Dentsply Sirona
Code of Ethics& Business Conduct

THE DENTAL
SOLUTIONSCOMPANY ™

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Dentsply Sirona has a renewed sense of commitment to an unwavering focus on performance with integrity. As wecontinue to grow, we rely on the integrity of every employee, board member and business partner to guide theiractions. However, it is not enough to just act with integrity, we must hold each other accountable and be willing to
speak up if we see something that does not align with our values and operating principles. We must be honest in ourcommunication - transparent in our intentions and forthcoming with all information that will help the company makegood decisions and operate in a compliant manner.
We are a leader in the dental and medical device industry, and this comes with increased responsibility.
Each Dentsply Sirona employee needs to make good ethical decisions that lead to positive actions and themost suitable healthcare solution for our customers. Dentsply Sirona must earn the trust of our customers
and investors every day, through the actions of our employees.
Every person in the Dentsply Sirona community helps preserve our solid reputation by making a personalcommitment to follow our Code of Ethics and Business Conduct (the Code). Built upon our Core Values andoperating principles, our Code and policies guide us in upholding our ethical commitment to ourcustomers, our employees, our shareholders, our industry, and to the global community. We ask that all
members of the Dentsply Sirona community – employees, officers, directors and business partners comply not only with these policies, but also use good judgment and integrity in all situations that may not
be specifically addressed in the Dentsply Sirona Code. Ultimately, the spirit and intent of Dentsply Sirona’sCore Values and operating principles, and the Dentsply Sirona Code should guide your actions.
As members of the Dentsply Sirona community, we are accountable to one another. Should you ever havequestions or concerns about the policies outlined in the Dentsply Sirona Code or the integrity of others’
actions, please alert your manager, your local compliance leader, the Chief Compliance Officer, or use one of
the many other channels the Company makes available to you including the Ethics Hotline. Do not allow
anything – such as “making the numbers,” competitive instincts, or even a direct order from a superior – tocompromise your commitment to unquestionable integrity.
Our Dentsply Sirona business leaders are responsible for their own actions and for fostering a culture
consistent with our Code of Ethics and Business Conduct, policies and applicable laws. Leaders are
expected to address employees’ concerns about appropriate conduct promptly and with care and respect.
Excellent financial performance and high standards of governance and compliance are equally importantand valuable. As we continually improve upon Dentsply Sirona’s business, we must recognize that only one
kind of performance will maintain our strong reputation, increase our customers’ confidence in our products
and services, and enable us to continue to grow; that is performance with integrity.

Simon Campion
Chief Executive Officer

Mike Pacella
VP, Chief Ethics & Compliance Officer

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Topics
Dentsply Sirona Hotline
Anti-Bribery, Anti-Corruption
International Trade ComplianceInteracting with Health Care Professionals
Interacting with Government Agencies & Officials
Third Party ComplianceInsider Trading
Anti-Money Laundering
Fraud
Anti-Trust
Conflict of Interest
Data Privacy, Protection & Cyber Security
Transparency
Environmental Health & Safety
Dentsply Sirona in the World
Community

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Dentsply Sirona’sCore Values

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What Employees Must Do

It is Dentsply Sirona’s policy and must also be every employee’s commitment to comply with the law
everywhere we do business. No one has the authority to violate any law or to direct another person to violate
the law on behalf of the Company. The Dentsply Sirona Code of Ethics and Business Conduct helps us define
who we are and identify specific risk areas, but it cannot prevent unlawful acts or other bad behavior. It is only
through the vigilance of each Dentsply Sirona employee that we can mitigate this risk and protect ourcompany, ourselves and our shareholders.
We must commit ourselves to understanding the relevant local laws as well as our Codes and Policies.
This can be accomplished by taking all training assigned to you through the Learning Management
System and by assuring that your employees and co-workers do likewise. Ask questions if you don’t
understand any elements of the assigned training or if you are asked to do something that you feel
conflicts with what you have learned.
We must hold ourselves and each other accountable for our respective actions and be willing to speak up
if we see something which goes against our values or our codes and policies. It is each employee’s
obligation to speak up – remember “SPEAK UP -YOUR VOICE MATTERS”. Violations must be reported
either to your manager, your local compliance manager or to local HR, or if you are not comfortablebringing it forward locally, you may report it directly to the Chief Compliance Officer or through theDentsply Sirona Ethics Hotline. If you choose to remain anonymous you may.

The Ethics Hotline isadministered by an external partner (Convercent). Issues may be reported via direct input into the Web
Portal by utilizing the link below or you may use the toll-free number unique for your location. Hotline
reports are only visible to the Chief Compliance Officer, the General Counsel, and the Chair of the Audit
and Finance Committee of the Board of Directors.
Anyone reporting an issue through the Ethics Hotline who wishes to remain anonymous may do so. If you
do not disclose your name or contact information, you will remain completely anonymous to therecipients of the complaint and to the broader organization. You are able to obtain a password however,

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which allows the investigators to communicate with you through the hotline platform while still
respecting your desire for anonymity.
All issues reported to the Ethics and Compliance department or directly in the Ethics
Hotline are investigated and reviewed with the Ethics and Compliance Committee. This
committee is Chaired by the Chief Compliance Officer and is comprised of seniorleaders from Legal, Human Resources, Finance, Accounting, Corporate Audit, Supply
Chain, QA/RA, and our Commercial Organization. If during an investigation, you are
asked questions by the investigating team (Compliance, Legal, Corporate Audit, externalcounsel, etc.), you are obligated and expected to answer honestly and fully andvolunteer information you think might be relevant, even if a direct question on that
topic is not asked.

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What Leaders Must Do

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Ethical business practices and compliance with all applicable laws is everyone’s responsibility. It starts with
our values and must be reflected in all of our actions. The tone from the top is important in creating afoundation for a culture of integrity but then leaders at all levels must live those values and demonstrateunwavering integrity in everything we do.
As a leader, you must act to cultivate this culture of compliance in your respective organizations and assurethat your employees understand their responsibilities and feel comfortable raising concerns without fear of
retaliation. This means encouraging ethical conduct and compliance with the law by personallydemonstrating and promoting Dentsply Sirona’s Core Values, considering compliance efforts whenevaluating and rewarding employees, and ensuring that employees understand that business results mustbe achieved while complying with Dentsply Sirona policies and all applicable laws.
It is the responsibility of our pillar leadership (Product Groups, RCO’s, Supply Chain and Corporate
Functions) at all levels to assure that the various polices and processes which constitute the Dentsply Sirona
Ethics and Compliance program are fully and effectively administered in their respective areas of
responsibility. The Ethics and Compliance department is always available to answer questions and provide
guidance to our global businesses.
All managers must take the following steps to build an infrastructure to prevent, detect and respond tocompliance issues:• Ensure that policies and processes, tailored to address your particular risk areas, are communicated andimplemented.
• Ensure that all employees receive education on Dentsply Sirona policies and applicable law.
• Commit adequate resources to your business efforts toward implementing the compliance program.
• Include ethics and compliance topics in your staff meetings and townhalls. The Compliance staff should
not be the only leaders talking about ethics and compliance.
• Implement control measures, such as appropriate financial controls to identify and prevent fraud andother violations.
• Promote Dentsply Sirona’s Core Values and Operating Principles and the Dentsply Sirona Code of Ethics
and Business Conduct.
• Support and encourage periodic compliance reviews with the assistance of the Chief Compliance Officer
or your regional Compliance Leader, and/or the Corporate Internal Audit Services staff.
• Encourage employees to speak up and report integrity or compliance issues.
• Promptly implement corrective action to fix identified compliance weaknesses.
• Report any legal and ethics issues to the Legal department and/or Chief Compliance Officer.

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In addition, the Chief Executive Officer (CEO), Chief Financial Officer (CFO), and Chief Accounting Officer(CAO) or persons performing similar functions, are subject to the following additional specific requirements:• Maintain high standards of honest and ethical conduct and avoid any actual or apparent conflict ofinterest;• report to the Audit and Finance Committee of the Board of Directors any conflict of interest that may
arise and any material transaction or relationship that reasonably could be expected to give rise to aconflict;• provide, or cause to be provided, full, fair, accurate, timely, and understandable disclosure in reports
and documents that the Company files with or submits to the Securities and Exchange Commission andin other public communications;• comply and take all reasonable actions to cause others to comply with applicable governmental laws,
rules, and regulations; and• promptly report violations of the Code of Ethics for the CEO, CFO, and CAO to the Audit and FinanceCommittee either through the DS Ethics Hotline or directly to the chair of the Audit and FinanceCommittee.
• the Audit and Finance Committee will in-turn assess compliance with this Code of Ethics for material
violations to the Board of Directors and recommend to the Board appropriate action.

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Dentsply Sirona – Code of
Ethics Decision Guide
Though conducting business in an ethical fashion typically only requires common sense, you may
sometimes be faced with challenging situations and decisions for which the right decision is not perfectly
clear. The following diagram is intended to guide you toward the resources available to help you makeinformed decisions.

Contact Legal for guidance?

Is this legal?

NO

The action may have serious
consequences to the company
and yourself.
DO NOT DO ITNOThe action may have serious
consequences to the company
and yourself.
DO NOT DO IT

YES

The action may have serious
consequences to the company
and yourself.
DO NOT DO IT

YES

The action may have serious
consequences to the company
and yourself.
DO NOT DO IT

YES

The action may have serious
consequences to the company
and yourself.
DO NOT DO IT

YES

Talk to the Chief Compliance
Officer or your local
Compliance Representative
for guidance?

Does this comply with the
Dentply Sirona Code of Ethics
and Business Conduct?
YES

Talk to your pillar leader,
Legal or Compliance for
guidance?

Could this adversely affectcompany stakeholders?

NO

Talk to your pillar leader,
Legal or Compliance for
guidance?

Would you be concerned if
this appeared in a news
headline?
NO

Talk to your pillar leader,
Legal Compliance for
guidance?

Could this adversely affect thecompany if all employees did
this?

NO

Ok To Move Forward

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Speak up –your voice matters!

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Raising a compliance or integrity concern protects Dentsply Sirona’s community, our Company, ouremployees, our colleagues, and our stakeholders. If you have a concern about compliance with a
Dentsply Sirona policy or an applicable law or regulation, you have the responsibility to raise thatconcern. Failure to do so is a violation of the Dentsply Sirona Code. Speak up – your voice
matters!
Raise Concerns Early

Confidentiality Is Respected

Employees need to be action oriented when it
comes to compliance and integrity. The longer wewait to address a concern, the worse it may
become.

If you identify yourself, your identity and the

You May Remain Anonymous
However, if you identify yourself, we are then able
to follow up with you and provide feedback.

information you provide will remain confidential
and will be shared only on a “need-to-know” basiswith those responsible for resolving the concern.
Retaliation Violates Our Policy
Dentsply Sirona absolutely prohibits retaliation
against anyone who in good faith raises or helps

You May Report Externally
You are not prohibited from communicatingwith government agencies about possible
violations including filing a complaint andparticipating in government investigations andproceedings.

to address an ethics, integrity or a complianceconcern. Retaliation is grounds for discipline up to
and including dismissal

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Anti-Bribery, AntiCorruption
Any payment, gift or favor that is made or offered in order to gain an improper advantage in any
business situation is never acceptable and exposes you and Dentsply Sirona to possible criminal
prosecution. Dentsply Sirona expressly prohibits improper payments of money or anything of value andimproper gifts and favors, directly or indirectly in all business dealings in every country around the world,both with government officials and with private individuals.
For more information, please review Dentsply Sirona’s Business Gifts and Entertainment Policy, Global
Travel Policy, and the Ethical Customer Interaction Policy. Contact the Compliance and Legal teams if
you are ever in doubt about the law or a gift received.
Extortion is the demand-side of the bribery equation. This is when a government official or othercustomer or third party uses pressure to force you to provide him/her money or other things of value inorder to get their business. For instance, the head of a dental clinic threatening to switch to acompetitor’s products unless you send them on a trip would be considered solicitation of a bribe or
extortion. Just as giving or accepting a bribe is illegal, so is the asking for or offering of a bribe, even if
the transaction never occurs. If you feel that you are being pressured by anyone to provide a personal
incentive, you must say “NO”. Failure to do so exposes you and the company to fines and penalties
including possible imprisonment. If you find yourself facing one of these situations, please contact
someone in the Compliance or Legal departments for assistance.
Internal Controls and Accurate Record Keeping Dentsply Sirona maintains internal
controls to comply with legal, accounting, tax, and other regulatory requirements. Keeping accurate
records instills trust in Dentsply Sirona by its employees, customers, patients, investors, and business
partners. Accurate recordkeeping allows us to make strategic, commercial, and operational decisions. It
is critically important that our books, records, accounts, and financial statements be maintained inreasonable detail. “Off the books” accounts, transactions, and assets are prohibited.
Never falsify any type of record or account. In every transaction, be honest, and make a proper andcomplete record. Regardless of your role at the Company, we all share this responsibility. All employees
are responsible for timely, accurately, and completely communicating matters impacting, or potentially
impacting, the Company’s books and records. These communications also extend to information usedin developing annual budgets or periodic forecasts in support of their accuracy and completeness.
These matters generally involve judgment, and it is recommended that when in doubt, an appropriate
member of the Finance organization is made aware of the matter and factors considered in orcontributing to the judgment.
These responsibilities extend to our customers and partners, thus employees involved in the commercial
sale of Dentsply Sirona’s products is responsible for knowing how for what purposes customers may beusing our products and services. This type of awareness helps Dentsply Sirona prevent illegal andimproper activity from occurring.
The company’s record retention policies provide guidance for when documents and information should
be maintained or destroyed. Keep financial and business records in accordance with the company
retention policies, and do not dispose of records and information that may be relevant to current or
threatened litigation until you are advised to do so.

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Accountants, managers and financial executives and their commercial counterparts should periodicallyconsider the manner in which illegal, improper, or questionable payments could be made and determine
whether existing controls provide appropriate protection to prevent such payments. Under nocircumstance are verbal arrangements allowed. Any verbal agreement must be documented in acontract and signed by both parties.

International Trade
Compliance
Trade Sanctions are imposed in response to perceived human-rights violations, military or terroristic
threats or even unfair trade and currency considerations. Trade Compliance and export control laws affectthe sale, shipment, and transmission of goods, services, and technology across national borders with aheavy focus on these sanctioned countries. These laws apply to many aspects of Dentsply Sirona’s
operations – not just shipping products. Exchanges of information across national boundaries, including
email and web access, are subject to trade controls.
The United States also controls the release of technical information to non-U.S. nationals within the UnitedStates. It is important that we carefully observe export laws in connection with these activities, that we donot sell or ship our goods, services, and technology to persons to whom we are not permitted to sell or
ship goods, and not selling or shipping those goods into countries where we are not permitted to do so.
It is equally important that Dentsply Sirona’s distributors and agents abide by these same laws whenselling and distributing our products.
The link below provides more guidance on this topic as well as a current list of those countries currently
under U.S. sanctions. However, as these change frequently, you are encouraged to engage your Legal andCompliance team if you have any doubt about the status of a country with whom you wish to conductbusiness.

Customer Interaction
Though customer interaction is the heart of our business, inappropriate interaction can expose you andthe company to allegations of corruption under the US Foreign Corrupt Practices Act, the U.K. Bribery Act
and numerous other countries anti-bribery/anti-corruption laws regulating interactions with healthcare
professionals, distributors and government officials. In the United States, the Anti-Kickback Statute also
regulates how medical device and pharmaceutical manufacturers may interact with medical professionals
and distributors.

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Interacting with Health Care Professionals

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Dentsply Sirona employees interact with health care professionals in many aspects of ourbusiness, including as customers, consultants, or as participants in research anddevelopment activities. Dentsply Sirona is committed to complying with all laws andregulations governing interactions with health care professionals, and to going beyond strict legal
requirements by following the highest ethical standards in these interactions. To this end, Dentsply Sirona
has issued an Ethical Customer Interaction Policy. All Dentsply Sirona employees interacting with or
establishing programming with any healthcare professional shall be trained on the Ethical Customer
Interaction Policy.

Interacting with Government Agencies
and Officials
In the course of our work, we frequently interact with government agencies,
government officials, and public international agencies. In many countries, healthcare is run by orsubsidized by the government, and therefore, healthcare providers, health clinics and hospitals are
deemed to be government entities in accordance to the United States Foreign Corrupt Practices Act
and other local and international anti-corruption regulations. In every instance, Dentsply Sirona
employees must comply with applicable laws and regulations, including certain special requirements
associated with doing business with government officials, as well as those associated with governmenttransactions.
Interaction with government agencies and officials occurs not only when we sell to government
customers. For example, we frequently interact with government agencies and officials when we registerour products, clear customs, or obtain a permit to allow us to manufacture or do business in a certain
location. We may also interact with government officials through third parties, such as distributors,
consultants, brokers, or agents. If these third parties are representing or working on the behalf ofDentsply Sirona, their actions can be deemed to be those of Dentsply Sirona.

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Third Party Compliance14

Dentsply Sirona’s relationships with suppliers, distributors, Key Opinion Leaders andconsultants are based on mutual respect and the expectation that we all engage inlawful, and fair practices at all times. We expect our third-party business partners toabide by all laws and to agree to follow our Code of Ethics and Business Conduct.
Dentsply Sirona can be held accountable for unethical behavior of our third parties conducted on our behalf
if we knew or should have known that it was occurring. Each relationship requires appropriate due diligence
to assure that who we chose to work with live to the highest standards of integrity. Additionally, eachbusiness relationship shall be governed by a written agreement which will include language precluding
engagement in corruption and bribery and will adhere to all US trade sanctions as well as specified laws
pertaining to human rights and anti-human trafficking actions.

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Financial Compliance

15

Insider Trading
In the course of your job, you may learn of material information about Dentsply Sirona or othercompanies before it is made public. In general, information is considered “material” if there isa reasonable likelihood that it would be considered important to an investor in making adecision to buy, hold or sell securities. Any information that could be expected to affect a company’s stock
price, whether positive or negative, and whether the change is large or small, may be considered material.
Information is not considered public until it has been disclosed broadly to the marketplace (for example,
included in a press release or a filing with the Securities and Exchange Commission) and the investing public
has had time to absorb the information fully. For Dentsply Sirona, we require a minimum of one trading
day after filing our annual or quarterly reports.
You may simply overhear a hallway conversation or come across a memo left at a copy machine. Using thisinformation for your financial or other personal benefit or conveying this information to others constitutes aviolation of Dentsply Sirona’s insider trading policy and may violate the law. This includes buying, selling orotherwise engaging in any transactions, directly or indirectly, in securities of any company about which you
have material non-public information and giving this “inside information” to anyone else who might basefinancial trades on the information you have shared.

• Do Not Buy or Sell the securities of any company, including Dentsply Sirona, either directly or throughfamily members or other persons or entities, while you are aware of inside information about the Company(this is known as “insider trading”).
• Do Not Recommend, Express opinions or Suggest that anyone else buy or sell the securities of any
company, including Dentsply Sirona, while you have inside information about the Company (this is known
as “tipping”).
Maintain the Confidentiality of Dentsply Sirona information and do not convey information to anyone
outside of Dentsply Sirona unless it is necessary for Dentsply Sirona’s business activities and you are certainthat person is under obligation to the Company by an appropriate non-disclosure agreement. In the courseof your job, you may learn of material information about Dentsply Sirona or other companies before it ismade public. In general, information is considered “material” if there is a reasonable likelihood that it
would be considered important to an investor in making a decision to buy, hold or sell securities. Any
information that could be expected to affect a company’s stock price, whether positive or negative, andwhether the change is large or small, may be considered material. Information is not considered public
until it has been disclosed broadly to the marketplace (for example, included in a press release or a filingwith the Securities and Exchange Commission) and the investing public has had time to absorb theinformation fully. For Dentsply Sirona, we require a minimum of one trading day after filing our annual orquarterly reports.
You may simply overhear a hallway conversation or come across a memo left at a copy machine. Using thisinformation for your financial or other personal benefit or conveying this information to others constitutes
a violation of Dentsply Sirona’s insider trading policy and may violate the law. This includes buying, selling orotherwise engaging in any transactions, directly or indirectly, in securities of any company about which
you have material non-public information and giving this “inside information” to anyone else who might
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base financial trades on the information you have shared.

16• Do Not Buy or Sell the securities of any company, including Dentsply Sirona, either directly or throughfamily members or other persons or entities, while you are aware of inside information about the Company(this is known as “insider trading”).
• Do Not Recommend, Express opinions or Suggest that anyone else buy or sell the securities of any
company, including Dentsply Sirona, while you have inside information about the Company (this is
known as “tipping”).
• Maintain the Confidentiality of Dentsply Sirona information and do not convey information toanyone outside of Dentsply Sirona unless it is necessary for Dentsply Sirona’s business activities andyou are certain that person is under obligation to the Company by an appropriate non-disclosureagreement.

Anti-Money Laundering
Money laundering is the act of placing illegal gains into the financial system in ways
designed to avoid drawing the attention of banks, financial institutions or law
enforcement agencies. People involved in criminal activity – such as terrorism, drugtrafficking, bribery, or fraud – may try to “launder” the proceeds of their crimes to hidethem or make them appear legitimate. Many countries have laws against money laundering and theselaws prohibit doing business that involves proceeds of criminal activities. Another concern is that
legitimate funds may be used to finance terroristic activities – sometimes called “reverse” money
laundering, and many countries have restrictions to combat this activity as well.
Dentsply Sirona runs the risk of inadvertent or explicit participation in money laundering schemes in
accepting cash-payments for products or services, accepting payments from entities other than thecontractual customer, or allowing a customer to settle their account through multiple payments directly
into our accounts.
Dentsply Sirona is committed to complying fully with all anti-money laundering and anti-terrorism laws
throughout the world. Dentsply Sirona will conduct business only with reputable customers involved inlegitimate business activities, with funds derived from legitimate sources. Each Dentsply Sirona business isrequired to implement risk- based “Know Your Customer” due diligence procedures calibrated to the risk inquestion, and to take reasonable steps to prevent and detect unacceptable and suspicious forms of payment.
Failing to detect customer relationships and transactions that place Dentsply Sirona at risk can severely
damage Dentsply Sirona’s integrity and reputation and could violate the law.

Fraud
Fraud is perpetrated by individuals or in concert with others to obtain money,
property, or services; to avoid payment or loss of services; or to secure personal or
business advantage. The majority of fraudulent acts are some form of asset
misappropriation or the manipulation of the system to artificially alter financial
results. The cumulative effect of repeated incidents of asset misappropriation may have significant
financial impact on a business and may result in the need for financial restatement or SEC reporting for a
U.S., publicly traded company such as Dentsply Sirona.
Dentsply Sirona has ambitious goals to grow our business and improve our operating margin. Thoughdelivering financial results and achieving goals is important, this will never be done by compromising
our values and operating principles.
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The following is not an exhaustive list of asset misappropriation schemes but provides an idea of thethings we need to focus on to mitigate the risk to our company:• Forgery or alteration of documents (checks, bank draft, time sheets, invoices, agreements, etc.),bank accounts belonging to the company or its subsidiaries or accounting records;• Misrepresentation of information on documents;• Misappropriation of funds, supplies, or assets and embezzlement;• Theft, disappearance, or destruction of assets;• Improprieties in the handling or reporting of money or financial transactions;• Authorizing or receiving payments for goods not received or services not performed;• Authorizing or receiving payment for hours not worked;• Inappropriate use of the company’s records and disclosing confidential and proprietary information
to outside parties;• Not disclosing pertinent information during an audit or investigation just because the question was
not asked.
• Abusing the corporate travel booking system;• Travel & Entertainment expense fraud;• Expensing gift cards for personal use;
• Misusing a purchasing card
• Altering payroll records• Pocketing maintenance fees
• Exploiting weak controls• Falsifying recruiter fees
• Falsifying shipping labels• Falsifying productivity figures• Abusing supplier accounts• Participation in sham or fraudulent transactions;• Payment or receipt of bribes, kickbacks, or other inappropriate payment;• Billing made at the request of a customer at higher or lower than market value;• Revenue Recognition:–o Pulling forward sales in a current reporting period which actually should not be realized until asubsequent reporting period. This includes selling product in one reporting period with the intent
of it being returned for credit in a subsequent reporting period and the books and records are notadjusted to remove the revenue in the previous period; ando Merchandizing - incentivizing distributors (through price discounts, extended payment terms orother concessions) to purchase more product than they need to satisfy retail customer demand withthe purpose of creating a false impression that the Company is meeting certain objectives, which
could be considered channel stuffing or merchandising.

Dentsply Sirona recognizes the risk that fraud of any type represents to the company and ourshareholders and takes the appropriate steps to prevent fraud before it occurs, detect fraud which may
be occurring and thoroughly investigates suspected fraud. If and when fraud is discovered, Dentsply
Sirona responds swiftly and aggressively to identify the person or persons responsible, assures that theschemes are fully understood and terminated, recover the misappropriated funds and will work with local
and U.S. federal agencies in legal prosecution of the responsible individuals.

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Anti-Trust

18

Anti-trust or anti-competition laws prohibit agreements or understandings between competitors that
undermine competition and regulate the behavior of dominant companies within an industry.
Additionally, anti-trust laws require prior review and possible clearance for mergers, acquisitions andcertain other transactions, in order to prevent transactions that would substantially reduce competition.
These laws are complex, global in reach, and can operate differently in each particular situation. It isessential that you involve a member of the Dentsply Sirona Legal department early in the process ofdeveloping new commercial initiatives with a competitor given the many uncertainties that arise in theapplication of these laws.

Conflict of Interest
Conflicts of interest arise when activities or interests of an employee call into question his/her actions or
judgement and objectivity in their professional capacity at Dentsply Sirona. On the job or in your freetime, nothing you do should conflict with your responsibilities to Dentsply Sirona. No activity at work or athome should hurt Dentsply Sirona’s reputation or business. Do not misuse or use for personal gain
Dentsply Sirona resources, intellectual property, time or facilities. Misusing Dentsply Sirona resources or
influence is also prohibited. Even when nothing wrong is intended, the appearance of a conflict can havenegative effects. It is crucial to consider how your actions might appear, and to avoid the perception of aconflict of interest.
Do not take any opportunities for yourself in which Dentsply Sirona might have an interest, particularly if you
discover them using your Dentsply Sirona position, information or property.
Get approval from Dentsply Sirona’s Legal organization before accepting positions with an outsidebusiness while you are a Dentsply Sirona employee.
Get your manager’s approval when accepting not-for-profit board positions, particularly if the organization
has a Dentsply Sirona relationship or might expect Dentsply Sirona financial or other support.

Personal Relationships
Dentsply Sirona recognizes there will be instances when the employment of relatives may occur in theworkplace. The Company does not discriminate in favor of or in opposition of the employment ofrelatives; however, business decisions may become difficult if you conduct business with a family member.
These relationships may result in a conflict of interest, create situations that may perpetuate favoritism andcause disruption within the organization.
Furthermore, while the Company does not prohibit personal relationships, if you are in a romantic
relationship with another employee, you may not supervise or otherwise manage your partner. To ensure
any potential conflicts of interest are resolved, disclosure of familial or close personal relationships tohuman resources is required. Contact human resources or review the Personal Relationships and AntiNepotism Policy for more information.

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Data Privacy, Protection& Cyber Security
Many countries across the world regulate the collection and use of personal data (which can include
individuals’ names, contact details and health status). It is our responsibility as a company to ensure thesafety and confidentiality of the personal data that we process of e.g. our customers, business partners,
employees and patients – in other words; the personal data of whomever we have been entrusted.
Dentsply Sirona is committed tocollecting, using, retaining and disclosing
personal data in a fair, transparent andsecure way. We must consider theprivacy risks before we collect, use,
retain, or disclose personal data, such as
in a new system or part of a project. We
must be open with individuals about
how we use their personal data, withwhom we share it and where it may be
sent. Once we no longer have a businessneed for the personal data, it must be destroyed in accordance with our legal obligations and company
retention policies.
Always keep in mind that we only collect personal data that we really need and remember to use thepersonal data solely for the purpose of which is what originally collected. Personal data has to be kept
safe at all times, so it does not fall into the wrong hands and be particularly careful when collecting andprocessing personal data of sensitive nature (such as patient data and health related data of employees).
Adhering to our information security and cybersecurity practices is an ethical obligation, and we must use
company email, applications, and accounts responsibly. Always strive to ensure that our processes toprotect our networks, computers, programs, and data from unauthorized access are followed. Not doing
so could lead to fines and sanctions against the Company.

01 August 2023

20Transparency
The United States Patient Protection and Affordable Health Care Act (the “Affordable
Care Act”) includes a section entitled “Transparency Reports and Reporting of Physician Ownership or
Investment Interests,” also referred to as Physician Payments Sunshine Act (PPSA). To facilitate compliancewith the PPSA portion of the Affordable Care Act, the federal “Open Payments Program” was enacted(“Open Payments”). Open Payments is intended to increase transparency with respect to financial
relationships that physicians, dentists, and teaching hospitals have with drug and medical device
manufacturers. Open Payments requires pharmaceutical, medical device, biological and medical supply
manufacturers to report to the Centers for Medicare & Medicaid Services any “payment or other transfer
of value” to “covered recipients”.
The United States is not alone in its transparency reporting requirements and several countries go beyond
these regulations and require pre-approval of business relationships such as speaker agreements andconsultancy arrangements between medical device manufacturers and health-care professionals.

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Environmental Health &Safety21

Protecting the health and safety of our people and operating in an environmentally responsible manner is acornerstone of our business. Dentsply Sirona views this simply as “the right thing to do – for our employees,
partner communities, patients and customers.”
Our Leadership is committed to support and achieve continuous EHS improvement through a culture ofaccountability and operational discipline at all levels. We strive to firmly integrate this focus into all our
global operations.
Our EHS program is established to:• Educate, motivate and support our people to operate safely and protect our environment,• Fulfill all applicable EHS regulatory compliance requirements, and• Support the sustainability of our customers, our patients, our communities and our company.
Dentsply Sirona does not tolerate acts or threats of violence. If you see or hear of possible threats of violence
it is important that you speak up immediately by contacting your manager, a member of the HR and/or Legal
departments, or the Dentsply Sirona Ethics Hotline.
The company is committed to providing a safe and productive work environment free from impairment
involving drugs and alcohol. Alcohol and drug use impair your ability to effectively perform your duties andpose a threat to the health, safety, and security of everyone and the Company’s assets. Possession, use, or
distribution of illegal drugs while performing work activities on behalf of the Company is strictly prohibited.
Use or distribution of alcohol is also prohibited, except in situations where alcohol is authorized or otherwise
provided at a company sponsored event or meeting. In those situations, lawful and modest consumption of
alcoholic beverages is permitted. Employees must comply with all laws, company policies, and principles andalways exercise good judgment. Individuals who do not adhere to the law and company policies or engage
in excessive consumption of alcohol (even if lawful) may be subject to disciplinary action up to and including
termination of employment.

Additional information can be found in the Substance Abuse and Drug

Screening Policy.

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Dentsply Sirona in the World
Community

22

Dentsply Sirona actively supports fair employment practices which do more than keep
Dentsply Sirona in compliance with applicable labor and employment laws, they
contribute to a culture of mutual respect and unquestionable integrity. Dentsply
Sirona Inc. is an equal opportunity employer.
Dentsply Sirona’s commitment to equal opportunity employment applies to all decisions about
recruitment, hiring, compensation, benefits, transfers, promotions, training, social programs, redundancies
and any other conditions of employment.
Dentsply Sirona does not tolerate harassment, bullying or any mistreatment by or of workers, guests, clients,
or vendors in the workplace or in a work-related situation, especially on the basis of sex, race, color,
nationality, ethnic or national origin, ancestry, citizenship, religion (or belief, where applicable), age, physical ormental disability, medical condition, sexual orientation, veteran status, marital status, genetic information or
characteristics (or those of a family member), or any other category protected under applicable federal, state,
or local law. If you suspectharassment, discrimination, or
retaliation (as described in our
Prohibition on Harassment Policy)
has occurred, you are encouraged,
and managers are required, topromptly provide a written or oral
complaint to an HR Business
Partner, Corporate HR or to ourWhistleblower Hotline. Please refer
to our full Prohibition on
Harassment Policy.
In line with the UN International Labor Organization’s declaration on Fundamental Principles and Rights at
Work, we support freedom of association and the effective recognition of the right to collective bargaining,
the elimination of forced or compulsory labor, the abolition of child labor and the elimination of
discrimination in respect of employment. We are committed to supporting the UK Modern Slavery Act of2015, the California Transparency in Supply Chain Act, the Australian Modern Slavery Act, the New South
Wales Modern Slavery Act, and the German Supply Chain Act along with the global effort to combat slavery
and human trafficking.

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23

Dentsply Sirona reserves the right to make updates to the Code of Ethics and Business Conduct asneeded to reflect changes in local and international laws or Dentsply Sirona policies except whereprohibited by law or contractual rights.

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