2025 Banner Health Code of Conduct V.3 (2)

Letter from our Chief Ethics and Compliance Officer

Dear Team Members: Banner has a longstanding Compliance Program that aligns with its values, which includes continuously earning trust. The program was initially implemented in the 90s and continually evolved as we’ve acquired new entities and areas of business. The design of our Compliance Program is based on the seven elements that originated in the Federal Sentencing Guidelines, as well as current regulatory guidance applicable to our work: • Written policies and procedures • Compliance leadership and oversight • Training and education • Effective lines of communication with the compliance officer and disclosure programs • Enforcing standards: consequences and incentives • Risk assessment, auditing, and monitoring • Responding to detected offenses and developing corrective action initiatives Our Code of Conduct is one of the key written policies and procedures that describes our program in greater detail. It also provides guidance on how we’re to conduct our work and make 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. Review this carefully and seek assistance if you have any questions. The success of our program depends upon the active participation of every team member. Thank you for all you do to support and strengthen our culture of compliance and your continuing commitment to Banner. Sincerely yours, Banner’s Chief Ethics and Compliance Officer