(As required by the California Health & Safety Code section 119402)

Banner Life Sciences (“Banner”) is a rare disease pharmaceutical company committed to our Code of Business Conduct and Ethics (“the Code”) and the belief that the Code must be lived in a way that is respectful of each other, our stakeholders, and applicable laws, regulations, and industry standards. For this reason, we have developed a Comprehensive Compliance Program that includes the following elements.

Oversight & Governance

Our Board of Directors is committed to sound corporate governance principles. As part of this commitment, it has designated its Audit Committee to establish expectations for, oversee, and evaluate the effectiveness of our U.S. Compliance Program (“Compliance Program”). Banner has designated a U.S. Chief Compliance Officer (“Compliance Officer”) to implement and oversee the Compliance Program that advances a culture of integrity and upholds our values. The Compliance Officer reports on a regular basis to the Audit Committee and to the General Counsel regarding the operations of all elements of the Compliance Program, including alleged violations and remedial or disciplinary measures.

Risk Assessment

Our Compliance Program is designed to address risks particular to our business activities. We assess various dynamics, including internal and external perspectives, as appropriate, to continually update our Compliance Program in light of the risks in a changing market.

Written Standards

Our Code is designed to advance compliance with our guiding principles, applicable federal and state laws, and industry standards. The commitments in the Code also include adherence to relevant industry codes, such as the PhRMA Code on Interactions with Healthcare Professionals. Our policies and procedures flow from the Code and must be consistent with it.

As required by California Health & Safety Code section 119402, Banner has established an annual, aggregate dollar limit of $2,000.00 for certain spending on individual healthcare providers or other medical professionals licensed in the state of California. The value of meals provided in connection with business and educational discussions, and educational items, are included in this limit. This limit does not include the value of any grants for medical education or research, sponsorships, or fair market value payments for professional services. This limit may be revised from time to time by Banner in its sole discretion. This limit represents an expenditure cap and not a goal or an average expenditure amount.

Training & Communication

All Banner employees and contractors who interact with Banner U.S. business operations are trained on the Code and the policies and procedures that flow from it. Our approach to training is engaging, interactive, and inclusive of knowledge tests and certifications. Banner also periodically reviews and updates its training programs to reflect developments in standards or understandings related to our comprehensive Compliance Program.

In addition to formal training, Banner encourages ongoing communication across all levels of our company. Our colleagues and contractors are encouraged to advance our culture of learning by proactively asking questions, seeking guidance, and making recommendations for improvements to business processes, training, and resources that support the Code and the work we do. Our colleagues and contractors have direct access to Human Resources, the Legal Department, and the U.S. Compliance Officer, and may communicate questions or concerns using our Compliance Hotline/Helpline +1-877-835-5784 resources, which include options for anonymity where permitted by law.

Monitoring & Auditing

Banner’s Compliance Program regularly monitors and audits business activities to assess compliance with the Code and the policies and procedures that flow from it. Through these monitoring and auditing activities, the Compliance Program can identify potential or existing problems or areas of concern and take corrective action in an effort to prevent the recurrence of non-compliance as needed. The nature and extent of our monitoring and auditing varies due to a variety of factors, including the learnings from our risk assessment.

Reward & Remediation

Our Compliance Program is committed to a framework of personal, focused, and sustained recognition to encourage our colleagues and contractors who carry out their responsibilities as contemplated in our Code. This framework also includes features to remediate missteps and poor choices. All reports of alleged violations are investigated. We conduct fair and diligent investigation of all matters that are brought to the company’s attention and seek to ensure consistent application of our standards. In collaboration with our leadership team and under the supervision of the Board of Directors, our Compliance Program imposes remedial and disciplinary measures for violations. Such measures are determined in Banner’s sole discretion and may include counseling, re-training, oral or written reprimands, warnings, probation or suspension with or without pay, demotions, reductions in salary, termination of employment or service, and restitution, among other measures.

Annual Declaration: April 2025

Banner declares that Banner is in compliance with the Compliance Program and with California Health & Safety Code section 119402.

US-CC-2500007 | April 2025