We periodically update our Code of Ethics (the “Code”) that is applicable to all employees, officers and directors of FirstSun Capital Bancorp and its subsidiaries. On August 12, 2026, our Board of Directors approved amendments to the Code, including, among others, to (i) update, clarify and/or enhance provisions regarding conflicts of interest, corporate opportunities, fair dealing and competition, public disclosures, confidentiality, and protection and proper use of assets, (ii) add a provision that addresses anti-bribery and anti-corruption, (iii) expand who can determine a waiver of the Code for individuals who are not executive officers or directors, and (iv) update provisions related to investigations of alleged violations and enforcement of the Code. The Code was also updated to reflect various other technical, administrative or non-substantive amendments.
The foregoing description of the amendments to the Code does not purport to be complete and is qualified in its entirety by reference to the full text of the Code.