GOVERNANCE

The Code of Business Conduct and Ethics was last amended effective March 31, 2022. The areas addressed by the changes include: (i) general language & considerations to guide application of the Code, (ii) broader goal-oriented language in regards to R&D and Regulatory compliance, (iii) conflicts of interest, (iv) maintenance of corporate books, records, documents and accounts, financial integrity, public reporting, (v) gifts and entertainment, (vi) dealings with government officials, (vii) compliance with the Foreign Corrupt Practices Act, (viii) prohibition against discrimination/equal opportunity employment, (ix) health and safety guidelines, (x) protection and proper use of company assets, (xi) waivers, and (xii) compliance standards and procedures. This summary is qualified in its entirety by reference to the full text of the Code of Business Conduct and Ethics.