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Medibank Private Ltd

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FY2023 Annual Report · Medibank Private Ltd
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Annual

Report 2023

Contents

Medibank Group – our story  
2023 highlights  
Chair’s message  
CEO’s message  

Delivering value to stakeholders through our strategy 
Deliver leading experiences 
Differentiate our insurance business 
Expand in health 
A sustainable future 

Operating and financial review  

Directors  
Executive leadership team  
Corporate governance statement  
Risk management 
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 
6

8 
10 
14 
18 
22

23

29 
32 
34 
45 
51 
54

74
75 
76 
77 
78 
79 
121 
122 
123

131

133

133

Sustainability

Report 2023

Annual

Report 2023

Full year results

2023

This report is part of our suite of reporting for the 2023 financial 
year. You can find more information about our performance in our 
Full Year Results Investor Presentation and Sustainability Report

References to a year are to the financial years ending 30 June in that year. References to COVID are for COVID-19. Reference to Net Zero 
or our Net Zero pathway are based on the 2022 business-as-usual operations of Medibank Private Limited (ACN 080 890 259) and its 
ultimately wholly owned subsidiaries and are exclusive of our investment portfolio. 

 
 
Medibank Group – our story

We’re a health company working to deliver the best health and wellbeing 
experience for Australia. From our beginnings as a health insurer, we’ve  
grown to become more to millions of people across the country. 

We’re giving people more control of their own health by working to provide greater choice, better access and 
more value. We’re investing more in preventative health and new ways of delivering care, working with other 
health innovators, hospitals and governments and we’re building more products and services personalised to 
people’s needs. In doing so, we’re changing healthcare for people across Australia – both now and in the future. 

Purpose

Vision

Better Health  
for Better Lives
The best health and 
wellbeing for Australia

Our strategy

Growing as a health company

Customer 
obsessed

Show  
heart

Brilliance 
together

Break 
boundaries

Health insurance

Health services

Diversified insurance

Travel

Pet

Life

Car and 
home

Health and wellbeing including Live Better program

Preventative health programs

Clinical homecare and virtual care

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

Investments in no gap programs

Values

Our brands

Sustainability 
focus areas

Customer 
health

Employee 
health

Community 
health 

Environmental 
health

Governance

Annual Report 2023    1 

2023 highlights

Delivering results

Customer

Healthcare

People and  
community

Financial

4m+

total health 
insurance 
customers

697k (+34%)

Live Better  
Rewards 
participants

7.7⁄10

employee 
engagement 

c. $1.15b

total COVID  
financial support 

 16,493 (+64%)

preventative health  
program participants

c. $3m

community  
investment

$511.1m  

(+29.8%)
Group net profit  
after tax 

14.6 cps

 total ordinary dividend

fully franked

Medibank

40.1 (-5.2)

ahm 

42.7 (+0.3)

customer advocacy 
(average Service NPS) 

+10.9k (+0.6%)

net resident 
policyholder growth

+78.4k (+39.9%)

net non-resident  
policy unit growth

$6b

total claims paid

2    Medibank 

 1.6m+

virtual health  
interactions 

5,129

patients used  
My Home Hospital

$15.5m

initial investment in 
iMH mental health 
joint venture 

Place to work

+23 

Products and service 

+24

employee advocacy

$650.4m (+9.8%) 

Health Insurance  
operating profit

$138.6m 

net investment income

3,640

employees 

including around

950

27.08% 

market share

c. $7m

health professionals

productivity savings

All data is presented on a statutory basis as at 30 June 2023. Some figures are subject to rounding.

" We are evolving as the 
needs of our customers 
evolve. We’re helping 
our customers both be 
better and get better"

    David Koczkar, CEO

Annual Report 2023    3 

Chair’s message

Committed to  
being responsible  
and sustainable

Mike Wilkins  AO

We have focused on doing what 
is right for our customers, our 
shareholders, our people and 
our community following the 
cybercrime event.

The 2023 financial year was a difficult 
one for Medibank, characterised by the 
cybercrime event which we identified 
in October of 2022 and an increasing 
difficult economic environment. 
Notwithstanding these challenges, the 
Company has continued to demonstrate 
its resilience and customer focus and 
delivered a solid financial result for  
the year.

At our 2022 Annual General Meeting, I 
said that Medibank would be measured 
on how we responded to the cybercrime 
and how we supported our customers. 
We have continued to focus on our 
customers and their needs, and while 
there is more work ahead for us, I am 
pleased to report that this focus has led 
to Medibank now having more than  
4 million health insurance customers, 
for the first time in our 47-year history.

The cybercrime was a significant event 
that has impacted both our customers 
and our people. It has been a critical 
focus for the Board throughout the 

year, particularly as we have overseen 
Medibank’s response to the event 
and support for those impacted, as 
well as the ongoing work to continue 
strengthening our IT security 
environment. 

We recognise the pressure on 
household budgets in the current 
economic environment, and we are 
responding to this by providing greater 
value for our customers through the 
products and services we offer. 

Recognising the expectations of our 
customers, our shareholders and our 
community for there to be meaningful 
consequences as a result of the 
cybercrime event, the Board determined 
the executive leadership team would 
receive zero short-term incentives 
for the FY23 year. You can find more 
detail on the decisions made in the 
remuneration section of this report. 

Throughout the 2023 financial year  
we have continued working to support  
the health and wellbeing of our 
customers and of our community.

Australia continues to grapple with  
the issue of productivity and the 
impact that this has on our economic 
settings. The health sector is certainly 
not immune to these pressures, and 
the role of companies like Medibank 
is to continue to drive innovation that 
will deliver better outcomes for our 
customers, while improving the  
overall efficiency of our system. 

Our investments in new patient-centric 
models of care and focus on prevention 
are not only benefiting our customers 
and patients, but also helping to 
address well-known challenges 
within our health system. Through our 
collaborative work with governments, 
hospitals and health professionals, we 
are improving health equity and helping 
to create a more sustainable health 
system for all people in Australia. 

This focus has helped to deliver a 
solid result this year, with a 9.8% 
increase in Health Insurance operating 
profit and 4.2% increase in Medibank 
Health segment profit from continuing 
business, positioning us for growth.  
At a Group level, Net Profit After 
Tax was up 29.8% to $511.1 million, 
including net investment income of 
almost $139 million. 

In June, APRA announced an additional 
capital adequacy requirement of  
$250 million on Medibank from  

4    Medibank 

Committed to  

being responsible  

and sustainable

1 July 2023 following a review of the 
cybercrime event. This requirement will 
apply until Medibank has met agreed 
key remediation milestones, which we 
will work to address through our IT 
security uplift program. The Company 
remains well capitalised, and in line 
with this we declared a fully franked 
final ordinary dividend of 8.3 cents per 
share, bringing our full year dividend  
to 14.6 cents per share fully franked 
– an increase of 9%.

Sustainability remains integral to our 
purpose of Better Health for Better 
Lives, and we continue to build upon  
our environmental, social and 
governance initiatives to make a  
positive impact on our community. 

As part of our journey towards Net 
Zero by 2040, this year we developed 
a strategy for transitioning to 100% 
renewable electricity. We also began 
engaging with investment fund 
managers to better understand their 
emissions reduction commitments  
as we consider a Net Zero pathway 
for our investment portfolio.

We continued to champion diversity  
and inclusion and met a range of 
targets set around gender diversity and 
the representation and engagement  

of employees with disability.  
We were also pleased to see 
engagement increase among our 
Aboriginal and Torres Strait Islander 
employees and we remain focused  
on increasing their representation  
in our business. 

To help create healthier communities, 
we continue to partner with parkrun 
Australia and build on our 10-year 
plan to address loneliness in Australia. 
As well, the Medibank Better Health 
Foundation marked a decade of 
supporting health research, investing 
around $1 million this year in 22 projects 
in areas of high health need in Australia.

2023 has been a challenging year for our 
company, and I would like to recognise 
the work of my Board colleagues, as 
well as the leadership shown by David 
and the executive team. The strength of 
Medibank has always been its people 
and throughout the past 12 months, 
they have displayed an unwavering focus 
on our customers and supported each 
other, for which I thank them. 

To our customers and our shareholders, 
we thank you for being with us. We will 
continue working to deliver the best 
health and wellbeing for you and for 
everyone in Australia. 

Sustainability

Report 2023

" We are committed to making 
a positive impact in the 
communities we are part of 
and our sustainability report 
highlights our work to help 
build a more sustainable 
future for all"

Annual Report 2023    5 

CEO's message

Supporting our 
customers and 
community

David Koczkar

We have worked really hard to 
regain the trust of our customers 
and while there is more to do, we 
are growing again.

To our shareholders, thank you for your 
ongoing support. It’s been a challenging 
year, but by focusing on our customers 
and managing our business well, 
momentum has returned following the 
cybercrime event.

Despite cost-of-living pressures, people 
continue to invest in their health and 
wellbeing, particularly younger people 
– across the industry we’ve seen the 
highest growth of people under 30 
taking out hospital cover in a decade. We 
grew resident policyholders by almost 
11,000, driven by families, younger 
people and those taking out cover for the 
first time. We also recorded the highest 
growth in our non-resident business in 
seven years and have delivered a strong 
result for our shareholders

Delivering for customers has been and 
remains our focus. Value starts with 
premiums, and our average resident 
premium increase in June 2023 was 
our lowest in 22 years and well below 
headline inflation. During the year we 
provided an additional $469 million in 
COVID support to our customers, with 

our total support now at more than  
$1 billion. 

We have also focused on providing  
value for money to our customers  
when they use their cover. Our 
Members’ Choice Advantage network 
saved customers more than $25 million 
in out-of-pocket costs while customers 
having a knee or hip replacement  
saved an average of $1,600 through  
our growing no gap network. 

We continued to evolve our relationship 
with customers across both our brands, 
with more people turning to us for 
additional services and products we 
offer as a health company, not just 
an insurer. In fact, around 30% of our 
Medibank customers engaged with  
one of our health offerings this year. 

Our Live Better program now has 
almost 700,000 members and 
enrolments in our preventative health 
programs grew 64% this year. Our 
Amplar Health team continues to work 
alongside governments and others 
to deliver health services across 
Australia. This team is supporting 
more customers alongside its work in 
the community, providing more than 
1.6 million virtual health interactions 
during the year. 

With demand for healthcare continuing 
to increase, the way the industry 
supports the health of our population 
needs to change if we are to sustain 
patient outcomes, support access and 
improve affordability – and ultimately 
drive productivity across our health 
system. Given the current challenges 
across the sector, we simply can’t move 
fast enough. Our focus on prevention and 
innovating in health is helping drive this 
change, enabled by the strength of our 
relationships with health professionals, 
hospitals and other partners. 

This is why we’re investing in a new 
mental health model in the private 
system that extends care beyond the 
hospital walls. It’s behind the virtual 
hospital we deliver through a joint 
venture with Calvary which is currently 
delivering the My Home Hospital service 
for the South Australian government – a 
service that saved more than 19,000 bed 
days in the public system this year. It’s 
driving the growth of our preventative 
health programs and our work in the 
community to improve health and 
wellbeing. It’s also why the majority of 
our hospital agreements incorporate 
new ways to support patients.

Nearly 12 months on from the 
cybercrime event, we have continued 

6    Medibank 

“ Our eyes are firmly 
focused on continuing 
to play a greater role in 
supporting the health 
needs of our customers” 

to support people impacted by the 
event, with mental health and wellbeing, 
identity protection and financial hardship 
among the support measures available. 
We have made good progress on our IT 
security uplift program which continues to 
enhance IT security across our business 
and mature our cybersecurity approach. 
We also established a new cross-
divisional customer trust team in July 
2023 to continue evolving our approach to 
safeguarding the data of our customers. 

While it has been a very challenging 
year we have listened and learnt, and we 
continue to strengthen our organisation. 
We are a resilient business and remain 
well positioned for the future where we 
will continue to play a greater role in 
supporting the needs of our customers, 
driving our growth as a health company 
and improving the way healthcare is 
delivered in Australia. 

To help us on this path, we are reinventing 
the way we work by challenging long-
held workplace traditions to empower 
our people to achieve our 2030 vision 
to deliver the best health and wellbeing 
for Australia. Changes to the executive 
leadership team announced in July 2023 
will also help us achieve this.

As we look forward, there is much to do, 
but I cannot think of a better group of 
people to deliver on our potential than the 
team across Medibank. They’ve navigated 
through a year that’s offered up both 
challenges and opportunities in equal 
measure – and they have delivered on 
both counts. I want to thank them for  
their commitment to our customers and 
to each other, and also thank Mike and  
the Board for their ongoing support as  
we continue play a bigger role in the 
future of health in Australia.

FY24 outlook

Customer 
relief

Resident 
policyholder  
growth

We continue to assess  
claims activity. Any  
permanent net claims  
savings due to COVID 
will be given back to 
customers through  
additional support in  
the future. 

We anticipate further 
moderation in resident 
industry growth in FY24 
relative to FY23.

Aiming to achieve  
1.5%-2.0% resident 
policyholder growth  
in FY24.

Resident 
claims

Underlying claims per  
policy unit growth of 2.6% 
for FY24 among resident 
policyholders.

PHI 
management 
expenses

Targeting $20m of  
productivity savings  
across FY24 and FY25.

Cybercrime 
costs

Growth 

Expect costs of between 
$30m-$35m in FY24 for 
further IT security uplift  
and legal and other costs 
related to regulatory 
investigations and litigation. 

–  Excludes the impacts of 
any potential findings or 
outcomes from regulatory 
investigations or litigation.

Targeted organic and  
inorganic growth for  
Medibank Health and  
Health Insurance remain 
areas of focus.

Annual Report 2023    7 

Delivering value to stakeholders through our strategy

Our stakeholders

Customers

Employees

Community 

Shareholders

The material issues they care most about

Affordable, 
innovative and 
personalised 
healthcare

Engaged, purpose-
led culture, attract 
and retain talent

Diverse and  
inclusive workforce

Support healthy 
communities

Ethical and 
sustainable  
business 

Environmental health and climate change

The megatrends in health 

Health providers 
and patients 

Work together 
to build a 
stronger and 
more sustainable 
health system 

Consumerisation 
of health

The shift to 
prevention

The rise of new 
care settings

Outcome-based 
care

Our strategy – growing as a health company

Deliver leading  
experiences

Differentiate our  
insurance business

Expand  
in health

Create personalised and  
connected customer experiences 

Deliver more value, choice  
and control for customers

Empower our people

Collaborate with our communities 
to make a difference

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

How we’re delivering 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 
challenges 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 healthcare 
innovation to make the 
health system more 
equitable, affordable and 
accessible, investing in 
prevention and primary 
care and working with 
doctors, hospitals and 
governments

8    Medibank 

Delivering value to stakeholders through our strategy

Growing as a  
health company

" By investing in new care models 
and preventative health, we’re 
changing healthcare in Australia 
and creating a more sustainable 
system for everyone"

   Mike Wilkins, Chair

Annual Report 2023    9 

Deliver leading 
experiences

Our goals

>  Create personalised and connected customer experiences 
>  Empower our people 
>  Collaborate with our communities to make a difference

FY23-FY25  
milestone  
achievements

page 28

85% 

of Medibank customers engaged 
through digital channels

10    Medibank 

We made it simpler for customers to manage their health 
and wellbeing and make healthy choices. We’re reinventing 
our workplace to empower our people and partnering with 
others to create healthier communities. 

Supporting our customers  
through the cybercrime

This year, our customers were the 
victims of a cybercrime and our focus 
on supporting them was and continues 
to be our priority. To help everyone 
impacted, we launched our Cyber 
Response Support Program including 
mental health and wellbeing support, 
identity protection and financial hardship 
measures. We extended our contact 
centre hours, increased our customer 
support team by more than 300 people 
and redeployed our people to phone 
and messaging channels to support our 
customers. We continue to strengthen 
our security environment – we launched 
additional measures including two-
factor authentication for customers 
contacting our contact centre and we 
continue to enhance our IT security 
processes and security systems so  
our customers can have confidence  
in the protection of their data. 

You can find more information about  
our response to the cybercrime

Sustainability Report – page 72

Improving our customer 
experience

As we’ve continued to build a more 
seamless digital experience that 
makes it simpler and easier for our 
customers, more people are choosing 
to use these channels. We enhanced 
the My Medibank app – integrating our 
health support programs, adding more 
Live Better features and analysing 
customer calls to help us identify the 
most common information requested 
so we can look to build new features 
and content in the app. Almost half 
of our Medibank service enquiries 
were managed through self-service 
channels, while our messaging channel 
team resolved more than a third of all 
assisted support queries.

We initiated a pilot program to equip 
our frontline leaders with enhanced 
abilities to support and guide their 
teams effectively, introduced new tools 
to simplify processes and help our 
people in assisting customers, and 
revitalised our onboarding training for 
new employees, including bolstering 
the specialised assistance they receive 
during their initial months.

Our ahm team were also focused on 
making it easier for customers to self-
serve, including redesigning the support 
section of the website and introducing a 
simple online hospital cost indicator tool 
to help customers understand what their 
cover includes and any associated costs. 
Now around 65% of all ahm queries are 
resolved using self-service channels. 

To better support our customers and 
communities in regional and rural 
areas, we brought our services to them, 
visiting 140 towns with our Medibank 
vans and kiosks this year. Our travelling 
teams have helped thousands of people 
with their health and wellbeing needs, 
assisting them with our products 
and services, while the new health 
machines we installed in each of our  
3 mobile store vans provided free health 
checks to around 1,400 people.

We’ve strengthened our ties to local 
communities so we can better support 
our customers’ health and wellbeing. In 
Geelong and throughout South Australia 
we’re trialling a new localised approach, 
in which customers from the region 
are being supported by team members 
who live locally, regardless of whether 
they visit a store, call us or connect via 
our digital channels. The teams are 
also deepening relationships with local 
health providers and corporate partners 
to make it easier for customers to find 
the right health support locally. These 
teams also have greater autonomy 
to implement their own ideas to help 
improve the health of their community.

Personalised 
and connected 
experiences

Medibank

ahm 

40.140.1 (-5.2) 42.742.7 (+0.3)
customer advocacy 
(average Service NPS) 

22%

growth in active users  
of My Medibank app

82%

of ahm customers 
logged in via app 

3,372

people helped by 
our Medibank vans

Annual Report 2023    11 

Deliver leading experiences

44%

of Board roles held  
by women

48%

of senior leadership  
roles held by women

Top 3 worldwide 
and 2nd
 in Australia
Equileap Global Gender  
Equality Index 

83%

employees have work/life 
flexibility 

In Brisbane and the Gold Coast, 
our Amplar team of allied health 
professionals are trialling a similar 
localised approach to supporting 
patients in the area. This has enabled 
them to more effectively pair patients 
and practitioners together for a course 
of treatment and reduce the time 
team members are travelling between 
appointments.

Building a workplace reinvented  
for our future

The strength of our culture and the 
importance of our values were never 
more important than throughout the 
cybercrime event. They underpinned 
our decision-making, drove our 
customer-first mindset and were visible 
in the care our employees showed for 
each other. Despite a challenging year, 
our people continued to feel strongly 
engaged, inspired by our vision and our 
focus on health and wellbeing. 

We know that to achieve our vision 
and create better experiences for 
our customers and community, we 
need to transform the way we work. 
Our work. reinvented program aims 
to foster greater collaboration and 
experimentation and earlier this year 
more than 2,200 of our people took part 
in workshops to reimagine what their 
work could look like both now and in the 
future. In addition to the many changes 
individual teams have made to their 
daily processes, we’ve now launched  
4 big experiments across the business 
focused on empowering self-managing 
teams, removing red tape, redesigning 

performance management and career 
development and challenging the 
traditional work week that builds on our 
market-leading approach to flexibility.

We continued building a more inclusive 
and diverse workplace and community. 
Our work to help address gender equality 
saw us recognised as top 3 worldwide 
and 2nd in Australia in Equileap’s Global 
Gender Equality Index. We exceeded 
our targeted procurement spend with 
Aboriginal and Torres Strait Islander 
businesses and implemented new 
recruitment processes to help increase 
the representation of Aboriginal and 
Torres Strait Islander employees. 
We also consulted widely with our 
people, including Aboriginal and Torres 
Strait Islander employees, to build 
understanding and awareness around 
the Uluru Statement from the Heart. 
This consultation informs the way we are 
demonstrating support for a First Nations 
Voice to Parliament and prioritising the 
cultural safety of employees. 

Find out more about our approach  
to Reconciliation 

Sustainability Report – page 50

We partnered with lived experience 
employees and stakeholders to design 
new learning modules about inclusion, 
disability awareness and reconciliation for 
our annual mandatory training program 
and were recognised by the Australian 
Network on Disability as a Top Performer 
in the 2022-23 Access and Inclusion Index 
for our work in social value procurement 
and products and services.

7.7/10

employee 
engagement

12    Medibank 

   
$940k

invested in 
22 active health  
research projects 

c. $1.4m 

procurement spend with 
Aboriginal and Torres Strait 
Islander businesses  

c. $3m

community investment

Building healthier communities

We’re working to make our 
communities healthier so that everyone 
can enjoy their best life. 

Across Australia, loneliness continues 
to be felt by more than half of our 
community, with far-reaching impacts 
to peoples’ health, relationships, 
work and study. We worked to raise 
awareness of loneliness and ways to 
better manage it by developing a new 
season of our We Are Lonely podcast, 
continuing our work with Ending 
Loneliness Together and establishing 
new partnerships with ReachOut and 
the University of Technology Sydney. 

In support of our ongoing partnership 
with parkrun Australia we launched 
a road trip to 12 locations across the 
country and helped parkrun Australia 
reach its goal of 900,000 participants 
two years ahead of schedule. Together 
we’re now working towards 1 million 
people experiencing the joy of crossing 
a parkrun finish line by the end of next 
financial year. 

The Medibank Better Health Foundation 
celebrated 10 years of supporting 
research that benefits the health of 
our customers and all Australians. 
This year the foundation supported 
22 projects and partnered with the 
Royal Australian College of General 
Practitioners (RACGP) to launch a 
$250,000 grant to fund research into 
digital health in primary care.

We’ve committed to achieving Net 
Zero by 2040 and have been working 
towards our first milestone of 
achieving Net Zero against our Scope 
1 and 2 emissions by 2025, including 
developing our strategy for the move 
to 100% renewable electricity. We’ve 
looked to reduce our environmental 
impact by trialling new options for 
employees finishing with the business 
to reuse and recycle their IT hardware 
in their local community and donating 
excess furniture to new businesses. 

Find out more about our approach  
to diversity and inclusion and Net Zero

Sustainability Report

300k+ 

people took  
part in parkrun  
in FY23, inc. 
 100k  
first timers

Annual Report 2023    13 

   
   
Differentiate our 
insurance business

Our goals

>  Deliver more value, choice and control for customers 
>  Offer products and services to meet all customer needs 
>  Leverage our dual brands and provider networks

FY23-FY25  
milestone  
achievements

page 28

4m+ 

health insurance customers

as at 30 June 2023

14    Medibank 

We worked to deliver even 
greater value and choice 
through our Medibank and 
ahm brands by enhancing 
our products and services 
and expanding our provider 
and partner networks.

More value, more ways

People continued to prioritise their 
health and wellbeing despite financial 
pressures increasing for many and 
we have responded to the affordability 
challenge by doing more for our 
customers. The health insurance 
industry has now seen 12 consecutive 
quarters of growth and our Medibank 
and ahm brands together represent 
more than 27% of people with private 
health insurance.

We returned a further $469 million 
to customers this year as part of our 
COVID support package and give back 
program. At the beginning of the 
pandemic we committed to not profit 
from COVID and we’ve kept our promise 
and our financial support for customers 
now totals around $1.15 billion. 

We checked in with almost 600,000 
customers to talk about their health 
cover and if it was the right one for 
their needs. We also launched our new 
Medibank Silver hospital cover range 
designed for people aged between 40 
and 60 offering new benefits including 
reduced out-of-pocket fees for private 
emergency department visits, access 
to preventative health programs for 
eligible customers and no excess  
when using the no gap program. 

Around 2,500 customers have saved 
thousands of dollars through our  
no gap program which expanded  
to 34 hospitals across the country 
including regional areas such as the 

Sunshine Coast and Albury-Wodonga. 
Our no gap joint replacement program 
can now be accessed by more than 
66% of Medibank customers, locally 
available at 19 hospitals. We also 
launched a new mental health model 
through a joint venture with Aurora 
Healthcare at Deakin Private Hospital, 
incorporating out-of-hospital services 
at no additional cost for patients with 
eligible health insurance apart from 
any excess or co-payment that would 
normally apply, with another two 
hospitals to follow. 

Find out more about our no gap  
and short stay programs

Sustainability Report – page 18 and 19

Since we adopted government reforms 
to extend the age that young adults 
could stay on their parents’ policy from 
24 to 30 years old, we saw around 
24,200 people remain covered across 
Medibank and ahm. 

We saw strong growth in the number of 
customers taking our travel insurance 
this year, while many others took 
advantage of the additional benefits 
and savings we offered on life, pet, car 
and home insurance. We introduced 
a complimentary 24/7 online vet 
consultation service and gap-only 
payments at a wide network of vet 
practices as part of our pet insurance 
and launched a new suite of life 
insurance products. 

Better products 
and services

34

hospitals in our  
no gap network

$1,600 

(average saving) no gap  
joint replacement program 

586,288

customer cover check ins 

$469m 

in FY23 COVID  
financial support

c. $1.15b total

Annual Report 2023    15 

Differentiate our insurance business

We continued to build upon our 
extensive network of health providers 
and partners to broaden the services 
and support we offer to our customers. 
Through our Members’ Choice 
Advantage network we provided our 
customers with greater value, more 
cost transparency and the widest range 
of services of any health insurer and 
this year, saved customers more than 
$25 million in out-of-pocket costs. 

We rewarded more people for making 
healthy choices – expanding our Live 
Better program to overseas workers 
and visitors, launching card linking 
to make it easy to shop and earn Live 
Better points with existing partners 
such as Apple, adidas and Brooks, 
and new partners such as The Iconic 
and Lite’n’Easy who we added to our 
rewards store this year. 

We paid $6 billion in claims and 
delivered our lowest average premium 
increase in 22 years which we then 
deferred by two months. We negotiated 
new funding agreements with major 
hospital partners, collaborating on 
initiatives to deliver greater mutual 
value; and we continued to manage  
our costs, delivering productivity 
savings of around $7 million this year. 

Our focus on value was again 
recognised this year by Canstar which 
awarded ahm outstanding value for 
overseas student health cover and 
Medibank for working visa health  
cover, while the value and quality of 
both brands’ travel insurance was 
recognised by Finder and Mozo.

Supporting our international 
customers and corporate teams

As travel restrictions ended and people 
began returning to Australia, we had 
our highest number of student, visitor 
and working visa customer joins 
in 7 years. Helping drive this is the 
extensive health and wellbeing support 
integrated into our health insurance 
offerings, such as the online GP service 
and student rewards program we’ve 
created as part of our Overseas Student 
Health Cover (OSHC). We continued 
to retain and grow our partnerships 
with universities around the country 
and contribute to the academic and 
professional student experience by 
providing mentor programs and student 
internships as well as collaborating on 
health research. 

$25.1m

out-of-pocket savings 
through Members’ 
Choice Advantage 

$6b 

total claims paid

Services supported

1.1m+

hospital admissions

27.4m+ 

extras services

500k+

surgical procedures 

16    Medibank 

An increasing number of our corporate 
partners looked to us to deliver health 
and wellbeing programs for their 
employees. We helped organisations 
design and deliver programs to 
bring employees back into the office 
to collaborate, engage and focus 
on their physical health, to create 
psychologically safe work environments 
and to offer virtual health support. 

A healthcare system better for all

We’re advocating for reforms that can 
help ensure healthcare is delivered in 
the most effective and efficient manner 
possible.

As people in Australia continue to  
pay some of the highest prices in 
the world for medical devices, we 
maintained our focus on the urgent 
need to reduce these costs. With the 
first stage of prostheses reform taking 
place in July 2022, we’ve started to see 
some impact of these changes which 
we expect to flow through over the next  
3 years, but we believe more needs to 
be done to fully realise the opportunity 
to deliver around $900 million in annual 
savings to all private health insurance 
customers, as anticipated by the 
Australian Government. We remain 
committed to passing on these savings 
to our customers. 

We were the first major health insurer 
to adopt the Federal Government’s 
voluntary age dependent reforms, 
extending the age that young adults 
could stay on their parents’ policy from 
24 years old until their 31st birthday.

We believe primary care is the 
foundation of our health system and 
GPs are essential to the health of 
our community. We’re supportive of 
the recommendations made in the 
Strengthening Medicare Taskforce Report 
which addresses ways to improve 
primary care and was handed to the 
government this year. We’ve been 
exploring ways we can enhance our 
health services operations in line with 
these recommendations and will share 
our findings with the government. 

We’ve also engaged regularly with key 
medical and health associations about 
ways to improve the health system, 
particularly in regard to primary and 
preventative care and chronic disease 
management, including working with 
the Australian Patients Association to 
advocate for health policy to reflect a 
patient-centred view of healthcare. 

Find our more about our work to  
deliver more affordable healthcare 

Sustainability Report

Annual Report 2023    17 

+78.4k (+39.9%)

non-resident  
policy unit growth 

36% 

growth of corporate partners 
using health services 

Medical device prices 
in Australia are the 
highest in the world

Private Healthcare Australia

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

FY23-FY25  
milestone  
achievements

page 28

10,638 

customers used 
Medibank at Home 

18    Medibank 

People deserve healthcare 
that is personalised to their 
needs and provides a more 
connected experience.

Personalising healthcare  
for our customers

We’re targeting some of Australia’s 
biggest health concerns through our 
preventative health programs and 
supporting people to make healthy 
choices. Our Live Better program has 
grown to almost 700,000 members, 
many of whom are engaging more 
regularly with the program and with  
our health campaigns – such as 
the 61,000 redemptions of our flu 
vaccination voucher. 

We introduced complimentary customer 
health checks with our registered 
nurses, and more than 16,000 people 
enrolled in one of our 9 preventative 
health programs. These programs are 
not only helping our customers to be 
healthier, they’re also taking pressure 
off our health system, saving the 
equivalent of around 55,000 hospital  
bed days. 

We also developed customised health 
programs for one of our corporate 
clients to help address the needs 
of their employees and the local 
community, including piloting a 
menopause program that featured  
one-on-one health consultations with 
a GP and workplace education and 
training, as well as establishing an 
orthodontic clinic in a remote area 
where no service was accessible. 

We made it easier for customers to find 
the care they need by connecting our 
healthcare offerings through the Home 
for Health tab in the My Medibank app, 
and saw nearly 800,000 unique daily 
views of this content since launch in 
January. We supported more than 
27% of our customers who required 
a hospital stay through our Health 
Concierge program, which we expanded 
this year to include a post-discharge 
service offering tailored support from 
nurses to make the transition home 
from hospital easier.

Making healthcare 
personal 

697k

Live Better Reward 
participants

27%

of Medibank customers  
going to hospital were 
supported by Health Concierge

769k

unique daily views of 
Home for Health content

 16,493 (+64%) 

customers enrolled in 
preventative health programs

“ One of the best things of this program was the ease and 
convenience, particularly with the exercise that I could even do 
in my caravan. The virtual side of things made it so convenient 
because you didn’t have to make appointments and drive through 
peak hour traffic to get to the meetings, they came to you.” 

   Leanne, Medibank customer and Better Knee, Better Me participant

Find out more on our preventative health approach

Sustainability Report – page 14

Annual Report 2023    19 

Healthcare the way people want it

We brought healthcare to our 
customers and community in more 
accessible, convenient ways. Our 
homecare teams helped more people 
in their homes than ever before, 
delivering hospital in the home, rehab, 
chemotherapy, infusion and wound 
therapy and palliative care through 
more than 250,000 home visits saving 
around 115,000 hospital bed days. 
The number of Medibank customers 
accessing our homecare services 
increased by 47% this year, with  
around 30% of Medibank patients  
who underwent a joint replacement 
choosing to have rehab at home. 

We continued developing our virtual 
health capabilities, strengthening our 
healthcare navigation and support and 
investing in new technology platforms 
to enhance our services. Our Amplar 
Health team learnt a lot from the first 
pilot of our virtual psychology program 
we ran in partnership with Myhealth 

GP clinics and Medinet and in April 
we relaunched the program across 
the clinics, providing hundreds of 
consultations in the first 3 months  
of the new service. 

Our Amplar Health virtual health teams 
supported more than 1.6 million calls 
and online interactions this year. In 
addition to the 24/7 general health 
and mental health support lines and 
online GP services we provide for our 
customers, we continued delivering a 
number of health services on behalf of 
governments including Nurse Triage for 
Healthdirect, After Hours GP and 24/7 
GP, NSW Quitline and the Head to Health 
service in WA. We also completed two 
key health programs through which we 
supported over half a million people – the 
COVID-19 Support Line for NSW Health 
and COVID Care at Home for Western 
Sydney Local Health District, delivered 
by our joint venture with Calvary.

We can deliver health services to

97.51%

of people across Australia

 1.6m+ 

virtual health  
interactions

26.1k

virtual health and  
online GP consults for 
international students  
and corporate customers

30%

of Medibank joint  
replacement patients  
are having rehab at home

250k+  
homecare visits
supporting 31k patients 

20    Medibank 

Expand in health$15.5m

initial investment  
in iMH mental health  
joint venture

almost 3m

patient consults across 
 108 Myhealth GP clinics  

Building a better health system

We are driving change in Australia’s 
health system, innovating with models 
of care that bring together the best 
benefits of homecare, virtual care 
and hospital care and building a more 
connected healthcare experience.

This year, the Calvary Medibank Joint 
Venture’s virtual hospital was accredited 
as one of the first standalone virtual 
hospitals to deliver hospital-level care. 
Our virtual hospital delivers My Home 
Hospital on behalf of SA Health. More 
than 5,000 patients were cared for in 
their home through this service which 
also expanded to support a broader 
range of health conditions and service 
a greater number of regions across 
Adelaide and its surrounding areas. 

To boost access to primary care for 
people living in northern NSW, we 
worked with Healthy North Coast to 
create a free 24/7 health support service 
to help residents find and access the 
right level of care for their needs. 
We worked collaboratively with local 
primary care providers and pharmacies 
to support improved priority access 
to appointments and enable direct 
connections to healthcare services.

We’ve also been investing in 
strengthening our health system, 
building new hospitals, surgical centres 
and operating theatres and partnering 
in new care models that can take the 
pressure off stretched hospital systems. 

Our iMH joint venture with leading 
specialty mental health provider 
Aurora Healthcare offers an innovative 
integrated mental health model that 
will deliver 153 much needed new 
mental health beds across 3 new 
private hospitals, alongside additional 
out-of-hospital support including 
homecare and telehealth. 52 beds are 
currently operating at Deakin Private 
Hospital in Canberra, with two hospitals 
to open in FY24 and FY26. 

Building is also underway on Adeney 
Private Hospital in Melbourne and 
the orthopaedic surgical centre at 
Macquarie University Hospital in 
Sydney, both of which will open in 2024, 
while East Sydney Private Hospital, 
which we have invested in, opened a 
new orthopaedic theatre to deliver short 
stay surgery and support the public 
system with around 20% of surgeries 
undertaken this year helping to reduce 
public wait lists. 

Our focus on supporting the broader 
healthcare system through innovative 
new models of care is not only 
benefiting our customers but helping  
to make healthcare more equitable  
for people across Australia.

Find out more about how we're  
changing healthcare in Australia

Sustainability Report

5,129

patients used  
My Home Hospital
saving 19k+  
hospital bed days 

Annual Report 2023    21 

A sustainable 
future

To deliver on our purpose of Better Health for Better Lives, we need to ensure our actions 
positively benefit our society, both now and in the future. Our Sustainability Report 2023 details 
how we are working to create healthier communities that are more inclusive, strengthening 
our health system so it is more accessible and affordable, helping address climate change by 
reducing our impact on the environment, and embedding ethical decision making in all we do. 

Our sustainability focus areas

Customer 
health

Employee 
health

Community 
health 

Environmental 
health

Governance

Better support our 
customers to improve 
their health and 
wellbeing through 
personalised advice 
and by delivering 
greater value, access 
choice and control 
Build an engaged, 

inclusive workforce 
that is customer 
obsessed, values and 
purpose driven and 
focused on health  
and wellbeing

Make a difference 
in our community, 
building partnerships 
and investing in 
preventative health  
and research to 
address some of 
Australia’s biggest 
health concerns

Entrench 
environmental 
sustainability into  
our decision making

Embed ethical and 
responsible business 
practices throughout 
Medibank and our 
supply chain

Material topics

Affordable, 
innovative and 
personalised 
healthcare

FY23 projects

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 

•  No gap and short  

•  Work. reinvented

•  We Are Lonely podcast 

•  Net Zero commitment 

•  Data Protect program

stay networks

•  Health, safety and 

•  Virtual healthcare  

wellbeing 

and homecare

•  Integrated care models

•  Gender equality

•  Carers support 

•  Van visits to regional 

program

and rural areas 

•  Cultural awareness 

•  Live Better and 

programs

preventative health 
programs

•  Partnerships  
with providers

•  Cyber Response 
Support Program

22    Medibank 

•  Aboriginal and 

Torres Strait Islander 
employee recruitment 
and engagement

•  Diversity and 

Inclusion support 
networks

and partnerships

•  Medibank Better Health 
Foundation research

•  parkrun and Feel  
Good programs

•  Reconciliation  
Action Plan

•  Accessibility and 
Inclusion Plan

•  Healthcare investments 

•  Myhealth GP network

•  Public health system 

support 

•  Environmental 
sustainability 
embedded into  
new Melbourne  
office plans

•  Olkola carbon  

credits partnership

•  IT security uplift 

program

•  Aboriginal and 

Torres Strait Islander 
procurement

•  Modern slavery  

and human rights

Operating and financial review

1. About Medibank

Medibank Private Limited (Medibank) is a health company 
providing health insurance to more than 4 million people in 
Australia as well as health services. Our core business is 
Health Insurance, where 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: 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; we offer a range 
of diversified insurance products such as travel, life, home 
and pet insurance; and we have a number of non-controlling 
investments supporting our strategy to provide greater access, 
choice and flexibility in healthcare. 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 2023, we had 
3,242 full-time equivalent (FTE) employees, including 723 
health professionals (excluding employees in associates and 
joint ventures). 

2. Financial and operating performance

References to “2022”, “2023” and “2024” are to the financial 
years ended on 30 June 2022, 30 June 2023 and 30 June 
2024 respectively, unless otherwise stated. The “Group” 
refers to the consolidated entity, consisting of Medibank  
and its subsidiaries. 

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)
Other income/(expenses)
Cybercrime costs
Profit before tax
Income tax expense
Group net profit after tax (NPAT) 
Effective tax rate
Earnings per share (EPS) (cents) 
Normalisation for growth asset returns
Normalisation for defensive asset returns
Underlying NPAT1
Underlying EPS (cents)1
Dividend per share (cents)
Dividend payout ratio1

2023
7,355.3
650.4
44.2
694.6
(47.1)
647.5
138.6
(12.6)
(46.4)
727.1
(216.0)
511.1
29.7%
18.6
(4.7)
(6.8)
499.6
18.1
14.6
80.5%

2022
7,128.5
592.6
45.5
638.1
(44.0)
594.1
(24.8)
(9.3)
-
560.0
(166.1)
393.9
29.7%
14.3
22.7
18.5
435.1
15.8
13.4
84.8%

Change
3.2%
9.8%
(2.9%)
8.9%
7.0%
9.0%
n.m.
35.5%
n.m.
29.8%
30.0%
29.8%
-
29.8%
n.m.
n.m.
14.8%
14.8%
9.0%
(430bps)

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.

During the year, Medibank and our customers were the subject 
of a cybercrime event whereby a criminal accessed Medibank 
systems using stolen credentials and stole information relating 
to around 9.7 million current and former Medibank and ahm 
customers, as well as My Home Hospital patients and healthcare 
providers. In response, we took immediate steps to contain the 
incident and put in place additional security measures across 
the network. We engaged specialised security firms and worked 
with the Australian Government’s lead cyber agency and the 
Australian Federal Police. We closed down the criminal’s attack 
path and can confirm no further activity by the criminal since  
12 October 2022 has been detected inside our systems.

Medibank established a Cyber Response Support Program 
to support its customers from the impact of the cybercrime 
which includes mental health and wellbeing support, identity 
protection and financial hardship measures. We have incurred 
$46.4 million of non-recurring costs associated with the 
cybercrime, largely related to our incident response and the 
customer support package. We expect $30 million to  
$35 million in 2024 for further IT security uplift, legal costs and 
other costs related to regulatory investigations and litigation. 
This does not include the impacts of any potential findings or 
outcomes from regulatory investigations or litigation. 

Annual Report 2023    23 

Operating and financial review

Following the cybercrime event, litigation and regulatory 
investigations have commenced. Refer to Note 13(d) of the 
2023 financial statements for further details. 

The 2023 financial results reflect the resilience of our Health 
Insurance business, strong underlying profit growth in 
Medibank Health and continued strong capital generation.

Group operating profit increased 9.0% to $647.5 million driven by 
strong growth in Health Insurance operating profit of 9.8%, partly 
offset by a decline in Medibank Health segment profit of 2.9%.  

In addition to the increase in Group operating profit, there was 
also a significant increase in net investment income of  
$163.4 million which resulted in a 29.8% increase in NPAT 
to $511.1 million. Underlying NPAT, which adjusts for the 
normalisation of investment returns, increased 14.8% to  
$499.6 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

Strong Health Insurance performance was driven by 
continued policyholder growth and subdued cover 
downgrading more than offsetting claims growth in the 
resident business, and strong policy unit growth and margin 
recovery in the non-resident business. 

Health insurance premium revenue grew 4.2% to $7,148.7 million 
on a reported basis, and underlying revenue, which adjusts 
for the $451.7 million of COVID-19 give back initiatives in 2023 
and $369.4 million in 2022, increased 5.1% to $7,600.4 million.

The resident Health Insurance market remains buoyant with 
policyholder growth of 1.9% only modestly below 2022. This is 
despite the implementation of the Adult Dependant Reform 
(ADR), which allows eligible dependants to remain on their 
parents’ policy up to and including 30 years of age. This reform 
has increased the number of 25 to 30-year-olds insured 
overall, however has reduced growth in single policies.

Industry policyholder and hospital lives insured growth
Industry policyholder and hospital lives insured growth

3.5%

3.0%

2.5%

2.0%

1.5%

1.0%

0.5%

0%

1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23

Policyholder growth (%)

Hospital lives growth  (%)

24    Medibank 

2023
7,148.7
(5,925.9)
1,222.8
(572.4)
650.4
17.1%
8.0%
9.1%

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

Change
4.2%
3.4%
8.3%
6.8%
9.8%
60bps
20bps
50bps

Our reported net resident policyholders increased by almost 
11,000 or 0.6% with a modest 0.4% decline in the Medibank 
brand and 3.4% growth in ahm, with this growth coming 
in the seasonally stronger fourth quarter. With business 
operations normalising during the third quarter, retention 
has progressively improved despite premium increases 
in the second half. Acquisition also improved in line with 
additional marketing activity and increased ahm aggregator 
sales, however our strategic focus continues to be on more 
profitable direct channels which accounted for 79% of total 
resident sales this year. 

Aided by the ADR, growth in hospital lives insured of 0.9%  
was 30 basis points above our policyholder growth and 
skewed towards younger customers. We expect further 
benefits from ADR over the next five years, and given our 
strong position in the family market, we anticipate the 
percentage of lives insured that are under 30 years of age to 
increase. These customers typically have a lower claiming 
profile, and we expect this will positively impact our overall 
claims mix. In 2024 we will continue to focus on growing 
market share through further capitalising on our dual-brand 
strategy, increasing our focus on growing in the corporate 
market and investing where it is commercially appropriate. 

In the non-resident business we saw continued strong 
momentum with policy units increasing 39.9% to 274,900. 
Strong policy unit growth continued in July and August,  
and we expect ongoing growth in 2024.

Total gross claims expense increased 3.4% and with risk 
equalisation having minimal impact on claims growth this 
period with the return to more normal resident age claiming 
patterns, net claims also increased 3.4%. 

Underlying resident claims growth per policy unit increased 
10 basis points to 2.4%, largely reflecting more lives insured 
per policy unit due to ADR. Hospital claims growth decreased 
reflecting the benefit of prosthesis savings and an improved 
risk equalisation outcome, with cost inflation having a modest 
impact this period. Growth in extras claims was due to 
investment in additional product benefits and sales mix. 

In 2024 we expect hospital claims headwinds to include 
inflation in public and private hospital claims and the 
maturing impact of ADR. We expect the tailwinds to be lower 
rehab claims, the benefit from our claims management 
initiatives and lower extras claims growth. 

We expect underlying resident claims growth per policy unit 
in 2024 of 2.6%. And while we have not yet seen the economic 
environment impacting demand for services, we continue to 
closely monitor the mix of hospital admissions and spend 
in more discretionary extras services for signs of further 
customer behaviour changes. 

Gross profit increased 8.3% to $1,222.8 million. Permanent 
net claims savings due to COVID-19 of $451.4 million were 
returned to customers through $451.7 million of give back 
initiatives resulting in COVID-19 having a modest $0.3 million 
negative impact on profit. Adjusting for this impact, underlying 
gross profit increased 8.3% to $1,223.1 million. 

Gross margin increased 60 basis points to 17.1% and 
underlying gross margin increased 50 basis points to 16.1%. 
This was driven by a 20 basis point increase in the underlying 
resident gross margin, and non-resident underlying gross 
margin increasing from 25.5% to 33.6%, reflecting a 
continuation of the favourable tenure and mix impacts we 
have seen since borders re-opened. 

The COVID-19 deferred claims liability, which is in recognition of 
claims that have likely been deferred since the commencement 
of COVID-19 restrictions, decreased $194.5 million to 
$253.8 million. Under the new accounting standard AASB17 
Insurance Contracts which applied from 1 July 2023, this will 
be transferred to an after tax equity reserve and will be used to 
offset future customer give backs, recovery of deferred hospital 
procedures and other temporary claims impacts.

Management expenses increased 6.8% to $572.4 million with 
growth in non-resident sales commissions and inflation, 
partially offset by savings from our productivity program. As 
a result of significant growth in non-resident policy numbers, 
sales commissions, which are expensed upfront, increased 
$18.8 million to $32.7 million. Operating expenses were up 
3.4% with cost inflation of 4% and modest volume impacts 
partially offset by approximately $7 million of productivity 
savings. While achieving productivity savings this period has 
been impacted by the cybercrime, we are targeting a further 
$20 million of savings over the next two years. 

The major drivers of expense growth in 2024 will be cost 
inflation, which we expect to be modestly higher at 4.5%,  

an additional $5 million of ongoing investment in IT security 
and $3 million increase in statutory charges.

The underlying management expense ratio remains among 
the lowest in the private health insurance market despite a 
slight increase of 10 basis points to 7.5%. We will continue to 
leverage our productivity program and the benefits of scale to 
target modest improvement in this ratio while balancing the 
need to invest for growth.

Health Insurance underlying management expense ratio
Health Insurance underlying management expense ratio

2023

2022

2021

2020

2019

2018

7.5%

7.4%

7.7%

8.2%

8.7%

8.8%

0

2

4

6

8

10

Health Insurance operating profit of $650.4 million increased 
9.8% this year, or 9.7% on an underlying basis, leading to a 50 
basis point improvement in operating margin. On an underlying 
basis, operating margin improved 40 basis points to 8.6%.

Medibank Health

While the majority of COVID-19 impacts on Medibank Health 
have eased, the business was impacted by the transition out of 
1800RESPECT and Beyond Blue contracts in 2H22. Operating 
profit increased 8.3% and segment profit, which includes 
the contribution from our investment in Myhealth and other 
healthcare investments, decreased by 2.9% to $44.2 million. 
Excluding the impact of these contract transitions, operating 
profit increased 17.2% and segment profit increased 4.2%.  
The remaining commentary on Medibank Health excludes  
the impact of these two contracts in 2022. 

Revenue of $277.1 million was modestly lower with growth in 
health and wellbeing and travel sales offset by a reduction in 
telehealth revenue.

Gross profit increased 9.2% to $131.8 million and gross 
margin improved by 450 basis points to 47.6% with business 
mix and improved utilisation and business efficiency, partially 
offset by higher labour costs and inflation. 

Management expenses increased $4.6 million reflecting 
inflationary impacts and investment in future growth, and 
with the modest decline in revenue, the management expense 
ratio increased 190 basis points to 31.6%.

Annual Report 2023   25 

Operating and financial review

The business has good momentum, and we continue to target 
on average, organic growth of at least 15% per annum over 
the next three years with key areas of focus including further 
volume and performance uplift in health services, continuing 
to reposition the business to meet the emerging needs of 
Medibank Group customers and delivering synergies between 
our health businesses. 

Net investment income/(expense)

Medibank’s investment portfolio was $3.3 billion as at 30 June 
2023. This investment portfolio, which includes $2.7 billion 
relating to the health fund and short-term operational cash 
(STOC) of $0.4 billion, provides liquidity to cover insurance 
liabilities related to the Health Insurance business and 
satisfies our obligation to maintain regulatory reserves to 
meet health claims and to fund ongoing operations. The  
STOC balance includes assets, largely 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.

Investment income was $138.6 million compared to a loss of 
$24.8 million in 2022, due to stronger equity markets, higher 
interest rates and narrowing credit spreads. The $40.3 million 
increase in growth portfolio income was due to significantly 
improved returns in both domestic and international equity 
markets, partially offset by a lower return in property 
investments. The defensive portfolio had a gain of $69.4 million 
compared to a loss of $23.5 million in 2022 largely due to 
higher RBA cash rates, a $9.7 million benefit from narrowing 
credit spreads versus a $26.5 million cost last period, and a 
more stable yield curve resulted in an improved but still below 
expectation return on international fixed interest holdings.

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

2.2 Group financial position

Medibank’s net asset position increased by $138.8 million  
or 7.1% to $2,084.4 million as at 30 June 2023. 

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

•  A decrease in claims liabilities largely due to a decrease  
in the COVID-19 deferred claims liability, partially offset  
by an increase in the outstanding claims liability. 

•  A decrease in cash and cash equivalents driven by the 

timing of tax payments. 

•  An increase in unearned premium liability due to the  
timing of the recent resident premium increase on  
1 June 2023 with prepayments usually peaking around  
the time of the rate rise, as well as the increase in  
overseas student policies.

As at 30 June 2023, Medibank’s consolidated statement  
of financial position remained debt-free.

26    Medibank 

2.3 Capital management and dividends

Medibank’s capital management objective is to maintain a 
strong financial risk profile and capacity to pay all eligible 
customer benefits, invest in the growth of our business 
to provide a return to shareholders, and to meet financial 
commitments. 

On 1 July 2023, accounting standard AASB17 Insurance 
Contracts and the new APRA capital standards became 
effective. The commentary below is based on the 2023  
pro forma capital position which reflects the impacts of  
these new standards. 

The introduction of these new standards has increased our 
eligible capital position by $87.0 million. The total capital 
benefit increases to $167.0m after reflecting the reduction  
in the Health Insurance target required capital ratio to  
10%-12% of premium revenue (from 11%-13%). 

In June 2023 APRA announced an additional capital adequacy 
requirement of $250 million on Medibank, with effect from 
1 July 2023, following a review of the cybercrime event. As 
a result, we have temporarily increased Health Insurance 
business related capital to offset this supervisory adjustment. 
After this increase, the Group remains well capitalised with 
1.8 times coverage of the health insurance prescribed capital 
amount (PCA) after adjusting for the supervisory adjustment, 
and unallocated capital of $175.4 million. As a business, we 
continue to have strong capital generation, and with the level 
of unallocated capital and the ability to issue Tier 2 debt we 
remain well placed to fund our M&A aspirations. 

•  Our total Health Insurance business-related capital was 

$1,168.0 million; equivalent to 14.6% of premium revenue 
after the allowance for determined but unpaid dividends. 
This is above the target range of 10%-12%.

•  Non-fund required capital increased $4.5 million to  

$191.7 million, reflecting our investment in the integrated 
mental health model joint venture with Aurora Healthcare. 
We expect to contribute more capital to the joint venture 
over the next six to 12 months.

•  Unallocated capital increased $27.4 million to $175.4 million.

Dividends paid or payable in respect of profits from the 
financial year totalled 14.6 cents per share fully franked, 
amounting to $402.1 million comprising:

•  An interim ordinary dividend of 6.3 cents per share fully 

franked, amounting to $173.5 million paid on 22 March 2023 
in respect of the 6-month period ended 31 December 2022, and

•  A final ordinary dividend of 8.3 cents per share fully franked, 
amounting to $228.6 million to be paid on 5 October 2023 in 
respect of the 6-month period ended 30 June 2023.

The full year 2023 ordinary dividend represents an 80.5% payout 
ratio of underlying NPAT, normalising for investment market 
returns. This is at the mid point of our dividend target payout 
ratio range of between 75% and 85% of underlying NPAT. 

Annual dividend (cents)

Annual dividend (cents)

2023

2022

2021

2020

14.6

13.4

12.7

12.0

0

3

6

9

12

15

2.4 Management changes

In April 2023, John Goodall, Group Executive – Technology  
& Operations, retired from Medibank. 

As part of Medibank’s continued focus on delivering on 
our strategy and 2030 vision to deliver the best health and 
wellbeing for Australia, there have been a number of changes 
to the executive leadership team, which came into effect on  
31 July 2023.

Group Lead – Chief Financial Officer & Group Strategy:  
Mark Rogers continues to hold this role with responsibility for 
finance, actuarial, treasury, internal audit, investor relations, 
strategy development and M&A. Mark adds procurement to 
his portfolio of responsibilities. 

Group Lead – Chief Customer Officer: Milosh Milisavljevic 
takes on this expanded role. This role brings together the 
Medibank and ahm brands including marketing, customer 
channels, customer portfolios, Live Better and diversified 
insurance. 

Group Lead – Chief Executive Amplar Health: Dr Andrew Wilson 
continues in this role. Andrew is responsible for Medibank’s 
growing role as a health services provider. This includes 
responsibility for the health services we deliver on behalf of 
business and government, including telehealth, in-homecare, 
and our investments in primary care and ambulatory care. 

Group Lead – Digital & Ventures: Rob Deeming takes on 
a new role to accelerate our growth in health through the 

development of digitally-led health products and services 
for our customers and the community. Rob maintains his 
responsibility for the group digital team supporting our 
insurance and health businesses. 

Group Lead – Data & Technology: This role has a dedicated 
focus on technology, data management and our core 
platforms. An internal and external recruitment process  
is underway. In the interim Kylie Williamson will continue  
to act in this role.

Group Lead – Trust, Legal & Compliance and Company 
Secretary: Mei Ramsay continues to hold this role, with 
responsibility for customer trust added to her existing 
portfolio of legal, governance, compliance and regulatory 
affairs. Mei continues as Company Secretary. 

Group Lead – People, Spaces & Sustainability: Kylie Bishop 
continues to hold this role, with additional responsibility 
for spaces (property). Kylie continues to lead the key 
people functions, as well as our environmental, social and 
governance (ESG) focus areas. 

Group Lead – Policy, Advocacy & Reputation: This is a new 
role in the executive leadership team. Meaghan Telford 
has responsibility for government and industry relations, 
health stakeholders, health policy, reputation and external 
communications. 

3. Strategy and future prospects

Medibank’s purpose is Better Health for Better Lives.  
Our vision is the best health and wellbeing for Australia. 
Our strategy puts our customers and people at the centre 
of everything we do. We connect people to a better quality 
of life in every moment. By working to create access, choice 
and control for Australia, we seek to sustainably build our 
customer base and grow shareholder value. 

In the year ahead we will continue to regain momentum  
in our health insurance business, prioritise greater value, 
progress our IT security uplift program and take further  
steps to expand in health, particularly in virtual health. 

Our strategy – growing as a health company 

Deliver leading  
experiences

Differentiate our  
insurance business

Expand  
in health

Create personalised and  
connected customer experiences 

Deliver more value, choice  
and control for customers

Empower our people

Collaborate with our communities 
to make a difference

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 2023   27 

 
Operating and financial review

Our people are our most valuable asset and 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 and 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. 

Although we are seeing cost of living concerns, the health 
insurance industry remains resilient. Growth continues 
to be well above pre-pandemic levels as consumers 
continue to prioritise their health and wellbeing, supported 
by sustained low premium increases, low levels of 
unemployment, and pressure on the public health system. 
We will continue to drive differentiation through integrated 
propositions, including diversified insurance products, 
strengthen value for our customers through new products 
and provider networks, optimise our dual brand strategy  
to support a broad range of customer segments, and  
invest to keep premium increases low. 

With the increasing pressure on the public system we will 
continue to partner with doctors, hospitals, governments 
and other organisations to drive change in the system 
and advocate for reform. We will grow, develop and scale 
innovative models of care, providing our customers and the 
community greater choice and access to the right care, in  
the right place, at the right time.

Milestones

Pillars

Milestones

We will support healthcare affordability through expansion 
of our no gap program across more clinical modalities and 
locations and drive integrated care initiatives that support the 
end-to-end patient journey. 

We will integrate the Live Better program into preventative 
health, acquisition and retention journeys to evolve the way 
we support the health and wellbeing of our customers, and 
expand our suite of preventative programs with the aim of 
50,000 enrolments by FY25. 

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. Connection between our various health 
assets will be key to delivering a better and more customer/
patient-centric health experience.

Medibank remains positioned for growth with strong customer 
advocacy, positive policyholder growth outlook, track record 
of health innovation, continued focus on cost discipline, and 
strong balance sheet to support our growth ambitions. 

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. 

4. Material business risks

Please refer to pages 46 to 48 of the risk management 
section for an overview of our material business risks  
and the APRA new prudential standard.

Deliver leading 
experiences

Customer advocacy: Service NPS (average)

Employee advocacy: eNPS

FY23
Medibank 40.1
42.7
ahm

FY24 benchmark1
>35
>35

Place to work
Products and services

FY23
 +23
 +24

FY24 benchmark2
≥+24
≥+26

Differentiate our 
insurance  
business 

Market share

FY23
27.08% 

FY26 aspiration
Up 25-75 bps 
on FY23

Health Insurance productivity delivered

FY23
c. $7m

FY23-FY25 target
$30m productivity savings 
including $10m in FY23

Expand  
in health 

Health and wellbeing 

Medibank Health profit – updated 

Live Better Rewards 
participants
Preventative program 
participants3

FY23

FY25 target

c. 697k  >800k 

FY23
$44.2m 

c. 16.5k  >50k 

FY24-FY26 target4
Average at least 15% p.a. organic  
profit growth over the next 3 years
Aim to invest $150m-$250m in total  
to grow Medibank Health inorganically  
as suitable opportunities arise 

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

2.  FY24 benchmarks for Place to Work eNPS based on the global average benchmark, Products and Services eNPS target based on historical trend 

3. 

 Includes total customers who have engaged with 9 preventative health programs (e.g. Better Knee, Better Me, Heart Health at Home) and any new offerings 
developed.

4.  Based on continuing businesses – excluding the impacts of Beyond Blue and 1800RESPECT contracts which ceased during February and June 2022 respectively.

28    Medibank 

 
 
 
Directors

 44%*

are women

11%*

were born 
overseas

100%*

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

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.

As at 24 August 2023 
*  including CEO  

Directors’ qualifications, experience and special responsibilities

Details of the qualifications, experience and special responsibilities of each director in office as at the date of this report  
are set out below.

Name and title

Biography

Mike Wilkins AO

Chair and Independent  
Non-executive Director

BCom, MBA, FAICD, FCA

Age: 66

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.

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: 50

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 performance of the Medibank and ahm Health Insurance and Diversified 
financial portfolios, and led the start-up of the Live Better program. David was also appointed 
Acting Chief Executive Officer between April 2016 and June 2016.

Prior to joining Medibank, David was Group Chief Commercial Officer at Jetstar where he was 
responsible for growing and sustaining the business and leading its customer facing functions 
across Asia Pacific, having joined as part of the start-up team, 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, innovation, commercial and operational experience, 
including previous work in the consulting and financial services industries. David is a Member  
of the Council of Management for the International Federation of Health Plans.

Annual Report 2023   29 

 
Directors

Name and title

Biography

Dr Tracey Batten

Independent  
Non-executive Director

MBBS, MHA, MBA,  
FAICD, FRACMA

Age: 57

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.

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 a 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. Anna is also National Ambassador for the 
Malaria Vaccine Project at the Institute of Glycomics at Griffith University.

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. 

Anna Bligh AC

Independent  
Non-executive Director

BA (QLD)

Age: 63

Gerard Dalbosco

Independent  
Non-executive Director

M.AppFin, B.Comm,  
FCA, GAICD 

Age: 60

Peter Everingham

Independent 
Non-executive Director

BEc, MBA, GAICD

Age: 54

30    Medibank 

Name and title

Biography

David Fagan

Independent 
Non-executive Director

LLB, LLM, GAICD

Age: 66

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, and a former director of PayGroup Limited (November 2017 
to November 2022), Grocon Funds Management Group, the Hilco Group and UBS Grocon Real 
Estate Investment Management Australia Pty Limited. He is also a former member of the advisory 
board of Chase Corporate Advisory.

David is currently Chair and member of the Risk Management Committee of BDO Group Holdings 
Limited and a member of the ASIC Corporate Governance Consultative Panel.

Kathryn Fagg AO

Independent 
Non-executive Director

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

Age: 62

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

Independent  
Non-executive Director

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.

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: 75

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

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

Company Secretary

Name and title

Biography

Mei Ramsay

Group Lead – Trust, 
Legal & Compliance 
and Company Secretary

BA, LLB, LLM

Mei is responsible for leading the customer trust, legal and governance functions, including 
compliance and regulatory affairs. Mei has been the Company Secretary since 2014 and previously 
held the position of Group General Counsel from 2011. She has been a member of the executive 
leadership team since 2016.

Mei has more than 25 years of experience as a senior in-house legal adviser for multinational 
and international companies as well as private practice. Prior to joining Medibank, Mei was the 
General Counsel and Company Secretary for the Asia Pacific region at Cummins Inc, and also 
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.

Annual Report 2023   31 

Executive 
leadership 
team

 44%*

are women

33%*

were born 
overseas

89%*

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

As at 24 August 2023 
*  including CEO

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

Name and title

Biography

Kylie Bishop 

Group Lead 
– People, Spaces
& Sustainability

Kylie is responsible for leading key people functions including culture, talent and capability, 
performance and rewards, shared services, diversity and inclusion, workplace relations, health, 
safety and wellbeing, employee experience and community as well as sustainability and spaces. 
She has been a member of the executive leadership team since 2013.

Kylie is a registered psychologist specialising in organisational psychology. She began her career in 
human resource consulting and prior to joining Medibank in 2010, held senior positions with NAB.

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

Rob Deeming

Group Lead 
– Digital & Ventures

Rob is responsible for accelerating our growth in health through the development of digitally-led 
health products and services for our customers and the community. Rob also leads the digital team 
supporting our insurance and health businesses. He has been a member of the executive leadership 
team since June 2021.

Rob was previously accountable for growing and sustaining the Medibank and ahm insurance 
businesses, including oversight for our operational and customer-facing teams. Prior to that he 
led the ahm business.

Rob has extensive experience in entrepreneurial leadership, as well as high-growth consumer 
brands. Before joining Medibank, Rob was the CEO of multi award-winning hardware/software 
business, Billy. He has also held commercial leadership roles at Jetstar and Qantas, and was the 
CEO of the travel booking engine, Jetsetter, which he sold to Tripadvisor. 

Rob is a director of Medinet Australia Pty Ltd.

32    Medibank 

Name and title

Biography

Milosh 
Milisavljevic

Group Lead  
– Chief Customer 
Officer

Mark Rogers

Group Lead  
– Chief Financial 
Officer & Group 
Strategy

Milosh is responsible for the Medibank and ahm brands including marketing, customer channels, 
customer portfolios, member health programs, Live Better, provider partnerships and diversified 
insurance. He has been a member of the executive leadership team since June 2021.

Milosh joined Medibank in 2016 and has held a number of roles leading 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.

Milosh is a director of Private Healthcare Australia Limited.

Mark is responsible for the finance, actuarial, treasury, internal audit, investor relations and 
procurement functions across Medibank as well as strategy development and M&A. He has been  
a member of the executive leadership team since January 2017.

Mark has more than 20 years of global experience across the healthcare, pharmaceuticals and 
financial services sectors. Before joining Medibank, Mark held performance, planning and group 
development leadership roles at NAB. Prior to that he was responsible for strategy and development 
for Mayne Group. Prior to that role, Mark led Group Investor Relations at Mayne Group. 

Mark is Chair of Myhealth Medical Group and a director of Integrated Mental Health, East Sydney 
Private Hospital and the Royal Children’s Hospital Melbourne.

Meaghan Telford

Group Lead 
– Policy, Advocacy  
& Reputation

Meaghan is responsible for government and industry relations, health stakeholders, health policy, 
reputation and external communications. Meaghan joined Medibank in 2016 leading the External 
Affairs function and previously held the role of Senior Executive – Policy, Advocacy and Reputation.
She has been a member of the executive leadership team since July 2023. 

Kylie Williamson

Acting Group Lead  
– Data & Technology

Meaghan is a corporate affairs professional with a career spanning more than 20 years in sport, 
politics and ASX-listed entities. In these roles, she has been responsible for driving the external 
agenda for organisations through media management, government relations, campaign and 
stakeholder management, employee engagement and public affairs research.

Prior to Medibank, Meaghan led Group Corporate Communications for NAB, responsible for 
communications on mergers and acquisitions, customer pricing strategy, financial reporting and 
issues management. 

Kylie is responsible for technology, data management and our core platforms. Kylie has been an 
acting member of the executive leadership team since April 2023.

Prior to this, Kylie was Senior Executive – Core Medibank Customer Systems with a focus on 
strategy and development, and support of core Medibank and Amplar Health systems that support 
marketing, CRM, policy management, procurement, payment, human resources, contact centre and 
finance processes.

Kylie joined Medibank in September 2015 after more than 20 years in information technology 
consulting for a range of industries with PwC and IBM both locally and globally. Her key roles were 
as program manager deploying technology to drive business benefits, growth and align to customer 
and stakeholder needs.

Dr Andrew Wilson

Group Lead  
– Chief Executive  
– Amplar Health

Andrew is responsible for Medibank’s growing role as a health services provider. This includes 
responsibility for the health services we deliver on behalf of business and government, including 
telehealth and virtual care, in-home care and our investments in primary care and ambulatory care. 
He has been a member of the executive leadership team since 2010.

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, Adeney Private 
Hospital Pty Ltd.

Annual Report 2023   33 

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 CPS510 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.

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 Chief Executive Officer (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 38 to 39.

The CEO has responsibility for managing the day-to-day 
affairs of Medibank. The CEO, with the support of the 
executive leadership team, 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.

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

34    Medibank 

Key areas of focus for the Board in 2023
Corporate governance

•  Oversight of the cybercrime event and response, including: 

People, remuneration and culture

•  Oversight of Medibank’s 2030 vision, values,  

strategy and culture. 

 – Supporting our customers including the Cyber Response 

•  Alignment of executive leadership team (ELT) roles.

Support Program.

 – Keeping our stakeholders informed, such as the 

government, shareholders and regulators.

 – Ensuring the health and wellbeing of our employees.

 – Continuing to strengthen our information security 

environment.

 – Monitoring the financial and other impact of the 

cybercrime event.

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

 – 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.

•  Continuing to embed 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. 

•  Continuing to embed our environmental, social and 

governance (ESG) strategy, including accelerating our 
pathway to Net Zero emissions by 2040.

•  Continuing to evolve our approach to data management, 
particularly in light of impending reform to the Privacy  
Act and changing community expectations.

•  Review and approval of Accounting Policies and associated 
Financial Statement disclosures in the light of the adoption 
of the new AASB17 Insurance Contracts with effect from  
1 July 2023.

•  Oversight of the Group's capital management policies  

and level of capital, including implementation of APRA’s 
new capital standards (from 1 July 2023).

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.

•  Review of Board composition, including consideration  
of succession planning and its continuing education.

•  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  
CPS511 Remuneration 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 29 to 31. Details of directors’ attendance at Board  
and committee meetings during the year ended 30 June  
2023 are on page 52. The non-executive directors' tenure 
profile is shown in the table below. The length of service  
of the non-executive directors ranges from one year and  
four months to ten years and eight months.

Non-executive director tenure profile

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

>9 years 
(1 director)

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

•  Monitoring the impacts of economic conditions and  

cost-of-living pressures.

6-9 years 
(2 directors)

<3 years
(3 directors)

3-6 years
(2 directors)

Annual Report 2023   35 

Corporate governance statement

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). Shareholders may also nominate 
individuals 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. Mike Wilkins 
AO and Dr Tracey Batten will retire and offer themselves 
for re-election at the upcoming AGM on 22 November 2023. 
Further information about these directors is set out on pages 
29 to 31, 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.

36    Medibank 

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, executive leadership team 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, executive leadership team 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. 

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.

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

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

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

Moderate

Strong

Very Strong

Annual Report 2023   37 

Corporate governance statement

Skills and experience

  Collective strength1

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

Technology, data and digital innovation
Understanding technology and innovation, including 
data management, data privacy and information 
security practices. Experience with businesses 
that have developed and implemented technology-
based initiatives to enhance productivity and/or 
customer experiences

1. 

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

Moderate

Strong

Very Strong

Moderate

Strong

Very Strong

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 2023, 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, practices and 
committees, and behaviours. This included an assessment of 
the committees' handling of the issues and challenges that 
occurred throughout the year. The internal Board evaluation 
in 2023 followed the external Board evaluation that was 
undertaken in 2021 and the internal Board evaluation in 2022. 

Following the survey, the Board discussed and evaluated the 
outcomes and committed to relevant action items. 

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 2023 to review their performance and professional 
development needs.

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 Board has also formed a Cyber Response Board 
Committee as part of its cyber response playbook. More 
information on this committee and its role during the recent 
cybercrime event can be found on page 49.

The relevant qualifications and experience of the members 
of each standing committee can be found in the director 
biographies on pages 29 to 31. The number of meetings 
of each committee, and the individual attendance of their 
members, are provided on page 52.

Committee membership 
as at 24 August 2023

Composition

Key roles and responsibilities

Audit Committee 

•  Gerard Dalbosco 

(Chair)

•  Peter Everingham

•  David Fagan

•  Kathryn Fagg

38    Medibank 

•  At least three members, all of whom 

•  Overseeing and reviewing the integrity of external 

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

•  Structured so that members are all 

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

•  The 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).

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.

 
 
Committee membership 
as at 24 August 2023

Composition

Risk Management 
Committee

•  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.

•  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).

Key roles and responsibilities

•  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.

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

•  Establishment and monitoring of Medibank’s overall 

risk appetite.

•  Monitoring and review of Medibank's risk culture.

•  Oversight of, and monitoring progress against, 

Medibank's sustainability strategy.

•  Oversight and prior endorsement of the appointment 

and replacement of the Chief Risk Officer.

Investment and 
Capital Committee

•  At least three members, all of whom 

•  Assisting and advising the Board on capital and 

are non-executive directors.

investment related matters.

•  Linda Bardo Nicholls 

•  The chair must be an independent 

•  Overseeing the investment strategy and Capital 

(Chair)

•  Anna Bligh

•  Mike Wilkins

non-executive director, appointed by 
the Board.

Management Policy.

•  Monitoring the effectiveness of the investment 

process.

•  Authorising delegated investment decisions.

People and 
Remuneration 
Committee

•  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, 
executive leadership team 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.

Annual Report 2023   39 

Nomination 
Committee

•  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 

•  Linda Bardo Nicholls

of the committee.

 
 
Corporate governance statement

Executive leadership team

The CEO, supported by the executive leadership team (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 
32 to 33. 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 54.

The remuneration report from page 59 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 2023 in accordance with 
that process for each ELT member in that role at 30 June 2023.

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 2023. 

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 

Breaches and reporting

Code of 
Conduct

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

Whistleblower 
Policy

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

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).

Anti-Bribery 
and  
Corruption 
Policy

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. 

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;

40    Medibank 

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, 
Spaces & 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 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.

Anti-Bribery 
and  
Corruption 
Policy cont.

Share Trading  
Policy

Purpose

Key provisions 

Breaches and reporting

•  not offer or give anything of value, or 

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

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

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

•  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.

Details the penalties 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. We recognise 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 
facilitates an inclusive culture and supports us to deliver an 

inclusive health and wellbeing experience for our community.
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 our 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 2023, the actual 
representation across the Group and senior executive 
population was 48%.

In May 2023, 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 2023, 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)1,2

Senior executives3

Group and senior executive total

Senior managers

Other managers

Non-managers

Overall (including Board)

Women

Men

Other

% Women

4

3

24

27

102

408

2,014

2,555

5

5

24

29

116

334

592

-

-

-

-

1

1

8

1,075

10

44%

38%

50%

48%

47%

55%

77%

70%

1.  Group executive positions refer to the CEO and the executive leadership team (ELT) as at 30 June 2023. All of the ELT report directly to the CEO. 

2.  Kylie Williamson, Acting Group Lead - Data & Technology, has been included in the Group Executive data.

3.  Senior executive positions include all roles classified as senior executives as part of Medibank’s broad based banding framework. 

Annual Report 2023   41 

Corporate governance statement

In 2022 the Board set measurable objectives for achieving diversity at Medibank and committed to reporting progress achieved 
against these in the 2023 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 executive 
leadership and senior leadership 
populations, 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 
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.

As at 30 June 2023, women represented 48% of Group and senior executive roles  
(up from 44% in FY22). Representation of women on the Medibank Board remains 
above target at 44% (including the CEO), aligned with FY22.

Women represented 53% of all manager roles (excluding Group and senior 
executives), unchanged from FY22 and 77% of non-manager positions (compared 
to 79% in FY22). This is largely driven by our Amplar Health division where women 
made up 87% of the non-manager workforce, compared to other Medibank divisions 
at 71%. 

In FY23, the number of employees identifying as Aboriginal and Torres Strait Islander 
in our annual engagement survey increased to 32 people, which equates to 1.2% of 
survey respondents1, an increase from 0.9% in FY22. Engagement for this cohort  
was 8.3 which is above the Medibank average of 7.7 and above FY22’s result of 8.1.

While our representation of Aboriginal and Torres Strait Islander employees 
was 0.4% lower than our target, in 2022 we developed our Aboriginal and Torres 
Strait Islander recruitment, engagement and professional development strategy. 
This strategy supports our aim to increase meaningful, sustained employment 
opportunities for Aboriginal and Torres Strait Islander peoples by facilitating a 
tailored recruitment process and regular surveys to better understand the ongoing 
experience of Aboriginal and Torres Strait Islander candidates and employees.

In FY23, the number of employees identifying as having a disability in our 
annual engagement survey rose to 184 people, which equates to 6.7% of survey 
respondents1, an increase from 5.9% in FY22. Engagement for this cohort was 7.6, 
which is below the Medibank average of 7.7 and 0.1 lower than FY22’s result of 7.7.

In May 2022, we launched our second Accessibility and Inclusion Plan. In the first year 
of the plan, we delivered disability awareness education as part of our annual training 
requirements for all employees as part of our goal to foster a disability confident 
culture. In FY24, we will focus on developing this further to uplift the capability of  
our leaders and ensure an inclusive and accessible recruitment process.

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 (18.2%, as 
measured by our employee survey). In FY23, we further invigorated our carers 
support proposition by refreshing our Carers Network, promoting our carers 
information hub and making our Caregiver Support Program available to all eligible 
employees, following a successful pilot in FY22. In FY24, we will continue to share 
the support offerings for carers with all employees and prioritise listening to 
feedback from our Carers Network to further enhance their experience.

1.  Based on employee engagement survey response rate of 80% (2,742) from 3,452 employees invited to participate.

42    Medibank 

For 2024, the Board has set the following measurable 
objectives for achieving diversity at Medibank and is committed 
to reporting progress achieved against these in the 2024 
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 49 employees (approx. 1.8%  
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 192 
employees (approx. 7% of survey respondents) as 
self-reported in our annual engagement survey.

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 our results, investor 
presentations, annual reports, sustainability 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.

We encourage 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 Morgan 
Stanley Private Healthcare Forum in May 2023 and the 
Macquarie Australia Conference in May 2023.

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

Annual Report 2023   43 

 
    
  
 
 
    
  
  
 
     
 
  
 
    
  
  
Corporate governance statement

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 2023, 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 38. In addition to the members of the 
Audit Committee, any director may attend Audit Committee 
meetings. Representatives of management and the Hub Lead 
– Internal Audit may attend Audit Committee meetings by 
standing invitation, and the Chief Actuary and external auditors 
are invited as required. 

44    Medibank 

Financial reporting assurances

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

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

This declaration was received by the Board prior to approving 
the financial statements for the half year ended 31 December 
2022 and the full year ended 30 June 2023.

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 Hub Lead – 
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 Hub Lead – 
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

Information about Medibank's risk management framework 
(page 45), risk governance (page 45) and material business 
risks, including environmental, social and governance risks 
and emerging risks (page 46), can be found in the following 
risk management section. 

This corporate governance statement is accurate and up to 
date as at 24 August 2023 and has been approved by the Board.

Risk management 

Our approach to risk management reflects our commitment 
to ethical and responsible business practices and guides the 
work we are doing to deliver on our 2030 vision of the best 
health and wellbeing for Australia.

Our risk management approach is defined within our risk 
management strategy and underpinned by our enterprise risk 
management framework, which encompasses the systems, 
structures, policies, processes and people that manage risks 
across the business. These align with the requirements of the 
Australian Prudential Regulation Authority’s (APRA) Consolidated 
Prudential Standard 220 Risk Management (CPS220).

We undertake an annual strategic planning process to 
establish and agree upon our strategic objectives with the 
Board and develop our risk appetite statement, corporate 
plan and capital management plan. 

Risk 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 
strategy and risk appetite statements on an annual basis 
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. Committee members are appointed based 
on their qualifications and experience to ensure that the 
committee can adequately discharge its duties. More 
information about the committee and its members can be 
found in the corporate governance statement on page 39. 

Risk management plays an important role in remuneration 
outcomes. For a short-term incentive award to be made 
to any employee, a risk, compliance and behaviour 
gateway must be met. As well all employees have risk-
related key performance measures 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 page 61.

The Board is further assisted by the Investment and Capital 
Committee, which oversees the implementation and 
monitoring of the investment strategy and ICAAP Summary 
Statement Policy approved by the Board, including monitoring 
the effectiveness of the investment process which aims to 
achieve optimum return relative to Medibank’s risk appetite. 

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. There are seven divisional risk committees 
covering key business units — Amplar Health, Customer, 
Digital & Ventures, Data & Technology, Finance & Strategy, 
Trust, Legal & Compliance and People, Spaces & Sustainability.

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.

Risk management framework

Our risk management framework guides risk management 
activities across the business to effectively identify, assess, 
manage, monitor and report risks. The framework is 
implemented through the three lines of defence model and 
its effectiveness is assessed by the internal audit function 
on an annual basis with a full comprehensive review on a 
three yearly basis in accordance with the Risk Management 
Committee Charter and APRA Prudential Standard CPS220. 

A key component of our risk management framework is the 
definition of Medibank’s risk appetite by the Board which 
informs management's decision-making process. The annual 
review of the framework considers whether the framework 
is sound, and Medibank is operating with due regard to 
the risk appetite set by the Board. The Risk Management 
Committee reviews the risk management framework at least 
yearly and regularly monitors the framework’s effectiveness. 
The annual review of the framework was completed in 2023. 
Medibank continues to operate and strengthen enterprise risk 
management practices in alignment with the requirements 
outlined in the APRA Prudential Standard CPS220 – Risk 
Management.

Annual Report 2023   45 

Risk management 

Medibank Group Board 
Group strategy, risk management strategy (Group), risk appetite and profile (Group)

Board Risk 
Management 
Committee

Board 
Investment 
and Capital 
Committee

Board 
Nomination 
Committee

Board 
People and 
Remuneration 
Committee

Board  
Audit 
Committee

Independent 
assurance
Internal  
audit 

Executive Risk Committee

Divisional risk committees

Business unit teams

Material risks

Strategic

Mandatory

Independent 
assurance
External  
audit  
(as required by 
the Board to 
meet regulatory 
obligations)

R
i
s
k
c
u
l
t
u
r
e

Operational 
(including 
regulatory 
compliance)

Credit  

Capital & 
liquidity  

Market &  
 investment

Insurance  

s
r
u
o
i
v
a
h
e
b
k
s
i
R

Strategic including: 

•  Strategic planning & enablement
•  Customer growth
•  Information security 
•  Portfolio management & optimisation 
•  Healthcare cost and utilisation
•  Health growth 
•  Clinical
•  Stakeholder risk

Emerging (including ESG risks)
risks we are monitoring that could have the  
potential to become material risks in the future

Climate risk

Heightened cyber risk 
associated with the  
geopolitical environment

Artificial 
intelligence

Macro and  
socio-economic / 
cost of living 

3 lines of defence 
     1st line – risk ownership     2nd line – oversight and compliance      3rd line – independent assurance

Material business risks

Material business risks are those risks deemed to have 
a significant impact on the Group’s operations, financial 
prospects and business objectives. Emerging risks are those 
we are monitoring that could have the potential to become 
material risks in the future. These risks are summarised on 
the following page.

The cybercrime event has, and will continue to have, the 
potential to impact our material business risks. Building upon 
our existing program of work to enhance IT security across 
our business, we expanded our work into an IT security uplift 
program following the cybercrime event. It aims to continue 
maturing our cybersecurity approach and better enable us 
to respond to the rapidly evolving cyber threat landscape. We 
continue to review our cybersecurity governance arrangements, 
recognising the increasing prevalence of cybercrime and the 
need to meet the ongoing expectations of our customers.

46    Medibank 

 
 
 
 
 
Material business risk

Mitigations

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

Credit

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

Capital &  
liquidity 

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

Material 
sustainability 
categories

Customer health 
Community health

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 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. 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.

Employeer health 
Environmental 
health 
Governace

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.

Governace

Governace

Medibank has Board-approved policies for capital management 
(ICAAP) and liquidity management designed to ensure it meets or 
exceeds regulatory capital requirements at all times, and is able to  
fund all payments as and when they fall due, as well as under adverse 
stress scenarios. Liquidity risk is managed by our treasury function 
through daily cash management of cash flows and liquid asset 
positions and projected future cash flows under current and adverse 
scenarios. The ICAAP (Internal Capital Adequacy Assessment Process) 
also includes actions that can be taken to support Medibank’s capital 
position under various stress scenarios.

Market &  
investment 

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

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.

Environmental 
health 
Governace

Customer 
health

Employee 
health

Community 
health 

Environmental 
health

Governance

Annual Report 2023   47 

 
 
 
 
Risk management 

Material business risk

Mitigations

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

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.

Emerging risk 
(including ESG risks)

Emerging risks

•  Climate risk
•  Heightened cyber risk associated with the geopolitical environment
•  Artificial Intelligence
•  Macro and socio-economic / cost of living

Material 
sustainability 
categories

Governace

Customer health 
Community health

Material 
sustainability 
categories

Employeer health 
Environmental 
health 
Governace

Customer 
health

Employee 
health

Community 
health 

Environmental 
health

Governance

Environmental, social and governance risks

Medibank’s risk management framework also applies to the 
environmental, social and governance (ESG) risks (including 
climate risk). Medibank commissioned an independent 
external review in 2021 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 57 to 65  
of the Sustainability Report 2023. Further detail on our 
approach to sustainability and ESG issues can also be  
found in the Sustainability Report 2023. 

48    Medibank 

 
 
 
 
 
 
 
Risk management during the cybercrime

This year, Medibank and our customers were the subject of 
a cybercrime event. A criminal accessed Medibank systems 
using stolen credentials and stole information relating to 
around 9.7 million current and former Medibank and ahm 
customers, as well as My Home Hospital patients and 
healthcare providers. The stolen information included health 
claims data for some patients and customers. In response, 
we then took immediate steps to contain the incident and put 
in place additional security measures across the network. 
We engaged specialised security firms and worked with 
the Australian Government’s lead cyber agency and the 
Australian Federal Police. We closed down the criminal’s 
attack path and no further activity by the criminal since  
12 October 2022 has been detected inside our systems.

We supported our customers and those impacted by the 
cybercrime through our Cyber Response Support Program, 
which includes mental health and wellbeing support, identity 
protection and financial hardship measures. We implemented 
further security controls, bolstered existing monitoring and 
added further detection and forensics capability. Building upon 
our existing program of work to enhance IT security across 
our business, we expanded our work into an IT security uplift 
program following the cybercrime event. It aims to continue 
maturing our cybersecurity approach and better enable us 
to respond to the rapidly evolving cyber threat landscape. 
We continue to review our cyber security governance 
arrangements, recognising the increasing prevalence of 
cybercrime and the need to meet the ongoing expectations  
of our customers. The cybercrime has, and will continue to 
have, the potential to impact our material business risks. 

As part of the Medibank cyber response playbook, the Board 
formed the Cyber Response Board Committee, delegating 
it with the authority to oversee and make decisions on 
behalf of the Board in relation to any cyber incidents. The 
committee comprises the Chair of the Board, the Chair of 
the Risk Management Committee and the CEO. Following 
the identification of the cybercrime event in October 2022, the 
Cyber Response Board Committee met regularly to oversee 
Medibank’s response to the cybercrime event on behalf of the 
Board. More information about meetings of the Cyber Response 
Board Committee and the Board in relation to the cybercrime 
event can be found in the directors’ report on page 52.

Following the identification of the cybercrime event, the 
Crisis Management Team (CMT) was activated, consisting 
of executive leadership team members and appropriate 
specialists in accordance with our crisis management plan. 
The CMT met extensively from October until Medibank 
transitioned to an ongoing business operations approach  
in December 2022. 

Under the direction of the CMT and in accordance with 
Medibank’s cyber response playbook, senior management 
activated specific workstreams to respond to, and to contain, 
the cybercrime event. The workstreams included extensive 
resources diverted to our response and consisted of:

•  Remediation – rapid closure of the attack pathway,  

threat actor eviction and enhanced monitoring

•  Data analysis – analysing and assessing data that had,  

or potentially had, been compromised

•  Customer teams – scaling up customer team resourcing  
to support our customers during the cybercrime event  
and ongoing 

•  Customer support – rapid implementation of a customer 
support program including mental health and wellbeing 
support, identity protection and financial hardship 
measures

•  Communications – ensuring open and transparent 

communications to our stakeholders including customers, 
regulators, providers, partners and agencies

•  Regulatory – ensuring our key regulators were informed 

and consulted early and regularly

•  Health – managing communications with health 

stakeholders, and ensuring health support programmes 
were available to our customers and people as needed

•  Employee support – ensuring our people were informed 
and supported during the cybercrime event, including  
their health and wellbeing

These workstreams continued to operate as needed for  
our customers following the standing down of the CMT  
in December 2022.

Our Sustainability Report 2023 includes more detail about  
our response to the cybercrime event.

APRA new prudential standard 

APRA finalised its new prudential standard CPS230 - 
Operational Risk Management in July 2023. The standard aims 
to ensure resilience to operational risks and disruptions and 
comes into effect from 1 July 2025. It defines requirements for 
operational risk and absorbs existing standards for business 
continuity (CPS231) and outsourcing (CPS232). We have 
reviewed our risk maturity roadmap (as aligned to APRA’s 
CPS220 Risk Management Standard) and identified the core 
operational requirements that need to be accelerated as 
part of the CPS230 plan. Beginning with a pilot of critical 
processes, we will implement the required changes, with key 
requirements of the standard to be embedded as part of our 
ongoing business-as-usual activities.

Annual Report 2023   49 

Risk management 

Risk culture

Medibank is committed to maintaining a strong risk culture. 
Our values are integral in the way we consider risk in the 
pursuit of our strategic objectives and customer-focused 
outcomes. We acknowledge and recognise the importance of 
doing the right thing for our customers, our people, and the 
community, and this commitment is reflected in our purpose 
and values.

Our risk culture framework is an integral part of our approach 
to risk management and brings together the key elements 
that influence and shape our risk culture in terms of 
behaviours and practices. It clearly highlights the behaviours 
we expect of our people and the practical application of the 
framework. The framework builds upon the foundation of our 
Code of Conduct, which sets out the way we work at Medibank 
via the establishment of standards of behaviour and conduct 
expected from all directors, employees and contractors.  

The Code of Conduct not only emphasises the importance of 
compliance with legal obligations, it also clearly outlines our 
responsibility toward our employees, our customers, and the 
wider community. In adhering to these principles, we strive 
to create a culture that goes beyond mere compliance, to 
one that fosters a genuine commitment to ethical decision-
making and responsible practices. 

When it comes to risk culture, we aim to:

•  Role model our organisational values and support others 
to do the same. This includes positive behaviours around 
managing risk to deliver the right outcomes for our 
shareholders, employees, customers and the community.

•  Encourage transparency and “speaking up” to provide 
opportunities to understand where we can improve, 
especially for our customers.

•  Foster a culture of continuous improvement in managing 

risks. Make it part of our DNA to strive for great outcomes, 
especially for our customers.

Medibank risk culture framework

The following highlights the behaviours we expect of our people and the practical application of the framework:

Leaders at all levels championing  
risk management, setting a clear  
tone and role modelling  
appropriate risk behaviours  
(tone from the top and  
tone from the middle) 

Leadership

Risk appetite
and strategy

Business and strategic 
decisions align with the 
risk appetite statement

Openness to consider  
diverse viewpoints and  
to provide constructive  
challenge and feedback  
across the organisation

Decision
making and
challenge

 in actio n

s
r
u
o

i

v

a

h

e

b

Alignment 
with purpose 
and values

Risk issues are openly  
communicated across the 
organisation and supported  
by an environment where  
people feel safe to speak up

Communication
and
escalation   

k

Ris

s

R i

ation

d

n

u

o

f

d

n

a

e
r
u
t
c

k  archite

Risk governance 
and oversight

There is effective oversight 
of risk and risk culture, 
and risk management is 
supported by appropriate 
frameworks, policies, 
controls and reporting

Responsibility 
and
accountability

 Responsibility and 
accountabilities of risk are 
clearly defined, understood 
and discharged across the 
organisation (particularly the 
three lines of defence)

Level of skills and training, processes,  
systems and data across the three lines  
of defence to support effective risk  
management practices and behaviours

Knowledge 
and capabilities

Performance
management
and incentives

Good risk management behaviour 
is encouraged and rewarded, 
and poor risk behaviour has 
proportionate consequences

50    Medibank 

 
 
 
Directors’ report 
For the financial year ended 30 June 2023

The directors of Medibank Private Limited (Medibank) present 
their report on the consolidated entity consisting of Medibank 
and its subsidiaries (collectively referred to as the Group) for 
the year ended 30 June 2023.

References to 2022 and 2023 are to the financial years 
ended on 30 June 2022 and 30 June 2023 respectively unless 
otherwise stated.

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, the Group’s operations, or the results 
of those operations, or the Group’s state of affairs in future 
financial years. Details of subsequent events are set out in 
Note 20(d). 

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:

•  Mike Wilkins AO – Chair

•  David Koczkar – Chief Executive Officer 

•  Dr Tracey Batten

•  Anna Bligh AC

•  Gerard Dalbosco 

•  Peter Everingham 

•  David Fagan

•  Kathryn Fagg AO 

•  Linda Bardo Nicholls AO

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 its Amplar Health Division, which capitalises 
on Medibank’s experience and expertise, and supports 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 23 to 28.

Significant changes in state of affairs

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

Future developments

Details of developments in the Group’s operations in future 
financial years and the expected results of those operations 
are included in the operating and financial review on pages  
23 to 28.

Dividends

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

•  A fully franked final ordinary dividend of 7.30 cents per 

share was determined in respect of the six-month period to 
30 June 2022, paid on 29 September 2022 to shareholders 
registered on 8 September 2022.

•  A fully franked interim ordinary dividend of 6.30 cents per 

share was determined in respect of the six-month period to 
31 December 2022, paid on 22 March 2023 to shareholders 
registered on 3 March 2023.

•  A fully franked final ordinary dividend of 8.30 cents per 
share has been determined in respect of the six-month 
period to 30 June 2023, payable on 5 October 2023 to 
shareholders registered on 14 September 2023.

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 29  
to 31 and form part of the directors’ report.

Annual Report 2023   51 

Directors’ report 
For the financial year ended 30 June 2023

Directors’ attendance at meetings

The tables below show 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 
tables below do not include the attendance of directors at committee meetings where they were not a committee member.

Director

Board (scheduled) 
9

Board (unscheduled)1 
16

Cyber Response Board Committee 
24

Mike Wilkins
Dr Tracey Batten
Anna Bligh
Gerard Dalbosco
Peter Everingham
David Fagan
Kathryn Fagg
David Koczkar
Linda Bardo Nicholls

A
9
9
9
9
9
9
9
9
9

B
9
9
8
8
9
9
8
9
9

A
16
16
16
16
16
16
16
16
16

B
16
16
13
16
15
16
15
16
16

A
24
-
-
-
-
24
-
24
-

B
24
-
-
-
-
24
-
24
-

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   With the exception of one meeting, all unscheduled Board meetings were primarily to consider the cybercrime event.

Audit Committee 
5

Risk Management 
Committee 
6

Investment and 
Capital Committee 
4

People and 
Remuneration 
Committee 
5

Nomination 
Committee 
2

A
-
-
-
5
5
5
5
-
-

B
-
-
-
5
4
5
4
-
-

A
-
6
6
6
-
6
-
-
6

B
-
6
5
5
-
6
-
-
6

A
4
-
4
-
-
-
-
-
4

B
4
-
4
-
-
-
-
-
4

A
5
5
-
-
5
-
5
-
-

B
5
5
-
-
4
-
5
-
-

A
2
2
-
2
-
2
-
-
2

B
2
2
-
2
-
2
-
-
2

Director

Mike Wilkins
Dr Tracey Batten
Anna Bligh
Gerard Dalbosco
Peter Everingham
David Fagan
Kathryn Fagg
David Koczkar
Linda Bardo Nicholls

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

B Indicates the number of meetings attended during the time the director was a member of the committee during the year.

In addition, ad-hoc committees were convened for special 
purposes, including in relation to financial reporting and  
other matters.

As part of the Medibank cyber response playbook, the Board 
formed the Cyber Response Board Committee to oversee 
Medibank’s response to, and delegated it authority to make 
decisions on behalf of the Board in relation to, any cyber 
incidents. The Committee comprises the Chair of the Board, 
the Chair of the Risk Management Committee, and the CEO. 
Following the identification of the cybercrime event in October 
2022, the Cyber Response Board Committee met regularly 
to oversee Medibank’s response to the cybercrime event on 
behalf of the Board.

Options and performance rights

During the financial year, 4,092,052 performance rights 
were issued to senior executives pursuant to Medibank’s 
Performance Rights Plan. No performance rights have been 
issued since the end of the financial year up to the date of this 
directors’ report.

During the financial year, 1,293,022 performance rights vested 
and were exercised. 

Further information regarding performance rights is included 
in the remuneration report from page 54.

52    Medibank 

Directors’ interest in securities 

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 122.

Non-audit services

The Group may decide to employ its external auditor, PwC, 
on assignments additional to its statutory audit duties, where 
the auditor’s expertise and experience with the Group are 
important. PwC will only be engaged to provide a permissible 
non-audit service where there is a compelling reason for 
it to do so, and will not be engaged to perform any service 
that may impair or be perceived to impair its judgement or 
independence. 

PwC did not provide any non-audit services to the Group 
during the year.

Remuneration report

The remuneration report on pages 54 to 73 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 
Chair   

24 August 2023 
Melbourne

David Koczkar 
Chief Executive Officer

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

Director
Mike Wilkins
David Koczkar
Dr Tracey Batten
Anna Bligh
Gerard Dalbosco
Peter Everingham
David Fagan
Kathryn Fagg
Linda Bardo Nicholls

Performance 
rights

1,894,877

Ordinary 
shares
100,000
1,042,597
50,000
44,623
72,832
40,000
47,016
32,750
45,000

Environmental regulation

The Group’s operations are not subject to any particular 
and 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.

Annual Report 2023   53 

 
 
  
 
 
Remuneration report
For the financial year ended 30 June 2023

Dear shareholder,

On behalf of the Board, I present to you Medibank’s 
remuneration report for 2023 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. 

•  62.3% vesting of Medibank’s 2021 long-term incentive (LTI) 
in line with the terms of grant, noting no vesting against the 
market share hurdle.

•  Zero increase to CEO remuneration in 2024.

•  2024 fixed remuneration increase only for Executive KMPs 

with expanded portfolios.

This has been a challenging year for Medibank, and we 
recognise the impact the cybercrime event has had on our 
customers, our people, and shareholders. We have worked 
hard to regain the trust of our customers, and I am pleased 
to report that momentum has returned to our business 
as a result of this focus. We continue to support affected 
customers through our Cyber Response Support Program, 
which includes a range of services including mental health 
and wellbeing support, identity protection and financial 
hardship initiatives. 

For the first time in our 47-year history, we have surpassed  
4 million health insurance customers. We have also delivered 
the lowest premium rise in 22 years and have returned more 
than $450m in permanent net claims savings to our customers, 
continuing to fulfil our commitment not to profit from COVID-19. 
We also continued to drive the change needed to make our 
health system more sustainable through our preventative 
health programs, new care models and virtual health care.

We have delivered a solid result this year, with our health 
insurance business returning to policyholder growth. This  
was supported by underlying profit growth in Medibank  
Health and our strong capital position, with net investment 
income more than offsetting the non-recurring costs 
associated with the cybercrime event.

Our remuneration strategy has been developed to recognise 
our people for responsibly executing Medibank’s strategy, 
role-modelling behaviours and achieving business objectives 
that increase value for our customers, shareholders, and 
the community. Supporting this strategy, our remuneration 
framework reinforces our risk management framework, 
linking individual performance and behaviours with achieving 
business objectives that support Medibank’s long-term 
financial success. 

Remuneration decisions at a glance

•  Average 3.8% increase in 2024 fixed remuneration for 

Executive KMP’s excluding the CEO. 

•  Zero increase to Non-executive director fees for 2024.

•  2024 Maximum STI opportunity increased to 120% for the 
Group Lead – Chief Customer Officer to align with other 
Executive KMP roles.

Short-term incentives

Consistent with prior years, the Board adjusted STI outcomes 
to normalise for COVID-19 related impacts (both negative 
and positive). Group operating profit and Health Insurance 
revenue growth were above the threshold required for STI 
payments, while our Customer Net Promoter Score (cNPS) 
fell short of expectations.

In consideration of striking the right balance between 
executive incentive outcomes and the expectations of our 
customers, shareholders and the community, the Board 
exercised its discretion, and reduced the 2023 STI outcomes 
for Executive KMP and other members of the executive 
leadership team to zero. 

Long-term incentives

Medibank’s 2021 LTI was tested following the completion 
of the performance period on 30 June 2023. The Board 
determined it was appropriate to allow the LTI to vest in line 
with the terms of its grant, as the vesting outcome of 62.3% 
reflects an appropriate balance between shareholder and 
customer interests over the three-year period including the 
impact of the cybercrime event. The outcome comprises:

•  full vesting against EPS CAGR measure with a result of 

10.8%, calculated including the costs associated with the 
cybercrime event, 

•  partial vesting against the TSR measure with a performance 
rank at the 64th percentile against our comparator group and 

•  Zero 2023 short-term incentive (STI) for the CEO, Executive 
KMP and other members of the executive leadership team.

•  no vesting against the market share growth measure, which 

was negatively impacted by the cybercrime event. 

•  Variable remuneration outcomes reduced by approximately 
$3.6m, including $2.6m specific to current ELT members  
in response, to the cybercrime event.

54    Medibank 

Executive KMP remuneration and non-executive 
director fees

As a result of changes to individual role accountabilities 
and with reference to the median of Medibank’s benchmark 
comparator group, fixed remuneration increases were 
provided to select Executive KMP to reflect their expanded 
portfolios. 

The maximum 2024 STI opportunity for the Group Lead – 
Chief Customer Officer was also changed from 100% to  
120% of fixed remuneration in recognition of the potential 
impact this role has on this organisation and to align with  
the STI opportunity of other Executive KMP. 

Key changes for 2024 include longer deferral periods on 
variable remuneration for our executive leadership team, 
the introduction of customer service satisfaction in our STI 
plan and the addition of a new brand sentiment performance 
hurdle in our LTI plan. These changes will be effective from 
1 July 2023 and are designed to meet both the deferral and 
non-financial measure requirements of the standard. Further 
details on these changes will be included in the 2023 notice of 
annual general meeting and in the 2024 remuneration report.

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

Yours sincerely,

Zero increase in remuneration for the CEO and non-executive 
directors.

2024 remuneration framework

During the year the Board reviewed the remuneration 
framework to meet the regulatory requirements of APRA's 
new remuneration standard (CPS511) and to further enhance 
the focus on customer in our remuneration structures. 

Dr Tracey Batten 
Chair, People and Remuneration Committee

Contents

1. 

 Key management personnel overview

8. 

 2023 actual remuneration (Non-IFRS disclosure)

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   2023 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 2023
 7.1   2023 short-term incentive (STI) performance scorecard
 7.2   Medibank’s 2023 financial performance
 7.3   2023 STI awards
 7.4   2021 long-term incentive plan outcomes

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.   2023 non-executive director remuneration statutory 

table

13.  Non-executive director ordinary shareholdings

14.  Medibank’s comparator group

15.  Loans and other transactions with KMP

Annual Report 2023   55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Remuneration report
For the financial year ended 30 June 2023

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 2023, KMP 
were as follows: 

Key management personnel

David Koczkar 
Chief Executive Officer 
Full-year 

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

Milosh Milisavljevic 
Group Lead – Chief Customer 
Officer 
Full-year 

Andrew Wilson 
Group Lead – Chief Executive 
Amplar Health 
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 

Peter Everingham 
Non-executive director 
Full-year 

David Fagan 
Non-executive director 
Full-year 

Kathryn Fagg 
Non-executive director 
Full-year 

Linda Bardo Nicholls 
Non-executive director 
Full-year 

56    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 of the Chief Executive Officer has been maintained at current levels for 2024.

•  Fixed remuneration increased only for Executive KMP’s with expanded portfolios for 2024. 

•  The average increase for Executive KMP's excluding the CEO was 3.8% for 2024. 

Short-term 
incentive  
(STI)

•  In consideration of the expectations of our customers, shareholders, and the community following 

the cybercrime event the Board exercised discretion and reduced the 2023 STI outcomes for 
Executive KMP to zero.

Long-term 
incentive  
(LTI)

•  2024 Maximum STI opportunity increased from 100% to 120% of fixed remuneration for the Group 

Lead – Chief Customer Officer in recognition of the impact this role has on the organisation.

•  Medibank’s 2021 LTI was tested following the completion of the performance period on 30 June 2023 

and resulted in a vesting outcome of 62.3% in line with the terms of the grant. 

•  This outcome reflects full vesting against EPS CAGR measure with a result of 10.8% which includes 

costs associated with the cybercrime event, partial vesting against the TSR measure with a 
performance rank at the 64th percentile against our comparator group and no vesting against the 
market share growth measure.

•  2024 LTI opportunity percentages for Executive KMP members, including the CEO, have been 

maintained at current levels.

Non-executive directors

Non-executive 
director fees

•  Non-executive director fees have been maintained at their current levels for 2024.

Annual Report 2023   57 

Remuneration report
For the financial year ended 30 June 2023

3. Medibank’s remuneration strategy 

At Medibank, we believe that remuneration has a key influence 
on behaviour and is valuable in reinforcing our culture. 
Our people are guided by our purpose and values which 
are anchored to the core pillars of our culture – health and 
wellbeing, our people and customers, and our performance. 

Our remuneration strategy has been developed to reward 
our people for responsibly executing Medibank’s strategy, 
role-modelling behaviours that strengthen our purpose and 

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 success and risk management framework.

The diagram below illustrates the relationship between 
Medibank’s remuneration strategy, reward framework and  
the timeline of when 2023 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

•  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

2023 remuneration timeline

•  50% cash

•  50% performance 
rights deferred  
for 12 months

•  Three-year deferred 
performance rights

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

58    Medibank 

FY23

FY24

FY25

50%

50%

35%

35%

30%

   date earned 

   date granted 

   eligible for payment or vesting

 
 
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 
Lead - People, Spaces & 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 52 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 performance measures that are aligned 
to the achievement of Medibank’s customer and financial 
milestones set out in the annual report. Aligned with 
Medibank’s Group-wide performance framework ‘I Perform 
Better’, the role-specific measures for 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. 

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 2023 did not 
constitute a remuneration 
recommendation

Annual Report 2023   59 

Remuneration report
For the financial year ended 30 June 2023

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.

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 performance, customer outcomes, 
community and shareholder expectations.

4.2.2 Malus and clawback of executive performance-
based remuneration

Medibank’s Malus and Clawback Policy provides the Board 
with discretion to reduce, cancel, or recover performance-
based awards made to employees 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 Malus and Clawback Policy provides that if any 
of these events occur 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.

Malus provisions allow Medibank to reduce or cancel the 
award before it has been paid, while clawback provisions 
allow Medibank to recover a performance-based award  
after it has been paid (or share awards vested). 

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 2023, 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 2023 $2

1,550,000
825,000
1,035,000
1,020,000

3,669,941
138,804
1,953,311
4,114,739

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 2023.

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 2023 ($3.52).

4.2.4 Share Trading Policy

We have a Share Trading Policy to ensure that non-
executive directors and 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 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. 

60    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.

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

Please refer to page 50 of the risk management section  
for an overview of our risk culture.

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 Hub Lead – Group Risk & Chief Risk Officer, 
Group Lead – People, Spaces & Sustainability and Group 
Lead – Trust, Legal & 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 long-term incentive (LTI) Plan to 
ensure risk outcomes are considered over extended periods.

5.3 Consequence management

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

In 2023, 15 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 10 individuals in 2023 
had their employment terminated following an incident of 
misconduct. Further details on consequence management 
can be found in our Sustainability Report 2023.

Medibank recognises the impact the cybercrime event 
has had on our customers, our people, and shareholders. 
In consideration of the expectations of our customers, 
shareholders, and the community the Board exercised their 
discretion and their powers under the malus and clawback 
policy to reduce the variable remuneration outcomes of 10 
(current and former) employees by approximately $3.6 million.

Annual Report 2023   61 

Remuneration report
For the financial year ended 30 June 2023

6. Executive KMP remuneration components

6.3.1 STI gateways

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 2023 target remuneration mix

The 2023 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)

6.2 Total fixed remuneration (TFR)

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 2023 $
1,550,000
825,000
1,035,000
1,020,000

1 July 2023 $
1,550,000
900,000
1,070,000
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.

62    Medibank 

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, cybersecurity, health and safety, bullying and 
harassment, bribery and corruption and meeting our legal, 
ethical and governance requirements.

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

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

Assessment of the risk, compliance and behaviour gateway 
is also subject to feedback provided by the Hub Lead – Group 
Risk & Chief Risk Officer, Group Lead – People, Spaces & 
Sustainability and Group Lead – Trust, Legal & 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, 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.

 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?

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

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. 

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 2023, 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 2023. Actual target values are not disclosed as this is 
considered commercially sensitive information.

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

Medibank has a Malus and Clawback Policy that provides discretion to the Board 
to reduce, cancel, or recover (clawback) any award made under the STI plan to 
employees 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 executive 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 executive will forfeit any payment 
under the STI plan, including any unvested deferred STI grants, unless otherwise 
determined by the Board.

Annual Report 2023   63 

Remuneration report
For the financial year ended 30 June 2023

6.3.4 Annual STI opportunity

6.4 Long-term incentive (LTI)

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

2023

2024

Executive KMP

Target Maximum Target Maximum

David Koczkar
Milosh Milisavljevic
Mark Rogers
Andrew Wilson

100%
65%
65%
65%

150%
100%
120%
120%

100%
65%
65%
65%

150%
120%
120%
120%

6.4.1 Key features of the LTI plan

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. 

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 2023 LTI plan?

The performance period for the 2023 LTI plan is three financial years commencing 1 July 
2022. 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.

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.

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

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 2023 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 2022. This average price was $3.19.

What are the performance 
hurdles under the 2023 LTI 
plan?

Performance rights issued under the 2023 LTI plan are subject to 3 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 2022 and the performance period for the EPS performance hurdle will run for  
3 years from 1 July 2022 through to 30 June 2025. 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.

64    Medibank 

What are the performance 
hurdles under the 2023 LTI 
plan? cont.

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 2023 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 
malus and clawback policy 
that applies to the LTI plan?

Medibank has a Malus and Clawback Policy that provides discretion to the Board to  
reduce, cancel, or recover (clawback) any award made under the LTI Plan to an employee  
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.

Annual Report 2023   65 

Remuneration report
For the financial year ended 30 June 2023

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

Medibank’s TSR ranking 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

2023 & 2024

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. Vesting schedules for the 2023 LTI allocation 
are consistent with schedule applied to the 2022 LTI offer. 

2023 EPS performance rights (35% of award)

Medibank’s TSR rank in the 
2023 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.

In this context, the Board approved maintaining a threshold 
EPS CAGR target of 3% for the 2023 LTI grant. Details of  
the vesting schedule are outlined in the table below:

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

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.

2023 TSR performance rights (35% of award)

The Board approved maintaining the vesting schedule for 
the TSR hurdle. 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 2023 TSR performance rights 
to vest, Medibank must achieve the threshold TSR ranking 
over the performance period. The percentage of the 2023 
TSR performance rights that vest, if any, will be based on 

 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 2023 comparator group are 
determined at the commencement of the performance 
period. If the ordinary shares or stock of a member of the 
2023 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.

2023 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%

66    Medibank 

 
 
7. Linking remuneration and performance in 2023
7.1 2023 short-term incentive (STI) performance scorecard

Gateways

Both the Financial Gateway and the Risk, Compliance & Behaviour Gateway (in respect of each of the Executive KMP’s roles) 
were met. In consideration of the cybercrime event and the expectations of our customers, shareholders, and the community, 
the Board exercised their discretion and reduced 2023 STI outcomes for Executive KMP to zero. The following table details the 
2023 STI performance scorecard measures, weightings, and assessment.

Measure

Description

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. Group operating profit for the purposes 
of the 2023 STI is inclusive of cybercrime event related 
expenses.

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.

Group 
operating 
profit

Health 
Insurance 
premium 
revenue 
growth

Weighting

Group 
Lead – CEO 
Amplar

Other 
Executive 
KMP

2023 
Outcomes

CEO

45%

22.5%

35%

Above 
threshold

20%

15%

25%

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%

12.5%

20%

Role-specific  
big goals

Aligned to one or more of the following milestones:

1.  Deliver leading experiences – Continue to achieve a high 
level of customer and employee advocacy by creating 
personalised and connected customer experiences, 
empowering our people and collaborating with our 
communities to make a difference. 

2.  Differentiate our insurance business – We aim to achieve 

market share and net policy holder growth (including 
growth in the Medibank brand) and to deliver $30m 
productivity savings in FY23-FY25 including $10m in FY23.

3.  Expand in health – We aim to achieve at least 15% p.a. 
organic segment profit growth and to invest $150m - 
$250m in total to grow Medibank Health inorganically 
as suitable opportunities arise over the next 3 years 
by focusing growth on prevention and integrated care 
models, scaling and connecting our health business and 
bringing benefits back to our core. 

15%

50%

20%

Above 
threshold

Below 
threshold

Ranging 
between 
below 
threshold 
to ahead 
of target

Annual Report 2023   67 

Remuneration report
For the financial year ended 30 June 2023

7.2 Medibank’s 2023 financial performance

Medibank’s 2023 annual financial performance is provided in the table below in addition to the average 2023 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

2023
4.2%
$601.1m
$511.1m
14.6 cent p/s
$3.25
$3.52

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

0%

72%

70%

0%

56%

1. 

 2019 Group operating profit of $558.7 million includes $30.2 million of operating profit attributable to discontinued operations. For 2023 Group operating profit 
of $647.5 million was adjusted to include the non-recuring cybercrime costs of $46.4 million.

7.3 2023 STI awards

The table below provides a summary of STI awards for the 2023 performance year. 

Executive KMP
David Koczkar
Milosh Milisavljevic
Mark Rogers

Andrew Wilson

Total STI 
achieved $
-
-
-

STI cash (50%) 
$
-
-
-

STI deferred 
(50%) $
-
-
-

Total STI 
achieved as % 
of target
0%
0%
0%

Total STI 
achieved as % of 
max opportunity
0%
0%
0%

-

-

-

0%

0%

 Target STI $
1,550,000
536,250
672,750

663,000

With consideration of the expectations of our customers, shareholders, and the community following the cybercrime event the 
Board exercised discretion and reduced the 2023 STI outcomes for Executive KMP to zero.

7.4 2021 Long-term incentive plan outcomes

Medibank’s 2021 LTI was tested following the completion of the performance period on 30 June 2023. The Board determined 
it was appropriate to allow the LTI to vest in line with the terms of its grant, as the vesting outcome of 62.3% reflects an 
appropriate balance between shareholder and customer interests over the three-year period including the impact of the 
cybercrime event. The table below outlines the final outcome against the EPS CAGR, Relative TSR, and market share 
performance hurdles and associated vesting percentage for each. 

Performance hurdle
EPS CAGR
Relative TSR
Market Share

Total 2021 LTI vesting percentage

Weighting
35%
35%
30%

Outcome
10.8%
64th Percentile
27.08%

Vesting percentage
100%
78%
0%

62.3%

The performance rights under the 2021 LTI Plan that do not vest because of the performance hurdle outcomes not being  
met will lapse immediately.

The 2022 and 2023 LTI plans remain in restriction and will be assessed against their performance hurdles at the completion  
of the 2024 and 2025 financial years respectively.

68    Medibank 

 
 
8. 2023 actual remuneration (Non-IFRS disclosure)

The table below represents the 2023 ‘actual’ remuneration for Executive KMP and includes all cash payments made in  
relation to 2023, in addition to deferred short-term incentive (STI) and long-term incentive (LTI) awards that vested in 2023.

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 
$ 
1,548,269
823,442
1,033,788
1,019,308

Cash STI for 
performance 
to 30 June 
2023 
$
-
-
-
-

Total cash 
payments 
in relation 
to 2023 
$
1,548,269
823,442
1,033,788
1,019,308

Deferred 
equity awards 
that vested in 
20231  
$
660,095
55,900
583,240
624,528

Total 
2023 actual 
remuneration 
$
2,208,364
879,342
1,617,028
1,643,836

Equity awards 
that lapsed in 
20232 
$
384,422
78,471
320,350
384,422

Executive KMP
David Koczkar
Milosh Milisavljevic
Mark Rogers
Andrew Wilson

1. 

2. 

 Deferred equity awards that vested in 2023 relate to 2021 STI deferred performance rights (including shares allocated as dividend equivalent for the deferral 
period as per plan rules) and 2020 LTI performance rights that vested during the year. 

 Equity awards that lapsed in 2023 relate to the portion of the 2020 long-term incentive (LTI) performance rights that lapsed following the testing of the 
performance hurdles in July 2022.

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 2023 
actual remuneration, the table below includes accrual amounts for equity awards being expensed throughout 2023 that are yet 
to, and may never, be realised.

Short-term 
benefits

Post-employment 
benefits

Long-term  
benefits

Equity-based 
benefits

Other

Executive 
KMP

Financial 
year

Salary  
$1

Short-term 
incentive 

(STI) $ Other $

Non-monetary 
benefits  
$2

Superannuation  
$

Leave  
$3

Deferred 
STI  
$

Performance 
rights  
$4

Termination 
benefits  
$

Total 
remuneration 
$

David  
Koczkar

Milosh 
Milisavljevic

Mark  
Rogers

Andrew 
Wilson

Total 
Executive 
KMP

2023

2022

2023

2022

2023

2022

2023

2022

2023

1,536,560

-

1,523,622

861,228

769,948

754,326

1,013,573

980,097

957,739

971,537

4,277,820

-

302,413

-

422,042

-

384,956

-

2022

4,229,582

1,970,639

-

-

-

-

-

-

-

-

-

-

18,082

21,838

13,897

14,833

15,891

15,836

20,929

20,614

68,799

73,121

27,500

27,500

27,500

27,500

59,869

47,627

56,347

40,033

25,408

110,493

23,749

25,456

25,000

64,362

50,213

60,576

105,864

276,922

103,749

212,598

-

-

-

-

-

-

-

-

-

-

1,616,992

1,279,338

419,506

299,655

634,380

649,377

612,467

626,895

3,283,345

2,855,265

-

-

-

-

-

-

-

-

-

-

3,259,003

3,761,153

1,287,198

1,438,760

1,799,745

2,155,463

1,666,804

2,089,578

8,012,750

9,444,954

1. 

2. 

3. 

4. 

 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.

 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.

 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. 

 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.

Annual Report 2023   69 

Remuneration report
For the financial year ended 30 June 2023

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 2023 remuneration mix for Medibank’s  
Executive KMP as detailed in the ‘statutory remuneration table’.

Executive KMP

David Koczkar
Milosh Milisavljevic
Mark Rogers
Andrew Wilson

Non-performance-related

          Performance-related

Fixed 
remuneration1

Cash 
STI

Deferred 
STI2

50.4%
67.4%
64.8%
63.3%

0%
0%
0%
0%

13.2%
11.7%
11.7%
11.5%

Total  
performance-related 
remuneration

49.6%
32.6%
35.2%
36.7%

LTI3

36.4%
20.9%
23.5%
25.2%

1. 

2. 

3. 

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

 Deferred STI includes the 2023 accounting expense of the 2022 deferred STI component within the ‘performance rights’ column of the ‘statutory  
remuneration table’.

 LTI includes the 2023 accounting expense of the 2021, 2022 and 2023 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 2023 Executive KMP equity award transactions and outstanding holdings granted in previous years are set out below.

Executive 
KMP

David  
Koczkar

Award type1

Balance  
1 July 2022

Units

Value

Units

Value

Units

Value

Units

Value

Acquired  
during 20232

Vested  
during 20233

Lapsed  
during 20234

Other 

changes Balance 30 June 20235

Long-term incentive

1,105,817

728,840

1,549,513

246,617

882,586

Short-term incentive

Ordinary shares

Milosh 
Milisavljevic

Long-term incentive

Short-term incentive

Mark  
Rogers

Andrew  
Wilson

Ordinary shares

Long-term incentive

Short-term incentive

Ordinary shares

Long-term incentive

Short-term incentive

Ordinary shares

102,787

858,734

241,774

-

24,118

557,043

94,480

392,355

594,635

93,322

995,119

75,025

108,838

183,863

15,315

-

15,315

62,521

100,042

162,563

75,025

98,816

273,841

386,254

660,095

55,900

-

55,900

228,202

355,038

583,240

273,841

350,687

624,528

105,321

384,422

-

-

-

-

21,499

78,471

-

-

-

-

87,767

320,350

-

-

-

-

105,321

384,422

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

1,654,311

3,679,826

240,566

861,226

1,042,597

3,669,941

373,063

84,472

39,433

829,528

302,410

138,804

617,648

1,371,012

117,888

422,039

554,918

1,953,311

622,125

1,381,118

107,529

384,954

1,168,960

4,114,739

-

173,841

-

168,103

84,472

-

210,893

123,450

-

207,836

113,023

-

-

357,387

302,410

-

448,358

441,673

-

441,859

404,348

1. 

2. 

3. 

 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.

 Represents the maximum number of equity awards that may vest to each executive in respect to their time as KMP during 2023. 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 2021, 2022 and 2023  
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.

 Awards that vested in 2023 relate to the 100% vesting of 2021 Deferred STI award (including shares allocated as dividend equivalent for the deferral period as 
per plan rules) and the 41.6% vesting of 2020 LTI award (granted 28 November 2019) 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. 

4. 

 Awards that lapsed in 2023 relate to the 58.4% of the 2020 LTI award that did not meet the performance hurdle and subsequently lapsed.

5. 

 The value of unvested STI is determined by the number of units at 30 June 2023 multiplied by the unit price at grant. The value of unvested LTI is determined 
by the number of units at 30 June 2023 multiplied by the fair value at grant. The value of ordinary shares is determined by multiplying the number of ordinary 
shares at 30 June 2023 by the closing price of Medibank shares on the same date.

70    Medibank 

10.2 Overview of unvested equity awards and fair value assumptions

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

Award
2023 LTI 
performance rights

2022 deferred STI 
performance rights
2022 LTI 
performance rights

2021 deferred STI 
performance rights
2021 LTI 
performance rights

2020 LTI 
performance rights

Award 
type
LTI

Performance 
start date
1/07/2022

Performance 

Performance 

end date1 Grant date
6/12/2022

30/06/2025

measure Weighting
35%
30%
35%

EPS
Market share
TSR

Unit price 
at grant
3.19
3.19
3.19

Fair value 
at grant2
2.63
2.63
1.19

STI
LTI

STI
LTI

1/07/2022
1/07/2021

15/09/2023
30/06/2024

6/12/2022
3/12/2021

1/07/2021
1/07/2020

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

LTI

1/07/2019

30/06/2022 28/11/2019

Service
EPS
Market share
TSR

Service
EPS
Market share
TSR
EPS
Market share
TSR

100%
35%
30%
35%

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

3.58
3.13
3.13
3.13

3.55
3.02
3.02
3.02
3.46
3.46
3.46

3.58
2.72
2.72
1.62

3.55
2.54
2.54
1.58
2.80
2.80
1.09

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

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). 

Component Delivered

Description

11.1.2 Non-executive director remuneration

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.

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).

Non-executive director base and committee fees have been 
maintained at their current levels for 2024. Based on the 
composition of the Board, non-executive director fee spend 
for 2024 will remain at $2,019,300 against the approved cap  
of $2,300,000. 

Annual Report 2023   71 

Remuneration report
For the financial year ended 30 June 2023

Non-executive director fees applicable throughout 2023 and 
2024 are set out in the table below:
Position

Fees 2023 & 2024 $

contribution limits. Superannuation contributions for non-
executive directors are drawn from the overall fees paid to 
non-executive directors.

Chair

Non-executive directors

Committee chair fees

Audit Committee

Risk Management Committee

People and Remuneration Committee

Investment and Capital Committee

Committee membership fees

Audit Committee

Risk Management Committee

People and Remuneration Committee

Investment and Capital Committee

458,500

170,000

41,200

41,200

41,200

41,200

20,600

20,600

20,600

20,600

11.2 Non-executive director superannuation

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 

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.

11.3 Shareholding policy for 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 at 30 June 2023, all non-executive directors have met 
the minimum shareholding requirement. Further details of 
current non-executive director shareholdings are provided in 
section 13.

12. 2023 non-executive director remuneration statutory table

Non-executive director

Mike Wilkins

Tracey Batten

Anna Bligh

Gerard Dalbosco

Peter Everingham3

David Fagan

Kathryn Fagg3

Linda Bardo Nicholls

Former non-executive directors
Peter Hodgett2
Christine O’Reilly2
Total non-executive director 
remuneration

Short-term 
benefits

Post-employment 
benefits

Financial 
year

Cash salary and fees  
$

Non-monetary1  
$

Superannuation  
$

Total  
$

2023
2022
2023
2022
2023
2022
2023
2022
2023
2022
2023
2022
2023
2022
2023
2022

2022
2022
2023
2022

453,452
446,711
210,549
191,670
191,837
187,054
209,840
213,703
191,837
47,308
210,548
215,023
191,837
47,308
232,691
204,643

79,846
87,863
1,892,591
1,721,129

4,818
4,414
2,792
2,703
3,343
3,532
2,747
1,248
3,315
593
3,118
3,019
143
-
2,812
3,026

6,070
5,355
23,088
29,960

6,812
-
22,143
19,196
20,175
18,734
22,851
4,470
20,175
4,731
22,143
21,534
20,175
4,731
-
-

465,082
451,125
235,484
213,569
215,355
209,320
235,438
219,421
215,327
52,632
235,809
239,576
212,155
52,039
235,503
207,669

8,053
-
134,474
81,449

93,969
93,218
2,050,153
1,832,538

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. 

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

3. 

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

72    Medibank 

13. Non-executive director ordinary shareholdings

Balance 
30 June 
2022

Acquired 
during the 
year

Other 
changes 

100,000
50,000

44,623

72,832

40,000

47,016

32,750

45,000

-
-

-

-

-

-

-

-

-
-

-

-

-

-

-

-

Balance 
30 June 
2023

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 
2023 $2

Minimum 
shareholding 
requirement timeline

229,250
85,000

85,000

85,000

85,000

85,000

85,000

85,000

352,000 Requirement satisfied
176,000 Requirement satisfied

157,073 Requirement satisfied

256,369 Requirement satisfied

140,800 Requirement satisfied

165,496 Requirement satisfied

115,280 Requirement satisfied

158,400 Requirement satisfied

Non-executive director

Mike Wilkins
Tracey Batten

Anna Bligh

Gerard Dalbosco

Peter Everingham

David Fagan

Kathryn Fagg

Linda Bardo Nicholls

1.  Minimum shareholding requirement based on annual non-executive director base fees for 2023 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 2023 ($3.52).

14. Medibank’s comparator group

15. Loans and other transactions with KMP 

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.

During 2022 and 2023 there were no loans to KMP or any of 
their 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 2023   73 

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 75

page 76

page 77

page 78

Section 1
Basis of  
preparation
page 79

1.  Basis of  

preparation

Section 2
Operating  
performance
page 80

2.  Segment 

information

3.  Insurance  

underwriting 
result

4.  Deferred 

acquisition costs

5.  Unearned premium 

liability

6.  Shareholder  

returns

Section 3
Investment portfolio 
and capital
page 92

Section 4
Other assets  
and liabilities
page 103

Section 5
Other 

page 111

7.       Investment 
portfolio

8.       Financial risk 
management

9.       Working capital

10.   Contributed equity 
and reserves

11.   Property, plant 
and equipment

12.   Intangible assets

13.   Provisions 

and employee 
entitlements

14.  Leases

15.  Income tax

16.  Group structure

17.   Related party 

transactions

18.   Share-based 
payments

19.   Auditor’s 

remuneration

20.  Other

Signed reports

Directors’ declaration

Auditor’s independence declaration

Independent auditor’s report

page 121

page 122

page 123

74    Medibank 

 
Consolidated statement of comprehensive income
For the financial year ended 30 June 2023

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

2023 
$m

2022 
$m

2(b) 3(a)

3(a)

13(a)(ii)

16(b)

 7,182.0 
 173.3 
 7,355.3 

 6,881.2 
 247.3 
 7,128.5 

 1.0 

 1.0 

 (5,859.7)
 (27.6)
 (455.5)
 (109.8)
 (115.5)
 (78.1)
 (118.4)
 (1.8)
 (1.4)
 (6,767.8)

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

Profit before net investment income and income tax

 588.5 

 584.8 

Net investment income/(expense)

7(a)

 138.6 

 (24.8)

Profit for the year before income tax

727.1

 560.0 

Income tax expense
Profit for the year

Other comprehensive income

Items that will not be reclassified to profit or loss
Actuarial gain 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)

(216.0) 
511.1

 (166.1)
 393.9 

 - 

 0.2 

 511.1

 394.1 

6(b)

 18.6 

 14.3 

Annual Report 2023   75 

 
 
Consolidated statement of financial position
 As at 30 June 2023

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. 

76    Medibank 

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

2023 
$m

2022 
$m

 420.6 
 248.1 
 2,866.8 
 34.8 
 97.8 
 25.9 
 3,694.0 

 70.5 
 328.1 
 44.3 
 130.8 
 117.6 
 3.5 
 694.8 

 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

 4,388.8 

 4,552.8

 328.5 
 767.3 
 776.8 
 - 
 136.1 
 94.0 
 2,102.7 

 39.4 
 10.0 
 131.7 
 20.6 
 201.7 

 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

 2,304.4 

 2,607.2

 2,084.4 

 1,945.6

10(a)
10(b)

 85.0 
 27.9 
 1,971.5 
 2,084.4 

 85.0
 25.7
 1,834.9
 1,945.6

Consolidated statement of changes in equity
For the financial year ended 30 June 2023

Contributed 
equity 
$m
 85.0 

Note

 Reserves 
$m 
 22.3 

Retained 
earnings 
$m
 1,798.8 

Balance at 1 July 2021

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)

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 2023

6(a)(i)

 - 
 - 
 - 

 - 
 - 
 - 
 85.0 

 - 
 - 
 - 

 - 
 - 
 - 
 85.0 

 - 
 - 
 - 

 - 
 (2.5)
 5.9 
 25.7 

 - 
 - 
 - 

 - 
 (4.5)
 6.7 
 27.9 

 393.9 
 0.2 
 394.1 

 (358.0)
 - 
 - 
 1,834.9 

 511.1 
 - 
 511.1 

 (374.5)
 - 
 - 
 1,971.5 

Total 
equity 
$m
 1,906.1 

 393.9 
 0.2 
 394.1 

 (358.0)
 (2.5)
 5.9 
 1,945.6 

 511.1 
 - 
 511.1 

 (374.5)
 (4.5)
 6.7 
 2,084.4 

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

Annual Report 2023   77 

Consolidated statement of cash flows
For the financial year ended 30 June 2023

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
Dividends received from equity accounted investments
Purchase of plant and equipment
Purchase of intangible assets
Net cash inflow/(outflow) from investing activities

Cash flows from financing activities
Purchase of shares to settle share-based payment
Lease principal and interest payments
Dividends paid
Net cash outflow from financing activities

Net increase/(decrease) in cash and cash equivalents

Cash and cash equivalents at beginning of the year

Cash and cash equivalents at end of the year

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

Note

2023 
$m 

2022 
$m 

9(d)

16(b)
16(b)

14
6(a)(i)

 7,148.1 
 192.4 
 4.5 
 (5,996.4)
 (846.5)
 (317.6)
 184.5 

 71.2 
 (5.0)
 1,761.2 
 (1,703.6)
 (25.9)
 2.5 
 (7.8)
 (34.1)
 58.5 

 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)

 (4.9)
 (39.7)
 (374.5)
 (419.1)

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

 (176.1)

 (75.0)

 596.7 

 671.7 

 420.6 

 596.7 

78    Medibank 

Notes to the consolidated financial statements
30 June 2023

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 2023 were authorised for issue in accordance 
with a resolution of the directors on 24 August 2023. 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 2023 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 2023 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 13: Provisions and employee entitlements. 

•  Note 15: Income tax.

Annual Report 2023   79 

Notes to the consolidated financial statements
30 June 2023

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 2023, 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.

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 

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.

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.

80    Medibank 

(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 2023 is as follows.

Health Insurance

Medibank Health

$592.6m

$6,859.8m

$650.4m

$7,148.7m

$45.5m

$321.8m

$44.2m

$277.1m

2022

2023

2022

2023

Revenue

Operating profit

Revenue

Operating profit

30 June 2023

Revenue

Total segment revenue

Inter-segment revenue

Health 
Insurance 
$m

Medibank 
Health  
$m

Note

Total  
$m

2(c)(iii)

 7,148.7 

 - 

 277.1 

 (70.5)

 7,425.8 

 (70.5)

Revenue from external customers

 7,148.7 

 206.6 

 7,355.3 

Operating profit

 650.4 

 44.2 

 694.6 

Items included in segment operating profit:

Depreciation and amortisation

Interest income from loans to associates

Share of net profit/(loss) from equity accounted investments

16(b)

 (103.3)

 - 

 - 

 (9.3)

 0.2 

 (0.2)

 (112.6)

 0.2 

 (0.2)

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 net profit/(loss) from equity accounted investments

16(b)

 (101.6)

 - 

 - 

 (7.3)

 0.2 

 4.5 

 (108.9)

 0.2 

 4.5 

Annual Report 2023   81 

 
Notes to the consolidated financial statements
30 June 2023

(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)

Cybercrime expenses

Acquisition intangible amortisation

Mergers and acquisitions expenses

Other income/(expenses)

Profit for the year before income tax

    Note 

2023 
$m

 694.6 

2022 
$m

 638.1 

 7(a) 

 (47.1)

 (44.0)

 647.5 

 594.1 

 138.6 

 (46.4)

 (1.4)

 (1.4)

 (9.8)

 (24.8)

 - 

 (2.0)

 (1.7)

 (5.6)

 727.1 

 560.0 

(ii) Other items

Segment operating profit excludes the following:

•  Corporate operating expenses of $47.1 million (2022:  

$44.0 million) relating to the Group's corporate function.

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

 – Interest and distribution income and related investment 
management expenses (refer to Note 7(a)), as this arises 
from investments which are managed by a central 
treasury function.

 – Net gains and losses on disposals of and fair value 
movements on financial assets and liabilities (refer  
to Note 7(a)), as they are not indicative of the Group's 
long-term performance.

•  Expenses incurred in relation to the Group’s cybercrime 
event of $46.4 million (2022: nil). These costs have been 
recognised within the relevant line items in the consolidated 
statement of comprehensive income, including office and 
administration expense of $22.0 million, employee benefits 
expense of $15.6 million, information technology expense  
of $7.6 million and marketing expense of $1.2 million.  
Refer to Note 13(d) for further information.

•  Acquisition intangible amortisation of $1.4 million  

(2022: $2.0 million) not allocated to segments.

•  Expenses in relation to mergers and acquisitions of  

$1.4 million (2022: $1.7 million) which are not allocated  
to the operating activities of the Group’s segments.

•  Other income/(expenses) of $9.8 million (2022: $5.6 million) 
which do not relate to the current period’s trading activities 
of the Group’s segments, comprising primarily net costs 
relating to the Group’s subleases and the Group’s share of 
interest on lease liabilities in relation to its investment in 
East Sydney Day Hospital Pty Ltd. 

(iii) Loyalty program

Segment private health insurance premium revenue is  
after $33.3 million (2022: $21.4 million) of transfers between 
the Group’s other operating segments in relation to the  
loyalty program.

(iv) Segment assets and segment liabilities

No information regarding segment assets and segment 
liabilities has been disclosed, as these amounts are not 
reported to the CEO for the purpose of making strategic 
decisions.

(v) Geographic information

Segment revenue based on the geographical location of 
customers has not been disclosed, as the Group derives  
all of its revenues from its Australian operations.

82    Medibank 

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.  

$7,148.7m

2023 underwriting result after expenses

2023 underwriting result after expenses

$(5,927.9)m

$(570.4)m

$650.4m

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)

2023 
$m

2022 
$m

 7,148.7 

 6,859.8 

 (6,016.6)
 194.5 
 (67.0)
 (36.8)
 (5,925.9)

 (2.0)
 (5,927.9)

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

 (0.5)
 (5,731.6)

 (570.4)

 (535.6)

 650.4 

 592.6 

(i)      Private health insurance premium revenue is  

(iii)   Net claims incurred consists of amounts paid and  

after $33.3 million (2022: $21.4 million) of transfers 
between the Group’s other operating segments in  
relation to the loyalty program and $451.7 million  
(2022: $369.4 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. 

Refer to Note 3(b) for further information.

(ii)    Claims incurred are prior to elimination of transactions 

with the Group’s other operating segments of  
$68.2 million (2022: $51.8 million).

Annual Report 2023   83 

 
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)

2023 
$m

 440.1 
 253.8 
 55.2 
 10.9 
 760.0 

 7.3 
 767.3 

 3.7 
 0.4 
 0.1 
 4.2 

 5.8 
 10.0 

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 

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.

84    Medibank 

Notes to the consolidated financial statements30 June 2023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 
in 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 4.35% per annum which equates to a reduction in the central  
estimate of $2.7 million (2022: 1.81%, $0.9 million).

(iii)  Risk margin

An overall risk margin considers the uncertainty surrounding the outstanding claims liability.  
The risk margin applied to the Group’s outstanding claims central estimate (net of risk equalisation)  
at 30 June 2023 is 12.2% (2022: 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 98% (2022: 95%), increasing  
this period as a result of increased uncertainty arising due to short-term changes in claims 
processing driven by the timing of hospital contracting. 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 2023 is 2.5% of the outstanding claims liability 
(2022: 2.5%).

Annual Report 2023   85 

(v)    Claims liability 
– provision 
for bonus 
entitlements

Certain private health insurance products (Package Bonus, Ultra Bonus and Membership Bonus) 
include benefits that carry forward. Package Bonus carries forward unused benefit entitlements  
in a calendar year for five calendar years. Membership Bonus carries forward unused benefit 
entitlements in a calendar year for 10 calendar years. Ultra Bonus carries forward unused benefit 
entitlements without limit. 

The Group’s claims liabilities include a provision to cover expected future utilisation of these  
benefit entitlements of the current membership.

Key estimate
The bonus provision includes the total entitlement available to members under the terms of the 
relevant insurance policies, less any amounts utilised, with a probability of utilisation based on  
past experience and current claiming patterns applied. The true cost of these entitlements cannot  
be known with certainty until any unclaimed entitlements are processed.

 (vi)   COVID-19 
claims  
liability 

The liability relates to claims deferred as a result of surgeries and other health services restricted  
for policyholders during the COVID-19 pandemic. At 30 June 2023, the COVID-19 liability includes 
surgical and non-surgical hospital claims of $253.8 million (2022: $405.6 million) and ancillary  
claims of nil (2022: $42.7 million). 

Key estimate
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 restrictions  
in March 2020. Any shortfall in claims up to June 2022 is deferred into the liability at the applicable 
claims deferral rate. Claims deferral was ceased after June 2022 as despite the prolonged impact  
of COVID-19, there have been no formal restrictions and lockdowns since that time impeding availability 
and accessibility to surgeries and other health services. The Group will continue to reassess this 
position. Utilisation of the liability occurs where the 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 annually for those 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% (2022: 85%)  
for surgical claims and 20% (2022: 40%) for non-surgical 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.

86    Medibank 

Notes to the consolidated financial statements30 June 2023(c) Reconciliation of movement in claims liabilities

Balance at 1 July

Claims incurred during the period

Increase/(decrease) in COVID-19 claims liability

Claims paid during the period

Amount (over)/under provided on central estimate1

Risk margin

Claims handling costs

Movement in discount rate

Balance at 30 June

Note

(i)

2023 
$m

 871.1 

 5,942.5 

 (194.5)

2022 
$m

 631.5 

 5,369.8 

 224.5 

 (5,847.7)

 (5,348.1)

 (13.6)

 20.2 

 2.0 

 (2.7)

 (8.2)

 2.0 

 0.5 

 (0.9)

 777.3 

 871.1 

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

1 

 The over provision recognised in the current year includes $4.0 million that has been recognised within the COVID-19 liability at the applicable deferral rate. 
Refer to Note 3(c)(i). The remaining amount has been recognised within the net permanent claims savings for the period. 

(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. 

Hospital 
$m

 405.6 

 (84.8)

 4.0 

 (71.0)

 253.8 

Ancillary 
$m

 42.7 

 - 

 - 

 (42.7)

 - 

Total 
$m

 448.3 

 (84.8)

 4.0 

 (113.7)

 253.8 

•  An increase/decrease of 10 percentage points in the 

adopted deferral rate for COVID-19 hospital claims would 
result in a $51.4 million decrease/increase to profit after  
tax and equity (2022: $54.2 million). The reasonable possible 
range for the hospital deferral assumption is 75-100% for 
surgical claims (2022: 75-100%) and 10-30% for non-
surgical and ancillary claims (2022: 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. 

Balance at 1 July 2022

Net change in assumptions1

Amount over/(under) provided from central estimate

Decrease during the period

Balance at 30 June 2023

1.  Includes change in expected deferral rate of $79.8 million.

(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 $31.1 million decrease/increase 
to profit after tax and equity (2022: $25.4 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 $92.6 million decrease and $118.8 million 
increase respectively to profit after tax and equity  
(2022: $117.9 million). 

Annual Report 2023   87 

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 regular 
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.

88    Medibank 

Notes to the consolidated financial statements30 June 2023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.  

2023 
$m

 82.9 

 35.1 

 (38.9)

 79.1 

2022 
$m

 81.1 

 39.6 

 (37.8)

 82.9 

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 
(2022: 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

Movements 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.

2023 
$m

 894.8 

 960.8 

 (817.5)

 (129.6)

 908.5 

2022 
$m

 757.4 

 700.9 

 (697.0)

 133.5 

 894.8 

The unearned premium liability balance at 30 June 2023 includes a provision for premium deferral of $3.9 million (2022:  
$133.5 million). The provision for premium deferral represents amounts owed at balance date in relation to the announcements 
made by the Group to return permanent net COVID-19 savings to eligible policyholders via premium deferrals. 

A separate customer give back provision of $136.1 million (2022: $178.6 million) is recognised in the consolidated statement  
of financial position. Refer to Note 13(c) for further information.

Annual Report 2023   89 

 
(a) Liability adequacy test

The expected cash outflows and the risk margin in the 30 June 2023 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 2023 and 2022. 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 

2023

2022 final fully franked dividend

2023 interim fully franked dividend

2022

2021 final fully franked dividend

2022 interim fully franked dividend

 Cents per fully 
paid share 

 7.30 

 6.30 

 6.90 

 6.10 

$m

 Payment date 

 201.0 

 173.5 

29 September 2022

22 March 2023

 190.0 

 168.0 

30 September 2021

24 March 2022

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

On 24 August 2023, the directors determined a final fully franked ordinary dividend for the six months ended 30 June 2023 of  
8.30 cents per share. The dividend is expected to be paid on 5 October 2023 and has not been provided for as at 30 June 2023. 

(iii) Franking account

Franking credits available at 30 June 2023 for subsequent reporting periods based on a tax rate of 30% are $533.6 million  
(2022: $372.7 million).

(iv) Calculation of dividend paid

Medibank’s target dividend payout ratio for the 2023 financial year is 75-85% (2022: 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.

90    Medibank 

Notes to the consolidated financial statements30 June 2023 
 
Profit for the year – after tax

Normalisation for growth asset returns

Normalisation for defensive asset returns – credit spread movement

Underlying NPAT

2023 
$m

 511.1 

 (4.7)

 (6.8)

 499.6 

2022 
$m

 393.9 

 22.7 

 18.5 

 435.1 

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)

2023

2022

 18.6 

 511.1 

 14.3 

 393.9 

Weighted average number of ordinary shares used in calculating basic and diluted  
earnings per share

 2,754,003,240 

 2,754,003,240 

Basic Earnings Per Share Accounting Policy
Basic earnings per share (EPS) is calculated by dividing 
the profit attributable to equity holders of Medibank, 
excluding any costs of servicing equity other than ordinary 
shares, by the weighted average number of ordinary shares 
outstanding during the reporting period, adjusted for bonus 
elements in ordinary shares issued during the reporting 
period and excluding treasury shares.

Diluted Earnings Per Share Accounting Policy
Diluted EPS adjusts the figures used in the determination  
of basic EPS to take into account:

•  The after income tax effect of any interest and other 

financing costs associated with dilutive potential ordinary 
shares.

•  The weighted average number of additional ordinary 

shares that would have been outstanding assuming the 
conversion of all dilutive potential ordinary shares.

Annual Report 2023   91 

 
Section 3. Investment portfolio and capital

Overview 

This section provides insights into the Group’s exposure to market and financial risks and outlines how these risks are 
managed. This section also describes how the Group’s capital is managed.

Note 7: Investment portfolios

This note 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 
Strategic Asset Allocation (SAA) 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 Non-Health 
Fund 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

 249.9 

 342.0 

 (4.8)

 1,879.3 

 (342.0)

 4.8 

 543.6 

 2,672.8 

 159.6 

 - 

 - 

 1.5 

 - 

 - 

 234.2 

 209.7 

 - 

 - 

 - 

 - 

 - 

 - 

 393.8 

 211.2 

 3,277.8 

Total

 411.0 

 342.0 

 (4.8)

 2,323.2 

 (342.0)

 4.8 

 543.6 

Portfolio composition 30 June 2023 ($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

92    Medibank 

Notes to the consolidated financial statements30 June 2023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 

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 $9.6 million (2022: $24.3 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 
2023

Portfolio 
composition 
30 June 
2022

Target  
asset 
allocation

5.7%
4.5%
6.6%
3.5%
20.3%

5.4%
4.1%
7.4%
2.3%
19.2%

6.0%
5.0%
7.0%
2.0%
20.0%

57.7%
22.0%
79.7%
100.0%

59.0%
21.8%
80.8%
100.0%

60.0%
20.0%
80.0%
100.0%

Health Fund Investment Portfolio

Health Fund Investment Portfolio

International equities
$121.3m

Cash
$587.1m

Infrastructure
$94.7m

Australian equities
$153.2m

Property
$174.4m

Fixed income
$1,542.1m

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

Annual Report 2023   93 

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)

2023 
$m

 86.0 

 27.2 

 34.8 

 (4.4)

 (5.0)

 138.6 

2022 
$m

 17.9 

 43.1 

 (93.0)

 12.3 

 (5.1)

 (24.8)

1. 

 Includes interest income of $6.7 million (2022: $1.0 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.

94    Medibank 

Notes to the consolidated financial statements30 June 2023The following tables present the Group’s financial assets measured and recognised at fair value on a recurring basis.

30 June 2023

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 2023

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

Level 1  
$m

Level 2  
$m

Level 3  
$m

Total  
$m

 - 

 - 

 - 

 - 

 153.2 

 121.3 

 - 

 - 

 58.7 

 2,054.8 

 - 

 209.7 

 - 

 - 

 174.4 

 94.7 

 - 

 - 

 153.2 

 121.3 

 174.4 

 94.7 

 2,113.5 

 209.7 

 58.7 

 2,539.0 

 269.1 

 2,866.8 

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 

1.   Australian equities, international equities, property and infrastructure are indirectly held through unit trusts. 

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.

The following table presents the changes in level 3 financial 
assets during the period.

Balance at 1 July 2022

Acquisitions

Net unrealised gain/(loss) 
on fair value movements

Infrastructure 
$m

Property 
$m

Total 
$m

 57.2 

 31.5 

 182.9 

 240.1 

 4.7 

 36.2 

 6.0 

 (13.2)

 (7.2)

Balance at 30 June 2023

 94.7 

 174.4 

 269.1 

A 10% increase/decrease in the redemption price would 
decrease/increase the fair value of the level 3 financial assets 
by $26.9 million (2022: $24.0 million).

Annual Report 2023   95 

 
 
 
 
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 target and 
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 market 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 (2023: $420.6 million, 2022: $596.7 million) and fixed income assets (2023: $2,323.2 million, 
2022: $2,379.8 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 0.5 years (2022: 0.3 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 $5.2 million increase/decrease to profit after tax and equity 
(2022: $6.9 million). The sensitivity analysis has been conducted using assumptions from published 
economic data.

(ii) Foreign currency risk

Description

The risk that the fair value of a financial instrument will fluctuate because of changes in foreign exchange rates.

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 (2023: $121.3 million, 2022: $100.7 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 $9.4 million decrease/increase to profit after tax and equity (2022: $7.8 million) in the 
AUD valuation of international equities financial assets. Balance date risk exposures represent the risk 
exposure inherent in the financial instruments.

96    Medibank 

Notes to the consolidated financial statements30 June 2023(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

2023  
$m

2022  
$m

+10.0%

-10.0%

+10.0%

-10.0%

 10.3 
 7.7 
 12.8 
 5.2 

 (10.3)
 (7.7)
 (12.8)
 (5.2)

 9.1 
 8.3 
 12.3 
 3.8 

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

In relation to fixed income assets, a 25bps increase/decrease in credit spreads, with all other variables 
remaining constant, would have resulted in a $7.4 million decrease/increase to profit after tax and equity 
(2022: $5.8 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

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% (2022: 50%) of the cash portfolio can be invested in any one counterparty 
bank and no more than 10% (2022: 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% (2022: 50%) and 15% (2022: 15%) of the portfolio respectively.  
As at 30 June 2023 and 2022, the counterparty exposure of the Group was within these limits.

Annual Report 2023   97 

(ii) Trade and other receivables

Description

Due to the nature of the industry and value of individual policies, the Group does not request any collateral 
nor is it the policy to secure its premiums in arrears and trade and other receivables. The Group regularly 
monitors its premiums in arrears and trade and other receivables, with the result that exposure to bad 
debts is not significant. The credit risk in respect to premiums in arrears, incurred on non-payment of 
premiums, will only persist during the grace period of 63 days as specified in the Fund Rules, 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 
2023

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

2022

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

 420.6 

 - 

 - 

 - 

 - 

 - 

 - 

A-1  
A  
$m

A-2  
BBB  
$m

B & below  
BB & below  
$m

Not rated  
$m

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 10.4 

 237.7 

 153.2 

 121.3 

 174.4 

 94.7 

Total  
$m

 420.6 

 10.4 

 237.7 

 153.2 

 121.3 

 174.4 

 94.7 

 326.1 

 649.2 

 400.0 

 338.2 

 7.7 

 392.3 

 2,113.5 

 - 

 209.7 

 - 

 - 

 - 

 - 

 209.7 

 326.1 

 1,279.5 

 400.0 

 338.2 

 7.7 

 1,184.0 

 3,535.5 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 596.7 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 6.3 

 596.7 

 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 

Financial assets at fair value through 
other comprehensive income

 - 

 176.2 

 - 

 - 

 - 

 - 

 176.2 

Total

 285.5 

 1,592.8 

 378.8 

 329.2 

 7.6 

 1,082.7 

 3,676.6 

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. 

98    Medibank 

Notes to the consolidated financial statements30 June 2023(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% (2022: 20%) of its total investment assets in cash/
bank deposits and highly liquid short-term money market 
instruments and fixed income securities. The Short-term 
Operational Cash (STOC) sub-portfolio is reserved for funding 
the COVID-19 claims liability and the customer give backs and 
is invested 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 2023, 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 2023.

2023

Other trade and other payables1

Lease liabilities2

Total trade and other payables

Claims liabilities

COVID-19 claims liability3

Total claims liabilities

2022

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

 295.0 

 18.4 

 313.4 

 482.5 

 78.0 

 560.5 

 329.8 

 17.7 

 347.5 

 389.8 

 95.9 

 485.7 

 2.6 

 17.6 

 20.2 

 33.9 

 175.8 

 209.7 

 1.4 

 17.4 

 18.8 

 23.8 

 352.4 

 376.2 

 5.9 

 14.9 

 20.8 

 6.8 

 - 

 6.8 

 2.5 

 31.8 

 34.3 

 6.8 

 - 

 6.8 

 9.1 

 10.6 

 19.7 

 3.0 

 - 

 3.0 

 7.4 

 15.9 

 23.3 

 3.3 

 - 

 3.3 

 312.6 

 61.5 

 374.1 

 526.2 

 253.8 

 780.0 

 341.1 

 82.8 

 423.9 

 423.7 

 448.3 

 872.0 

 312.6 

 55.3 

 367.9 

 523.5 

 253.8 

 777.3 

 341.1 

 76.9 

 418.0 

 422.8 

 448.3 

 871.1 

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.

Annual Report 2023   99 

Note 9: Working capital

The Group’s working capital balances are summarised in  
this note.

(a) Capital management

Medibank’s health insurance fund is required to maintain 
sufficient capital to comply with APRA’s solvency and capital 
adequacy standards. The solvency standard aims to ensure 
that the fund has enough cash or liquid assets to meet all 
of its liabilities as they become due, even if the cash flow is 
‘stressed’. The standard consists of a requirement to hold 
a prescribed level of cash, and also mandates a Liquidity 
Management Plan.

The capital adequacy standard aims to ensure that there is 
sufficient capital within a health insurance fund to enable 
the ongoing conduct of the business of the fund. The 
standard consists of a requirement to hold a prescribed 

(b) Trade and other receivables

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. 

From 1 July 2023 the new Private Health Insurance (PHI) 
Capital Framework will apply to the Group. In addition, APRA 
has advised the Group that it will apply an additional capital 
adequacy requirement of $250 million from with effect from  
1 July 2023 following APRA’s review of the cybercrime event. 

Premiums in arrears

Allowance for impairment loss

Trade receivables

Allowance for impairment loss

Government rebate scheme

Accrued revenue

Other receivables

Total trade and other receivables

Note: Government rebate scheme is non-interest bearing and generally on 15-day terms.

Note

(i)

(ii)

2023 
$m

 17.2 

 (6.8)

 10.4 

 71.2 

 (3.5)

 67.7 

 146.1 

 16.8 

 7.1 

 170.0 

 248.1 

2022 
$m

 11.9 

 (5.6)

 6.3 

 66.7 

 (2.1)

 64.6 

 137.7 

 13.4 

 3.4 

 154.5 

 225.4 

Past due but not considered impaired

(i)   Premiums in arrears past due but not impaired are  

$10.4 million (2022: $6.3 million). 

(ii)  Trade receivables past due but not impaired are  

$10.0 million (2022: $8.0 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.

100    Medibank 

Notes to the consolidated financial statements30 June 2023(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

2023 
$m

2022 
$m

14

14

 215.7 

 241.4 

 66.2 

 30.9 

 4.1 

 11.6 

 66.2 

 30.2 

 16.7 

 6.9 

 328.5 

 361.4 

 24.4 

 15.0 

 39.4 

 46.7 

 9.9 

 56.6 

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.

Annual Report 2023   101 

 
(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

(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

16(b)

14

2023 
$m

 511.1 

2022 
$m

 393.9 

 118.4 

 115.0 

 6.7 

 1.4 

 1.8 

 4.4 

 (34.8)

 (86.0)

 (27.2)

 5.0 

 1.8 

 (22.0)

 (35.1)

 (4.1)

 (214.8)

 113.2 

 (27.7)

 13.7 

 (93.8)

 (47.5)

 184.5 

 5.9 

 (4.5)

 1.6 

 (12.3)

 93.0 

 (17.9)

 (43.1)

 5.1 

 2.4 

 (11.1)

 (39.6)

 1.7 

 123.2 

 (157.1)

 34.2 

 137.4 

 239.6 

 81.1 

 948.5 

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

(b) Reserves

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.

102    Medibank 

Equity reserve1

Share-based payments reserve2

Total

2023 
$m

 17.8 

 10.1 

 27.9 

2022 
$m

 17.8 

 7.9 

 25.7 

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.

Notes to the consolidated financial statements30 June 2023 
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

2023

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

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

Note

14

2023 
$m

11.4

10.5

5.7

42.9

70.5

Plant and 
equipment  
$m

Leasehold 
improvements 
$m

Assets under 
construction 
$m

 26.9 

 (15.5)

 11.4 

 10.0 

 1.1 

 2.2 

 (1.9)

 11.4 

 23.6 

 (13.6)

 10.0 

 10.2 

 - 

 1.1 

 (1.3)

 10.0 

 99.5 

 (89.0)

 10.5 

 16.8 

 1.8 

 1.7 

 (9.8)

 10.5 

 96.0 

 (79.2)

 16.8 

 23.7 

 0.4 

 2.7 

 (10.0)

 16.8 

 5.7 

 - 

 5.7 

 7.1 

 2.5 

 (3.9)

 - 

 5.7 

 7.1 

 - 

 7.1 

 4.5 

 6.4 

 (3.8)

 - 

 7.1 

2022 
$m

10.0

16.8

7.1

54.5

88.4

Total 
$m

 132.1 

 (104.5)

 27.6 

 33.9 

 5.4 

 - 

 (11.7)

 27.6 

 126.7 

 (92.8)

 33.9 

 38.4 

 6.8 

 - 

 (11.3)

 33.9 

(c) Property, plant and equipment capital expenditure commitments

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

2023 
$m

2022 
$m

1.7

2.0

Annual Report 2023   103 

 
 
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

2023

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

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

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 

 (89.4)

 0.3 

 1.7 

 - 

 - 

 (1.4)

 0.3 

 89.7 

 (88.0)

 1.7 

 3.7 

 - 

 - 

 (2.0)

 1.7 

 508.0 

 (418.4)

 89.6 

 99.8 

 10.3 

 18.3 

 (38.8)

 89.6 

 479.4 

 (379.6)

 99.8 

 111.9 

 4.5 

 19.4 

 (36.0)

 99.8 

 33.7 

 - 

 33.7 

 26.3 

 25.7 

 (18.3)

 - 

 33.7 

 26.3 

 - 

 26.3 

 25.2 

 20.5 

 (19.4)

 - 

 26.3 

Total 
$m

 914.3 

 (586.2)

 328.1 

 332.3 

 36.0 

 - 

 (40.2)

 328.1 

 878.3 

 (546.0)

 332.3 

 345.3 

 25.0 

 - 

 (38.0)

 332.3 

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.

104    Medibank 

Notes to the consolidated financial statements30 June 2023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 

2023

Growth 
rate 
%

 2.5 

2.5 

 2.5 

Pre-tax 
discount 
rate %

Goodwill 
allocation 
$m

 11.4 

 11.7 

 11.7

 96.2 

 11.1 

 97.2 

2022

Growth 
rate 
%

 2.5 

 1.0 

 2.5 

Pre-tax 
discount 
rate %

 11.6 

 12.4

 12.4 

Forecast 
future cash 
flows

Discount 
rates

Growth rates

Other key 
assumptions

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 the VIU calculations.

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 forecast cash flows contain key assumptions around 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.

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.

Annual Report 2023   105 

 
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. 

(b) Intangible assets capital expenditure commitments

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.

2023 
$m

2022 
$m

 -

 0.7

2023 
$m

 65.3 

 14.4 

 79.7 

2023 
$m

33.0 

 7.0 

 1.6 

6.7 

2022 
$m

 72.4 

 13.8 

 86.2 

2022 
$m

 31.0 

 4.9 

 3.3 

 5.9 

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

106    Medibank 

Notes to the consolidated financial statements30 June 2023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

Other 
$m 

Total 
$m 

Balance at 1 July 2022

Additional provision

Amounts utilised during the year

Reversal of unused provision

Balance at 30 June 2023

Balance comprised of:

Current

Non-current

 8.7 

 6.2 

 (7.1)

 - 

 7.8 

 7.8 

 - 

 4.2 

 - 

 (0.2)

 - 

 4.0 

 1.3 

 2.7 

 4.5 

 0.7 

 (0.9)

 - 

 4.3 

 0.8 

 3.5 

 10.7 

 9.8 

 (3.7)

 - 

 16.8 

 16.8 

 - 

 8.1 

 5.3 

 - 

 14.1 

 41.5 

 30.8 

 (5.4)

 (2.7)

 - 

 - 

 - 

 (17.4)

 (34.7)

 - 

 2.0 

 (2.7)

 34.9 

 2.0 

 28.7 

 - 

 6.2 

Annual Report 2023   107 

(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 (2022:  
$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. $5.4 million was paid  
during the year. 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 2022

Additional provision

Amounts utilised during the year

Balance at 30 June 2023

Total 
$m

 178.6

 337.9 

 (380.4)

 136.1 

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. 

108    Medibank 

Customer give backs totalling $451.7 million were announced 
during the current period, with $337.9 million of this expected 
to be provided via a one-time cash payment and recognised 
in the customer give back provision. The remaining give back 
amount of $113.7 million has been recognised in the provision 
for premium deferral in the unearned premium liability (refer 
to Note 5). The closing balance at 30 June 2023 is largely 
comprised of the recently announced $125 million one-time 
cash give back that is expected to be paid by October 2023.

Provisions Accounting Policy
Provisions are recognised when:
•  The Group has a present legal or constructive 

obligation as a result of past events.

•  It is probable that an outflow of resources will be 

required to settle the obligation. 

•  The amount has been reliably estimated. 

Provisions are not recognised for future operating losses.

Where there are a number of similar obligations, the 
likelihood that an outflow will be required in settlement 
is determined by considering the class of obligations as 
a whole. A provision is recognised even if the likelihood 
of an outflow with respect to any one item included in the 
same class of obligations may be small.

Provisions are measured at the present value of 
management’s best estimate of the expenditure required 
to settle the present obligation at the end of the reporting 
period. Expected future payments are discounted using 
market yields at the end of the reporting period using 
corporate bonds with terms to maturity that match, as 
closely as possible, the estimated future cash outflows. 
The increase in the provision due to the passage of time 
is recognised as interest expense.

(d) Contingent liabilities

(i) Cybercrime event 

The Group was subject to a cybercrime during this year which 
resulted in a data breach. Costs have been recognised in the 
current period in relation to this matter, largely related to our 
incident response and the customer support package. 

Specific contingent liabilities in relation to the cybercrime 
that may impact the Group as known at this reporting period 
are set out below. The outcome and any potential financial 
impacts of the matters below are currently unknown.

OAIC regulatory investigation

The Office of the Australian Information Commissioner 
(OAIC) informed Medibank on 1 December 2022 that it was 
commencing an investigation into the cybercrime. The 
investigation will consider Medibank’s conduct in relation to 
the unauthorised access that occurred in respect of the data 
breach, including whether Medibank took reasonable steps  
to protect personal information from unauthorised access  

Notes to the consolidated financial statements30 June 2023and misuse, and to destroy or deidentify personal information 
that it is no longer required to retain.

Medibank continues to co-operate with the OAIC and its’ ongoing 
investigation and has not received notice of any findings. The 
OAIC investigation may result in fines, penalties, enforceable 
undertakings or other regulatory enforcement action. 

OAIC representative complaint 

Maurice Blackburn, in collaboration with Bannister Law and 
Centennial Lawyers, has lodged a representative complaint 
with the OAIC alleging Medibank has breached its privacy 
obligations and seeks compensation for loss and damage, 
including but not limited to loss and damage for injury to 
feelings and humiliation. 

Medibank is defending the representative complaint.

Consumer class actions

On 7 February 2023, Medibank received notice of a consumer 
class action filed in the Federal Court of Australia by Baker 
& McKenzie in relation to the cybercrime. On 5 May 2023 
Medibank received notice of a second consumer class action 
filed in the Federal Court of Australia by Slater & Gordon. 

On 1 August 2023 orders were made in the Federal Court 
to consolidate the two consumer class action proceedings. 
The consolidated consumer class action is being brought 
on behalf of persons who were Medibank or ahm health 
insurance customers between 21 December 2001 and  
12 October 2022, and persons who provided personal 
information to Medibank or ahm for the purpose of obtaining 
a quote for insurance but did not become a customer. 
The consolidated statement of claim includes allegations 
of breach of contract, contraventions of the Australian 
Consumer Law, breach of equitable obligations of confidence, 
breach of the Privacy Act and breach of APRA Prudential 
Standard CPS234. The amount claimed is unspecified, 
however remedies sought include damages, declarations for 
contraventions of the Privacy Act, injunctive relief requiring 
Medibank to take reasonable steps to destroy or deidentify 
personal information which Medibank no longer needs to 
retain, interest and costs. 

Medibank is defending this consolidated consumer class 
action proceeding.

Shareholder class actions

On 29 March 2023, Medibank received notice of a 
shareholder class action filed in the Supreme Court of 
Victoria by Quinn Emanuel on behalf of persons who 
acquired an interest in Medibank shares during the period  
1 July 2019 to 19 October 2022.

On 29 June 2023, Medibank received notice of a second 
shareholder class action filed in the Supreme Court of 
Victoria by Phi Finney McDonald on behalf of persons who 
acquired an interest in Medibank shares or entered into  
equity swap confirmations of Medibank shares during the 
period 10 September 2020 to 25 October 2022. 

The statements of claim for both shareholder class actions 
are substantially similar and include allegations of misleading 
or deceptive conduct and that Medibank breached its 
continuous disclosure obligations under the Corporations Act 
2001 and ASX Listing Rules by not disclosing to the market 
information relating to alleged deficiencies in its cyber 
security systems. The amount claimed in both proceedings 
is unspecified, however remedies sought include damages, 
interest and costs.

Quinn Emanuel and Phi Finney McDonald have made an 
application to the Supreme Court of Victoria to consolidate 
the two shareholder class actions into one consolidated 
shareholder class action. The outcome of this application  
is currently unknown. 

Medibank is defending the shareholder class action 
proceedings.

(ii) Other contingency matters (excluding cybercrime 
event)

The Group has issued $18.3 million of bank guarantees to 
third parties for various operational and legal purposes, 
including $10.0 million (2022: $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.

In addition to the items noted above in relation to the 
cybercrime event, the Group is exposed from time to time to 
contingent liabilities which arise from the ordinary course of 
business, including:

•  Losses which might arise from litigation.

•  Investigations from internal reviews and by regulatory 
bodies such as the ACCC, APRA, ATO, ASIC 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 from these other contingency matters is not material 
or are not at a stage to support a reasonable evaluation of the 
likely outcome. 

Key judgement and estimate
Contingent liabilities are possible obligations whose 
existence will be confirmed only on the occurrence or 
non-occurrence of uncertain future events outside the 
Group’s control, or present obligations that are not 
recognised because it is not probable that a settlement 
will be required or the value of such a payment cannot  
be reliably estimated.

Judgement is exercised to identify whether a present 
obligation exists and also in estimating the probability, 
timing, nature and quantum of the outflows that may 
arise from past events.

Annual Report 2023   109 

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 lease agreements. The leases have 
varying terms, escalation clauses and renewal rights.

As at 30 June 2023, 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

2023 
$m

 54.5 
 16.0 
 (27.6)
 42.9 

2022 
$m

 63.3 
 19.1 
 (27.9)
 54.5 

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

2023 
$m
 76.9 
 16.3 
 1.8 
 (39.7)
 55.3 

 30.9 
 24.4 

2022 
$m
 93.4 
 19.9 
 2.4 
 (38.8)
 76.9 

 30.2 
 46.7 

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

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 $0.6 million have been 
recognised by the Group at 30 June 2023 (2022: $4.9 million). 
These are presented within other assets in the consolidated 
statement of financial position. 

110    Medibank 

Leases Accounting Policy
As a lessor
The Group acts as an intermediate lessor for one sublease 
(2022: 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.

Notes to the consolidated financial statements30 June 2023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

2023 
$m

 98.6 

 118.1 

 (0.7)

 216.0 

2022 
$m

 322.0 

 (156.6)

 0.7 

 166.1 

1. 

 Includes deferred tax of $110.1 million (2022: ($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

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

2023 
$m

 727.1 

2022 
$m

 560.0 

 218.1 

 168.0 

 0.8 

 (3.6)

 0.4 

 1.0 

 0.9 

 (1.6)

 (1.3)

 (0.6)

 216.7 

 165.4 

 (0.7)
 216.0 

 0.7 
 166.1 

Annual Report 2023   111 

 
(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

2023 
$m

 3.1 

 (16.3)

 (23.7)

 (12.0)

 (6.3)

 22.9 

 23.9 

 80.1 

 54.2 

 0.2 

 4.3 

 130.4 

 0.4 

 0.4 

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 

Net deferred tax assets

 130.8 

 243.6 

1.  Includes deferred tax of $76.1 million (2022: $134.5 million) in relation to the COVID-19 claims liability. Refer to Note 3(b) for further information.
2. 

 Includes deferred tax of $40.8 million (2022: $53.6 million) in relation to the customer give back provision and $1.2 million (2022: $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.

112    Medibank 

Notes to the consolidated financial statements30 June 2023 
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 Ltd

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 Ltd

Medi Financial 
Services 
Pty Ltd

HealthStrong 
Pty Ltd

East Sydney Day 
Hospital Pty Ltd  
(49%)

Adeney Private 
Hospital Pty Ltd  
(49%)

Integrated 
Mental Health 
Pty Ltd 
(50%)

Medinet Australia 
Pty Ltd 
(3.82%)

Amplar Home 
Health  
Pty Ltd2

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.  Home Support Services Pty Ltd changed its name to Amplar Home Health Pty Ltd on 28 July 2023.

Annual Report 2023   113 

 
 
 
 
 
 
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 2023 the Group held the following investments in associates and joint ventures:

Name of company

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

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
Australia
Short stay hospital

Associate
Joint Venture
Associate
Associate
Associate
Joint Venture
Joint Venture

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

Balance at 1 July 

Net additions

Dividends received

Share of net profit/(loss) for the year

Balance at 30 June

(i) Integrated Mental Health Pty Ltd

Ownership interest %

2023

49.00%
50.00%
49.00%
49.00%
3.82%
50.00%
50.00%

2023 
$m

 103.7 

 17.8 

 (2.5)

(1.4)

117.6

2022

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

2022 
$m

 77.1 

 22.1 

-

 4.5 

 103.7 

On 3 March 2023, MHSI Pty Ltd acquired a 50% shareholding in Integrated Mental Health Pty Ltd (iMH) for consideration of  
$15.5 million. The joint venture is seeking to deliver an innovative integrated mental health model via mental health facilities  
and out-of-hospital support.

(ii) Other

Other movements during the period comprised: 

•  MH Solutions Investments Pty Ltd subscribed for an additional $5.0 million of shares in SydOrtho Holdings Pty Ltd  

(SydOrtho) in line with SydOrtho’s achievement of milestones. 

•  Non-cash decrease of $2.7 million in relation to the reduction in the East Sydney Day Hospital Pty Ltd contingent 

consideration provision (refer to Note 13(b)(v)). 

114    Medibank 

Notes to the consolidated financial statements30 June 2023 
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 in associate or joint 
venture is initially recognised at cost and is increased 
or decreased to recognise the Group’s share of profit or 
loss. Dividends received from an associate or joint venture 

reduce the carrying amount of the investment. 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

2023 
$m

3,609.9 

 4,297.2 

 2,091.8 

2,331.0 

2022 
$m

 3,441.7 

 4,192.8 

 2,207.1 

 2,355.8 

 85.0 

 85.0 

 6.3 

 10.1 

1,864.8 

 1,966.2 

 6.3 

 7.9 

 1,737.8 

 1,837.0 

 501.5 

 377.1 

 501.5 

 377.1 

(ii) Guarantees entered into by parent entity

The parent entity has entered into $10.0 million (2022: $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. 

(iii) Contingent liabilities of the parent entity

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

2023 
$m

 1.7 

 - 

2022 
$m

 2.0 

 0.4 

Parent Entity Financial Information Accounting Policy
The financial information for the parent entity, Medibank, has been prepared on the same basis as the consolidated 
financial statements, except as set out below:

•  Investments in subsidiaries are accounted for at cost less accumulated impairment losses in the financial statements  

of Medibank.

•  Assets or liabilities arising under tax funding arrangements with the tax consolidated entities are recognised by  

Medibank as current assets or current liabilities.

Annual Report 2023   115 

 
Note 17: Related party transactions
(a) Transactions with equity accounted investments

Transactions with equity accounted investments
Claims incurred
Services received
Services provided
Interest received

Outstanding balances with related parties
Amounts payable
Amounts receivable
Loan receivable

2023 
$m

 (3.8)
 (0.6)
 6.6 
 0.2 

 (0.1)
 0.5 
 2.9 

2022 
$m

 (3.8)
 - 
 26.6 
 0.2 

 (0.1)
 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

2023 
$

2022 
$

 6,262,298 
 240,338 
 276,922 
 3,283,345 
 10,062,903 

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

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.

116    Medibank 

Notes to the consolidated financial statements30 June 2023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.

Performance rights granted do not carry any voting rights. 

Medibank has an Employee Share Plan Trust to manage its 
share-based payments arrangements. Shares allocated by 
the trust to the employees are acquired on-market prior to 
allocation. The Trust held nil shares at 30 June 2023.

(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.

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 2023 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 2022. This average price was $3.19.

(ii) Annual STI offer

Under the Group’s STI Plan, 50% of STI awarded to ELT 
members is paid in cash after the announcement of financial 
results. The remaining 50% is deferred for 12 months in the 
form of performance rights granted under the Performance 
Rights Plan. Vesting of deferred performance rights is 
conditional on the participant remaining employed by 
Medibank until the end of the 12-month deferral period.

On vesting of the performance rights, each performance right 
will convert into a share on a one-for-one basis, subject to any 
adjustment required to ensure that the participant receives a 
benefit equivalent to any dividends paid by Medibank during 
the deferral period.

The number of rights to be granted will be determined  
based on the monetary value of the STI award, divided by  
the volume-weighted average share price over the 10 trading 
days up to and including the payment date of cash STI.

Share-based Payment Accounting Policy
The fair value of the performance rights is recognised as an 
employee benefits expense, with a corresponding increase 
in equity. The total amount to be expensed is determined 
by reference to the fair value of the performance rights 
granted, which includes any market performance conditions 
and the impact of any non-vesting conditions, but excludes 
the impact of any service and non-market performance 
vesting conditions. Non-market vesting conditions are 
included in assumptions about the number of performance 
rights that are expected to vest.

The total expense is recognised over the period in which  
the performance and/or service conditions are fulfilled  
(the vesting period), ending on the date on which the 
relevant employees become fully entitled to the award  
(the vesting date).

At the end of each reporting period, the Group revises its 
estimates of the number of awards that are expected to vest 
based on the non-market vesting conditions. The impact 
of the revision to original estimates, if any, is recognised in 
profit or loss, with a corresponding adjustment to equity.

Annual Report 2023   117 

(b) Performance rights – Group

Outstanding at 1 July

Granted4

Forfeited1

Exercised2 4

Lapsed3

Outstanding at 30 June

Exercisable at 30 June

Number of equity 
instruments

2023

2022

 7,670,453 

 8,079,042 

 4,118,306 

 3,542,600 

 (535,324)

 (1,371,837)

 (1,319,276)

 (825,420)

 (1,189,011)

 (1,753,932)

 8,745,148 

 7,670,453 

 - 

 - 

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.
4. 

 Instruments granted and exercised includes the additional Medibank shares received on the vesting of deferred STI performance rights as a benefit equivalent 
to any dividends paid during the deferral period. 

(c) Fair value of performance rights granted

Below is a summary of the fair values of the 2022 and 2023 LTI plans and the key assumptions used in determining the 
valuation. The fair value was determined by an independent valuation expert and takes into account the terms and conditions 
upon which they were granted.

TSR 
performance rights

EPS and market share  
performance rights

Grant date

Date of commencement of  
service and performance period
Expected vesting date

Fair value

Share price at grant date

Dividend yield (per annum effective)

Franking rate

Risk free discount rate (per annum)

Volatility

2023

2022

2023

2022

6 December 2022

3 December 2021

6 December 2022 3 December 2021

1 July 2022

1 July 2021

1 July 2022

1 July 2021

30 June 2025

30 June 2024

30 June 2025

30 June 2024

$1.19 

$2.93 

4.2%

100.0%

3.1%

21%

$1.62 

$3.14 

3.7%

100.0%

0.2%

20%

$2.63 

$2.93 

4.2%

100.0%

n/a

n/a

$2.72 

$3.14 

3.7%

100.0%

n/a

n/a

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

118    Medibank 

2023 
$

2022 
$

 1,883,676 

 1,693,192 

 325,200 

 180,208 

 281,550 

 248,280 

 - 

 229,780 

 2,389,084 

 2,452,802 

Notes to the consolidated financial statements30 June 2023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 2022 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 2023 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.

Measurement 

The standard introduces a new general measurement model 
for accounting for insurance contracts. However, a simplified 
premium allocation approach (PAA), similar in nature to the 
Group’s existing measurement basis under AASB 1023 is 
permitted if the coverage period of the contracts is less than 
a year or provided there is not a material difference between 
the PAA and what would have been recognised under the 
general model. 

The majority of the Group’s insurance policies have a coverage 
period of one year or less and the Group will apply the 
simplified PAA to these insurance contracts. For those policies 
with a coverage period of greater than a year the Group has 
developed a model and methodology to assess their eligibility 
to apply the PAA. This assessment will be reperformed on an 
ongoing basis, but has shown that the PAA is expected to apply 
to all of the Groups’ insurance policies at transition. 

For groups of contracts that apply the PAA and have a 
coverage period of one year or less, AASB 17 provides 
an option to recognise any insurance acquisition costs 
as expenses when incurred. The Group expects to adopt 
this option and will expense acquisition costs as incurred, 
which is a departure from the current accounting whereby 
acquisition costs are amortised over the average expected 
retention period. 

COVID-19 accounting 

The impact of COVID-19 on the Group has seen the 
recognition of a deferred claims liability and give back 
provisions, both of which will be impacted by the new 
standard. 

The deferred claims liability represents claims that have been 
deferred as a result of COVID-19. Under the new standard, 
insurance liabilities are only able to include claims that have 
occurred prior to the end of the reporting period. Therefore 
claims that are expected to arise in the future but have not 
yet been incurred, such as the deferred claims liability, are 
unable to be recognised under AASB 17. Whilst not related 
to COVID-19, the provision for bonus entitlements is similar 
in that it represents the expected future utilisation of unused 
benefit entitlements and is also unable to be recognised 
under AASB 17 and will be derecognised on transition. 

The cost of any premium deferral give backs provided to 
policyholders is currently recognised upfront within the 
provision for premium deferral in the unearned premium 
liability. AASB 17 requires that any reduced premium received 
from policyholders is recognised on a passage of time basis 
over the coverage period. Accordingly the provision for 
premium deferral will be derecognised on transition. 

Onerous contracts 

AASB 17 requires the identification of ‘groups’ of onerous 
contracts which will be determined at a more granular level 
of aggregation than the level at which the liability adequacy 
test is currently performed under AASB 1023. Contracts that 
are measured under the PAA are assumed to not be onerous 
unless facts and circumstances indicate otherwise. 

The Group has developed a framework to identify indicators of 
possible onerous contracts which includes the consideration 
of information provided to senior management to monitor 
financial performance. If facts and circumstances are 
identified that indicate an onerous contract may exist, then 
detailed testing using the general model is performed and  
any onerous contract losses are required to be recognised  
in the statement of comprehensive income. 

Risk adjustment 

AASB 17 requires a risk adjustment to be used in the 
measurement of insurance contract liabilities. The Group 
expects to use a confidence level technique to estimate the 
risk adjustment and this is expected to be in line with the 
equivalent AASB 1023 risk margin. 

Presentation and disclosure 

AASB 17 will introduce a number of changes to the 
presentation of the statement of comprehensive income 
and balance sheet. In addition, the standard contains more 
granular disclosure requirements compared with existing 
reporting requirements. 

Transition 

The standard requires the full retrospective approach to 
be adopted on transition, except to the extent that it is 
impractical to do so. Given the relatively few measurement 
differences that arise under the PAA, the Group will adopt  
the full retrospective approach. 

Annual Report 2023   119 

Financial impact 

Based on the key estimates and judgements outlined above 
and the work performed to date, the adoption of AASB 17 is 
estimated to increase the Group’s net assets by approximately 
$360 million as at 1 July 2022. This is largely comprised of 
increases to net assets arising from the derecognition of the 
deferred claims liability and premium deferral provisions 
offset by a decrease to net assets due to the derecognition  
of deferred acquisition costs. 

(c) Other accounting policies

(ii) Other accounting standards or amendments that 
will become applicable in future reporting periods

Other accounting standards or amendments that will become 
applicable in future reporting periods are not expected to have 
a material impact on the Group’s accounting policies or on the 
consolidated financial report.

Impairment of Tangible and Intangible Assets (other than Goodwill) Accounting Policy
Assets other than goodwill and financial assets classified at fair value through other comprehensive income, are tested 
for impairment whenever events or changes in circumstances indicate that the carrying amount may not be recoverable. 
An impairment loss is recognised for the amount by which the asset’s carrying amount exceeds its recoverable amount. 
The recoverable amount is the higher of an asset’s fair value less costs of disposal and its value-in-use. In assessing 
value-in-use, the estimated future cash flows are discounted to their present value using a discount rate that reflects 
current market assessments of the time value of money and the risks specific to the asset. For the purposes of assessing 
impairment, assets are grouped at the lowest levels for which there are separately identifiable cash inflows which are 
largely independent of the cash inflows from other assets or groups of assets (CGUs).

Financial Assets and Financial Liabilities Accounting Policy
The Group’s financial assets consist of cash and cash equivalents, financial assets at fair value and trade and other 
receivables. Management determines the classification of its financial assets at initial recognition based on the business 
model test and cash flow characteristics. Purchases and sales of financial assets are recognised on trade-date – the date 
on which the Group commits to purchase or sell the asset. Financial assets are derecognised when the rights to receive 
cash flows from the financial assets have expired or have been transferred. The Group’s financial liabilities comprise trade 
and other payables. Financial liabilities are classified and measured at amortised cost and derecognised when the Group’s 
contractual obligations are discharged, cancelled or expired.

Goods and Services Tax (GST) Accounting Policy
Revenues, expenses and assets are recognised net of the amount of associated GST, unless the GST incurred is not 
recoverable from the taxation authority. In this case it is recognised as part of the cost of acquisition of the asset or as  
part of the expense.

Receivables and payables are stated inclusive of the amount of GST receivable or payable. The net amount of GST 
recoverable from, or payable to, the taxation authority is included with other receivables or payables in the consolidated 
statement of financial position.

Cash flows are presented on a gross basis. The GST component of cash flows arising from investing or financing activities 
which are recoverable from, or payable to, the taxation authority, are presented as operating cash flows. Commitments  
and contingencies are disclosed net of the amount of GST recoverable from, or payable to, the taxation authority.

(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 2023.

120    Medibank 

Notes to the consolidated financial statements30 June 2023Directors' declaration

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

(a)    the financial statements and notes set out on pages 74  
to 120 are in accordance with the Corporations Act 
Regulations 2001, including:

   (i)  

 giving a true and fair view of the Company and the 
Group's financial position as at 30 June 2023 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

(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.

Note 1(b) confirms that the financial statements also comply 
with International Financial Reporting Standards as issued  
by the International Accounting Standards Board.

This declaration has been made after receiving the 
declarations required to be made to the directors by the  
Chief Executive Officer and Chief Financial Officer in 
accordance with section 295A of the Corporations Act 2001  
for the year ended 30 June 2023.

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

On behalf of the Board,

Mike Wilkins AO   
Chair   

24 August 2023 
Melbourne

David Koczkar 
Chief Executive Officer

Annual Report 2023   121 

 
 
 
  
 
 
Auditor's independence declaration

Independent auditor’s report 

To the members of Medibank Private Limited 
Auditor’s Independence Declaration 
Report on the audit of the financial report 
As lead auditor for the audit of Medibank Private Limited for the year ended 30 June 2023, I declare 
that to the best of my knowledge and belief, there have been:  
Our opinion 

(a) 
In our opinion: 

no contraventions of the auditor independence requirements of the Corporations Act 2001 in 
relation to the audit; and 

The accompanying financial report of Medibank Private Limited (the Company) and its controlled entities 
(b) 
(together the Group) is in accordance with the Corporations Act 2001, including: 

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 
(a) giving a true and fair view of the Group's financial position as at 30 June 2023 and of its financial performance
for the year then ended
period. 

(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 2023

Marcus Laithwaite 
•
Partner 
•
PricewaterhouseCoopers 
•

the consolidated statement of comprehensive income for the year then ended

the consolidated statement of changes in equity for the year then ended

Melbourne 
24 August 2023 

•

•

•

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 
PricewaterhouseCoopers, ABN 52 780 433 757 
2 Riverside Quay, SOUTHBANK  VIC  3006, GPO Box 1331, MELBOURNE  VIC  3001 
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 
T: 61 3 8603 1000, F: 61 3 8603 1999, www.pwc.com.au  

Liability limited by a scheme approved under Professional Standards Legislation. 
Liability limited by a scheme approved under Professional Standards Legislation. 

122    Medibank 

 
 
  
  
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 2023 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 2023

the consolidated statement of comprehensive income for the year then ended

the consolidated statement of changes in equity for the year then ended

the consolidated statement of cash flows for the year then ended

the notes to the consolidated financial statements, which include significant accounting policies and other
explanatory information

the directors’ declaration.

Basis for opinion 

We conducted our audit in accordance with Australian Auditing Standards. Our responsibilities under those 
standards are further described in the Auditor’s responsibilities for the audit of the financial report section of our 
report. 

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our 
opinion. 

Independence 
We are independent of the Group in accordance with the auditor independence requirements of the Corporations 
Act 2001 and the ethical requirements of the Accounting Professional & Ethical Standards Board’s APES 110 
Code of Ethics for Professional Accountants (including Independence Standards) (the Code) that are relevant to 
our audit of the financial report in Australia. We have also fulfilled our other ethical responsibilities in accordance 
with the Code. 

PricewaterhouseCoopers, ABN 52 780 433 757 
2 Riverside Quay, SOUTHBANK VIC 3006, GPO Box 1331, MELBOURNE VIC 3001 
T: 61 3 8603 1000, F: 61 3 8603 1999, www.pwc.com.au  

Liability limited by a scheme approved under Professional Standards Legislation. 

Annual Report 2023   123 

Independent auditor’s report

Our audit approach 

An audit is designed to provide reasonable assurance about whether the financial report is free from material 
misstatement. Misstatements may arise due to fraud or error. They are considered material if, individually or in 
aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of 
the financial report. 

We tailored the scope of our audit to ensure that we performed enough work to be able to give an opinion on the 
financial report as a whole, taking into account the geographic and management structure of the Group, its 
accounting processes and controls and the industry in which it operates. 

Materiality 

Audit scope 

Key audit matters 

Our audit focused on where the Group 
made subjective judgements; for 
example, significant accounting 
estimates involving assumptions and 
inherently uncertain future events. 

We performed: 

•

•

an audit of the financially
significant component of the
Group, being the Health Insurance
segment.

specific audit procedures over
significant account balances or
classes of transactions of the
Medibank Health segment.

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

•

•

•

Impact of the cybercrime event

Continued impact of the COVID-19
pandemic

Estimation of the outstanding
claims liability

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

For the purpose of our audit we used 
overall Group materiality of $32m, 
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.  

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. 

124    Medibank 

Key audit matter 

How our audit addressed the key audit matter 

Impact of the cybercrime event 

During the year the Group was subject to a cybercrime event 
whereby a criminal accessed the Group’s systems using 
stolen credentials, removed data and released data on the 
dark web. The Group took steps to contain the incident and 
close down the criminal’s attack path.   

The Office of the Australian Information Commissioner 
(OAIC) has commenced investigations into the cybercrime 
event. A representative complaint has been lodged with the 
OAIC alleging the Group breached its privacy obligations. 
Consumer and shareholder class actions have been filed 
against the Group in the Federal Court of Australia and the 
Supreme Court of Victoria, respectively. 

We considered this a key audit matter because of the 
potential impact of the cybercrime event on the following 
aspects of the Group’s financial report: 

Financial reporting information 

The Group prepares its financial report using data from 
underlying systems, some of which were accessed by the 
criminal. As a result, there is a risk that data may have been 
compromised. 

The preparation of the Group’s financial report is heavily 
reliant on the effective design and operation of key 
Information Technology (IT) and business process controls, 
some of which are tested as part of planned audit 
procedures. The cybercrime event increased the risk that key 
controls relevant to the preparation of the Group’s financial 
report may not operate effectively as intended.  

Provisions and contingent liabilities 
(refer to note 13(d))  

Ongoing legal and regulatory matters may result in costs 
associated with litigation, fines and penalties, compensation, 
and/or other regulatory enforceable actions. Such costs are 
dependent on the outcome of legal and regulatory processes 
which remain ongoing. 

As a result, significant judgement is required by the Group to 
determine whether a provision and/or contingent liability is 
required, and to estimate the amount of any such provision 
and/or contingent liability required in accordance with the 
requirements of Australian Accounting Standards. 

Our audit procedures included consideration of the 
potential impact of the cybercrime event on the following 
aspects of the Group’s financial report: 

Financial reporting information 

In conjunction with PwC IT specialists and PwC cyber 
security experts we have performed the following audit 
procedures, amongst others: 

• developed an understanding of:

o

o

o

key aspects relating to the facts and
circumstances of the cybercrime event, such as
the criminal’s attack path and the nature of the
criminal’s activities

the scope and results of the investigative work
performed by the Group and the Group’s experts

the Group’s governance and oversight of the
cybercrime event and cybersecurity uplift
activities.

• developed an understanding of the control activities

relevant to our audit and assessed whether they were
appropriately designed and implemented.

• assessed, on a sample basis, whether key control
activities relevant to our audit were operating
effectively throughout the year, including:

o

the potential impact of business disruption on the
operating effectiveness of ‘business as usual’
control activities

o the Group’s monitoring of fraudulent activities and
discrepancies or inconsistencies in financial 
reporting information 

o

o

o

o

the Group’s monitoring of customer and/or
hospital provider complaints

new control activities implemented by the Group
following the cybercrime event

in-scope IT Dependencies (such as interfaces,
key reports and calculations)

IT General Controls for breached and
non-breached systems.

• agreed, on a sample basis, the reliability and validity of
underlying financial reporting information obtained from
breached systems to an alternative data source.

•

inspected user activity in breached and non-breached
systems, including privileged users, for potentially
unauthorised activity.

Annual Report 2023    125 

Independent auditor’s report

Key audit matter 

How our audit addressed the key audit matter 

Provisions and contingent liabilities 

We performed the following procedures in relation to 
provisions and contingent liabilities, amongst others:  
• developed an understanding of the Group’s processes
and key controls for identifying and assessing the
impact of relevant legal and regulatory matters.
• evaluated the nature and financial impact of relevant
legal and regulatory matters on the Group’s financial
report, including any relevant post-balance date
developments.

• assessed, on a sample basis, whether costs in relation
to the cybercrime event were appropriately recognised
in accordance with the requirements of the Australian
Accounting Standards.

• assessed the reasonableness of relevant disclosures in
the financial report against the requirements of the
Australian Accounting Standards.

Continued impact of the COVID-19 pandemic 

Estimation of the COVID-19 claims liability 
(refer to note 3: $253.8m)  

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’).  

Claims deferral ceased after June 2022 because, despite the 
prolonged impact of COVID-19, there have been no formal 
restrictions and lockdowns impeding availability and 
accessibility to surgeries and other health services during the 
year.  

The liability has been 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 for
the period March 2020 to June 2022, inclusive
(expected claims service level).

the rate at which deferred surgical and non-surgical
procedures are expected to catch up in future periods
(deferral rate).

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

average policyholder lapse rate.

We have performed the following audit procedures, 
amongst others: 
• evaluated the design of the Group’s key controls
relevant to the COVID-19 provisioning process.

• evaluated the Group’s accounting policy for

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

• assessed, on a sample basis, significant data inputs

used by the Group to estimate utilisation of the COVID-
19 claims liability during the year (including the
relevance and reliability of data and potential indicators
of management bias).

•

together with PwC actuarial experts, we have:

o

assessed significant assumptions, and any
changes to these assumptions, adopted by the
Group in estimating the extent of a continued
impact of COVID-19 on claims incidence and
development patterns, with reference to
management’s clinical analysis as well as
external environmental and internal policyholder
or product factors.

126    Medibank 

Key audit matter 

How our audit addressed the key audit matter 

o

o

o

considered the appropriateness of the Group’s
methodologies used to determine claims deferred
to future periods with reference to Private Health
Insurance industry practices.

on a sample basis, performed recalculations over
the mathematical accuracy of movements in the
COVID-19 claims liability during the year.

analysed claims incidence patterns against
expected underlying claims growth during the
year.

• assessed the reasonableness of disclosure of the

COVID-19 claims liability in the financial report against
the requirements of the Australian Accounting
Standards.

We have performed the following audit procedures, 
amongst others: 
• developed an understanding of the Group’s relevant
public announcements and commitments to financial
analysts, shareholders and policyholders during the
year.

• developed an understanding of the Group’s key

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

• assessed the appropriateness of the accounting

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

•

reconciled the amount and nature of customer
giveback public announcements made by the Group
during the year with amounts recognised and disclosed
in the Group’s financial report.

The COVID-19 claims liability is included in the financial 
statement line item titled ‘Claims liabilities’ recognised on the 
consolidated statement of financial position but does not form 
part of the outstanding claims liability (refer to the Key Audit 
Matters titled ‘Estimation of the outstanding claims liability’). 

We considered this a key audit matter due to the: 

•

•

complexity, significant uncertainty and subjectivity
impacting the Group’s estimate of the liability, including
determining expected future claims utilisation patterns.

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 claims
liability.

Recognition of COVID-19 customer givebacks      
(refer to Note 3: $451.7m, Note 5: $3.9m and 
Note 13(c): $136.1m) 

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

COVID-19 customer givebacks are recognised with 
reference to the Group’s publicly announced customer 
initiatives representing a return of permanent net COVID-19 
savings to eligible policyholders.  

The Group’s COVID-19 customer givebacks 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 givebacks owed to customers 
as at 30 June 2023 is included in the consolidated statement 
of financial position as ‘Unearned premium liability’ (Note 5) 
or ‘Customer giveback provision’ (Note 13(c)), depending on 
the mechanism used to giveback to customers. 

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 givebacks
with reference to specific characteristics of the giveback
mechanisms.

Annual Report 2023    127 

Independent auditor’s report

Key audit matter 

How our audit addressed the key audit matter 

Estimation of the outstanding claims liability 
(refer to note 3: $510.4m)  

The liability for outstanding claims relates to claims received 
but not assessed and claims incurred but not 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.   

A risk margin is therefore 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 98% 
(2022: 95%). 

The estimation of the outstanding claims liability involves 
complex and subjective judgements about future events, 
both internal and external to the business, including: 

•

•

•

service levels for the most recent service month
(hospital) or two service months (overseas)

claims processing delays and pre-admission hospital
eligibility checks

historical patterns of claims incidence and processing.

We considered this a key audit matter because of the 
significant judgement required by the Group in estimating 
claims liabilities, including the extent to which claims 
incidence and development patterns are consistent with past 
experience, 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.  

We have performed the following audit procedures, 
amongst others: 

• evaluated the design of the Group’s key controls

relevant to the claims reserving process (including data
reconciliations and the Group’s review of the
estimate).

• assessed, on a sample basis, whether the key controls

relevant to our audit were operating effectively
throughout the year.

•

together with PwC actuarial experts, we have:

o

o

o

assessed, on a sample basis, significant data
inputs used in the Group’s modelling and
measurement of the central estimate (including
the relevance and reliability of data and potential
indicators of management bias).

considered whether the Group’s actuarial
methodologies were consistent with actuarial
practices and those used in the Private Health
Insurance industry.

assessed significant assumptions, and any
changes to these assumptions, adopted by the
Group in estimating the outstanding claims liability
with reference to external and internal
environmental factors.

o

reperformed calculations over the mathematical
accuracy of the Group’s actuarial models.
• assessed the appropriateness of the accounting

treatment and the reasonableness of disclosure of the
outstanding claims liability in the Group’s financial
report against the requirements of the applicable
Australian Accounting Standards.

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 2023, 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 directors' 
report and operating and financial review. We expect the remaining other information to be made available to us 
after the date of this auditor's report.  

128    Medibank 

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 through our opinion on the financial report. We have 
issued a separate opinion on the remuneration report. 

In connection with our audit of the financial report, our responsibility is to read the other information and, in 
doing so, consider whether the other information is materially inconsistent with the financial report or our 
knowledge obtained in the audit, or otherwise appears to be materially misstated. 

If, based on the work we have performed on the other information that we obtained prior to the date of this 
auditor’s report, we conclude that there is a material misstatement of this other information, we are required to 
report that fact. We have nothing to report in this regard. 

When we read the other information not yet received, if we conclude that there is a material misstatement 
therein, we are required to communicate the matter to the directors and use our professional judgement to 
determine the appropriate action to take. 

Responsibilities of the directors for the financial report 

The directors of the Company are responsible for the preparation of the financial report that gives a true and fair 
view in accordance with Australian Accounting Standards and the Corporations Act 2001 and for such internal 
control as the directors determine is necessary to enable the preparation of the financial report that gives a true 
and fair view and is free from material misstatement, whether due to fraud or error. 

In preparing the financial report, the directors are responsible for assessing the ability of the Group to continue 
as a going concern, disclosing, as applicable, matters related to going concern and using the going concern 
basis of accounting unless the directors either intend to liquidate the Group or to cease operations, or have no 
realistic alternative but to do so. 

Auditor’s responsibilities for the audit of the financial report 

Our objectives are to obtain reasonable assurance about whether the financial report as a whole is free from 
material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. 
Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in 
accordance with the Australian Auditing Standards will always detect a material misstatement when it exists. 
Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they 
could reasonably be expected to influence the economic decisions of users taken on the basis of the financial 
report. 

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. 

Annual Report 2023    129 

Independent auditor’s report

Report on the remuneration report 

Our opinion on the remuneration report 

We have audited the remuneration report included in pages 54 to 73 of the directors’ report for the year ended 
30 June 2023. 

In our opinion, the remuneration report of Medibank Private Limited for the year ended 30 June 2023 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 

Marcus Laithwaite 
Partner 

Melbourne 
24 August 2023 

130    Medibank 

Shareholder information

The shareholder information below is current as at 24 August 2023.

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

Rounding

Total

Number of 
shareholders

44,365

131,268

13,990

7,381

201

Number of 
shares

38,510,715

367,520,439

96,796,442

161,156,612

2,090,019,032

% of issued  
shares

1.40

13.34

3.51

5.85

75.89

0.01

197,205

2,754,003,240

100.00

Unmarketable parcels 

There were 919 holdings of less than a marketable parcel ($500) of shares (143 shares based on a market price of  
$3.51 per share) and such holders held a total of 27,232 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 

6 BNP PARIBAS NOMINEES PTY LTD 

7

CITICORP NOMINEES PTY LIMITED  

Number of 
shares

886,438,939

454,621,638

352,442,059

135,979,370

72,474,536

27,460,612

26,018,991

8 HSBC CUSTODY NOMINEES (AUSTRALIA) LIMITED 

18,749,785

9 BNP PARIBAS NOMINEES PTY LTD HUB24 CUSTODIAL SERV LTD 

10 HSBC CUSTODY NOMINEES (AUSTRALIA) LIMITED

11 WARBONT NOMINEES PTY LTD 

12 BOND STREET CUSTODIANS LIMITED 

13 NETWEALTH INVESTMENTS LIMITED 

14 BNP PARIBAS NOMS (NZ) LTD 

15 IOOF INVESTMENT SERVICES LIMITED 

16 NAVIGATOR AUSTRALIA LTD  

17 NETWEALTH INVESTMENTS LIMITED 

18 SOLIUM NOMINEES (AUSTRALIA) PTY LTD 

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

20 BNP PARIBAS NOMINEES PTY LTD 

6,934,877

6,394,969

6,036,480

4,808,007

4,671,507

4,407,028

4,291,839

3,721,738

3,067,565

2,522,537

2,485,524

2,279,500

% of 
issued capital

32.19

16.51

12.80

4.94

2.63

1.00

0.94

0.68

0.25

0.23

0.22

0.17

0.17

0.16

0.16

0.14

0.11

0.09

0.09

0.08

Total

2,025,807,501

73.56

Annual Report 2023   131 

Shareholder information

Substantial shareholders

As at 24 August 2023 the following holders had provided a substantial shareholding notice:

Number of shares % of issued capital

193,895,716

172,722,617

137,868,557

7.04%

6.27%

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 2023, 1,319,276 
Medibank ordinary shares were purchased on market at 
an average price of $3.70 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 

24 August 2023

Ex-dividend share trading commences 

13 September 2023

Record date for final dividend 

14 September 2023

Payment date for final dividend 

5 October 2023

Annual general meeting 

22 November 2023

Half year results announcement 

Payment date for interim dividend 

February 2024

March 2024

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 2023   133 

 
 
 
Medibank Private Limited
ABN  47 080 890 259