2023 Banner Code of Conduct

Physician andOther Provider Relationships Interactionswith Physicians andOther Providers

Facilities owned and operated by Banner reflect a collaboration between those who performnon-clinical functions and those who performclinical functions. As with any collaboration, each party has important roles and responsibilities. Banner is committed to providing a supportive and respectful work environment for all Team Members, including our physicians and other providers who practice in our entities. All business arrangements with physicians and other providersmust be structured to ensure compliance with legal requirements and, where appropriate, set forth expectations regarding compliance with laws, regulations, Banner’s CIA, this Code of Conduct, and applicable Banner policies. Two overarching principles govern our facility interactionswith physicians and other providers: • We do not pay for referrals. We accept patient referrals and admissions based on patients’ medical needs and our ability to render the needed services. We do not directly or indirectly give or offer anything of value in exchange for patient referrals as that would be a violation of the law. • We do not accept payment for referrals or authorizations to accept patients. No TeamMember or any person acting on Banner’s behalf is permitted to directly or indirectly solicit or receive anything of value in exchange for a patient referral or authorization to accept a patient. The acceptance of any such remuneration would be a violation of the law. Violation of these principlesmay have serious consequences for Banner and the individuals involved, including civil and criminal penalties and possible exclusion fromFederal health care programs. Qualified to ProvideCare Only physicians and other providers who have the necessary training and are properly credentialed will be permitted to provide patient care services at Banner. Business Courtesies and Tokens of Appreciation Any entertainment, gift or token of appreciation offered to physicians or other providers who are in a position to refer patients to Banner must comply with all applicable laws and regulations. TeamMembersmust consult Banner policies and/or the Ethics &Compliance Department prior to offering any business courtesy or token of appreciation to a potential referral source. Any items of value provided to physicians or other providers who are associated with Banner’s Accountable Care Organizations (ACO) must meet the requirements of those federal programs.

Compliance@BannerHealth.com | ComplyLine: 1-888-747-7989 13