Related Conflict of Interest Policies

Title : Secondary/Additional Professional Activities and Outside Activities of Employed Practitioners Policy and Procedure Number : 3977, Version : 1 Practitioner and the applicable Medical Group, and (b) the related agreement between the applicable Medical Group and the Outside Entity, if a related agreement is required, has been fully executed by both parties. 10. The applicable Medical Group may terminate an Employed Practitioner's Review of Covered Professional Activities by SPAC’s Designees. 1. The following procedures will apply to the review by certain people and entities designated by SPAC of proposed Covered Professional Activities to be provided to an Outside Entity. 2. For all Employed Physicians, the authority to approve the following proposed Outside Activity has been delegated to the Chief Executive Officer of the applicable Medical Group, or his/her designee: a. Providing clinical services to an Outside Entity so long as (i) there is no opportunity for the Employed Physician to provide the same type of clinical services within Banner, and (ii) such clinical services will not be provided in a state in which Banner does business. 3. For all Employed Physicians, the authority to approve the following proposed Secondary/Additional Professional Activities has been delegated to the Chief Executive Officer of the applicable Medical Group, or his/her designee: a. Providing clinical services to an Outside Entity (i) within the scope of the Employed Physician’s employment with the applicable Medical Group and (ii) within the service area of the applicable Medical Group. Providing medical director services or other similar administrative services to an Outside Entity that is not a drug or device company/manufacturer (i) within the scope of the Employed Physician’s employment with the applicable Medical Group and (ii) within the service area of the applicable Medical Group. Attending educational conferences within the United States of America as long as such attendance also has been approved by the Compliance Department in the case of vendor sponsored activities. Performing clinical research within the scope of the Employed Physician’s employment by the applicable Medical Group; provided, however, that for Employed Practitioners employed by B—UMG, performing clinical research within the scope of the Employed Physician’s employment is a Primary Activity that is not subject to SPAC review. 4. For Employed Physicians employed by BMG, BMGC or BUCS, the authority to approve the following proposed Secondary/Additional Professional Activities within the United States has been delegated to the Chief Executive Officer of the applicable Medical Group, or his/her designee: a. Speaking at or otherwise participating in specialty society meetings or other professional conferences as long as the activities do not involve a direct relationship with a drug or device company/manufacturer. Engaging in grand rounds or lecturing opportunities at non-Banner facilities as long as the activities do not involve a direct relationship with a drug or device company/manufacturer. Providing continuing medical education (CME) as long as the activities do not involve a direct relationship with a drug or device company/manufacturer. c. d. b. c. obligation to provide any Covered Professional Activities at any time upon written notice to such Employed Practitioner, and, if applicable, the Outside Entity. F. b.

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