ANTITRUST & COMPETITION LAW COMPLIANCE POLICY

HERPTIVARIUS, LLC

EFFECTIVE DATE: DECEMBER 2025

LAST UPDATED: DECEMBER 2025

SUPREMACY; INCORPORATION; APPLICABILITY: THIS ANTITRUST & COMPETITION LAW COMPLIANCE POLICY ESTABLISHES MANDATORY STANDARDS FOR LAWFUL COMPETITION AND FAIR BUSINESS PRACTICES IN ACCORDANCE WITH APPLICABLE FEDERAL AND STATE ANTITRUST AND CONSUMER PROTECTION LAWS, INCLUDING THE SHERMAN ANTITRUST ACT, THE CLAYTON ACT, AND THE FEDERAL TRADE COMMISSION ACT. THIS POLICY APPLIES TO HERPTIVARIUS, LLC, ALL DIVISIONS, DBAS, FUTURE SUBSIDIARIES, OWNERS, OFFICERS, EMPLOYEES, CONTRACTORS, AGENTS, AND REPRESENTATIVES. THIS POLICY IS EXPRESSLY SUBORDINATE TO THE HERPTIVARIUS, LLC TERMS & CONDITIONS AND ALL APPLICABLE FEDERAL AND MICHIGAN LAW. IN THE EVENT OF ANY CONFLICT, CONTROLLING LAW AND THE TERMS & CONDITIONS SHALL GOVERN.

PURPOSE AND SCOPE: THE PURPOSE OF THIS POLICY IS TO ENSURE FULL COMPLIANCE WITH UNITED STATES ANTITRUST AND COMPETITION LAWS, PROMOTE FAIR AND OPEN MARKET COMPETITION, PREVENT UNLAWFUL OR DECEPTIVE BUSINESS PRACTICES, AND PROTECT HERPTIVARIUS, LLC FROM CIVIL, CRIMINAL, AND REGULATORY LIABILITY.

GOVERNING ANTITRUST AND COMPETITION LAWS: HERPTIVARIUS, LLC OPERATES IN COMPLIANCE WITH THE SHERMAN ANTITRUST ACT, THE CLAYTON ANTITRUST ACT, THE FEDERAL TRADE COMMISSION ACT, AND THE MICHIGAN ANTITRUST REFORM ACT, AS WELL AS ANY OTHER APPLICABLE FEDERAL, STATE, OR MUNICIPAL COMPETITION LAWS. WHERE MULTIPLE LAWS APPLY, HERPTIVARIUS, LLC SHALL COMPLY WITH THE LAW PROVIDING THE STRONGEST PROTECTION FOR FAIR COMPETITION AND CONSUMERS.

PROHIBITED ANTICOMPETITIVE CONDUCT: HERPTIVARIUS, LLC STRICTLY PROHIBITS ANY AGREEMENT, ARRANGEMENT, UNDERSTANDING, OR COORDINATED PRACTICE THAT RESTRAINS TRADE OR RESTRICTS FAIR COMPETITION. THIS INCLUDES, WITHOUT LIMITATION, PRICE FIXING OR COORDINATED PRICING, BID RIGGING OR BID SUPPRESSION, MARKET OR TERRITORY ALLOCATION, CUSTOMER ALLOCATION, GROUP BOYCOTTS OR REFUSALS TO DEAL, OUTPUT OR PRODUCTION RESTRICTIONS, AND ANY FORM OF COORDINATED CONDUCT INTENDED TO DISTORT MARKET CONDITIONS.

UNFAIR METHODS OF COMPETITION AND DECEPTIVE PRACTICES: HERPTIVARIUS, LLC STRICTLY PROHIBITS UNFAIR OR DECEPTIVE ACTS OR PRACTICES IN OR AFFECTING COMMERCE. PROHIBITED CONDUCT INCLUDES FALSE OR MISLEADING ADVERTISING, DECEPTIVE PRICING PRACTICES, FAKE SCARCITY OR SUPPLY MANIPULATION, BAIT-AND-SWITCH PRACTICES, MATERIAL MISREPRESENTATION OF GOODS OR SERVICES, AND THE SUPPRESSION, OMISSION, OR FALSIFICATION OF MATERIAL INFORMATION LIKELY TO AFFECT CONSUMER DECISIONS.

MONOPOLIZATION AND MARKET DOMINANCE: HERPTIVARIUS, LLC STRICTLY PROHIBITS MONOPOLIZATION, ATTEMPTED MONOPOLIZATION, OR CONSPIRACY TO MONOPOLIZE ANY MARKET. LAWFUL COMPETITION BASED ON INNOVATION, EFFICIENCY, QUALITY, AND SUPERIOR SERVICE IS PERMITTED AND ENCOURAGED. EXCLUSIONARY, COERCIVE, OR PREDATORY CONDUCT DESIGNED TO ELIMINATE COMPETITION OR CONTROL MARKETS IS STRICTLY PROHIBITED.

MERGERS, ACQUISITIONS, AND EXCLUSIVE ARRANGEMENTS: ANY MERGER, ACQUISITION, JOINT VENTURE, EXCLUSIVE DEALING ARRANGEMENT, TYING ARRANGEMENT, OR OTHER STRATEGIC TRANSACTION THAT COULD REASONABLY BE EXPECTED TO SUBSTANTIALLY LESSEN COMPETITION MUST BE REVIEWED FOR ANTITRUST AND CLAYTON ACT COMPLIANCE PRIOR TO EXECUTION. NO SUCH TRANSACTION MAY PROCEED WITHOUT APPROPRIATE LEGAL REVIEW WHERE REQUIRED.

COMPETITOR COMMUNICATION RESTRICTIONS: EMPLOYEES AND REPRESENTATIVES OF HERPTIVARIUS, LLC MAY NOT DISCUSS OR EXCHANGE INFORMATION WITH COMPETITORS REGARDING PRICING, COSTS, PROFIT MARGINS, MARKUPS, SALES VOLUMES, OUTPUT LEVELS, SHIPPING PRACTICES, MARKET OR CUSTOMER ALLOCATION, CUSTOMER LISTS, OR SUPPLIER RESTRICTIONS. COMMUNICATIONS WITH COMPETITORS ARE PERMITTED ONLY FOR LEGITIMATE, LAWFUL PURPOSES, SUCH AS PROPERLY CONDUCTED TRADE ASSOCIATION ACTIVITIES THAT FULLY COMPLY WITH ANTITRUST LAW.

INDEPENDENT BUSINESS JUDGMENT: ALL PRICING, PRODUCTION, SUPPLY, SHIPPING, MARKETING, AND CUSTOMER SELECTION DECISIONS MUST BE MADE INDEPENDENTLY BY HERPTIVARIUS, LLC AND WITHOUT CONSULTATION, COORDINATION, OR AGREEMENT WITH COMPETITORS.

WHISTLEBLOWER AND NON-RETALIATION PROTECTION: HERPTIVARIUS, LLC STRICTLY PROHIBITS RETALIATION AGAINST ANY INDIVIDUAL WHO, IN GOOD FAITH, REPORTS SUSPECTED ANTITRUST OR COMPETITION LAW VIOLATIONS OR WHO COOPERATES WITH ANY INVESTIGATION OR INQUIRY BY THE FEDERAL TRADE COMMISSION, THE DEPARTMENT OF JUSTICE, OR ANY STATE OR LOCAL REGULATORY AUTHORITY.

REPORTING AND INVESTIGATION: ALL SUSPECTED ANTITRUST OR COMPETITION LAW CONCERNS MUST BE REPORTED PROMPTLY TO LEGAL@HERPTIVARIUS.COM. HERPTIVARIUS, LLC WILL INVESTIGATE ALL REPORTS IN A TIMELY, CONFIDENTIAL, AND PROFESSIONAL MANNER CONSISTENT WITH APPLICABLE LAW.

ENFORCEMENT AND DISCIPLINE: VIOLATIONS OF THIS POLICY OR APPLICABLE ANTITRUST LAW MAY RESULT IN DISCIPLINARY ACTION UP TO AND INCLUDING TERMINATION OF EMPLOYMENT OR CONTRACTUAL RELATIONSHIPS, CIVIL LIABILITY, CRIMINAL PENALTIES, REGULATORY ENFORCEMENT ACTIONS, AND PERMANENT DISQUALIFICATION FROM FUTURE DEALINGS WITH HERPTIVARIUS, LLC.

NO CONTRACTUAL RIGHTS CREATED: NOTHING IN THIS POLICY CREATES A CONTRACT OF EMPLOYMENT, GUARANTEE OF CONTINUED ENGAGEMENT, OR MODIFICATION OF ANY AT-WILL EMPLOYMENT OR CONTRACTUAL RELATIONSHIP.

POLICY REVIEW AND MODIFICATION AUTHORITY: THIS POLICY SHALL BE REVIEWED PERIODICALLY AND UPDATED AS NECESSARY TO REFLECT CHANGES IN LAW, REGULATORY GUIDANCE, OR BUSINESS OPERATIONS. HERPTIVARIUS, LLC RESERVES THE UNRESTRICTED RIGHT TO MODIFY THIS POLICY AT ANY TIME. CONTINUED ASSOCIATION WITH OR ENGAGEMENT BY HERPTIVARIUS, LLC CONSTITUTES ACCEPTANCE OF ANY REVISIONS.