Optional_2023 Board Resources

5. What will be the level of resources necessary to implement the compliance program as envisioned by the Board? How has management determined the adequacy of the resources dedicated to implementing and sustaining the compliance program? • The Ethics & Compliance Department’s budget is reviewed on an annual basis and is adjusted accordingly as needed to maintain the effectiveness of the Compliance Program. • The Department’s budget and its number of FTEs have remained the same or increased every year, notwithstanding any financial challenges and reductions. This demonstrates the commitment to compliance notwithstanding the financial situation within the organization. Operational Questions Code of Conduct How has the Code of Conduct or its equivalent been incorporated into corporate policies across the organization? How do we know that the Code is understood and accepted across the organization? Has management taken affirmative steps to publicize the importance of the Code to all of its employees? • New employees at Banner are provided information about the Code of Conduct in their new employee orientation. In addition, every year all of Banner’s employees undergo mandatory compliance training through the MyHR | Workday platform, including a course that covers certain topics in the Code of Conduct and requires employees to acknowledge that they have received and understand the Code of Conduct. • The Code of Conduct is also available on the Ethics & Compliance Department’s intranet site. • To publicize other compliance matters, the Ethics & Compliance Department utilizes the Yammer platform in addition to, sponsoring promotional activities during National Compliance Week. 2. Policies and Procedures Has the organization implemented policies and procedures that address compliance risk areas and established internal controls to counter those vulnerabilities? • The Compliance Policies & Procedures clarify different aspects of the Compliance Program, address some of Banner’s principal risks, and establish internal standards for compliance with laws and regulations. 1.