Lead with trust and transparency

President and Chief Executive Officer Byron Jobe leads the Vizient team from our Irving, Texas, headquarters. A coordinated communications program ensures that members, customers, suppliers, and employees remain well-informed about financial performance updates. We create customized Value Scorecards each spring to highlight the benefits members gain through network participation.

The Vizient Board of Directors ensures the integrity of financial audits and reports through our Audit and Finance Committee. The Governance Nominating and Compliance Committee oversees our compliance program, including our Standards of Business Conduct. We provide a toll-free compliance line at (800) 750-4972 to encourage anyone to report concerns anonymously.

We expect our contracted suppliers to conduct themselves with the highest business integrity and ethics. Suppliers must execute a certification form and comply with our gifts and entertainment policies. To preserve the independence of all decisions, employees must avoid situations where personal activities create a conflict of interest. Employees complete a disclosure form annually.

We strive to provide members with a unique competitive advantage via access to products with unmatched quality, value, and efficiency. We carefully select and approve suppliers based on member direction. Our quality assurance personnel monitor supplier performance throughout the contract period to facilitate necessary actions and proactively notify members of regulatory issues.

The Governance Nominating and Compliance Committee oversees the implementation of our compliance program, including our Standards of Business Conduct and policy on conflicts of interest. The Compliance Officer presents status reports and issues at committee meetings. The Compliance Officer is a resource for any person in the organization who has a concern about ethical conduct.

Additionally, a toll-free compliance line is available, (800) 750-4972. To encourage anyone to report possible conflicts of interest or other compliance-related issues, callers can report their concerns anonymously.

We are committed to maintaining the highest standards of ethics and openness in everything we do. To maintain a transparent organization, we share information through an integrated system of communications. Our Standards of Business Conduct convey our expectation that employees demonstrate ethical practices and ensure we comply with legal and contractual requirements, prudent financial practices, and related corporate policies and procedures. Related, our Conflict of Interest Policy further preserves and protects the integrity of all decisions made, making certain the interests of Vizient, not the individual, prevail.

Employee commitment to compliance is an essential component of our core business practices. We have developed a comprehensive Business Conduct, Compliance and Ethics Program. The Standards of Business Conduct serve as the foundation for our program, which is supported by our Board of Directors and management.

The program reflects the principles outlined in the Standards of Business Conduct, the Code of Conduct adopted by the Healthcare Supply Chain Association (HSCA), the Healthcare Group Purchasing Industry Initiative (HGPII), and other related industry and governmental compliance guidance and applicable law.

Led by the Compliance Officer, the Compliance team works with senior management to ensure Vizient's compliance with the program. Oversight and direction are provided by the Vizient Board of Directors and its Governance Nominating and Compliance Committee. The program includes the key elements outlined by the Federal Sentencing Guidelines:

• Standards, policies and procedures
• Governance and oversight
• Confidential procedure for asking questions and investigating compliance concerns
• Compliance hotline and website for asking questions and reporting compliance concerns
• Ongoing monitoring and auditing
• Education and training

At Vizient, we expect our contracted and prospective suppliers to comply with the spirit of these Supplier Standards as well as all applicable laws and regulations, in all facets of their business relationship with us and with members.

In addition, suppliers are expected to:

• Execute a supplier certification form acknowledging their receipt and understanding of these Standards.
• Refrain from giving, offering, accepting or soliciting anything that can be construed as a bribe, kickback or other illegal or unethical payment with respect to business arrangements between Vizient and the supplier.
• Comply with Vizient’s gifts, business meals and entertainment policies in their dealings with our employees.
• Honor the terms, conditions and spirit of all agreements with Vizient and members.
• Maintain the confidentiality of Vizient’s and members’ confidential information, including but not limited to contract terms and supply chain data.
• Honor the intellectual property rights of our company and members, and refrain from infringing upon any of their respective trademark, service mark, copyright or other intellectual property rights.
• Submit timely and accurate reports regarding transactions with Vizient and members, including sales and administrative fee reports.

These supplier expectations should not be considered exclusive. At Vizient, we expect our contracted suppliers to conduct themselves with the highest business integrity and ethics in dealings with both us and members.

To ensure that contracted and prospective suppliers have the ability to voice concerns regarding our contracting process, we have a Vendor Grievance Policy. Additionally, our Legal and Compliance Departments are available to address supplier questions and concerns.

To preserve and protect the integrity and independence of all decisions affecting Vizient, employees must avoid situations in which their personal activities and/or relationships could create, or appear to create, a conflict of interest. A conflict of interest occurs when it becomes difficult to objectively carry out job responsibilities or act in the best interest of Vizient. All officers and employees of Vizient must maintain the highest standards of business conduct and ethical principles.

It is not practical to describe every situation that might raise a conflict of interest or the appearance of one. However, specific guidelines and examples of conflict situations are outlined in our Conflicts of Interest policy, which is accessible through our intranet or by contacting a member of our Compliance team. If an employee thinks a conflict of interest situation may exist, the employee should disclose the potential conflict of interest situation to a supervisor and/or a member of the Compliance or Legal teams.

General guidelines

Employees should use sound judgment and exercise reasonable business discretion in all business interactions. Employees who are, or potentially may be, involved in a conflict of interest should discuss and disclose such situations with a supervisor and/or the Compliance and Legal teams.

Topics covered under the Conflicts of Interest Policy include:

• Individual equity interests
• Property or service transactions
• Gifts, meals and entertainment
• Confidential and proprietary information
• Personal relationships
• Employment or consulting relationships
• Serving as an officer or member of a board of directors outside of Vizient
• Political contributions and unethical payments
• Lobbying and other contacts with government officials
• Honorariums

Disclosure obligations

Employees are required to complete a Conflicts of Interest Disclosure form within the first 30 days of employment.

All employees are required to complete a conflicts of interest disclosure form at least annually and as actual or potential conflicts arise.