91̽

STANDARDS OF BUSINESS CONDUCT

Click here to download the Standards of Business Conduct

On June 23, 2023, the Board of Directors of 91̽oration (the “Company”) amended and restated the Company’s Standards of Business Conduct (“SOBC”). Certain provisions of the SOBC were reorganized or reworded to improve clarity and readability, or updated to provide additional resources or guidance (e.g., by updating references to specific Company policies or resources that may be relevant).

Substantive amendments reflect the following:

  • Enhanced and clarified the discussion of the responsibilities applicable to the Company’s directors, officers and employees under the SOBC;
  • Clarified the description of the Company’s rights with respect to content contained in Company systems; and
  • Added additional details regarding the Company’s insider trading policy, including clarifications as to the definition of insider trading and discussion of when an employee (including all directors and officers) of the Company may begin trading following the dissemination of material, non-public information about the Company or another company to align with the terms of the insider trading policy.

The above is only a summary of changes to the SOBC. Please refer to the full text of the SOBC, which is available by clicking the link above.