2023 Banner Code of Conduct

Letter fromDavid Ledbetter Dear TeamMembers:

Banner has a longstanding Compliance Program. The Programwas initially implemented in the 1990s and has continually expanded as Banner has acquired new facilities and areas of business. Banner’s Compliance Program incorporates the seven elements that originated in the Federal Sentencing Guidelines: • Compliance Personnel and Structure • Compliance Documents • Compliance Training and Education • Reporting and Investigating • Monitoring and Auditing • Response and Prevention • Enforcement and Discipline

One of the key Compliance Documents is the Code of Conduct. This Code of Conduct describes Banner’s Compliance Program in greater detail. It also provides guidance on how to conduct our work andmake decisions within appropriate ethical and legal standards. Finally, it serves as a resource for understanding some of the complex laws and regulations governing the health care industry. Please carefully review this Code of Conduct and seek assistance if you have any questions. The success of Banner’s Compliance Programdepends upon the active participation of every TeamMember. Thank you for your continuing commitment to Banner. Sincerely yours, David Ledbetter Vice President, Chief Ethics &ComplianceOfficer