42    Medibank 

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.

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).

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 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 & Sustainability 
team, the CEO, or via the 
Whistleblower Policy.

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

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.

Material incidents reported 
under the 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. 

Ethical conduct is also supported by a range of other 
corporate policies, including in the areas of 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 and inspiring our 
people to eat, move and feel good in a way that works for 
them. 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 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% women 
representation in the Group and senior executive population 
and on our Board. As at 30 June 2022, the actual representation 
across Group and senior executives was 44%.

In June 2022, 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 30 June 2022, the respective proportions of 
men and women on the Board, in senior executive positions 
and across the whole 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 (including Board)

Women

Men

Other

% Women

4

2

22

24

100

353

2,258

2,739 

5

6

24

30

115

292

578

0

0

0

0

1

1

8

1,019

10

44%

25%

48%

44%

46%

55%

79%

73%

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. 

Annual Report 2022    43 

Corporate governance statement

In 2021 the Board set measurable objectives for achieving diversity at Medibank, including gender diversity,  
and committed to reporting progress achieved against these in the 2022 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% 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.

As at June 2022, women represented 44% of Group and senior executive roles (down 
from 50% in FY21). Representation of women on the Medibank Board is still above 
target at 44% (including the CEO), aligned with FY21.

Women represented 53% of all manager roles (excluding Group and senior 
executives), up from 51% in FY21 and 79% of non-manager positions (compared to 
77% in FY21). This is largely driven by our Health Services and Homecare divisions 
(now Amplar Health) where women made up 87% of the non-manager workforce, 
compared to other Medibank divisions which sit at 63%. This is in line with the 
broader Australian health workforce, which is comprised of approximately 80% 
women1. 

In FY22, the number of employees identifying as Aboriginal and Torres Strait Islander 
in our annual engagement survey decreased to 25 people, which equates to 0.9% of 
survey respondents2 and 17 employees less than our target of 42 employees. This 
may be reflective of a reduction in overall participation in the survey. Engagement 
for this cohort was 8.1 which is above the Medibank average of 7.9 and above FY21’s 
result of 6.9.

Through the launch of our fifth Reconciliation Action Plan this year, we have set out 
our key focus areas from 2022 – 2024, including 16 new actions with deeper delivery 
accountability across the business. Cultural capability has been identified as a 
key priority and we are working on the development of a cultural responsiveness 
framework to provide practical and appropriate guidelines for the development and 
growth of cultural safety within Medibank, to be delivered by the end of this year.

In FY22, the number of employees identifying as having a disability in our 
annual engagement survey rose to 163 people, which equates to 5.9% of survey 
respondents2, an increase from 4% in FY21. Engagement for this cohort was 7.7, 
which is below the Medibank average of 7.9 and 0.1 lower than FY21’s result of 7.8.

We continued to focus on the inclusion of people with disabilities through the 
development of our second Accessibility and Inclusion Plan. It details our areas 
of focus for the next three years, including the creation of an inclusive, safe and 
disability confident workplace. As part of this focus, we launched our first disability 
awareness training module at the end of 2021. We are now working to include this 
training in our onboarding and annual compliance training programs.

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 person with a disability  
or chronic condition.

A significant proportion of our people have caring responsibilities; either elderly 
parents, or a family member with a disability or chronic condition (19.3%, as 
measured by our employee survey). In FY21 we began developing a targeted carers 
support package, including a carers support network. This year, we launched a 
carers information hub and piloted a carers support program with a small group  
of employees, which we will review in FY23 to determine its potential to scale to  
all employees.

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

2.  Based on employee engagement survey response rate of 76% (2,758) from 3,628 employees invited to participate.

44    Medibank 

For 2023, 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 2023 corporate governance statement:

 Medibank will remain committed to ensuring a 
representation of at least 40% women across 
our executive leadership and senior leadership 
populations, 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 to focus on increasing  
the representation and engagement of  
Aboriginal and Torres Strait Islander employees 
with a target set of at least 43 employees  
(approx. 1.6% of survey respondents) as  
self-reported in our annual engagement survey.

  Medibank will continue to focus on increasing 
the representation and engagement of  
employees with disability with a target set of 
at least 178 employees (approx. 6.5% of survey 
respondents) as self-reported in our annual 
engagement survey.

 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 
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 all 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. 

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 (Computershare) 
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. 
Unless a shareholder elects to receive information by post, 
Medibank and through its share registry, Computershare, 
communicate with shareholders 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 and the Credit Suisse Asia 
Pacific ESG Conference in October 2021, the Morgan Stanley 
Private Healthcare Forum in April 2022 and the Macquarie 
Australia Conference in May 2022.

Annual Report 2022    45 

 
    
  
 
 
    
  
  
 
     
 
  
 
    
  
  
 
     
  
 
Corporate governance statement

We generally communicate with the investment community 
through the CEO, the Group Executive – CFO & Group 
Strategy and the Senior Executive – Investor Relations. 
We also communicate through the Chair for governance 
and remuneration issues and the Company Secretary and 
Group Executive – People, Culture & Sustainability for 
environmental, social and governance issues. Feedback from 
engagement with the investor community is communicated to 
the Board at each Board meeting.

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.

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.  In 2022 and subject 
to any COVID-19 related restrictions at that time, investors 
will be able to attend the meeting in person at an accessible 
venue in Melbourne, or virtually, with the ability to vote and 
ask questions at the venue or online; the meeting will also 
be webcast live and made available on our website. All 
substantive resolutions at the meeting are decided by a poll 
and not by a show of hands.

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 40. In addition to the members of the 
Audit Committee, any director may attend 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 
2021 and the full year ended 30 June 2022.

Internal audit

Medibank has an internal audit function that provides the 
Board and Audit Committee with an independent evaluation 
of the adequacy and the effectiveness of Medibank’s financial 
and risk management framework. The 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 
Chair, with a direct communication line to the CEO and 
administrative reporting line to the CFO. 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 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. The framework is 

46    Medibank 

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 CPS 
220. The annual review of the framework was completed 
in 2022, with the three yearly comprehensive review having 
been undertaken 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 2022. 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 the 
environment, social and governance (ESG) risks (including 
climate risk). Medibank’s material ESG topics, as identified 
in our social and governance framework, have been mapped 
to our material risks in the operating and financial review on 
pages 28 to 29 of the Annual Report 2022. 

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 pages 53 to 59 of the Sustainability Report 2022. 
Further detail on Medibank’s approach to sustainability and 
ESG issues can also be found in the Sustainability Report 2022.  

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 
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. Information about the committee’s membership 
can be found on page 40; 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 51 to 72.

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 18 August 2022 and has been approved by the Board.

Annual Report 2022    47 

Directors’ report
For the financial year ended 30 June 2022

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 2022.

References to 2021 and 2022 are to the financial years  
ended on 30 June 2021 and 30 June 2022 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 – Chair

•  David Koczkar – Chief Executive Officer 

•  Dr Tracey Batten

•  Anna Bligh AC

•  Gerard Dalbosco 

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

•  Peter Everingham (appointed effective 31 March 2022)

•  David Fagan

•  Kathryn Fagg AO (appointed effective 31 March 2022)

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:

•  Linda Bardo Nicholls AO

Former:

•  Peter Hodgett (retired effective 18 November 2021)

•  Christine O’Reilly (retired effective 18 November 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 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.

•  A fully franked final ordinary dividend of 6.90 cents 

per share was determined in respect of the six-month 
period to 30 June 2021, payable on 30 September 2021  
to shareholders registered on 9 September 2021.

•  A fully franked interim ordinary dividend of 6.10 cents  
per share was determined in respect of the six-month 
period to 31 December 2021 and paid on 24 March 2022  
to shareholders registered on 7 March 2022.

•  A fully franked final ordinary dividend of 7.30 cents per 
share has been determined in respect of the six-month 
period to 30 June 2022, payable on 29 September 2022  
to shareholders registered on 8 September 2022.

Directors’ qualifications, experience 
and special responsibilities

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

48    Medibank 

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. All directors may attend committee meetings even if they are not a member of the relevant committee. The 
table below does not include the attendance of directors at committee meetings where they were not a committee member.

Board 
(scheduled) 
11

Board 
(unscheduled) 
2

Audit 
Committee 
4

Risk 
Management 
Committee 
6

Investment 
and Capital 
Committee 
4

People and 
Remuneration 
Committee 
4

Nomination 
Committee 
4

A
11
11
11
11
3
11
3
5
11
11
5

B
11
11
11
11
3
11
3
5
11
10
5

A
2
2
2
2
2
2
2
0
2
2
0

B
2
2
2
2
2
2
2
0
2
1
0

A
2
-
-
4
1
3
1
1
-
-
1

B
2
-
-
4
1
3
1
1
-
-
1

A
-
6
1
6
-
6
-
-
-
-
3

B
-
6
1
6
-
6
-
-
-
-
3

A
4
-
4
-
-
4
-
2
-
-
-

B
4
-
4
-
-
4
-
2
-
-
-

A
4
4
3
-
1
-
1
-
-
3
-

B
4
4
3
-
1
-
1
-
-
3
-

A
4
1
-
3
-
4
-
1
-
4
1

B
4
1
-
3
-
4
-
1
-
4
1

Director

Mike Wilkins1
Dr Tracey Batten2
Anna Bligh3
Gerard Dalbosco4
Peter Everingham5
David Fagan6
Kathryn Fagg7
Peter Hodgett8
David Koczkar
Linda Bardo Nicholls9
Christine O’Reilly10

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 time the director held office or was a member of the committee during the year.
1 
2   Tracey Batten was appointed a member of the Nomination Committee effective 31 March 2022. 
3     Anna Bligh was appointed a member of the Risk Management Committee effective 31 March 2022 and retired as a member of the People and 

 Mike Wilkins was appointed a member of the Audit Committee effective 18 November 2021 and retired as a member of that committee effective 31 March 2022.

Remuneration Committee effective 31 March 2022.

4   Gerard Dalbosco was appointed a member of the Nomination Committee effective 18 November 2021.
5   Peter Everingham was appointed as a director and a member of the Audit Committee and People and Remuneration Committee effective 31 March 2022.
6     David Fagan was appointed a member of the Audit Committee effective 18 November 2021 and retired as a member of the Investment and Capital 

Committee effective 1 June 2022.

7   Kathryn Fagg was appointed as a director and a member of the Audit Committee and People and Remuneration Committee effective 31 March 2022.
8   Peter Hodgett retired as a director effective 18 November 2021.
9     Linda Bardo Nicholls was appointed a member of the Risk Management Committee and the Investment and Capital Committee effective 1 June 2022, 

retired as a member of the People and Remuneration Committee effective 1 June 2022 and retired as a member of the Nomination Committee effective  
31 March 2022 and was re-appointed as a member of the Nomination Committee effective 1 June 2022.

10  Christine O’Reilly retired as a director effective 18 November 2021.

In addition, ad-hoc committees were convened for special 
purposes, including in relation to financial reporting 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, 3,542,600 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, 825,420 performance rights became 
eligible to vest and were exercised. Further information 
regarding performance rights is included in the remuneration 
report from page 51.

Director
Mike Wilkins
David Koczkar
Dr Tracey Batten
Anna Bligh
Gerard Dalbosco
Peter Everingham
David Fagan
Kathryn Fagg
Peter Hodgett*
Linda Bardo Nicholls
Christine O’Reilly*

Performance 
rights

1,208,604

Ordinary 
shares
100,000
858,734
50,000
44,623
72,832
40,000
47,016
32,750
67,800
45,000
69,930

*  Peter Hodgett and Christine O’Reilly retired from the Board effective  
18 November 2021, and their ordinary shareholding information is as  
at that date.

Annual Report 2022    49 

Directors’ report
For the financial year ended 30 June 2022

Environmental regulation

Non-audit services

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.

Auditor’s independence declaration

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 121. 

During the year, PwC, the Group’s external auditor, performed 
certain other services to the Group in addition to its statutory 
responsibilities as auditor. Details of the amounts paid or 
payable to PwC for non-audit services provided by it during 
the year are set out in Note 19 Auditor’s remuneration.

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 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 51 to 72 forms part  
of the directors’ report.

Rounding of amounts

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 

18 August 2022 
Melbourne

David Koczkar 
Chief Executive Officer

50    Medibank 

 
 
 
Remuneration report
For the financial year ended 30 June 2022

Contents

1. 

 Key management personnel overview

2. 

 Summary of remuneration outcomes

3. 

 Medibank’s remuneration strategy

4. 

5. 

6. 

7. 

 Remuneration governance
 4.1  The role of the 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 KMP remuneration components
 6.1   2022 target remuneration mix
 6.2   Total fixed remuneration (TFR)
 6.3   Short-term incentive (STI)
 6.4   Long-term incentive (LTI)

 Linking remuneration and performance in 2022
 7.1   2022 short-term incentive (STI) performance scorecard
 7.2   Medibank’s 2022 financial performance
 7.3   2022 STI awards
 7.4   2020 long-term incentive plan outcomes

8. 

 2022 actual remuneration (Non-IFRS disclosure)

9. 

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

10.  Executive KMP equity awards

 10.1  Executive KMP equity award transactions
 10.2   Overview of unvested equity awards and fair value 

assumptions

11.   Non-executive director remuneration and framework

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

12.   2022 non-executive director remuneration statutory 

table

13.  Non-executive director ordinary shareholdings

14.  Medibank’s comparator group

Annual Report 2022    51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Remuneration report
For the financial year ended 30 June 2022

On behalf of the Board, I am pleased to present Medibank’s 
remuneration report for 2022 which describes how non-
executive directors and Executive Key Management Personnel 
(Executive KMP) are paid. Included in this report are the fixed 
and variable remuneration outcomes for Executive KMP, 
which were determined after considering the Company’s 
results and their individual performance. 

Our remuneration strategy has been developed to ensure 
remuneration is fair and competitive. During 2022 the 
Board continued to focus on a framework that rewards 
responsible behaviours, aligns remuneration with 
performance outcomes and regulatory requirements, 
and has regard for the expectations of our customers, 
shareholders and the community. 

As a health company working to create Better Health for 
Better Lives by providing the best health and wellbeing 
experience for people across Australia, the Board is proud 
of how Medibank has continued to support our customers, 
employees and the broader community.

Despite the challenging environment over the last year, 
Medibank has delivered a strong result. As part of the 
standing commitment to not profit from COVID-19, the 
company continued to support customers and returned 
$369.4 million of permanent net claims savings during the 
year. Our business performance was driven by continued 
policyholder growth, ongoing cost control, momentum in our 
Medibank Health businesses and an uplift in contributions 
from our healthcare investments, all of which helped deliver 
strong growth in Group operating profit.

Changes to key management personnel

As stated last year, following the changes to Medibank’s 
Executive Leadership Team (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 are 
the CEO, Group Executive – CFO & Group Strategy, Group 
Executive – CEO Amplar Health and Group Executive – 
Customer Portfolios.

Changes to the Board

During September 2021 Medibank announced that non-
executive directors Christine O’Reilly and Peter Hodgett 
would not stand for re-election and would retire from the 
Board at the conclusion of the Annual General Meeting 
on the 18 November 2021. Both directors joined prior to 
Medibank’s public listing in 2014 and played a critical role  
in Medibank’s transformation over the past eight years  
into a health company.

Following the retirements of Peter and Christine, Medibank 
announced in February 2022 the appointment of Kathryn 
Fagg AO and Peter Everingham as non-executive directors 
effective 31 March 2022. Kathryn is a highly respected director 
and chair with significant, wide-ranging senior commercial 
and operational experience. Peter brings deep corporate and 
strategy experience, particularly as an executive in the digital 
and consumer sectors. As Medibank continues to grow and 
increase its focus on delivering for our customers, the Board 
is pleased to be able to appoint two new directors with such 
extensive experience and proven track records.  

Remuneration decisions at a glance

•  All Executive KMP met their individual risk, compliance  

and behaviour gateways for 2022.

•  Discretion was exercised to reduce short-term incentive 

(STI) outcomes to Executive KMP members from an average 
of 84% to 72% of their maximum opportunity considering 
the challenging social and economic environment and 
the expectations of our shareholders, customers and the 
broader community.

•  The final vesting outcome for the FY20 long-term incentive 
(LTI) is pending the release of market share data by APRA, 
however there will be partial vesting in accordance with 
the plan rules against the total shareholder return (TSR) 
performance hurdle.  

•  Fixed remuneration for Executive KMP increased by an 

average of 3.7% for 2023.

•  Non-executive director aggregate fees have been  
increased by 3% for 2023 and remain below the  
approved total fee pool of $2,300,000.

52    Medibank 

The new APRA regulatory standard on remuneration 
(CPS511) comes into effect on 1 July 2023 for private health 
insurers. Medibank has begun a conversation with APRA 
and determined that changes will be required to increase 
incentive deferral, enhance the use of non-financial 
performance measures and strengthen our clawback and 
malus policy to satisfy the new requirements. The Board will 
consider enhancements to the remuneration framework 
during 2023 to ensure that it remains competitive whilst 
meeting regulatory obligations.

Short-term incentives

Medibank delivered another strong result driven by continued 
policyholder growth, double-digit growth in Medibank Health 
and remaining disciplined in how we grow and run our 
business. Consistent with prior years, the Board adjusted 
outcomes to normalise for COVID-19 related impacts (both 
negative and positive) to ensure that executives are rewarded 
fairly for their efforts. Following this assessment, Group 
operating profit exceeded target, whilst Health Insurance 
revenue growth and Customer Net Promoter Score (cNPS) 
exceeded stretch expectations. 

With consideration of the challenging social and economic 
environment and the expectations of our shareholders, 
customers and the broader community, the Board exercised 
its discretion to reduce Executive KMP incentive outcomes 
from 84% to 72% of their maximum opportunity.

Long-term incentives

Testing of the performance hurdles associated with 
Medibank’s FY20 long-term incentive (LTI) plan is partially 
complete and will be finalised following the release of market 
share data. 

Following the three-year performance period which 
concluded on 30 June 2022 both the earnings per share 
(EPS) and total shareholder return (TSR) hurdles were tested, 
with no vesting against the EPS measure and partial vesting 
against the TSR measure with a performance rank at the 
53rd percentile against our comparator group. Performance 
against the market share hurdle will be tested following the 
release of June market share data by APRA in late August 
2022. Final FY20 LTI vesting results will be mentioned at the 
2022 Annual General Meeting (AGM) and included in the 2023 
remuneration report.

Executive KMP remuneration and non-executive 
director fees

Following a review of fixed remuneration levels of Executive 
KMP members against the median of Medibank’s market 
comparator group, the fixed remuneration of Executive KMP 
was increased by an average of 3.7%, effective 1 July 2022. 
This includes a remuneration increase for the Chief Executive 
Officer (CEO), David Koczkar of 3.3%.

Board and committee fees were also reviewed against the 
median of Medibank’s market comparator group with a 3% 
increase in Board and Committee fees agreed. These changes 
are the first in three years, and the aggregate fee spend for 
non-executive directors remains below the total fee pool of 
$2,300,000 approved by shareholders in the annual general 
meeting in 2018. 

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

Yours sincerely,

Dr Tracey Batten 
Chair, People and Remuneration Committee

Annual Report 2022    53 

Remuneration report
For the financial year ended 30 June 2022

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 2022, KMP were as follows: 

Key management personnel

David Koczkar 
Chief Executive Officer 
Full-year

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

Non-executive directors

Mike Wilkins 
Chair 
Full-year

Tracey Batten 
Non-executive director 
Full-year

Anna Bligh 
Non-executive director 
Full-year

Gerard Dalbosco 
Non-executive director 
Full-year

Milosh Milisavljevic 
Group Executive  
– Customer Portfolios 
Full-year

Andrew Wilson 
Group Executive –  
CEO Amplar Health 
Full-year

Peter Everingham 
Non-executive director 
From 31 March 2022

David Fagan 
Non-executive director 
Full-year

Kathryn Fagg 
Non-executive director 
From 31 March 2022

Linda Bardo Nicholls 
Non-executive director 
Full-year

Peter Hodgett 
Non-executive director 
Retired 18 November 2021

Christine O'Reilly 
Non-executive director 
Retired 18 November 2021

Former KMP

54    Medibank 

2. Summary of remuneration outcomes

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

Executive key management personnel

Fixed 
remuneration 

•  Fixed remuneration for Executive KMP including the CEO increased by an average of 3.7% effective  

1 July 2022.

•  Fixed remuneration of the Chief Executive Officer (CEO), David Koczkar was increased by 3.3%  

to $1,550,000, effective 1 July 2022.

Short-term 
incentive  
(STI)

•  STI awards for Executive KMP reflected Group operating profit exceeding target expectations and 
both Health Insurance revenue growth and Customer Net Promoter Score (cNPS) performance 
exceeding stretch expectations. 

•  Discretion was exercised by the Board to reduce the 2022 STI outcomes for Executive KMP from  

an average of 84% of their maximum opportunity to 72%. 

•  50% of STI awards for Executive KMP are deferred for 12 months in the form of performance rights. 

•  STI target percentages for Executive KMP members, including the CEO, have been maintained at 

current levels. 

Long-term 
incentive  
(LTI)

•  Testing of the performance hurdles associated with Medibank’s FY20 long-term incentive (LTI) Plan 
is partially complete and will be finalised following the release of market share data by APRA in late 
August 2022.

•  There was no vesting against the EPS CAGR measure and partial vesting against the relative TSR 

measure, with a performance rank at the 53rd percentile against our comparator group.

•  Performance against the market share hurdle will be tested following the release of June market 

share data by APRA in late August 2022.

•  LTI opportunity percentages for Executive KMP members, including the CEO, have been maintained 

at current levels.  

Non-executive directors

Non-executive 
director fees

•  The annual base fee for the Chair was increased by 3% to $458,500, and the annual base fee for other 

non-executive directors was increased by 3% to $170,000, both effective 1 July 2022.

•  Committee chair fees and committee membership fees were increased by 3% effective 1 July 2022  

to $41,200 and $20,600 respectively. 

•  The aggregate non-executive director fee spend remains below the approved total fee pool of 

$2,300,000.

Annual Report 2022    55 

Remuneration report
For the financial year ended 30 June 2022

3. Medibank’s remuneration strategy 

At Medibank, we believe that remuneration has a key 
influence on behaviour and is a valuable 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 
purpose, our people and customers and our performance. 
 We focus on our values every day to ensure we do the right 
thing by our customers, our people and the community. 

Our remuneration strategy has been developed to focus  
our people 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 2022 remuneration is delivered.

 Medibank’s remuneration strategy

Focus employees on responsibly executing Group strategy to increase customer and shareholder value 
with behaviours aligned to 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 employees for the 
achievement of business 
outcomes aligned with 
Medibank’s culture

Align the interests of 
executives 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

•  Customer Net Promoter Score (cNPS)

•  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

2022 remuneration timeline

FY22

FY23

FY24

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

56    Medibank 

 
 
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 & Sustainability  
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 49 of the directors’ report.

4.2.1 Performance evaluation of Executive KMP members

At the outset of each performance year, the Board determines 
the measures against which Executive KMP will be assessed. 
The measures are a combination of Medibank (Company) 
and role-specific (individual) performance measures that 
are aligned to the achievement of Medibank’s customer 
and financial milestones set out in the Annual Report 2022. 
Aligned with Medibank’s Group-wide performance framework ‘I 
Perform Better’, the role-specific measures for Executive KMP 
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 Executive KMP then form the basis 
for the Big Goals adopted by their leadership team members 
and respective teams to ensure all employees across the 
Group are working towards a shared and consistent strategy. 

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

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 Executive KMP is outlined in section 6.2.

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

Ensuring that Medibank’s 
performance and 
remuneration practices 
are consistent with the 
risk management 
framework and drive 
appropriate behaviours 
and a values-based 
culture

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, 
workplace relations and 
payroll integrity

Independent remuneration 
consultant

• Ernst & Young provides  

information to assist the P&RC 
in making remuneration 
decisions and 
recommendations to the Board

•  The work undertaken by Ernst 

& Young in 2022 did not 
constitute a remuneration 
recommendation

Annual Report 2022    57 

Remuneration report
For the financial year ended 30 June 2022

The CEO provides his performance assessment of each 
Executive KMP, and other ELT members, to the Board for 
consideration. The Chair, 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's performance, customer 
outcomes, community and shareholder expectations.

4.2.2 Clawback and malus 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 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.

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.

While clawback provisions allow an organisation to recover a 
performance-based award after it has been paid out (or share 
awards vested), malus provisions allow the organisation to 
reduce or cancel the award before it has been paid out. 

4.2.3 Executive shareholding requirements

Executive KMP 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 Executive Leadership Team. The policy does not require a 
person 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 person (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.

As at 30 June 2022, progress towards the minimum 
shareholding requirement for each Executive KMP is 
provided below:

Executive KMP

David Koczkar
Milosh Milisavljevic
Mark Rogers
Andrew Wilson

Minimum 
shareholding 
requirement $1

Value of eligible 
shareholdings as 
at 30 June 2022 $2

1,500,000
780,000
1,000,000
1,000,000

2,790,886
78,384
1,275,154
3,234,137

Minimum 
shareholding 
requirement timeline

Requirement satisfied
22 June 2026
Requirement satisfied
Requirement satisfied

1.  Minimum shareholding requirement based on each persons’ total fixed remuneration (TFR) as at 30 June 2022.

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

price of Medibank’s shares on 30 June 2022 ($3.25).

4.2.4 Share Trading Policy

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.

In addition, non-executive directors, all senior executives  
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. 

58    Medibank 

4.2.5 Termination provisions in Executive KMP 
contracts

All current Executive KMP are employed under ongoing 
contracts with notice periods set at 3 months (employee) and 
6 months (employer), or in the case of the CEO, 6 months 
(both employee and employer). Termination provisions 
included in Executive KMP contracts are limited to 6 months 
payment of fixed remuneration, in lieu of notice. 

If an Executive KMP 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.

Medibank risk culture framework

Decision making 
and challenge

Communication 
and escalation   

Leadership

e

Risk b

h a v iours in a

c

t
i

o

Alignment 
with purpose 
and values

R

i

s

k

a

r

c

hitecture  a n d   f o

Performance 
management 
and incentives

n

n

u ndatio

Knowledge 
and capabilities

Risk appetite 
and strategy

5. Risk and remuneration

A key focus for Medibank’s Board and the 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.

5.1 Risk culture

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. We recently 
updated our risk culture framework, and our current suite of 
measurements (behavioural metrics and survey responses) 
fully align with the framework elements and risk behaviours to 
ensure they provide the right insights and conditions for positive 
action. The risk culture framework, outlined below, articulates 
the key elements that influence and shape our risk culture in 
terms of behaviours and practices.

Our risk culture framework 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 
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

Responsibility 
and accountability

Risk governance 
and oversight

Annual Report 2022    59 

 
Remuneration report
For the financial year ended 30 June 2022

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 five-point rating 
scale (with a minimum rating of three 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 & Sustainability 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 Executive KMP (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 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 the performance period 
and potential termination.

In 2022, 5 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 4 individuals in 2022 
had their employment terminated following an incident of 
misconduct. Further details on consequence management 
can be found in our Sustainability Report 2022.

6. Executive KMP remuneration components

Target remuneration for Executive KMP 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 2022 target remuneration mix

The 2022 target remuneration mix for Medibank’s KMP is 
shown below. 

David 
Koczkar

Milosh 
Milisavljevic

Mark 
Rogers

Andrew 
Wilson

28.6%

14.3% 14.3%

42.9%

43.5%

14.1% 14.1%

28.3%

43.5%

14.1% 14.1%

28.3%

43.5%

14.1% 14.1%

28.3%

Fixed

STI cash

Deferred 
STI (equity)

LTI 
(equity)

60    Medibank 

6.2 Total fixed remuneration (TFR)

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

Total fixed remuneration (TFR) 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. The table 
below outlines the current TFR settings for Executive KMP. 

6.2.1 Total fixed remuneration

Executive KMP
David Koczkar
Milosh Milisavljevic
Mark Rogers
Andrew Wilson

30 June 2022 $
1,500,000
780,000
1,000,000
1,000,000

1 July 2022 $
1,550,000
825,000
1,035,000
1,020,000

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 executive, the following 
gateways must be achieved:

Risk, compliance and behaviour gateway

Individually assessed, the risk, compliance and behaviour 
gateway requires executives 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.

•  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.

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 & Sustainability and Group 
Executive – Legal, Governance & Compliance as outlined in 
section 5.2.

Financial gateway

•  Assessed at the Group level, Medibank must achieve  
a baseline Group operating profit target for an STI to  
be awarded.

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, executives are then assessed against the company 
and role-specific performance measures to determine STI 
award outcomes. There is a threshold level of performance for 
each Medibank and role-specific measure as set by the Board 
that needs to be achieved for an STI award to be paid (for that 
element of the award). For an executive 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 executive 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 behaviours aligned with Medibank’s 
values and purpose. This would represent exceptional 
performance, well above that of Medibank’s strategic plan.

Annual Report 2022    61 

Remuneration report
For the financial year ended 30 June 2022

 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 Executive KMP 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 Executive KMP is divided by the volume weighted average share price (VWAP) of 
Medibank shares to determine the number of units granted. 

For the 2022 deferred STI component the VWAP will be calculated on the 10 trading days  
up to and including 15 September 2022.

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

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. 

What gateways apply to the 
STI plan?

For an STI award to be made to Executive KMP, 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.

What are the performance 
measures under the  
STI plan?

Performance measures under the STI plan are determined by the Board at the 
commencement of each performance period. For 2022, the performance measures were:

•  Group operating profit (excluding investment income).

•  Health Insurance premium revenue growth.

•  Customer Net Promoter Score (cNPS).

•  Role-specific metrics.

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 2022. Actual target values are not disclosed as this is considered 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 
Executive KMP 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 executive 
leaves Medibank?

If an executive 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.

62    Medibank 

6.3.4 Annual STI opportunity

The target and maximum annual STI opportunity as a percentage of total fixed 
remuneration for each Executive KMP is outlined in the table below.

Executive KMP

David Koczkar
Milosh Milisavljevic
Mark Rogers
Andrew Wilson

2022 & 2023

Target

Maximum

100%
65%
65%
65%

150%
100%
120%
120%

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 executives 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 executives over the three-year deferral 

period.

What is the performance 
period for 2022 LTI plan?

The performance period for the 2022 LTI plan is three financial years commencing 1 July 
2021. 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 executives 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 executive 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 participant 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 2022 LTI plan, the number of performance rights granted to each participant 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 2021. This average price was $3.13.

What gateways apply to the 
LTI plan?

Each participant must meet the risk, compliance and behaviour gateway prior to being 
granted LTI. Further detail on this gateway is outlined in section 6.3.1.

Annual Report 2022    63 

Remuneration report
For the financial year ended 30 June 2022

What are the performance 
hurdles under the 2022  
LTI plan?

Performance rights issued under the 2022 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 2021 and the performance period for the EPS performance hurdle will run for  
3 years from 1 July 2021 through to 30 June 2024. 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 2022 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 
executive 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 a participant 
leaves Medibank?

If a participant 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. 

In what circumstances  
are LTI entitlements 
forfeited?

LTI entitlements are forfeited if performance hurdles are not met. In the event a participant 
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.

64    Medibank 

The annual LTI allocation value as a percentage of TFR for 
each Executive KMP is outlined in the table below. 

at the end of the performance period, as set out in the 
following vesting schedule:

6.4.2 Annual LTI allocation

Executive KMP

LTI allocation value as % of TFR

2022 & 2023

David Koczkar
Milosh Milisavljevic
Mark Rogers
Andrew Wilson

150%
65%
65%
65%

6.4.3 LTI hurdles explained

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 2022 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.

2022 EPS performance rights (35% of award)

In this context, the Board approved maintaining a threshold 
EPS CAGR target of 3% for the 2022 LTI grant and 
maintaining the vesting schedule that applied to the 2021 
LTI offer. 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
Between 3% and 7% EPS 
CAGR
7% EPS CAGR or greater

Nil
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.

2022 TSR performance rights (35% of award)

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 2022 TSR performance rights to vest, Medibank must 
achieve the threshold TSR ranking over the performance 
period. The percentage of the 2022 TSR performance rights 
that vest, if any, will be based on Medibank’s TSR ranking

Medibank’s TSR rank in the 
2022 comparator group

Percentage of TSR 
performance rights that vest

Less than 50th percentile
Between the 50th and 75th 
percentile
At or above 75th percentile

Nil
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 2022 comparator group are 
determined at the commencement of the performance 
period. If the ordinary shares or stock of a member of the 
2022 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.

2022 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.  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
Between 25 basis points 75 
basis points
At or above 75 basis points

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

Annual Report 2022    65 

 
 
Remuneration report
For the financial year ended 30 June 2022

7. Linking remuneration and performance in 2022
7.1 2022 short-term incentive (STI) performance scorecard

The following table details the 2022 STI performance scorecard measures, weightings and assessment.

Measure

Description

Individually assessed, Executive KMP 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 Officer, Group Executive 
– People, Culture & Sustainability and Group Executive – 
Legal, Governance & Compliance as outlined in section 5.2.

Medibank must achieve a baseline of financial performance, 
as determined by the Board for the performance period. 
In 2022, this baseline financial performance was a Group 
operating profit target.

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.

Risk,  
compliance 
and behaviour 
gateway

Financial 
gateway

Group 
operating  
profit

Weighting

GE-CEO 
Amplar 
Health

Other 
Executive 
KMP

2022 
Outcomes

CEO

Gateway Gateway Gateway All achieved

Gateway Gateway Gateway

Met

45%

22.5%

35%

Above target

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.

Customer Net 
Promoter  
Score (cNPS)

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

20%

15%

25%

20%

12.5%

20%

Above 
stretch

Above 
stretch

Aligned to one or more of the following milestones:

1.  Deliver leading experiences – Continue to achieve a high 
level of advocacy by delivering exceptional experiences 
for our customers and employees.

2.  Differentiate our insurance business – we aim to 

increase market share, achieve net policyholder growth of 
3.1% to 3.3% (including continued growth in the Medibank 
brand) and to deliver FY22 productivity target of $15 
million (plus an additional $25 million during FY23-FY24)

3.  Expand in health – replace the reported FY18 $30 

million operating profit of Garrison and achieve 480,000 
customers engaged with Live Better

Role-specific  
big goals

66    Medibank 

15%

50%

20%

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

7.2 Medibank’s 2022 financial performance

Medibank’s 2022 annual financial performance is provided in the table below in addition to the average 2022 STI award achieved 
by Executive KMP, as a percentage of maximum opportunity. This table illustrates the relationship between the key indicators of 
shareholder wealth creation and STI outcomes for Executive KMP.

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 Executive KMP STI as a percentage 
of maximum opportunity

2022
2.7%
$594.1m
$393.9m
13.4 cents p/s
$3.16
$3.25

2021
2.1%
$528.3m
$441.3m
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

72%

70%

0%

56%

58%

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

7.3 2022 STI awards

The table below provides a summary of STI awards for the 2022 performance year. 

Executive KMP
David Koczkar
Milosh Milisavljevic
Mark Rogers
Andrew Wilson

Total STI 
achieved $
1,722,456
604,826
844,084
769,912

STI cash  
(50%) $
861,228
302,413
422,042
384,956

STI deferred 
(50%) $
861,228
302,413
422,042
384,956

Total STI 
achieved as  
% of target
115%
119%
130%
118%

Total STI 
achieved as % of 
max opportunity
77%
78%
70%
64%

7.4 2020 Long-term incentive plan outcomes

The performance period for the 2020 LTI plan concluded on 30 June 2022. The table below outlines the final outcome against 
the EPS CAGR and Relative TSR (expressed as a compound annual rate of return) performance hurdles and associated vesting 
percentage for each. Testing of the market share performance hurdle will be completed following the release of market share 
information by APRA.  

Performance hurdle
EPS CAGR
Relative TSR
Market Share
Total 2020 LTI vesting percentage

Weighting
35%
35%
30%

Outcome
0.2%
53rd percentile
Pending1

Vesting percentage
0%
56%
Pending
Pending

1.  To be confirmed following the release of APRA market share data in late August 2022 

Medibank’s 2020 LTI was tested following the completion of the performance period on 30 June 2022. EPS CAGR and Relative 
TSR hurdles were assessed in line with the terms of the plan and the Board did not exercise discretion in determining the 
outcome. The total number of rights vesting will be confirmed once testing against the market share hurdle is completed. The 
performance rights under the 2020 LTI Plan that do not vest as a result of the performance hurdle outcomes not being met will 
lapse immediately.

The 2021 and 2022 LTI plans remain in restriction and will be assessed against their performance hurdles at the completion of 
the 2023 and 2024 financial years respectively.

Annual Report 2022    67 

Remuneration report
For the financial year ended 30 June 2022

8. 2022 actual remuneration (Non-IFRS disclosure)

The table below represents the 2022 ‘actual’ remuneration for Executive KMP and includes all cash payments made in relation 
to 2022, in addition to deferred short-term incentive (STI) awards that vested in 2022.

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 for Executive KMP is presented in section 9.

Base 
salary and 
superannuation 
$  
1,500,000
778,825
1,000,000
999,846

Cash STI for 
performance 
to 30 June 
2022 
$
861,228
302,413
422,042
384,956

Total cash 
payments 
in relation 
to 2022 
$
2,361,228
1,081,238
1,422,042
1,384,802

Deferred 
equity awards 
that vested in 
20221  
$
229,609
34,065
172,352
242,225

Total 
2022 actual 
remuneration 
$
2,590,837
1,115,303
1,594,394
1,627,027

Equity awards 
that lapsed in 
20222 
$
487,913
72,379
366,241
514,720

Executive KMP
David Koczkar
Milosh Milisavljevic
Mark Rogers
Andrew Wilson

1.  Deferred equity awards that vested in 2022 relate to the 2019 LTI performance rights that vested during the year. 

2.   Equity awards that lapsed in 2022 relate to the portion of the 2019 long-term incentive (LTI) performance rights that lapsed following the testing  

of the performance hurdles in July 2021.

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 Executive KMP. In contrast to the table in section 8 that details 2022 
actual remuneration, the table below includes accrual amounts for equity awards being expensed throughout 2022 that are yet 
to, and may never, be realised.

Short-term 
benefits

Post-employment 
benefits

Long-term  
benefits

Equity-based 
benefits

Other

Short-term 
incentive 

(STI) $ Other $

Non-monetary 
benefits  
$2

Superannuation  
$

Leave  
$3

Deferred 
STI  
$

Performance 
rights  
$4

Termination 
benefits  
$

Total 
remuneration 
$

Executive 
KMP

Financial 
year

Salary  
$1

David  
Koczkar

Milosh 
Milisavljevic5

Mark  
Rogers

Andrew 
Wilson

2022

2021

2022

2021

2022

2021

2022

2021

1,523,622

1,027,440

754,326

21,818

980,097

882,649

971,537

963,798

Former Executive KMP

861,228

364,896

302,413

4,772

422,042

335,405

384,956

331,296

Craig 
Drummond

Total 
Executive 
KMP6

2021

2022

1,555,477

871,312

4,229,582

1,970,639

2021

4,451,182

1,907,681

-

-

-

-

-

-

-

-

-

-

-

21,838

18,895

14,833

212

15,836

17,457

20,614

22,936

15,364

73,121

74,864

27,500

47,627

22,650

174,791

27,500

40,033

740

8

23,749

64,362

21,802

146,945

25,000

60,576

25,096

33,501

-

-

-

-

-

-

-

-

1,279,338

512,839

299,655

1,762

649,377

458,958

626,895

498,587

25,096

51,868

871,312

1,227,715

103,749

212,598

-

2,855,265

95,384

407,113

871,312

2,699,861

-

-

-

-

-

-

-

-

-

-

-

3,761,153

2,121,511

1,438,760

29,312

2,155,463

1,863,216

2,089,578

1,875,214

4,618,144

9,444,954

10,507,397

1.   Salary includes annual base salary paid on a fortnightly basis and annual leave entitlements accrued, but not taken, during the year 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 annual leave entitlements accrued, but not taken, during the year which are not 
expected to be taken in the next 12 months. Comparatives have been revised to represent the movement in annual leave entitlements accruals.  

4.   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.

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

6.   Total remuneration for FY2021 is $3.16 million less than that disclosed in the 2021 Remuneration Report as it does not include the Total Remuneration 
amounts of $1.09m for Kylie Bishop, $1.04m for John Goodall and $1.03m for Mei Ramsay who were KMP in 2021. Effective 1 July 2021, following  
changes to ELT operation effective 1 July 2021, they are no longer deemed KMP. 

68    Medibank 

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 2022 remuneration mix for Medibank’s Executive KMP as 
detailed in the ‘statutory remuneration table’.

Non-performance-related

Performance-related

Executive KMP

David Koczkar
Milosh Milisavljevic
Mark Rogers
Andrew Wilson

Financial 
year

Fixed 
remuneration1

2022
2022
2022
2022

43.1%
58.2%
50.3%
51.6%

Cash 
STI

22.9%
21.0%
19.6%
18.4%

Deferred 
STI2

16.3%
10.5%
17.6%
17.1%

LTI3

17.7%
10.3%
12.5%
12.9%

Total  
performance-related 
remuneration

56.9%
41.8%
49.7%
48.4%

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 2022 accounting expense of the 2022 deferred STI components within the ‘performance rights’ and ‘deferred STI’ columns  

of the ‘statutory remuneration table’.

3.   LTI includes the 2022 accounting expense of the 2020, 2021 and 2022 LTI component within the ‘performance rights’ column of the ‘statutory remuneration table’.

10. Executive KMP equity awards
10.1 Executive KMP equity award transactions

Details of 2022 Executive KMP equity award transactions and outstanding holdings granted in previous  years are set out below.

Executive 
KMP1

David  
Koczkar

Award type2

Balance  
1 July 2021

Units

Value

Units

Value

Units

Value

Units

Value

Acquired  
during 20223

Vested  
during 20224

Lapsed  
during 20225

Other 

changes Balance 30 June 20226

Long-term incentive

590,232

718,849

1,674,918

65,045

229,609

138,219

487,913

Short-term incentive

-

102,787

364,894

Ordinary shares

Milosh 
Milisavljevic

Long-term incentive

Short-term incentive

Ordinary shares

793,689

109,948

-

14,468

Mark  
Rogers

Long-term incentive

501,952

207,667

Short-term incentive

-

94,480

Andrew  
Wilson

Ordinary shares

Long-term incentive

Short-term incentive

343,530

601,400

-

Ordinary shares

926,500

-

207,667

93,322

-

-

-

161,980

377,413

-

-

-

-

483,864

335,404

-

483,864

331,293

-

65,045

9,650

-

9,650

48,825

-

48,825

68,619

-

-

229,609

34,065

-

34,065

-

-

-

-

20,504

72,379

-

-

-

-

172,352

103,751

366,241

-

172,352

242,225

-

-

-

-

-

145,813

514,720

-

-

-

-

-

68,619

242,225

-

-

-

-

-

-

-

-

-

-

-

-

1,105,817

2,532,485

102,787

364,894

858,734

2,790,886

241,774

554,237

-

-

24,118

78,384

557,043

1,257,796

94,480

335,404

392,355

1,275,154

594,635

1,341,431

93,322

331,293

995,119

3,234,137

1.   Effective 1 July 2021, Kylie Bishop, John Goodall and Mei Ramsey were no longer deemed KMP and a such their equity award transactions are not 

reported in the 2022 period. 

2.   Long-term incentive corresponds to performance rights awarded under the LTI plan that are subject to performance hurdles. Short-term incentive 
represents performance rights awarded under the STI Plan. Ordinary shares include all Medibank shares held by the executive or related parties.

3.   Represents the maximum number of equity awards that may vest to each Executive in respect to their time as KMP during 2022. The minimum potential 
outcome for the equity awards is 0. The values are calculated using the fair value as at grant date. 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 2020, 2021 and 2022 
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.

4.   Awards that vested in 2022 relate to the 32% vesting of 2019 LTI award (granted 6 December 2018) following the assessment of performance hurdles. 

Performance rights that vested were automatically exercised and no payment was required from participants. Executives received one ordinary share for 
each performance right that vested during the financial year. The value of vested awards is calculated using the closing share price on vesting date. 

5.  Awards that lapsed in 2022 relate to the 68% of the 2019 LTI award that did not meet the performance hurdle and subsequently lapsed.

6.   The value of unvested STI is determined by the number of units at 30 June 2022 multiplied by the unit price at grant. The value of unvested LTI is 

determined by the number of units at 30 June 2022 multiplied by the fair value at grant. The value of ordinary shares is determined by multiplying the 
number of ordinary shares at 30 June 2022 by the closing price of Medibank shares on the same date.

Annual Report 2022    69 

Remuneration report
For the financial year ended 30 June 2022

10.2 Overview of unvested equity awards and fair value assumptions

All awards are subject to continued employment, malus and clawback provisions.

Award
2022 LTI 
performance rights

2021 Deferred STI 
performance rights
2021 LTI 
performance rights

2020 LTI 
performance rights

2019 LTI 
performance rights

Award 
type
LTI

Performance 
start date
1/07/2021

Performance 

Performance 

end date1 Grant date
3/12/2021

30/06/2024

measure Weighting
35%
30%
35%

EPS
Market share
TSR

Unit price 
at grant
3.13
3.13
3.13

Fair value 
at grant2
2.72
2.72
1.62

STI
LTI

1/07/2021
1/07/2020

3/12/2021
15/09/2022
30/06/2023 26/11/2020

LTI

1/07/2019

30/06/2022 28/11/2019

LTI

1/07/2018

30/06/2021

6/12/2018

Service
EPS
Market share
TSR
EPS
Market share
TSR
EPS
TSR

100%
35%
30%
35%
35%
30%
35%
50%
50%

3.55
3.02
3.02
3.02
3.46
3.46
3.46
2.91
2.91

3.55
2.54
2.54
1.58
2.80
2.80
1.09
2.44
1.37

1.   The performance end date represents 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. Performance rights that vest are 
automatically exercised and no payment is required from participants. Any performance rights that don’t vest at this point will immediately expire.

2.  Fair value of LTI performance rights has been calculated as at the start of the performance period.  

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 a minimum number of 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 Chair 
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). 

11.1.2 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 increased for 2023. Based on  
the composition of the Board, non-executive director fee 
spend for 2023 will be $2,019,300 against the approved  
cap of $2,300,000. Non-executive director fees applicable 
throughout 2022 and 2023 are set out in the table below:

Position

Chair

Non-executive directors

Committee chair fees

Audit Committee

Risk Management Committee

2022 $ 2023 $

445,000 458,500

165,000 170,000

40,000

41,200

40,000

41,200

People and Remuneration Committee

40,000

41,200

Investment and Capital Committee

40,000

41,200

Committee membership fees

Audit Committee

Risk Management Committee

20,000

20,600

20,000

20,600

People and Remuneration Committee

20,000

20,600

Investment and Capital Committee

20,000

20,600

70    Medibank 

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 2022, all non-executive directors have met 
the minimum shareholding requirement. Further details of 
current non-executive director shareholdings are provided in 
section 13.

12. 2022 non-executive director remuneration statutory table

Non-executive director

Mike Wilkins

Tracey Batten

Anna Bligh

Gerard Dalbosco2

Peter Everingham5

David Fagan

Kathryn Fagg5

Linda Bardo Nicholls

Former non-executive directors
Elizabeth Alexander3
Peter Hodgett4

Christine O’Reilly4

Total non-executive director 
remuneration

Short-term 
benefits

Post-employment 
benefits

Financial 
year

Cash salary and fees  
$

Non-monetary1  
$

Superannuation  
$

Total  
$

2022
2021
2022
2021
2022
2021
2022
2021
2022

2022
2021
2022

2022
2021

2021
2022
2021
2022
2021
2022
2021

446,711
377,228
191,670
187,935
187,054
187,934
213,703
20,882
47,308

215,023
206,270
47,308

204,643
187,456

107,435
79,846
206,270
87,863
225,865
1,721,129
1,707,275

4,414
3,954
2,703
2,581
3,532
3,296
1,248
-
593

3,019
2,736
-

3,026
3,014

9,434
6,070
3,849
5,355
2,765
29,960
31,629

-
9,352
19,196
17,854
18,734
17,854
4,470
1,984
4,731

21,534
19,596
4,731

-
18,127

6,112
8,053
19,596
-
-
81,449
110,475

451,125
390,534
213,569
208,370
209,320
209,084
219,421
22,866
52,632

239,576
228,602
52,039

207,669
208,597

122,981
93,969
229,715
93,218
228,630
1,832,538
1,849,379

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.

4.  Peter Hodgett’s and Christine O’Reilly’s 2022 remuneration reflects their retirement date from the Medibank Board of 18 November 2021.

5.  Kathryn Fagg’s and Peter Everingham’s 2022 remuneration reflects their commencement date as non-executive directors of 31 March 2022. 

Annual Report 2022    71 

Remuneration report
For the financial year ended 30 June 2022

13. Non-executive director ordinary shareholdings

Balance 
30 June 
2021

Acquired 
during the 
year

Other 
changes 

Non-executive director

Mike Wilkins
Tracey Batten

Anna Bligh

Gerard Dalbosco

Peter Everingham4

David Fagan

Kathryn Fagg4

100,000
50,000

44,623

24,432

-

47,016

-

Linda Bardo Nicholls

45,000

Former non-executive director

Peter Hodgett3
Christine O’Reilly3

67,800
69,930

-
-

-

48,400

-
-

-

-

-

-

-

-

-
-

40,000

-

32,750

-

(67,800)
(69,930)

Balance 
30 June 
2022

100,000
50,000

44,623

72,832

40,000

47,016

32,750

45,000

-
-

Minimum 
shareholding 
requirement 
$1

Shareholding 
Value  
at 30 June 2022 
$2

Minimum 
shareholding 
requirement timeline

222,500
82,500

82,500

82,500

82,500

82,500

82,500

82,500

-
-

325,000 Requirement satisfied
162,500 Requirement satisfied

145,025 Requirement satisfied

236,704 Requirement satisfied

130,000 Requirement satisfied

152,802 Requirement satisfied

106,438 Requirement satisfied

146,250 Requirement satisfied

-
-

Not applicable
Not applicable

1.  Minimum shareholding requirement based on annual non-executive director base fees for 2022 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 2022 ($3.25).

3.   Peter Hodgett and Christine O’Reilly ceased to be a KMP on 18 November 2021 and therefore their balance at 30 June 2022 has been adjusted to  

reflect no further holdings as a KMP.

4.   Peter Everingham and Kathryn Fagg commenced as non-executive directors on 31 March 2022, and therefore their balance at 30 June 2021 was zero. 

Both Peter and Kathryn held Medibank shares prior to becoming non-executive directors of Medibank.

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.

72    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 74

page 75

page 76

page 77

Section 1
Basis of  
preparation
page 78

1.  Basis of  

preparation

Section 2
Operating  
performance
page 79

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 91

Section 4
Other assets  
and liabilities
page 102

Section 5
Other 

page 110

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 120

page 121

page 122

Annual Report 2022    73 

 
Consolidated statement of comprehensive income
For the financial year ended 30 June 2022

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
Depreciation and amortisation expense
Finance expense
Share of net profit/(loss) from equity accounted investments

Note

2022 
$m

2021 
$m

2(b) 3(a)

3(a)

13(a)(ii)

16(b)

 6,881.2 
 247.3 
 7,128.5 

 6,691.1 
 219.3 
 6,910.4 

 1.0 

 1.8 

 (5,679.8)
 (34.7)
 (467.5)
 (90.1)
 (85.9)
 (73.8)
 (115.0)
 (2.4)
 4.5 
 (6,544.7)

 (5,557.9)
 (34.0)
 (439.9)
 (88.6)
 (81.4)
 (72.3)
 (122.0)
 (2.8)
 (1.0)
 (6,399.9)

Profit before net investment income and income tax

 584.8 

 512.3 

Net investment income/(expense)

7(a)

 (24.8)

 120.0 

Profit for the year before income tax

 560.0 

 632.3 

Income tax expense
Profit for the year

Other comprehensive income

Items that will not be reclassified to profit or loss
Actuarial gain/(loss) on retirement benefit obligation, net of tax
Total comprehensive income for the year, net of tax, attributable to equity holders 
of the parent
Earnings per share attributable to ordinary equity holders of the Parent - basic 
and diluted (cents)

The above statement should be read in conjunction with the accompanying notes. 

15(a)

 (166.1)
 393.9 

 (191.1)
 441.2 

 0.2 

 0.4 

 394.1 

 441.6 

6(b)

 14.3 

 16.0 

74    Medibank 

Consolidated statement of financial position
 As at 30 June 2022

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

The above statement should be read in conjunction with the accompanying notes. 

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

2022 
$m

 596.7 
 225.4 
 2,854.5 
 35.4 
 - 
 19.3 
 3,731.3 

 88.4 
 332.3 
 47.5 
 243.6 
 103.7 
 6.0 
 821.5 

2021 
$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 

 4,552.8 

 3,923.8 

 361.4 
 860.9 
 817.5 
 117.0 
 178.6 
 104.6 
 2,440.0 

 56.6 
 10.2 
 77.3 
 23.1 
 167.2 

 338.2 
 622.4 
 697.0 
 -   
 103.0 
 94.7 
 1,855.3 

 70.2 
 9.1 
 60.4 
 22.7 
 162.4 

 2,607.2 

 2,017.7 

 1,945.6 

 1,906.1 

10(a)
10(b)

 85.0 
 25.7 
 1,834.9 
 1,945.6 

 85.0 
 22.3 
 1,798.8 
 1,906.1 

Annual Report 2022    75 

Consolidated statement of changes in equity
For the financial year ended 30 June 2022

Contributed 
equity 
$m
 85.0 

Note

 Reserves 
$m 
 22.4 

Retained 
earnings 
$m
 1,690.4 

Total 
equity 
$m
 1,797.8 

 441.2 
 0.4 
 441.6 

 (333.2)
 (5.3)
 5.2 
 1,906.1 

 393.9 
 0.2 
 394.1 

 (358.0)
 (2.5)
 5.9 
 1,945.6 

 - 
 - 
 - 

 - 
 - 
 - 
 85.0 

 - 
 - 
 - 

 - 
 - 
 - 
 85.0 

 - 
 - 
 - 

 - 
 (5.3)
 5.2 
 22.3 

 - 
 - 
 - 

 - 
 (2.5)
 5.9 
 25.7 

 441.2 
 0.4 
 441.6 

 (333.2)
 - 
 - 
 1,798.8 

 393.9 
 0.2 
 394.1 

 (358.0)
 - 
 - 
 1,834.9 

Balance at 1 July 2020

Profit for the year
Other comprehensive income
Total comprehensive income for the year

Dividends paid
Acquisition and settlement of share-based payment, net of tax
Share-based payment transactions
Balance at 30 June 2021

6(a)(i)

Profit for the year
Other comprehensive income
Total comprehensive income for the year

Dividends paid
Acquisition and settlement of share-based payment, net of tax
Share-based payment transactions
Balance at 30 June 2022

6(a)(i)

The above statement should be read in conjunction with the accompanying notes. 

76    Medibank 

Consolidated statement of cash flows
For the financial year ended 30 June 2022

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
Purchase of equity accounted investments
Loan to associate
Purchase of plant and equipment
Purchase of intangible assets
Net cash 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

2022 
$m 

2021 
$m 

9(d)

16(b)
16(b)

14
6(a)(i)

 7,089.4 
 274.6 
 3.3 
 (5,422.6)
 (795.9)
 (200.3)
 948.5 

 14.2 
 (5.0)
 1,349.6 
 (1,926.2)
 (21.1)
 - 
 (7.0)
 (28.1)
 (623.6)

 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)

 (3.1)
 (38.8)
 (358.0)
 (399.9)

 (5.6)
 (37.0)
 (333.2)
 (375.8)

 (75.0)

 (199.7)

 671.7 

 871.4 

 596.7 

 671.7 

Annual Report 2022    77 

Notes to the consolidated financial statements
30 June 2022

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 2022 were authorised for issue in accordance 
with a resolution of the directors on 18 August 2022. 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, 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.

•  Adopt all new and amended accounting standards that are 
mandatory for 30 June 2022 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 2022 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.

78    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 2022, 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 2022    79 

(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 2022 is as follows.

Health Insurance

Medibank Health

$45.5m

$538.6m

$6,680.3m

$592.6m

$6,859.8m

$31.4m

$283.8m

$321.8m

2021

2022

2021

2022

Revenue

Operating profit

Revenue

Operating profit

30 June 2022

Revenue

Total segment revenue

Inter-segment revenue

Health 
Insurance 
$m

Medibank 
Health  
$m

Note

Total  
$m

2(c)(iii)

 6,859.8 

 - 

 321.8 

 (53.1)

 7,181.6 

 (53.1)

Revenue from external customers

 6,859.8 

 268.7 

 7,128.5 

Operating profit

 592.6 

 45.5 

 638.1 

Items included in segment operating profit:

Depreciation and amortisation

Interest income from loans to associates

Share of profit/(loss) from equity accounted investments

16(b)

 (101.6)

 - 

 - 

 (7.3)

 0.2 

 4.5 

 (108.9)

 0.2 

 4.5 

30 June 2021

Revenue

Total segment revenue

Inter-segment revenue

Health 
Insurance 
$m

Medibank 
Health  
$m

Note

Total  
$m

2(c)(iii)

 6,680.3 

 - 

 283.8 

 (53.7)

 6,964.1 

 (53.7)

Revenue from external customers

 6,680.3 

 230.1 

 6,910.4 

Operating profit

 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

16(b)

 (104.8)

 - 

 - 

 (8.3)

 0.2 

 (1.0)

 (113.1)

 0.2 

 (1.0)

80    Medibank 

Notes to the consolidated financial statements30 June 2022 
(c) Other segment information

(i) Segment operating profit or loss 

A reconciliation of segment operating profit to the profit for the year before income tax of the Group is as follows: 

Total segment operating profit

Unallocated to operating segments: 

  Corporate operating expenses

Group operating profit

Net investment income/(expense)

Acquisition intangible amortisation

Mergers and acquisitions expenses

Other income/(expenses)

Profit for the year before income tax

               Note 

2022 
$m

 638.1 

2021 
$m

 570.0 

 (44.0)

 (41.7)

 594.1 

 528.3 

 7(a) 

 (24.8)

 120.0 

 (2.0)

 (1.7)

 (5.6)

 (4.6)

 (5.5)

 (5.9)

 560.0 

 632.3 

(ii) Other items

(iii) Loyalty program

Segment operating profit excludes the following:

•  Corporate operating expenses of $44.0 million (2021:  

$41.7 million) relating to the Group's corporate function.

Segment private health insurance premium revenue is  
after $21.4 million (2021: $10.8 million) of transfers between 
the Group’s other operating segments in relation to the  
loyalty program.

•  Net investment income/(expense), which comprises:

(iv) Segment assets and segment liabilities

 – 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.

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.

 – 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 $2.0 million  

(2021: $4.6 million) not allocated to segments.

•  Expenses in relation to mergers and acquisitions of  

$1.7 million (2021: $5.5 million) which are not allocated  
to the operating activities of the Group’s segments.

•  Other income/(expenses) of $5.6 million (2021:  
$5.9 million) which do not relate to the current  
period’s trading activities of the Group’s segments, 
comprising primarily net sublease rent. 

Annual Report 2022    81 

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.  

$6,859.8m

2022 underwriting result after expenses

$(5,731.6)m

$(535.6)m

$592.6m

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 COVID-19 claims liability has been recorded for deferred 
claims that were a result of surgeries and other health 
services which were inaccessible to policyholders due  
to COVID-19 restrictions. Medibank has an obligation to 
settle these claims when they occur 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 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)

2022 
$m

2021 
$m

 6,859.8 

 6,680.3 

 (5,415.0)
 (224.5)
 (55.5)
 (36.1)
 (5,731.1)

 (0.5)
 (5,731.6)

 (5,606.2)
 73.3 
 (53.3)
 (24.6)
 (5,610.8)

 0.2 
 (5,610.6)

 (535.6)

 (531.1)

 592.6 

 538.6 

(i)      Private health insurance premium revenue is after  

(iii)   Net claims incurred consists of amounts paid and  

$21.4 million (2021: $10.8 million) of transfers between the 
Group’s other operating segments in relation to the loyalty 
program and $369.4 million (2021: $103.0 million) in 
relation to the recognition of customer give backs publicly 
announced by the Group during the period to return 
permanent net COVID-19 savings to eligible policyholders 
(refer to Note 5 and Note 13(c) for further information).

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. 

(ii)     Claims incurred are prior to elimination of transactions 

Refer to Note 3(b) for further information.

with the Group’s other operating segments of  
$51.8 million (2021: $52.7 million).

82    Medibank 

Notes to the consolidated financial statements30 June 2022 
Health Insurance Premium Revenue Recognition 
Accounting Policy
Premium revenue is recognised in the consolidated 
statement of comprehensive income when it is earned. 
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. Adjustments made 
to past premiums are recognised as a reduction in premium 
revenue. See Note 5 and Note 13(c) for further information.

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 liabilities

Non-current
Outstanding claims liability - central estimate
Risk margin
Claims handling costs

Claims liability - provision for bonus entitlements
Gross claims liabilities

Note

(i,ii)
(vi)
(i,iii)
(iv)

(v)
(c)

(i,ii)
(i,iii)
(iv)

(v)
(c)

2022 
$m

 359.3 
 448.3 
 35.1 
 8.9 
 851.6 

 9.3 
 860.9 

 3.1 
 0.3 
 0.1 
 3.5 

 6.7 
 10.2 

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 

Annual Report 2022    83 

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 comprises 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.

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 as a result of the COVID-19 pandemic. 
Medibank has an obligation to settle these claims when 
they occur in future periods. The liability is calculated by 
comparing the difference between the actual and expected 
claims since the commencement of COVID-19 restrictions 
from March 2020. 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. 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 and pre-admission hospital eligibility check volumes. 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 1.81% per annum which equates to a reduction in the central  
estimate of $0.9 million (2021: 0.03%, less than $0.1 million).

84    Medibank 

Notes to the consolidated financial statements30 June 2022(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 2022 is 9.4% (2021: 9.4%).

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% (2021: 95%). This risk 
margin is only applied to the outstanding claims liability, however relevant risks and uncertainties  
have been taken into account in key assumptions used to estimate the COVID-19 claims liability.

(iv)   Claims 

handling costs

The allowance for claims handling costs at 30 June 2022 is 2.5% of the outstanding claims liability 
(2021: 2.5%).

(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 COVID-19 claims liability represents the continued and prolonged impact of the COVID-19 
pandemic during the period on availability and accessibility to surgeries and other health services. 
The COVID-19 claims liability includes hospital claims of $405.6 million (2021: $220.2 million), which 
includes surgical and non-surgical claims, and ancillary claims of $42.6 million (2021: $3.6 million).

Key estimate – Hospital
The liability is calculated by comparing the difference between the actual and expected volume of 
insured surgical, non-surgical and ancillary procedures since the commencement of COVID-19 
restrictions from March 2020. Any shortfall is deferred into the liability at the applicable claims 
deferral rate. Utilisation of the liability occurs where actual claims exceed expected claims. 

The liability has been assessed by geography and modality (claim type) with the deferral of claims 
 (and any subsequent utilisation) varying based on the extent of COVID-19 restrictions. The ancillary 
liability resets for ancillary claims with expired limits. 

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 estimate include:

•  The expected claims level at the Single Equivalent Unit per policy (PSEU), which is based  

on statistical analysis of 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.

•  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% (2021: 85%)  
for surgical claims, 40% (2021: 50%) for non-surgical claims and 50% (2021: 50%) for ancillary 
claims.

•  This liability only includes insured surgeries and other health services that will ultimately be 

performed for policyholders of the Group. Given the extended duration of the COVID-19 pandemic, 
a policyholder lapse rate has been applied to the surgical and non-surgical claims. This rate is 
based on the average lapse rate since the commencement of the COVID-19 pandemic. The ancillary 
liability does not include a lapse rate as it resets when limits expire. 

Annual Report 2022    85 

(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 estimate

Risk margin

Claims handling costs

Movement in discount rate

Balance at 30 June

Note

2022 
$m

 631.5 

2021 
$m

 639.2 

 5,369.8 

 5,496.1 

(i)

 224.5 

 (73.3)

 (5,348.1)

 (5,414.4)

 (8.2)

 2.0 

 0.5 

 (0.9)

 (22.0)

 6.1 

 (0.2)

 - 

 871.1 

 631.5 

Note: Movement includes both current and non-current. Claims incurred and claims settled exclude levies and rebates.

(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 period. 

Balance at 1 July 2021

Change in respect of previous period

Net change in assumptions1

Net deferral/(utilisation) during the period

Balance at 30 June 2022

Hospital 
$m

Ancillary 
$m

 220.2 

 (8.5)

 (42.2)

 236.1 

 405.6 

 3.6 

 (0.2)

 - 

 39.3 

 42.7 

Total 
$m

 223.8 

 (8.7)

 (42.2)

 275.4 

 448.3 

1.   Includes change in expected deferral rate of $19.2 million and changes in other assumptions, including policyholder lapse rate and price indexation.

(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 $25.4 million decrease/increase 
to profit after tax and equity (2021: $24.4 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 $117.9 million decrease/increase to  
profit after tax and equity (2021: $67.0 million). 

•  An increase/decrease of 10 percentage points in the 

adopted deferral rate for COVID-19 hospital claims would 
result in a $54.2 million decrease/increase to profit after tax 
and equity (2021: $26.8 million). The reasonable possible 
range for the hospital deferral assumption is 75-100% for 
surgical claims (2021: 75-100%) and 30-70% for non-
surgical and ancillary claims (2021: 30-70%).

(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.  

86    Medibank 

Notes to the consolidated financial statements30 June 2022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 since the commencement of the COVID-19 pandemic includes daily and 
weekly dashboard reports.

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 and customer give backs.

Annual Report 2022    87 

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. 

2022 
$m

 81.1 

 39.6 

 (37.8)

 82.9 

2021 
$m

 78.1 

 42.3 

 (39.3)

 81.1 

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 
(2021: 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. 

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

Earning of premiums deferred in prior years

Movement in provision for premium deferral

Balance at 30 June

Note: Movement includes both current and non-current.

2022 
$m

 757.4 

 700.9 

 (697.0)

 133.5 

 894.8 

2021 
$m

 746.1 

 682.4 

 (671.1)

 - 

 757.4 

The unearned premium liability balance at 30 June 2022 includes a provision for premium deferral of $133.5 million (2021: nil). 
This balance is comprised of an initial recognition of $184.8 million during the period, offset by $51.3 million utilisation. The 
provision for premium deferral represents amounts owed at balance date in relation to the announcements made by the Group 
during the period to return permanent net COVID-19 savings to eligible policyholders via a 7 month deferral of the 1 April 2022 
premium increase. 

A separate customer give back provision of $178.6 million (2021: $103.0 million) is recognised in the statement of consolidated 
position. Refer to Note 13(c) for further information.

88    Medibank 

Notes to the consolidated financial statements30 June 2022 
(a) Liability adequacy test

The expected cash outflows and the risk margin in the 30 June 2022 liability adequacy test (LAT) includes the impacts of  
COVID-19. The LAT did not result in the identification of any deficiency as at 30 June 2022 and 2021. 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
At each balance date, a liability adequacy test is performed 
to determine whether the unearned premium liability, net 
of related deferred acquisition costs, is adequate to cover 
expected future claims arising from current insurance 
coverage. An additional risk margin is included in the test to 
reflect the inherent uncertainty in the central estimate. The 
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 the present value of the expected future claims, 
including a risk margin, exceeds the net unearned premium 
liability. The entire deficiency is recognised immediately 
in the statement of comprehensive income by first writing 
down any related intangible assets and then related 
deferred acquisition costs, with any excess being recognised 
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 

2022

2021 final fully franked dividend

2022 interim fully franked dividend

2021

2020 final fully franked dividend

2021 interim fully franked dividend

 Cents per fully 
paid share 

 6.90 

 6.10 

 6.30 

 5.80 

$m

 Payment date 

 190.0 

 168.0 

30 September 2021

24 March 2022

 173.5 

 159.7 

24 September 2020

25 March 2021

Annual Report 2022    89 

 
 
(ii) Dividends not recognised at the end of the reporting period

On 18 August 2022, the directors determined a final fully franked ordinary dividend for the six months ended 30 June 2022 of  
7.30 cents per share. The dividend is expected to be paid on 29 September 2022 and has not been provided for as at 30 June 2022. 

(iii) Franking account

Franking credits available at 30 June 2022 for subsequent reporting periods based on a tax rate of 30% are $372.7 million  
(2021: $324.2 million).

(iv) Calculation of dividend paid

Medibank’s target dividend payout ratio for the 2022 financial year is 75-85% (2021: 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

2022 
$m

 393.9

22.7

 18.5

 435.1 

2021 
$m

 441.2 

 (31.2) 

 (11.3) 

398.7 

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

Basic and diluted earnings per share attributable to ordinary equity holders of the  
parent (cents)

Profit for the year attributable to ordinary equity holders of the parent ($m)

2022

 14.3

 393.9 

2021

 16.0

 441.2

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.

90    Medibank 

Notes to the consolidated financial statements30 June 2022 
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 provides information on the net investment income/
(expense) and the carrying amounts of the financial assets 
residing in the two investment portfolios; the Health Fund 
Investment Portfolio (including the sub-portfolio) and the 
Non-Health Fund Investment Portfolio.

Health Fund Investment Portfolio

The Health Fund Investment Portfolio is managed 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. Consequently, the asset allocation 
of the 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 approved short-term target asset 
allocation (TAA) for the Health Fund Investment Portfolio 
is 20%/80% for growth and defensive assets, and the long-
term TAA is 25%/75% for growth and defensive assets. 

During, and because of, the COVID-19 pandemic, the Short-
term Operational Cash (STOC) sub-portfolio was created with 
the purpose of funding the COVID-19 claims liability and the 
customer give backs. Given the sub-portfolio’s short-term 
nature, it is managed separately from the TAA framework. 
This sub-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 assets  
with a minimum credit rating of AA-. 

Non-Health Fund Investment Portfolio

The Non-Health Fund Investment Portfolio is designed to 
provide the Group with additional liquidity and financial 
flexibility. The portfolio resides outside of the health fund and 
is not subject to the same regulatory requirements as the 
Health Fund Investment Portfolio. The CFO has delegation 
from the Investment and Capital Committee to manage the 
portfolio in accordance with the Board approved Investment 
Management Policy and investment strategy. 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  
assets with a minimum credit rating of AA-.

Health Fund 
Investment 
Portfolio1

Short-term 
Operational 
Cash (STOC)

Non-Health 
Fund Investment 
Portfolio

Portfolio composition 30 June 2022 ($m)

Cash portfolio

Cash and cash equivalents (as reported in the statement  
of financial position)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)

Less cash investments with longer maturities

Cash allocated to the Fixed income portfolio

Growth portfolio

Equities and investment trusts

Total investment portfolio

 232.2 

 322.2 

 (14.4)

 1,769.8 

 (322.2)

 14.4 

 474.7 

 2,476.7 

Total

 572.4 

 541.4 

 (14.4)

 2,379.8 

 (541.4)

 14.4 

 474.7 

 326.6 

 199.4 

 - 

 433.8 

 (199.4)

 - 

 - 

 13.6 

 19.8 

 - 

 176.2 

 (19.8)

 - 

 - 

 760.4 

 189.8 

 3,426.9 

Annual Report 2022    91 

Health Fund 
Investment 
Portfolio1

Short-term 
Operational 
Cash (STOC)

Non-Health 
Fund Investment 
Portfolio

Portfolio composition 30 June 2021 ($m)

Cash portfolio

Cash and cash equivalents (as reported in the statement  
of financial position)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)

Less cash investments with longer maturities

Cash allocated to the Fixed income portfolio

Growth portfolio

Equities and investment trusts

Total investment portfolio

 428.8 

 179.0 

 (37.3)

 1,563.6 

 (179.0)

 37.3 

 488.5 

 2,480.9 

Total

 659.9 

 179.0 

 (37.3)

 1,823.4 

 (179.0)

 37.3 

 488.5 

 178.2 

 - 

 - 

 52.9 

 - 

 - 

 148.6 

 111.2 

 - 

 - 

 - 

 - 

 - 

 - 

 326.8 

 164.1 

 2,971.8 

1.  The Health Fund Investment Portfolio excludes the Short-term Operational Cash (STOC) sub-portfolio.

2.  Cash and cash equivalents as reported in the statement of financial position also include operational cash of $24.3 million (2021: $11.8 million).

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 
2022

Portfolio 
composition 
30 June 
2021

Target  
asset 
allocation

5.4%
4.1%
7.4%
2.3%
19.2%

4.8%
6.0%
6.9%
2.1%
19.8%

6.0%
5.0%
7.0%
2.0%
20.0%

59.0%
21.8%
80.8%
100.0%

57.8%
22.4%
80.2%
100.0%

60.0%
20.0%
80.0%
100.0%

Health Fund Investment Portfolio

International equities
$100.7m

Cash
$540.0m

Infrastructure
$57.2m

Australian equities
$133.9m

Property
$182.9m

Fixed income
$1,462.0m

Financial Assets at Fair Value Accounting Policy
Investments in listed and unlisted equity securities held 
by the Health Fund Investment Portfolio are accounted for 
at fair value through profit or loss (FVTPL). Fixed income 
investments held by the Health Fund Investment Portfolio 
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. 

Non-Health Fund Investment Portfolio

Fixed income assets held by the Non-Health Fund 
Investment Portfolio 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. These assets 
are measured at fair value, with unrealised gains and 
losses recognised within equity in other comprehensive 
income. When the assets are derecognised, the cumulative 
unrealised gain or loss previously recognised in other 
comprehensive income is reclassified from equity to profit

92    Medibank 

Notes to the consolidated financial statements30 June 2022Financial Assets at Fair Value Accounting Policy continued
or loss. Interest income is recognised within net investment 
income/(expense) in the consolidated statement of 
comprehensive income using the effective interest method.

For financial assets measured at FVOCI, the Group applies 
the general impairment approach under AASB 9, which 
requires the 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 in the valuation techniques used to 
measure fair value. 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/(expense)

Net investment income/(expense) is presented net of investment management fees in the consolidated statement of 
comprehensive income. 

Interest income1

Trust distributions 

Net gain/(loss) on fair value movements on financial assets

Net gain/(loss) on disposal of financial assets

Investment management expenses

Net investment income/(expense)

2022 
$m

 17.9 

 43.1 

 (93.0)

 12.3 

 (5.1)

 (24.8)

2021 
$m

 17.7 

 38.0 

 47.8 

 21.2 

 (4.7)

 120.0 

1.   Includes interest income of $1.0 million (2021: $0.7 million) relating to financial assets at fair value through other comprehensive income  

(Non-Health Fund Investments).

Net Investment Income/(Expense) Accounting Policy

Net investment income/(expense) includes:

•  Trust distribution income derived from financial assets  
at FVTPL, which is recognised when the Group’s right  
to receive payments is established.

•  Interest income, which is recognised using the  

•  Gains or losses arising from changes in the fair value  

effective interest method.

(b) Fair value hierarchy

of financial assets measured at FVTPL.

•  Investment management fees.

The Group’s financial instruments are categorised 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.

Annual Report 2022    93 

The following tables present the Group’s financial assets measured and recognised at fair value on a recurring basis.

30 June 2022

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 2022

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

Level 1  
$m

Level 2  
$m

Level 3  
$m

Total  
$m

 - 

 - 

 - 

 - 

 133.9 

 100.7 

 - 

 - 

 53.0 

 2,150.6 

 - 

 176.2 

 - 

 - 

 182.9 

 57.2 

 - 

 - 

 133.9 

 100.7 

 182.9 

 57.2 

 2,203.6 

 176.2 

 53.0 

 2,561.4 

 240.1 

 2,854.5 

Level 1  
$m

Level 2  
$m

Level 3  
$m

Total  
$m

 - 

 - 

 - 

 - 

 119.3 

 147.4 

 - 

 - 

 82.0 

 1,630.2 

 - 

 111.2 

 - 

 - 

 169.3 

 52.5 

 - 

 - 

 119.3 

 147.4 

 169.3 

 52.5 

 1,712.2 

 111.2 

 82.0 

 2,008.1 

 221.8 

 2,311.9 

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 2021

Acquisitions

Net unrealised gain/(loss) 
on fair value movements

Infrastructure 
$m

Property 
$m

Total 
$m

 52.5 

 169.3 

 221.8 

 4.3 

 6.5 

 10.8 

 0.4 

 7.1 

 7.5 

Balance at 30 June 2022

 57.2 

 182.9 

 240.1 

A 10% increase/decrease in the redemption price would 
decrease/increase the fair value of the level 3 financial assets 
by $24.0 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.

Transfers between fair value hierarchy levels are recognised 
from the date of effect of the transfer. There were no 
transfers between the fair value hierarchy levels during  
the year.

Fair value measurements using significant 
unobservable market data (level 3)

The Group’s investments in infrastructure and property 
financial assets are classified within level 3 of the fair value 
hierarchy. These assets are held in unlisted unit trusts and 
are valued at the redemption value per unit as reported by the 
managers of such funds. They are classified within level 3 of 
the fair value hierarchy as their fair values are not based on 
observable market data due to the infrequent trading of these 
investments which results in limited price transparency.

94    Medibank 

Notes to the consolidated financial statements30 June 2022Note 8: Financial risk management

This note reflects risk management policies and procedures 
associated with financial instruments. The Group’s principal 
financial instruments comprise cash and cash equivalents 
(short-term money market instruments), fixed income 
assets (floating rate notes, asset-backed securities, 
syndicated loans, fixed income absolute return funds and 
hybrid investments), property assets, infrastructure assets, 
Australian equities and international equities.

A strategic asset allocation is set and reviewed at least 
annually by the Board, and establishes the maximum and 
minimum exposures in each investment class. Transacting 
in individual investments is subject to the delegation of 
authorities and approval process that is established and 
reviewed by the Investment and Capital Committee (ICC). 

Trading of derivative instruments for purposes other than 
risk management cannot be undertaken, unless explicitly 
approved by the ICC. The Group was in compliance with this 
policy during the current and prior reporting periods.

The main risks arising from the Group’s financial instruments 
are interest rate risk, foreign currency risk, price risk, 
credit risk and liquidity risk. Primary responsibility for the 
consideration and control of financial risks rests with the 
ICC 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. 

Exposure

The Group has exposure to Australian variable and global fixed interest rate risk in respect of its cash and 
cash equivalents (2022: $596.7 million, 2021: $671.7 million) and fixed income assets (2022: $2,379.8 million, 
2021: $1,823.4 million). Both classes of financial assets have variable interest rates and are therefore 
exposed to cash flow movements if these interest rates change. 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 assets had a modified duration of 0.3 years (2021: 0.5 years).

Sensitivity

A 50bps increase/decrease in interest rates for the entire reporting period, with all other variables remaining 
constant, would have resulted in a $6.9 million increase/decrease to profit after tax and equity (2021: $4.4 
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.

Exposure

All of the Group’s financial assets with a non-AUD currency exposure are fully economically hedged, except 
for International equities which are unhedged.

At balance date, international equities financial assets (2022: $100.7 million, 2021: $147.4 million) had net 
exposure to foreign currency movements.

Sensitivity

A 10% increase/decrease in foreign exchange rates, with all other variables remaining constant, would have 
resulted in a $7.8 million decrease/increase to profit after tax and equity (2021: $11.5 million) in the AUD 
valuation of international equities financial assets. Balance date risk exposures represent the risk exposure 
inherent in the financial instruments.

Annual Report 2022    95 

(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.

Exposure

The Group is exposed to price risk in respect of its fixed income assets 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 the average monthly 
balances during the period and shows the impact on profit after tax and equity if market prices had  
moved, with all other variables held constant.

Australian equities
International equities
Property
Infrastructure

2022    
$m

2021    
$m

+10.0%

-10.0%

+10.0%

-10.0%

 9.1 
 8.3 
 12.3 
 3.8 

 (9.1)
 (8.3)
 (12.3)
 (3.8)

 8.7 
 10.1 
 11.6 
 2.1 

 (8.7)
 (10.1)
 (11.6)
 (2.1)

In relation to fixed income assets, a 25bps increase/decrease in credit spreads, with all other variables 
remaining constant, would have resulted in a $5.8 million decrease/increase to profit after tax and equity 
(2021: $5.9 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. 

Exposure

Credit risk exposure is measured by reference to exposures by ratings bands, country, industry and 
instrument type.

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 portfolios are subject to counterparty exposure limits. These limits 
specify that no more than 50% (2021: 50%) of the cash portfolio can be invested in any one counterparty 
bank and no more than 10% (2021: 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% (2021: 50%) and 15% (2021: 15%) of the portfolio respectively.  
As at 30 June 2022 and 2021, the counterparty exposure of the Group was within these limits.

96    Medibank 

Notes to the consolidated financial statements30 June 2022(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, after which 
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 then 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 credit risk on trade and other receivables within the Group.

(iii) Counterparty credit risk ratings
The following tables outline the Group’s credit risk exposure by classifying assets according to the short-term and equivalent 
long-term credit ratings (as per published Standard & Poor’s correlations) of the counterparties. Assets that fall outside the 
range AAA to BBB are classified as non-investment grade. 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 rating 
Long-term rating 
2022

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

2021

Cash and cash equivalents

Premiums in arrears

Trade and other receivables

Financial assets

Australian equities

International equities

Property

Infrastructure

Fixed income

A-1+  
AAA  
$m

 - 

 - 

 - 

 - 

 - 

 - 

 - 

A-1+  
AA  
$m

 596.7 

 - 

 - 

 - 

 - 

 - 

 - 

A-1  
A  
$m

A-2  
BBB  
$m

B & below  
BB & below  
$m

Not rated  
$m

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

Total  
$m

 596.7 

 6.3 

 -   

 6.3 

 219.1 

 219.1 

 133.9 

 100.7 

 182.9 

 57.2 

 133.9 

 100.7 

 182.9 

 57.2 

 285.5 

 819.9 

 378.8 

 329.2 

 7.6 

 382.6 

 2,203.6 

 - 

 176.2 

 - 

 - 

 - 

 -   

 176.2 

 285.5 

 1,592.8 

 378.8 

 329.2 

 7.6 

 1,082.7 

 3,676.6 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 671.7 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 8.5 

 671.7 

 8.5 

 207.4 

 207.4 

 119.3 

 147.4 

 169.3 

 52.5 

 119.3 

 147.4 

 169.3 

 52.5 

 183.2 

 528.4 

 293.0 

 301.3 

 7.9 

 398.4 

 1,712.2 

Financial assets at fair value through 
other comprehensive income

 - 

 111.2 

 - 

 - 

 - 

 - 

 111.2 

Total

 183.2 

 1,311.3 

 293.0 

 301.3 

 7.9 

 1,102.8 

 3,199.5 

The not rated fixed income assets relate to investments in unrated unit trusts. The majority of the underlying securities  
held by these unit trusts are investment grade assets and Senior Loans. 

Annual Report 2022    97 

(c) 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% (2021: 20%) 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 below reflect all contractually fixed pay-offs  
for settlement and interest resulting from recognised 
financial liabilities as at 30 June 2022, 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 2022.

2022

Other trade and other payables1

Lease liabilities2

Total trade and other payables

Claims liabilities

COVID-19 claims liability3

Total claims liabilities

2021

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

1 to 2  
years  
$m

Over 2 
years  
$m

Total 
contractual 
cash flows  
$m

Carrying 
amount  
$m

 329.8 

 17.7 

 347.5 

 389.8 

 95.9 

 485.7 

 309.4 

 16.1 

 325.5 

 376.7 

 63.5 

 440.2 

 1.4 

 17.4 

 18.8 

 23.8 

 352.4 

 376.2 

 0.7 

 15.4 

 16.1 

 21.9 

 160.3 

 182.2 

 2.5 

 31.8 

 34.3 

 6.8 

 - 

 6.8 

 1.1 

 29.7 

 30.8 

 5.5 

 - 

 5.5 

 7.4 

 15.9 

 23.3 

 3.3 

 - 

 3.3 

 3.8 

 36.4 

 40.2 

 3.6 

 - 

 3.6 

 341.1 

 82.8 

 423.9 

 423.7 

 448.3 

 872.0 

 315.0 

 97.6 

 412.6 

 407.7 

 223.8 

 631.5 

 341.1 

 76.9 

 418.0 

 422.8 

 448.3 

 871.1 

 315.0 

 93.4 

 408.4 

 407.7 

 223.8 

 631.5 

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.   The COVID-19 claims liability is specifically funded by the Short-term Operational Cash (STOC) sub-portfolio (refer to Note 7 for further information).  

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 COVID-19 claims liability 
extending beyond 12 months. This liability is specifically 
funded by the STOC sub-portfolio.

98    Medibank 

Notes to the consolidated financial statements30 June 2022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  

(b) Trade and other receivables

to enable the ongoing conduct of the business of the fund. 
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
Accrued revenue
Other receivables

Note

(i)

(ii)

2022 
$m

 11.9 
 (5.6)
 6.3 

 66.7 
 (2.1)
 64.6 

 137.7 
 13.4 
 3.4 
 154.5 

2021 
$m

 13.2 
 (4.7)
 8.5 

 59.0 
 (2.2)
 56.8 

 133.8 
 13.2 
 3.6 
 150.6 

Total trade and other receivables

 225.4 

 215.9 

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  

are $6.3 million (2021: $8.5 million). 

(ii)  Trade receivables past due but not impaired are  

$8.0 million (2021: $8.3 million). Each business unit  
of the Group has reviewed their individual debtors  
and is satisfied that payment will be received in full. 

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.

Trade and Other Receivables Accounting Policy
Trade and other receivables are non-interest bearing 
and generally due for settlement within 7 - 30 days. 
These receivables are initially measured at fair value 
and subsequently at amortised cost using the effective 
interest method, less a loss allowance for expected credit 
losses. The carrying value of trade and other receivables is 
considered to approximate fair value, due to the short-term 
nature of the receivables. Collectability of trade receivables 
is reviewed on an ongoing basis. The Group applies the 

simplified impairment approach under AASB 9, where 
expected lifetime losses are assessed based on historical 
bad and doubtful debt roll rates and adjusted for forward 
looking information where required. Uncollectible trade 
receivables are written off against the allowance account 
when identified. Any impairment loss on trade receivables 
is recognised within other expenses in the consolidated 
statement of comprehensive income. Any impairment loss 
on premiums in arrears is offset against health insurance 
premium revenue.

Annual Report 2022    99 

(c) Trade and other payables

Current

Trade creditors

Other creditors and accrued expenses

Lease liabilities

Risk Equalisation Special Account

Other payables1

Total current

Non-current

Lease liabilities

Other payables1

Total non-current

Note

2022 
$m

2021 
$m

14

14

 241.4 

 239.9 

 66.2 

 30.2 

 16.7 

 6.9 

 55.6 

 28.1 

 7.7 

 6.9 

 361.4 

 338.2 

 46.7 

 9.9 

 56.6 

 65.3 

 4.9 

 70.2 

1.  Other payables include a contract liability in relation to the loyalty program.

Trade and Other Payables Accounting Policy
Trade and other payables, with the exception of lease liabilities, are non-interest bearing and are initially measured at 
fair value and subsequently at amortised cost using the effective interest method. The carrying value of trade and other 
payables is considered to approximate fair value, due to the short-term nature of the payables.

Refer to Note 3(a) for the Risk Equalisation Special Account accounting policy.

Refer to Note 14 for the accounting policy for lease liabilities.

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) Reconciliation of profit after income tax to net cash flow from operating activities

Profit for the year

Non-cash items

Depreciation and amortisation

Non-cash share-based payments expense

Share of (profit)/loss from equity accounted investments

Other non-cash items

Investing and financing items

Net realised loss/(gain) on financial assets

Net unrealised loss/(gain) on financial assets

Interest income 

Trust distributions

Investment management expenses

Interest paid – leases

100    Medibank 

Note

16(b)

14

2022 
$m

 393.9 

2021 
$m

 441.2 

 115.0 

 122.0 

 5.9 

 (4.5)

 1.6 

 (12.3)

 93.0 

 (17.9)

 (43.1)

 5.1 

 2.4 

 5.2 

 1.0 

 - 

 (21.2)

 (47.8)

 (17.7)

 (38.0)

 4.7 

 2.8 

Notes to the consolidated financial statements30 June 2022 
 
(Increase)/decrease in operating assets

Trade and other receivables

Deferred acquisition costs

Other assets

Income tax receivable/liability

Net deferred tax assets

Increase/(decrease) in operating liabilities

Trade and other payables

Unearned premium liability

Claims liabilities

Provisions and employee entitlements

Net cash inflow from operating activities

Note

2022 
$m

 (11.1)

 (39.6)

 1.7 

 123.2 

 (157.1)

 34.2 

 137.4 

 239.6 

 81.1 

 948.5 

2021 
$m

 (8.8)

 (42.3)

 6.2 

 (63.9)

 4.3 

 15.7 

 11.3 

 (7.7)

 115.2 

 482.2 

Cash and Cash Equivalents Accounting Policy
Cash and cash equivalents comprise short-term highly liquid investments that are readily convertible to known amounts  
of cash and are subject to an insignificant change in value. These investments have original maturities of three months  
or less and include cash on hand, short-term bank bills, term deposits and negotiable certificates of deposit.

Amounts in cash and cash equivalents are the same as those included in the consolidated statement of cash flows.

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 on a 
 poll, at a general meeting of Medibank, and in a 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, entitle their  
holders to participate in the distribution of the surplus  
assets of Medibank.

(b) Reserves

Equity reserve1

Share-based payments reserve2

Total

2022 
$m

 17.8 

 7.9 

 25.7 

2021 
$m

 17.8 

 4.5 

 22.3 

1.   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.

2.   The share-based payments reserve is used to record the cumulative 
expense recognised in respect of performance rights issued to 
participating employees. Refer to Note 18 for further information.

Annual Report 2022    101 

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 carrying amount

Plant and equipment

Leasehold improvements

Assets under construction

Right-of-use assets

Total property, plant and equipment

(b) Reconciliation of the net carrying amount

2022

Gross carrying amount

Accumulated depreciation and impairment

Net carrying amount

Net carrying amount at 1 July

Additions

Transfers in/(out)

Depreciation expense

Net carrying amount at 30 June

2021

Gross carrying amount

Accumulated depreciation and impairment

Net carrying amount

Net carrying amount at 1 July

Additions

Transfers in/(out)

Depreciation expense

Net carrying amount at 30 June

Note

14

2022 
$m

10.0

16.8

7.1

54.5

88.4

Plant and 
equipment  
$m

Leasehold 
improvements 
$m

Assets under 
construction 
$m

 23.6 

 (13.6)

 10.0 

 10.2 

 - 

 1.1 

 (1.3)

 10.0 

 22.9 

 (12.7)

 10.2 

 6.1 

 6.2 

 1.7 

 (3.8)

 10.2

 96.0 

 (79.2)

 16.8 

 23.7 

 0.4 

 2.7 

 (10.0)

 16.8 

 95.0 

 (71.3)

 23.7 

 31.0 

 1.0 

 1.2 

 (9.5)

23.7

 7.1 

 - 

 7.1 

 4.5 

 6.4 

 (3.8)

 - 

 7.1 

 4.5 

 - 

 4.5 

 3.0 

 4.4 

 (2.9)

 - 

4.5

2021 
$m

10.2

23.7

4.5

63.3

101.7

Total 
$m

 126.7 

 (92.8)

 33.9 

 38.4 

 6.8 

 - 

 (11.3)

 33.9 

 122.4 

 (84.0)

 38.4 

 40.1 

 11.6 

 - 

 (13.3)

 38.4

(c) Property, plant and equipment capital expenditure commitments

Capital expenditure contracted for at the end of the reporting period but not 
recognised as liabilities

2022 
$m

2021 
$m

2.0

0.2

102    Medibank 

Notes to the consolidated financial statements30 June 2022 
 
Property, Plant and Equipment Accounting Policy
Refer to Note 14 for the accounting policy for  
right-of-use assets.

Depreciation
Property, plant and equipment is depreciated using the 
straight-line method over the estimated useful life as follows: 

Property, plant and equipment is carried at cost less 
accumulated depreciation and impairment losses.  
Cost includes expenditure that is directly attributable 
to the acquisition of the item and any subsequent 
expenditure eligible for capitalisation. Repairs and 
maintenance costs are recognised in the consolidated 
statement of comprehensive income during the period  
in which they are incurred.

Plant and equipment 
Leasehold improvements      the lease term 
Assets under construction     not depreciated until in use

    3 - 15 years 

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

2022

Gross carrying amount

Accumulated amortisation and impairment

Net carrying amount

Net carrying amount at 1 July

Additions

Transfers in/(out)

Amortisation expense

Net carrying amount at 30 June

2021

Gross carrying amount

Accumulated amortisation and impairment

Net carrying amount

Net carrying amount at 1 July

Additions

Transfers in/(out)

Amortisation expense

Net carrying amount at 30 June

Customer 
contracts and 
relationships 
$m

Goodwill 
$m

Software 
$m

Assets under 
construction 
$m

 282.9 

 (78.4)

 204.5 

 204.5 

 - 

 - 

 - 

 204.5 

 282.9 

 (78.4)

 204.5 

 204.5 

 - 

 - 

 - 

204.5

 89.7 

 (88.0)

 1.7 

 3.7 

 - 

 - 

 (2.0)

 1.7 

 89.7 

 (86.0)

 3.7 

 8.3 

 - 

 - 

 (4.6)

  3.7

 479.4 

 (379.6)

 99.8 

 111.9 

 4.5 

 19.4 

 (36.0)

 99.8 

 455.5 

 (343.6)

 111.9 

 124.7 

 4.1 

 20.7 

 (37.6)

 111.9 

 26.3 

 - 

 26.3 

 25.2 

 20.5 

 (19.4)

 - 

 26.3 

 25.2 

 - 

 25.2 

 26.2 

 19.7 

 (20.7)

 - 

25.2 

Total 
$m

 878.3 

 (546.0)

 332.3 

 345.3 

 25.0 

 - 

 (38.0)

 332.3 

 853.3 

 (508.0)

 345.3 

 363.7 

 23.8 

 - 

 (42.2)

345.3

Goodwill Accounting Policy
Goodwill is carried at cost less accumulated impairment losses. Goodwill is not amortised and is tested for impairment 
annually, or more frequently if events or changes in circumstances indicate that it might be impaired.

Key estimate
Refer to Note 12(a) for further information on the assumptions used in the recoverable amount calculations.

Annual Report 2022    103 

Software Accounting Policy
Software is carried at cost less accumulated amortisation and impairment losses. Costs capitalised include external direct 
costs of acquiring software, licences and service, and payroll related costs of employees’ time spent on the project. Assets 
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). 

Customer Contracts and Relationships Accounting Policy
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).

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) Impairment tests for goodwill – key assumptions and judgements 

Below is a summary of the Group’s goodwill allocation to cash generating unit (CGU) 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 

2022

Growth 
rate 
%

 2.5 

 1.0 

 2.5 

Pre-tax 
discount 
rate %

Goodwill 
allocation 
$m

 11.6 

 12.4 

 12.4 

 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 

The recoverable amounts of the CGUs are based on value in use (VIU) calculations, which use a three-year 
cash flow projection per the Group’s Board approved Corporate Plan. A terminal value has been assumed in 
all the VIU calculations, except for the Medibank Health Telehealth CGU VIU calculation which is based on 
the expected tenure of current contracts.

Estimated future cash flows are discounted using post-tax discount rates which reflect risks specific to each 
CGU. The equivalent pre-tax discount rates are disclosed above.

The growth rates do not exceed the long-term average growth rates for the businesses in which the CGUs 
operate as per industry forecasts.

The key assumptions underpinning the cash flows are specific to each CGU and the industry in which it 
operates. The assumptions applied are based on management’s past experience and knowledge in the market 
in which the CGU operates. They include the following: 

•  Health Insurance CGU: Key assumptions include policyholder growth and future premium revenue rate 

rises, along with claims growth and claims inflation. 

•  Medibank Health Telehealth CGU: The business model of the CGU is contract based by nature and the 
forecast cash flows contain key assumptions for key customer contracts, including contract renewals, 
new wins and losses. 

•  Medibank Health Home Care group of CGUs: 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 forecast cash flows contain key assumptions around volumes of services performed across 
geographic areas, expected contract renewals and new wins and losses.

Forecast 
future cash 
flows

Discount 
rates

Growth rates

Other key 
assumptions

104    Medibank 

Notes to the consolidated financial statements30 June 2022 
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 
reporting periods.

Impairment Accounting Policy
For the purposes of assessing impairment, 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. A CGU is the smallest group of 
assets that generate separately identifiable cash inflows.

An impairment loss is recognised if the asset’s or CGU’s 
carrying amount exceeds its recoverable amount. The 

recoverable amount of an asset or CGU is the higher of its 
fair value less costs of disposal and VIU. In assessing VIU, 
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 or CGU.

(b) Intangible assets capital expenditure commitments

Capital expenditure contracted for at the end of the reporting period  
but not recognised as liabilities

Note 13: Provisions and employee entitlements
(a) Employee entitlements

(i) Employee entitlements provision

Current

Non-current

Total employee entitlements

This provision incorporates annual leave, long service leave, bonus plans and termination payments.

(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

2022 
$m

2021 
$m

 0.7

 1.9

2022 
$m

 72.4 

 13.8 

 86.2 

2022 
$m

 31.0 

 4.9 

 3.3 

 5.9 

2021 
$m

 69.7 

 13.0 

 82.7 

2021 
$m

 30.4 

 5.4 

 3.7 

 5.2 

Annual Report 2022    105 

Notes to the consolidated financial statements
30 June 2022

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
Movements in provisions are as follows:

Commissions 
$m

Make good 
$m 

Workers 
compensation 
$m 

Corporate 
loyalty benefits 
$m

Contingent 
consideration 
$m

Balance at 1 July 2021

Additional provision

Amounts utilised during the year

Reversal of unused provision

Balance at 30 June 2022

Balance comprised of:

Current

Non-current

 8.9 

 7.2 

 (7.4)

 - 

 8.7 

 8.7 

 - 

 5.0 

 - 

 (0.8)

 - 

 4.2 

 1.4 

 2.8 

 5.3 

 0.5 

 (1.3)

 - 

 4.5 

 0.7 

 3.8 

 10.0 

 4.2 

 (3.1)

 (0.4)

 10.7 

 10.7 

 - 

106    Medibank 

Other 
$m 

Total 
$m 

 2.8 

 2.8 

 34.7 

 20.1 

 (0.3)

 (12.9)

 - 

 5.3 

 (0.4)

 41.5 

 2.7 

 5.4 

 - 

 - 

 8.1 

 5.4 

 2.7 

 5.3 

 32.2 

 - 

 9.3 

(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 parent entity 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 parent entity has entered into $10.0 million (2021:  
$10.0 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.

(v) Contingent consideration provision

Contingent consideration relates to the investment in East 
Sydney Day Hospital Pty Limited (refer to Note 16(b) for 
further information).

(c) Customer give back provision

Movement in the customer give back provision is as follows: 

Balance at 1 July 2021

Additional provision

Amounts utilised during the year

Balance at 30 June 2022

Total 
$m

 103.0 

 184.6 

 (109.0)

 178.6 

During the current and prior periods, the Group has 
announced various customer give backs as part of its 
commitment to return permanent net COVID-19 savings to 
eligible policyholders. These give backs are initially recognised 
as a reduction to Health Insurance premium revenue in the 
consolidated statement of comprehensive income with the 

corresponding liability recognised in either the customer 
give back provision or provision for premium deferral in 
the unearned premium liability (refer to Note 5) depending 
on the mechanism used to provide the give back to eligible 
policyholders. One-time cash payments are recognised in  
the customer give back provision, and premium deferrals  
are recognised within the unearned premium liability.

The 2021 give back of $103.0 million that was recognised 
at 30 June 2021 has all been returned to eligible 
policyholders during the period. The total amount given 
back was $104.6 million, with the additional $1.6 million 
recognised in the current period consolidated statement  
of comprehensive income.

Further customer give backs totalling $367.8 million were 
announced during the current period in relation to a 7 month 
deferral of the 1 April 2022 premium increase and a one-time 
cash payment. Of this, $183.0 million has been recognised 
within the customer give back provision, with $4.4 million 
of this being paid during the current period. The remaining 
give back amount of $184.8 million has been recognised in 
the provision for premium deferral in the unearned premium 
liability (refer to Note 5).

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.

Annual Report 2022    107 

(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 state and 

federal regulators such as the ACCC, ASIC, APRA or other 
regulatory bodies 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 has issued $17.6m of bank guarantees to third 
parties for various operational and legal purposes, including 
$10.0 million (2021: $10.0 million) in relation to its self-
insured workers compensation obligations (refer to Note 13(b)
(iii)) and other guarantees relating to conditions set out in 
property agreements. 

It is not expected that these guarantees will be called upon.

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. 

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 2022, management have determined it  
is not reasonably certain that any of its leases will be 
extended or terminated.

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

2022 
$m

 63.3 
 19.1 
 (27.9)
 54.5 

2022 
$m
 93.4 
 19.9 
 2.4 
 (38.8)
 76.9 

 30.2 
 46.7 

2021 
$m

 72.1 
 18.4 
 (27.2)
 63.3 

2021 
$m
 109.2 
 18.4 
 2.8 
 (37.0)
 93.4 

 28.1 
 65.3 

The maturity profile of the Group's lease liabilities based on contractual undiscounted payments is provided in Note 8(c).

108    Medibank 

Notes to the consolidated financial statements30 June 2022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 $4.9 million have been 
recognised by the Group at 30 June 2022 (2021: $7.0 million). 
These are presented within other assets in the consolidated 
statement of financial position. 

Leases Accounting Policy
As a lessor
The Group acts as an intermediate lessor for two 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.

Annual Report 2022    109 

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 

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.

(a) Income tax expense

Current tax

Deferred tax1

Adjustment for tax of prior period

Income tax expense

2022 
$m

 322.0 

 (156.6)

 0.7 

 166.1 

2021 
$m

 182.2 

 8.6 

 0.3 

 191.1 

1.   Current period includes deferred tax of $130.2 million in relation to the movements in the COVID-19 claims liability and provision for customer give backs 

(including premium deferral). Refer to Note 15(c).

(b) Numerical reconciliation of income tax expense to prima facie tax payable

2022 
$m

 560.0 

2021 
$m

 632.3 

 168.0 

 189.7 

 0.9 

 (1.6)

 (1.3)

 (0.6)

 2.8 

 (1.2)

 0.3 

 (0.8)

 165.4 

 190.8 

 0.7 
 166.1 

 0.3 
 191.1 

Profit for the year 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

Share of (profit)/loss from equity accounted investments

Other items

Adjustment for tax of prior period 
Income tax expense

110    Medibank 

Notes to the consolidated financial statements30 June 2022 
(c) Deferred tax assets and liabilities
Deferred tax balances comprise temporary differences attributable to following 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 directly in other comprehensive income

Actuarial loss on retirement benefit obligation

Net deferred tax assets

2022 
$m

 2.3 

 (4.2)

 (24.9)

 (17.2)

 (11.1)

 26.9 

 25.8 

 139.3 

 104.1 

 0.1 

 2.1 

 243.2 

 0.4 

 0.4 

 243.6 

2021 
$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 

1.  Includes deferred tax of $134.5 million (2021: $67.1 million) in relation to the COVID-19 claims liability. Refer to Note 3(b) for further information.

2.   Includes deferred tax of $53.6 million (2021: $30.9 million) in relation to the customer give back provision and $40.1 million in relation to the provision 

 for premium deferral recognised in the unearned premium liability. Refer to Note 5 and Note 13(c) for further information. 

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.

Annual Report 2022    111 

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.

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 

Medibank Health 
Solutions 
Pty Ltd

Australian Health 
Management Group  
Pty Ltd

Medibank Private 
Employee Share  
Plan Trust1

MHSI  
Pty Ltd2

Medibank 
Health Solutions 
Telehealth  
Pty Ltd

MH Investment 
Holdings 
Pty Ltd

MH Solutions 
Investments 
Pty Ltd

Live Better 
Management  
Pty Ltd

Integrated  
Care Services 
Pty Ltd

MH  
Operations  
Pty Ltd2

Medi Financial 
Services 
Pty Ltd

HealthStrong 
Pty Ltd

East Sydney Day 
Hospital Pty Ltd  
(49%)

Adeney Private 
Hospital Pty Ltd  
(49%)

Medinet Australia 
Pty Ltd 
(3.85%)

Home Support 
Services  
Pty Ltd

Adeney Private 
Hospital Pty Ltd  
(49%)

Calvary  
Medibank JV  
Pty Ltd  
(50%)

Myhealth Medical 
Holdings Pty Ltd  
(49%)

SydOrtho  
Holdings Pty Ltd  
(50%)

   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.

2.  MHSI Pty Ltd and MH Operations Pty Ltd were registered on 9 May 2022.

112    Medibank 

Notes to the consolidated financial statements30 June 2022 
 
 
 
 
 
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.

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 and 

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.

(b) Equity accounted investments

As at 30 June 2022 the Group held the following investments in associates and joint ventures:

Name of company

East Sydney Day Hospital Pty Ltd (iii)
Calvary Medibank JV Pty Ltd
Myhealth Medical Holdings Pty Ltd
Adeney Private Hospital Pty Ltd (iii)
Medinet Australia Pty Ltd (i)
SydOrtho Holdings Pty Ltd (ii)

Principal  
activity

Place of 
incorporation

Type

Australia
Short stay hospital
Australia
Medical services
Australia
Medical services
Short stay hospital
Australia
Digital health services Australia
Australia
Short stay hospital

Associate
Joint Venture
Associate
Associate
Associate
Joint Venture

The following table shows the Group’s aggregated interests in equity accounted investments.

Balance at 1 July  

Additions

Share of net profit/(loss) for the year

Balance at 30 June

Ownership interest %

2022

49.00%
50.00%
49.00%
49.00%
3.85%
50.00%

2022 
$m

 77.1 

 22.1 

 4.5 

 103.7 

2021

49.00%
50.00%
49.00%
49.00%
-
-

2021 
$m

 - 

 78.1 

 (1.0)

 77.1 

(i) Medinet Australia Pty Ltd

(iii) Other

On 15 March 2022, Medi Financial Services Pty Ltd acquired a 
3.85% shareholding in Medinet Australia Pty Ltd, a digital health 
service provider, for $10.0 million. The Group has significant 
influence over Medinet as it has 28.5% of the voting power.

Other additions during the period comprised: 

•  Non-cash addition of $5.4 million in relation to the 

increase in the East Sydney Day Hospital Pty Ltd contingent 
consideration provision (refer to Note 13(b)(v)).

•  Subscription for an additional $5.2 million of shares in 

Adeney Private Hospital Pty Ltd (APH) in line with APH’s 
achievement of milestones.

(ii) SydOrtho Holdings Pty Ltd

On 16 March 2022, MH Solutions Investments Pty Ltd acquired 
a 50% shareholding in SydOrtho Holdings Pty Ltd (SydOrtho) 
for $1.5 million, to develop a hospital in Sydney for short stay 
surgical procedures. As part of the purchase agreement, the 
Group may make future equity purchases in SydOrtho up to 
$13.3 million. These future equity purchases are contingent 
on SydOrtho achieving certain milestones in the development 
of the hospital and therefore will only be recognised when the 
milestones are achieved.

Annual Report 2022    113 

 
Equity Accounted Investments 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.

(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

2022 
$m

2021 
$m

 3,441.7 

 3,186.5 

 4,192.8 

 3,794.7 

 2,207.1 

 1,832.2 

 2,355.8 

 1,980.2 

 85.0 

 85.0 

 6.3 

 7.9 

 1,737.8 

 1,837.0 

 377.1 

 377.1 

 6.3 

 4.5 

 1,718.7 

 1,814.5 

 432.7 

 432.7 

(ii) Guarantees entered into by parent entity

(iii) Contingent liabilities of the parent entity

The parent entity has entered into $10.0 million  
(2021: $10.0 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. 

Refer to Note 13(d) for details of the contingent liabilities  
of the parent entity.

(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

2022 
$m

2021 
$m

 2.0 

 0.4 

 0.2 

 1.6 

114    Medibank 

Notes to the consolidated financial statements30 June 2022 
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.

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

2022 
$m

 (3.8)
 26.6 
 0.2 

 (0.1)
 1.5 
 2.9 

2021 
$m

 (2.9)
 1.7 
 0.2 

 - 
 1.5 
 2.9 

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. 

•  Receipts in relation to services rendered, largely comprised of services provided to Calvary Medibank JV Pty Ltd for the  

COVID Care at Home programs.

•  Reimbursement of costs incurred.

(b) Key management personnel remuneration

Short-term benefits
Post-employment benefits
Long-term benefits
Share-based payments
Total key management personnel

2022 
$

2021 
$

 8,024,431 
 185,198 
 212,598 
 2,855,265 
 11,277,492 

 10,300,436 
 281,954 
 1,420,495 
 3,515,299 
 15,518,184 

Refer to the Remuneration Report for further details of the composition of the key management personnel.

(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 current and prior reporting periods. 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.

Annual Report 2022    115 

Note 18: Share-based payments
(a) Share-based payments arrangements 

Performance rights to acquire shares in Medibank are granted 
to members of the Executive Leadership Team (ELT), Senior 
Executive Group (SEG) and other selected senior employees as 
part of Medibank’s short-term incentive (STI) and long-term 
incentive (LTI) plans. These plans are designed to:

•  Align the interests of participating employees 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 

participating employees.

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 2022 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 2021. This average price was $3.13.

Performance rights granted do not carry any voting rights. 

(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.

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 2022.

(i) LTI offer

Under the LTI plan, performance rights were granted 
to members of the ELT, SEG and other selected senior 
employees 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.

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.

116    Medibank 

Notes to the consolidated financial statements30 June 2022(b) Performance rights – Group

Outstanding at 1 July

Granted

Forfeited1

Exercised2

Lapsed3

Outstanding at 30 June

Exercisable at 30 June

Number of equity 
instruments

2022

2021

 8,079,042 

 8,938,073 

 3,542,600 

 3,168,794 

 (1,371,837)

 (624,784)

 (825,420)

 (1,980,272)

 (1,753,932)

 (1,422,769)

 7,670,453 

 8,079,042 

 - 

 - 

1.  Forfeited relates to instruments that lapsed on cessation of employment.

2.  Performance rights are exercised as soon as they vest.

3.   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 2021 and 2022 
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

1 July 2021

1 July 2020

1 July 2021

1 July 2020

TSR 
performance rights

EPS and market share  
performance rights

2022

2021

2022

2021

Date of commencement of  
service and performance period

Expected vesting date

Fair value at grant date

Share price at grant date

Dividend yield (per annum effective)

Franking rate

Risk free discount rate (per annum)

Valuation method

Volatility assumptions (per annum)

Medibank

Comparator group average

Correlation between comparator  
companies' TSR

1 July 2021

1 July 2020

1 July 2021

1 July 2020

30 June 2024

30 June 2023

30 June 2024

30 June 2023

$1.62 

$3.14 

3.7%

100.0%

0.2%

$1.58 

$2.97 

4.0%

100.0%

0.3%

$2.72 

$3.14 

3.7%

100.0%

n/a

$2.54 

$2.97 

4.0%

100.0%

n/a

Monte Carlo 
simulation model

Monte Carlo 
simulation model

Black-Scholes 
option pricing 
methodology

Black-Scholes 
option pricing 
methodology

20%

32%

30%

28%

35%

25%

n/a

n/a

n/a

n/a

n/a

n/a

Annual Report 2022    117 

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:

- Health consulting services

Total remuneration of PwC

2022 
$

2021 
$

 1,693,192 

 1,570,108 

 281,550 

 248,280 

 231,830 

 15,530 

 229,780 

 199,517 

 2,452,802 

 2,016,985 

Note 20: Other
(a) New and amended standards adopted

Certain new accounting standards and amendments became 
effective for the annual reporting period commencing on  
1 July 2021 but did not have a material impact on the Group’s 
accounting policies or on the consolidated financial report.

(b) New accounting standards and interpretations  
not yet adopted

Certain new accounting standards have been published that 
are not mandatory for 30 June 2022 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. 

The Group expects to apply the simplified premium allocation 
approach to all of its insurance contracts. The Group is 
considering applying the option provided under AASB 17 for 
groups of contracts that apply the simplified approach (and 
have a coverage period of less than one year) to recognise 
insurance acquisition cash flows as expenses when incurred. 
This is different to the current approach of amortising 
acquisition costs over the average expected retention period, 
however this potential change in treatment is not expected to 
result in a significant change to measurement. The impact of 
AASB 17 on the recognition, measurement and classification 
of the COVID-19 deferred claims liability and customer give 
backs is currently being evaluated by the Group.

All other 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. However, it is 
expected that under AASB 17 there will be substantial changes 
in presentation of the financial statements and disclosures.

(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.

118    Medibank 

Notes to the consolidated financial statements30 June 2022(c) Other accounting policies

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.

(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 2022.

Annual Report 2022    119 

Directors' declaration

The directors declare that, in the opinion of the directors:

(a)    the financial statements and notes set out on pages 73  

to 119 are in accordance with the Corporations Regulations 
2001, including:

   (i)  

 giving a true and fair view of the Group’s financial 
position as at 30 June 2022 and of its performance 
for the financial year ended on that date; and

   (ii) 

 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 Regulations 
2001 for the year ended 30 June 2022.

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   
Chair   

18 August 2022 
Melbourne

David Koczkar 
Chief Executive Officer

120    Medibank 

 
 
 
  
 
 
Auditor's independence declaration

Auditor’s Independence Declaration 

As lead auditor for the audit of Medibank Private Limited for the year ended 30 June 2022, 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 
18 August 2022 

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 2022    121 

Independent auditor’s report

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 2022 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 2022 

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 

Liability limited by a scheme approved under Professional Standards Legislation. 

122    Medibank 

 
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 

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.  

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 

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. 

Amongst other relevant topics, we 
communicated the following key 
audit matters to the Audit 
Committee: 

•  Continued impact of the 
COVID-19 pandemic 

•  Estimation of the outstanding 

claims liability 

• 

Impairment test of goodwill 
allocated to the Home Care 
group of Cash Generating Units 
(CGUs)  

•  Reliance on automated 
processes and controls 

These are further described in the 
Key audit matters section of our 
report. 

Annual Report 2022    123 

 
 
 
 
 
Independent auditor’s report

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 

Continued impact of the COVID-19 pandemic 

Estimation of the COVID-19 deferred claims liability  

(Refer to Note 3: $448.3m) 

The COVID-19 claims liability relates to expected 
future payments to customers as a result of the 
Coronavirus pandemic (COVID-19) preventing access 
to surgery and other health services (referred herein 
as ‘COVID-19 restrictions’). 

The COVID-19 claims liability is calculated by 
considering: 
• 

the difference between actual claims service levels 
and estimated underlying claims growth that 
would have occurred in the absence of COVID-19 
restrictions (expected claims service level)  

• 

the rate at which deferred surgical and 
non-surgical procedures will catch up in future 
periods (deferral rate) 

•  variations in the above key assumptions by 
geography and modality (claim type)  

•  average policyholder lapse rate.  
Utilisation of the COVID-19 claims liability is assessed 
with reference to claims levels and the extent of 
COVID restrictions by geography and modality. 

The COVID-19 deferred 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: 

•  complexity, significant uncertainties and 

subjectivity impacting the Group’s estimate of the 
liability, including: 

We performed the following audit procedures, 
amongst others: 

•  Evaluated the design of the Group’s relevant key 

controls over the COVID-19 provisioning process. 

•  Evaluated the Group’s accounting policy for the 

deferral of claims due to the COVID-19 pandemic 
against applicable Australian Accounting 
Standard requirements, Private Health Insurance 
(PHI) industry practices and publicly available 
health services data. 

•  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, and any 
changes to these assumptions, adopted by 
the Group in determining the impact of 
continued COVID-19 restrictions on claims 
deferred to future periods with reference to 
PHI trends, clinical analysis of deferral 
expectations and claims patterns with and 
without COVID-19 restrictions. 

o  Considered the appropriateness of the 

Group’s methodologies used to determine 
claims deferred to future periods with 
reference to PHI actuarial practices. 

124    Medibank 

 
 
 
Key audit matter 

How our audit addressed the key audit matter 

o 

o 

o 

o 

the impact and variability of disruptions to 
planned insured surgeries and other insured 
procedures arising from COVID-19 
restrictions 

an absence of historical precedent on which to 
analyse data due to the impact of COVID-19 
on claims patterns 
the determination of the proportion of claims 
not incurred that is attributable to COVID-19 
restrictions 

the estimation of the proportion of deferred 
claims expected to be made post balance date. 

• 

the focus on disclosures that are fundamental to 
understanding the impact of COVID-19 on the 
Group’s financial report, including the 
methodology and key assumptions used to 
estimate the COVID-19 deferred claims liability 
and the impact of changes in key variables on the 
COVID-19 deferred claims liability. 

Recognition of COVID-19 customer give backs 

(Refer to Note 3: $369.4m, Note 5: $133.5m and 
Note 13(c): $178.6m) 

The COVID-19 customer give backs represent the 
Group’s commitments to return permanent net 
COVID-19 savings to eligible customers arising from 
COVID-19 restrictions.    

COVID-19 customer give backs are recognised with 
reference to the Group’s publicly announced customer 
initiatives representing a return of past premiums to 
eligible policyholders prevented from accessing 
insured services during the period. 

The Group’s COVID-19 customer give backs 
announced during the year are recognised as a 
reduction in the financial statement line item ‘Health 
Insurance premium revenue’ on the consolidated 
statement of comprehensive income. The portion of 
COVID-19 customer give backs owed to customers as 
at 30 June 2022 is included in the consolidated 
statement of financial position as ‘Unearned premium 
liability’ (Note 5) or ‘Customer give back provision’ 
(Note 13(c)), depending on the mechanism used to 
give back to customers. 

o  On a sample basis, performed recalculations 
over the mathematical accuracy of the 
Group’s COVID-19 claims liability model. 

•  Assessed the reasonableness of disclosure of the 
COVID-19 claims liability in the financial report 
against the requirements of the applicable 
Australian Accounting Standards. 

We performed the following audit procedures, 
amongst others: 

•  Developed an understanding of the Group’s public 
announcements and commitments to financial 
analysts, shareholders and policyholders during 
the year. 

•  Develop an understanding of the Group’s key 

controls relevant to estimating and processing the 
COVID-19 customer give backs.  

•  Assessed the reasonableness of accounting 
treatment and disclosure of the COVID-19 
customer give backs within the Group’s financial 
report against the requirements of the applicable 
Australian Accounting Standards, having regard 
to the Group’s public announcements, give back 
mechanisms and policyholder eligibility.  

•  Reconciled the amount and nature of customer 
give back public announcements made by the 
Group during the year with amounts recognised 
and disclosed in the Group’s financial report.  

Annual Report 2022    125 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Independent auditor’s report

Key audit matter 

How our audit addressed the key audit matter 

We considered this a key audit matter due to the 
impact of the Group’s public announcements on:  

●  key recognition criteria under applicable 

Australian Accounting Standards with reference to 
the nature of commitments made by the Group 
and eligibility of policyholders  

●  the classification and disclosure of customer give 
backs with reference to specific characteristics of 
the give back mechanisms. 

Estimation of the outstanding claims liability 

(Refer to Note 3: $406.8m) 

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% (2021: 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.   

•  Performed analytics over the proportion of 

COVID-19 customer give backs recognised as an 
unearned premium liability (Note 5) versus a 
customer give back provision (Note 13(c)) by 
comparing to the give back mechanisms publicly 
announced by the Group during the year.  

We performed the following audit procedures, 
amongst others:  

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, on a sample basis, whether these 
controls were operating effectively throughout the 
year 

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 PHI industry. 

•  On a sample basis, performed recalculations over 

the mathematical accuracy of the Group’s 
actuarial models. 

•  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 the 
Home Care group of Cash Generating Units 
(CGUs)  

(Refer to Note 12: $97.2m) 

The Group recognised goodwill of $97.2 million in 
respect of a number of in-home care businesses. This 
goodwill has been allocated to a group of Cash 
Generating Units (CGUs) 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: 

•  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. 

•  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 claims 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. 

Annual Report 2022    127 

 
 
 
 
 
Independent auditor’s report

Key audit matter 

How our audit addressed the key audit matter 

• 

• 

• 

financial significance of the goodwill allocated to 
Home Care which accounts for 48% of the 
goodwill balance recognised by the Group 

fact that the 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. 

•  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. 

•  On a sample basis, tested the mathematical 

accuracy of the value-in-use model. 

•  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 and key 
assumptions. 

•  Evaluated the valuation methodology supporting 

the Group’s impairment analysis against 
applicable Australian Accounting Standards. 

•  Compared the growth rate assumed in the cash 

flow projections extrapolated beyond three years 
to market data and industry research. 

•  Evaluated the Group’s discount rate assumptions 

against market data, comparable data and 
industry research.  

Reliance on automated processes and controls 

The Group utilises a number of complex and 
interdependent Information Technology (IT) systems 
to capture, process and report a high volume of 
transactions. 

We developed an understanding of the Group’s IT 
governance framework, as well as performing testing 
over the information technology internal controls 
designed to mitigate the risk of material errors in the 
Group’s financial report: 

We considered this a key audit matter because the: 

•  operations and financial reporting processes of 
the Group are heavily reliant on IT systems 

•  underlying IT controls over business processes are 
significant to the financial reporting process 

• 

• 

• 

• 

• 

program development and changes 

access to programs and data 

computer operations 

business process 

key automated controls and reports.  

128    Medibank 

 
 
 
 
Key audit matter 

How our audit addressed the key audit matter 

•  data migration activities which occurred during 
the year impacted the key IT processes, systems 
and controls relevant to the financial reporting 
process. 

Together with PwC IT specialists, we have evaluated 
the design and assessed, on a sample basis, the 
operating effectiveness of key IT controls relevant to 
the Group’s financial reporting processes.  

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 2022, 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. 

Annual Report 2022    129 

 
 
 
Independent auditor’s report

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. 

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 51 to 72 of the directors’ report for the 
year ended 30 June 2022. 

In our opinion, the remuneration report of Medibank Private Limited for the year ended 30 June 2022 
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 
18 August 2022 

130    Medibank 

Shareholder information

The shareholder information below is current as at 18 August 2022.

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

Number of 
shareholders

43,965

137,328

14,629

7,169

200

Number of 
shares

39,105,916

385,303,765

101,238,523

151,637,443

2,076,717,593

203,291

2,754,003,240

Unmarketable parcels 

There were 886 holdings of less than a marketable parcel ($500) of shares (141 shares based on a market price 
of $3.55 per share) and such holders held a total of 24,109 shares.

20 largest shareholdings

1 HSBC CUSTODY NOMINEES (AUSTRALIA) LIMITED

2

3

J P MORGAN NOMINEES AUSTRALIA PTY LIMITED

CITICORP NOMINEES PTY LIMITED

4 NATIONAL NOMINEES LIMITED

5 BNP PARIBAS NOMS PTY LTD 

Number of 
shares

904,623,020

494,010,434

294,226,334

116,099,097

93,624,000

6 HSBC CUSTODY NOMINEES (AUSTRALIA) LIMITED 

25,673,694

7 BNP PARIBAS NOMINEES PTY LTD 

8

CITICORP NOMINEES PTY LIMITED  

9 HSBC CUSTODY NOMINEES (AUSTRALIA) LIMITED - A/C 2

10 BNP PARIBAS NOMINEES PTY LTD HUB24 CUSTODIAL SERV LTD 

11 AUSTRALIAN EXECUTOR TRUSTEES LIMITED 

12 NAVIGATOR AUSTRALIA LTD  

13 NETWEALTH INVESTMENTS LIMITED 

14 BOND STREET CUSTODIANS LIMITED 

15 NETWEALTH INVESTMENTS LIMITED 

16 BNP PARIBAS NOMINEES PTY LTD ACF CLEARSTREAM

17 SOLIUM NOMINEES (AUSTRALIA) PTY LTD 

18 AUSTRALIAN EXECUTOR TRUSTEES LIMITED 

19 NAVIGATOR AUSTRALIA LTD 

20 NULIS NOMINEES (AUSTRALIA) LIMITED  

25,647,778

20,692,879

9,947,321

6,588,819

5,913,816

4,651,553

4,427,034

3,287,129

3,085,762

2,511,692

1,782,571

1,773,399

1,696,936

1,660,511

% of 
issued capital

32.85

17.94

10.68

4.22

3.40

0.93

0.93

0.75

0.36

0.24

0.21

0.17

0.16

0.12

0.11

0.09

0.06

0.06

0.06

0.06

Total

2,021,923,779

73.42

Annual Report 2022    131 

Shareholder information

Substantial shareholders

As at 18 August 2022 the following holders had provided a substantial shareholding notice:

Number of shares % of issued capital

224,049,642

141,100,861

137,868,557

8.13%

5.12%

5.006%

Name of holder

BlackRock Group

State Street Corporation

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 2022, 825,420 
Medibank ordinary shares were purchased on market  
at an average price of $3.53 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 

Financial calendar

Key dates

Full year results announcement 

18 August 2022

Ex-dividend share trading commences 

7 September 2022

Record date for final dividend 

8 September 2022

Payment date for final dividend 

29 September 2022

Annual general meeting 

16 November 2022

Half year results announcement 

February 2023

Payment date for interim dividend 

March 2023

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  
Level 6, 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 2022    133 

 
 
 
Medibank Private Limited
ABN  47 080 890 259