Related Conflict of Interest Policies

Title : Secondary/Additional Professional Activities and Outside Activities of Employed Practitioners Policy and Procedure Number : 3977, Version : 1 The Outside Activity is not inconsistent with any applicable policies of Banner or the applicable Medical Group; The Outside Activity does not create any risk of liability or loss to Banner or the Medical Group or any undue risk of damage to their respective reputation, image, or good standing in the community; and The Outside Activity does not present an actual or potential conflict of interest. 2. The applicable Medical Group will not be required to approve any proposed Outside Activity, even if all of the criteria set forth in Article III, Section C.1 have been met. 3. Any materials prepared for public use by an Employed Practitioner in connection with an approved Outside Activity must be accompanied by a reasonably prominent disclaimer stating that the views/opinions/conclusions expressed in the materials are the Employed Practitioner’s and do not reflect the views/opinions/conclusions of Banner. 4. Receipts from Outside Activities are the property of the Employed Practitioner and not of the applicable Medical Group. Such receipts would include passive income from non-healthcare investments (e.g., income from financial instruments, rental receipts from property investments, farm income) and from investments related to healthcare in which the Employed Practitioner is not an active participant and the investee is not a competitor to or doing business with Banner (e.g., a specialty laboratory serving an area in which Banner does not have operations). 5. To comply with Banner’s Conflict of Interest Policy and to avoid the appearance of impropriety, any Employed Physician who enters into an agreement with an Outside Entity cannot participate in any decision-making process involving Banner’s use or purchase of any items or services provided by the Outside Entity. Any potential relationship with the Outside Entity must be reviewed and approved under Banner’s Supply Chain Management process and procedures in the ordinary course without regard to the Employed Practitioner. Under no circumstances will an Employed Practitioner receive Secondary/Additional Compensation or any other compensation intended to influence the referral decision-making process, to reward past referrals, or to generate federal healthcare program business. 2. An Employed Physician is prohibited from entering into a POD without express written approval of Banner's Legal Department and Banner's Ethics and Compliance Department. Should a Physician participate in a POD with express approval of Banner's Legal Department and Banner's Ethics and Compliance Department, this Policy will only apply to those products or services utilized in a Banner facility. 3. No products or non-Physician services may be offered or sold by an Employed Practitioner to patients of any Medical Group or to any other person on any premises belonging to Banner or any Medical Group, other than through the applicable Medical Group. 4. Under no circumstances may an Employed Practitioner individually bill or charge any patient or third-party payor for the services provided by the Employed Practitioner pursuant to his/her Employment Agreement. e. f. D. Prohibited Arrangements. 1. d.

Page 7 of 18