ZIONS BANCORPORATION, NATIONAL ASSOCIATION /UT/

We have adopted insider trading policies and procedures that govern the purchase, sale, and other dispositions of our securities by directors, officers, and non-executive employees. These policies and procedures are reasonably designed to promote compliance with applicable insider trading laws, rules, and regulations, as well as relevant listing standards.

No director or officer adopted, modified, orterminated a Rule 10b5-1(c) trading arrangement during the year ended December 31, 2025. Our directors and officers participate in certain benefit plans, including our Omnibus Incentive Plan and Payshelter 401(k) and Employee Stock Ownership Plan. From time to time, they may elect to have shares withheld to satisfy tax-withholding obligations or to pay the exercise price of options granted under these plans. Such elections may be intended to satisfy the affirmative defense conditions of Rule 10b5-1 under the Exchange Act or may constitute non-Rule 10b5-1 trading arrangements as defined in Item 408(c) of Regulation S-K.