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Prime TherapeuticsCode of Conduct

A Message from Prime’s President and CEOAs employees, directors and officers of Prime Therapeutics, our clients and members have placed in us a unique trust.We need to be accountable to that trust and together conduct our business lawfully and responsibly. Beyond complyingwith the law, we must actively strive to do the right thing. We must always exercise sound judgment in our decision-makingbecause integrity is the foundation on which our relationships are built.Prime’s Code of Conduct is based on our core values and summarizes important policies and legal obligations. Our Codecannot address all circumstances or anticipate every situation that we, as Prime employees, may face. Rather, Primeexpects all individuals to read all policies that impact the work that they do, use good judgment and ask questionswhenever they are in doubt about the best action to take.You may seek assistance from your supervisors, the Human Resources Department, Legal Department, ComplianceDepartment or Prime’s Compliance Officer if you are faced with a situation and are unsure of what to do. Also, a 24-hourCompliance hotline (800.474.8651) has been set up to allow employees to ask questions or raise potential complianceconcerns. All Prime employees should feel comfortable using candor as it relates to the reporting of any compliancerelated matters without fear of retaliation or retribution.By responsibly and consistently following our Code, we can each do our part to ensure that Prime maintains its reputationas a company that conducts its business with the utmost integrity.With regards,Eric ElliottPresident and Chief Executive OfficerReport Compliance concerns: 24-hour anonymous Compliance hotline 800.474.8651i

Mission and VisionYou should be aware of and understand Prime Therapeutics’ mission and vision.MissionOur mission is to provide the highest quality care and service for members whilefocusing on delivering the lowest cost of care and empowering clients to makeinformed decisions in health care management.VisioniiTo be the PBM of choice for Blue Cross and Blue Shield plans. Prime Therapeutics llc

Compliance Program and Code of ConductPoliciesPrime Therapeutics LLC (Prime), is committed to the values of integrity, honesty andrespect. Our activities and the activities of everyone working for Prime must reflectpositively on the company and our customers. Our policies insist that we all: Do business with integrity and in accordance with all applicable laws andregulations Prevent unethical or unlawful behavior Halt any such behavior as soon as reasonably possible after its discovery Implement any policy and procedure changes needed to prevent recurrencesof a violation Use disciplinary action as necessaryPrime honors these policies as part of the work of the Compliance Department,which includes, but is not limited to: The Code of Conduct (the Code) which applies to all of Prime’s officers, directors,employees, contractors, agents, consultants, suppliers, first tier entities,downstream entities and related entities Other related management policies and procedures as may be amended fromtime to time (Compliance Program)Report Compliance concerns: 24-hour anonymous Compliance hotline 800.474.8651iii

Compliance Program and Code of ConductWhat is the goal of the ComplianceOne goal of the Compliance Program and the Code is to provide guidance to you asProgram and the Code?you continue to work with or for Prime and to raise awareness of the ethical, legaland other rules that affect our business.The Code should be used as a reference for difficult or questionable situations.In addition to reviewing the Code, you should review the corporate policies that arementioned throughout the Code. These policies are available for your reference inboth the Policies and the Compliance sections of Prime’s intranet, PrimeTime.com.You may approach your supervisor or manager if you are unsure of a situation orhave questions regarding the Code, the Compliance Program or any of our policies.The Human Resources, Legal and Compliance Departments, as well as Prime’sCompliance Officer are available for assistance. Additionally, you may use the24-hour anonymous Compliance hotline (800.474.8651). A dditional information about Prime’s Compliance Program is available on Prime’sintranet, PrimeTime.com.Who oversees the ComplianceThe Board of Directors is charged with oversight of the overall Compliance Program.Program and approves the Code?The Board’s Audit and Finance Committee reviews and approves the Code annuallyas a part of its oversight.iv Prime Therapeutics llc

Who must follow the Code?The Code applies to all of Prime’s officers, directors, employees, contractors, agents,consultants, suppliers, first tier entities, downstream entities, related entities andthird parties acting on our behalf.Ethical conduct is at the core of how we do business and is the foundation fromwhich all of our business relationships and activities are formed and maintained.Although illegal or unethical conduct is usually easy to identify and avoid, someseemingly harmless conduct can be considered illegal or improper. Moreover,contracting with the government or any transaction involving government fundsinvolves a special trust and, as a consequence, a stricter code of behavior as isoutlined throughout the Code.You are personally responsible for being familiar with the Code and for seekinghelp or clarification to avoid unethical or illegal business conduct. Compliance withthe Code is a condition of your employment. In addition, if you are responsible forsupervising anyone else, you must ensure that they are aware of and comply withthe Compliance Program and the Code. You must diligently set an example of ethicalbusiness behavior and must foster a work environment in which compliance isexpected and encouraged and in which there is no suggestion that violations arepermitted at any time — even if they might benefit Prime. You should review the Codeon a regular basis so that these standards are incorporated into your daily work.What should be reported?You are responsible for reporting: Any activity you believe may be a violation of the Code Any activity you believe may be a violation of any applicable policy, lawor regulationHow do employees reportYou can report without fear of retaliation or retribution. We have several reportingquestionable activities?options available including, but not limited to, talking to your supervisor, the HumanResources Manager, the Legal or Compliance Departments or the Compliance Officer.A 24 hour/7 days a week anonymous hotline is also available at 1.800.474.8651.Report Compliance concerns: 24-hour anonymous Compliance hotline 800.474.8651v

Table of ContentsWorking together to ensure compliance with laws 1Accountability to Prime, our clients, our members and each other: Protecting company assets and information 1Conflicts of interest Use of Prime’s funds and assets Confidential and proprietary information Data security and software license obligations 1233Integrity when dealing with suppliers and customers 4Reciprocity Gifts or gratuities Entertainment, travel and honorariums Other improper payments Appropriate service and coverage Antitrust Price fixing Market allocation and other agreements restraining trade 45677788Candor with the government 9Bribery 9Anti-kickback laws 9Medicare and Medicaid participation 9Ineligible health care providers and pharmacies 9HIPAA and privacy 10Political activity and contributions 10Candor with our members, clients and owners in our advertising and promotion 11Working with purpose: Accounting and record management 11Proper accounting Accounting practice complaints Labor and materials costs Falsification of records Record management policies Record ownership Record creation Record retention Record destruction 111111121213131313Working together to create a safe and healthy work environment 14Workplace violence Discrimination Harassment Substance abuse Computer usage E-mail and instant messaging usage 141414151515Prime’s active Compliance Program 16Exceptions and amendments Non-retaliation Investigations Corrective actions 16161717Equal employment opportunities 18Reporting violations 18vi Prime Therapeutics llc

Code of ConductWorking together to ensure compliance with lawsPrime is committed to doing business in compliance with all applicable state,federal and local laws including, but not limited to, the Health Insurance Portabilityand Accountability Act, the Privacy and Security Standards and the MedicarePrescription Drug, Improvement, and Modernization Act. If you have any questionsor concerns regarding specific laws, regulations or any legal issue, please contactthe Legal Department.Accountability to Prime, our clients, our members and each other:Protecting our assets and informationConflicts of interestYou have a duty to avoid financial, business or other relationships that put you atodds with our interests or that may conflict with your assigned duties. You shouldconduct yourself in a manner that prevents even the appearance of a conflictbetween your personal interests and those of Prime.Conflicts of interest may arise through: Employment or any engagement with a competitor, regardless of the nature of theemployment or engagement Acceptance of gifts, payments or services from those who do business or seek todo business with Prime Placement of Prime business with a firm owned or controlled by a Prime employeeor a family member of an employee Ownership of, or substantial interest in, a company that is a customer, competitoror supplier of Prime Serving as a consultant to a current or prospective Prime customer or supplierYou are required to annually disclose personal, financial and other interests to theCompliance Department. You also have an ongoing duty to disclose these conflictedrelationships throughout the year. This information is reviewed by the ComplianceOfficer to determine whether or not those interests pose a real or potential conflict.Report Compliance concerns: 24-hour anonymous Compliance hotline 800.474.86511

Code of ConductUse of Prime’s funds and assetsPrime’s assets may be used only for Prime’s benefit. You have a duty to ensurethat all corporate assets are used only for valid business purposes. Prime’s assetsshould never be used by anyone for personal gain. These assets include muchmore than equipment, inventory, corporate funds or office supplies. Assets are alsoconcepts, business strategies and plans, financial data, intellectual property rightsfor trademarks and patents, and other information about our business.Confidential and proprietaryWe must maintain a strict standard of confidentiality to protect Prime’s clients’,information — Primemembers’ and Prime’s confidential and proprietary information. Any unauthorizedaccess, use or disclosure of this private information is prohibited.Confidential information is anything that is not generally known or shared with thepublic and includes: Patient and employee medical record, claims, credit card and other sensitiveinformation that we obtain through our business or employment relationships Proprietary information, often known as “trade secrets,” which is helpful to Primeand/or competitors and is generally not available to the public Information about our customers, employees, consultants, temporary workersor participating providers that isn’t public knowledge2 Prime Therapeutics llc