EXHIBIT A

ILLINOIS DEPARTMENT OF INSURANCE VENDOR

CONFIDENTIAL INFORMATION NON-DISCLOSURE AGREEMENT

THIS AGREEMENT is made and entered into effective as of the last date of signature (“Effective date”) by and between, the Illinois Department of Insurance, (the “Department”), and _________________________________ (“Vendor”) for itself and its affiliated companies.

WHEREAS, the parties entered into State of Illinois Contract B-50721 on for Pharmacy Benefit Managers Oversight and Reform Implementation Services ;

WHEREAS, pursuant to this contract the Department may disclose to Vendor certain business and/or technical information, which is proprietary, restricted or secret, and confidential under the Illinois Insurance Code which requires Vendor agree to certain terms; and

WHEREAS, this AGREEMENT provides additional terms regarding the use and disclosure of all CONFIDENTIAL INFORMATION as defined in and shared with Vendor pursuant to State of Illinois Contract B-50721 .

NOW, THEREFORE, the Department and Vendor agree as follows:

1. Vendor shall use such CONFIDENTIAL INFORMATION only to provide services described in State of Illinois Contract B-50721 . Vendor shall restrict disclosure of such CONFIDENTIAL INFORMATION to its employees with a need to know (and advise such employees of the obligations assumed herein) and shall not disclose such CONFIDENTIAL INFORMATION to any third party without prior written approval of the Department.

These restrictions on the use or disclosure of CONFIDENTIAL INFORMATION shall not apply to any CONFIDENTIAL INFORMATION: i. which is independently developed by Vendor or is lawfully received free of restriction from another source having the right to so furnish such CONFIDENTIAL INFORMATION; ii. after it has become generally available to the public without breach of this AGREEMENT by Vendor; or iii. which the Department agrees in writing is free of such restrictions.

2. Vendor has verified that that Vendor has the legal authority to maintain confidentiality as provided for in Illinois law, including but not limited to, the Illinois Insurance Code provisions attached. Vendor agrees to protect from disclosure, information received from or produced by the Department and determined by the Department to be CONFIDENTIAL INFORMATION. Vendor further agrees to notify the Department in writing prior to disclosing any information received from the Department and take all actions reasonably necessary to preserve, protect, and maintain all confidentiality, privileges, and/or other protections from disclosure related to the CONFIDENTIAL INFORMATION.

3. No license under any trademark, patent, copyright, mask work protection right or any other intellectual property right is either granted or implied by conveying CONFIDENTIAL INFORMATION to Vendor. None of the CONFIDENTIAL INFORMATION which may be disclosed by the Department shall constitute any representation, warranty, assurance, guarantee or inducement by the Department of any kind, and, in particular, with respect to the non-infringement of trademarks, patents, copyrights, or any other intellectual property rights, or other rights of third persons or of the Department.

4. Vendor agrees that the CONFIDENTIAL INFORMATION disclosed by the Department remains the property of the Department. Vendor further agrees that the use of the CONFIDENTIAL INFORMATION by Vendor is subject to the permission of the Department and agrees that it will take no action the effect of which would be to limit, waive, or jeopardize any privilege or claim of confidentiality related to the CONFIDENTIAL INFORMATION.

5. Prior to sharing certain CONFIDENTIAL INFORMATION with Vendor, the Department will obtain any required written consent by the insurer, including, but not limited to information obtained by the Department pursuant to Article VIII ¼ Risk Management and Own Risk and Solvency Assessment and Enterprise Risk Filings obtained pursuant to section 131.14b(a) of the Insurance Code. See 215 ILC 5/129.8(d)(6) and 215 ILCS 5/131.22(c-5).

6. In the event that Vendor receives a third-party request for CONFIDENTIAL INFORMATION, or in the event that the Vendor is served with a subpoena, motion, order, or other process requiring production of such information or testimony related thereto, Vendor shall:

a. Immediately notify the Department in writing that such production is being sought and afford the Department the opportunity to take whatever action it deems appropriate to protect the confidential or privileged nature of the CONFIDENTIAL INFORMATION;

b. Immediately provide written notification to the insurer or insurance holding company system whose CONFIDENTIAL INFORMATION is in the possession of Vendor that such production is being sought and afford the insurer or insurance holding company system the opportunity to take whatever action it deems appropriate to protect the confidential or privileged nature of the CONFIDENTIAL INFORMATION;

c. Notify the party seeking production of the CONFIDENTIAL INFORMATION that it is the property of the Department;

d. Use its best efforts to resist production of the CONFIDENTIAL INFORMATION to the third party except to the extent that the Department has consented to such disclosure; and

e. Consent to any application by the Department, or the insurer or insurance holding company system that submitted the CONFIDENTIAL INFORMATION to the Department, to intervene in any action for the purpose of asserting and preserving any privileges, confidentiality rights or other protection from disclosure with respect to the CONFIDENTIAL INFORMATION.

7. It is expressly agreed and understood that if a court of competent jurisdiction issues an order to compel Vendor to produce CONFIDENTIAL INFORMATION covered by this AGREEMENT, Vendor may comply with such an order. Vendor agrees to provide prompt written notice of the order to compel in order to provide the Department and the insurer or insurance holding company system that submitted the CONFIDENTIAL INFORMATION to the Department, with an opportunity to file a timely appeal from or otherwise contest the order. No compulsory disclosure to third parties of CONFIDENTIAL INFORMATION shall be deemed a waiver of any privilege, protection from disclosure or other claim of confidentiality.

8. Vendor further agrees not to store CONFIDENTIAL INFORMATION received from the Department pursuant to this AGREEMENT in a permanent database.

9. All CONFIDENTIAL INFORMATION furnished hereunder shall be returned or destroyed pursuant to State of Illinois Contract B-50721 . However, if this AGREEMENT is terminated before State of Illinois Contract B-50721 , the promptness of Vendor’s return or destruction of CONFIDENTIAL INFORMATION shall be measured relative to the termination of this AGREEMENT.

10. Vendor shall ensure the security, storage, and integrity of the Department’s content, data, computers, networks, and systems (which may include the use of encryption technology to protect the Department’s content and data from unauthorized access). Notwithstanding anything to the contrary in this AGREEMENT, to the extent that Vendor negligently or intentionally experiences or causes an information breach or security incident that impacts the Department’s data, content, computers, systems, or networks, Vendor shall immediately notify the Department in writing and will use best efforts to immediately remedy any such breach or incident, and to prevent any further breach or incident, at Vendor’s expense, in accordance with applicable privacy rights, laws, regulations, policies, and standards, including but not limited to the Illinois Personal Information Protection Act (815 ILCS 530). Vendor shall reimburse the Department for any and all costs incurred by the Department in responding to, and mitigating damages caused by, any such breach or security incident, including all costs of notice and/or remediation.

11. Vendor shall be liable where any damage or impairment to the Department’s computers, systems, and networks, or any loss or corruption of the Department’s data or content, is due to Vendor’s negligent or intentional acts and omissions. Further, Vendor shall reimburse the Department for any and all costs incurred by the Department in restoring such data, content, computers, systems, or networks.

12. Nothing in this AGREEMENT shall be construed as a delegation of regulatory or rulemaking authority nor shall it be construed to restrict, enlarge or otherwise modify the regulatory prerogatives, rights, or obligations of the Department in any way.

13. Nothing in this AGREEMENT shall be construed as a waiver of any privileges, defenses, rights, remedies, or immunities available to the Department.

14. This AGREEMENT shall be governed by the laws of the State of Illinois. The venue for any dispute under this AGREEMENT shall be Sangamon County, Illinois, or the Illinois Court of Claims as appropriate.

15. This AGREEMENT shall terminate no later than State of Illinois Contract B-50721 , but prior to that it may be terminated by either the Vendor or the Department upon thirty (30) days’ written notice to the other party. Termination of this AGREEMENT shall not affect the rights and obligations of the Vendor with respect to CONFIDENTIAL INFORMATION already shared by the Department pursuant to this AGREEMENT.

16. This AGREEMENT constitutes the entire understanding between the parties hereto as to the CONFIDENTIAL INFORMATION and merges all prior discussions between them relating thereto.

17. In the event that any portion of this AGREEMENT is held invalid, the invalid portion shall be deemed to be severed and all remaining provisions of this AGREEMENT shall be given full force and effect and shall not be affected in any way.

18. This AGREEMENT may be signed in multiple counterparts, each of which shall constitute a duplicate original, but which taken together shall constitute but one and the same instrument. Execution by facsimile or by an electronically transmitted signature shall be fully and legally effective and binding.

19. No amendment of this AGREEMENT shall be valid or binding on the parties unless made in writing and signed on behalf of each of the parties by their respective duly authorized representatives.

IN WITNESS WHEREOF,

Revised 01/2026

Illinois Department of Insurance

CONFIDENTIAL INFORMATION NON-DISCLOSURE AGREEMENT

Illinois Insurance Law Confidentiality Provisions

215 ILCS 5/35A-50 Risk-Based Capital Reports/Plans/Orders or examination under Article IIA Risk-Based Capital

215 ILCS 5/35B-25 Plan of Division

215 ILCS 5/129.8 All document and information (including ORSA) obtained pursuant to Article VIII ¼ Risk Management and Own Risk and Solvency Assessment

215 ILCS 5/130.6 All documents, materials, or other information, including the corporate governance annual disclosure, obtained created by, or disclosed pursuant to Article VIII 1/3

215 ILCS 5/131.20c Supervisory colleges generally

215 ILCS 5/131.20d Group-wide supervision of internationally active insurance groups

215 ILCS 5/131.22 Documents and information obtained in an examination or investigation or reported pursuant to Article VIII ½ Insurance Company Holding Systems

215 ILCS 5/132 Examination Reports and ancillary information provided in the course of market conduct action and market analysis

215 ILCS 5/132.5 Examination Reports and ancillary information provided in the course of a financial exam

215 ILCS 5/136 Various documents filed in connection with Annual Statements (Property Casualty)

215 ILCS 5/141.4 Monthly report on material transactions

215 ILCS 5/155.35 Insurance compliance self-evaluative audit document

215 ILCS 5/223 Various documents filed in connection with Actuarial Statements (Life)

215 ILCS 5/401.5 Papers, documents, reports, or evidence relevant to an ongoing investigation into insurance law violations

215 ILCS 5/404 General withholding of documents for good reason, general sharing with other states, NAIC and law enforcement

215 ILCS 215/30 Documents, materials, or other information obtained pursuant to the Insurance Data Security Law

820 ILCS 310/6 Worker compensation injury reports filed with Workers Compensation Commission