Owner: General Counsel (Access Persons list maintained with the CFO)
Effective Date: 2026-06-14
Reviewed: Annually
Collection surface: Vanta (signed certification); signed-PDF mirror in the restricted SharePoint folder owned by the CFO (compliance.insider/certifications/<year>/)
Retention: 7 years from disposition
Completed annually by every Access Person, and at onboarding for newly designated Access Persons. Assigned through Vanta. See the Insider Trading Policy → Training & certification.

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Certification

I, {{worker_name}}, in my capacity as {{worker_role}} and as a designated Access Person under the Insider Trading Policy, certify the following for the period {{period_start}} through {{period_end}}:
  1. I have read and understand the policy. I have read the current Insider Trading Policy, I understand my obligations as a Covered Person and as an Access Person, and I agree to continue to comply with it.
  2. No trading on MNPI. I have not traded in the securities of any company — Neuroscale or any other issuer — while aware of material non-public information (“MNPI”) about that company.
  3. No tipping. I have not disclosed MNPI to any person who was not authorized to receive it, and I have not recommended that any person trade on the basis of MNPI.
  4. Pre-clearance. For every transaction requiring pre-clearance — any transaction in Neuroscale securities, any transaction in a Restricted List security, and any 10b5-1 plan adoption, modification, or termination — I obtained written pre-clearance from the General Counsel before transacting, and I transacted only within the validity window granted.
  5. No prohibited transactions. I have not engaged in short sales, hedging, or pledging of Neuroscale securities, and I have not held Neuroscale securities in a margin account, in violation of the policy.
  6. Restricted List. I have monitored the active Restricted List before any public-company trade and have complied with the controls that apply to listed issuers.
  7. 10b5-1 plans. Any Rule 10b5-1 trading plan to which I am a party was adopted while I was not aware of MNPI, outside any blackout period, and with the General Counsel’s prior approval. (List any active plans, or state “None”: {{rule_10b5_1_plans}})
  8. Exceptions and disclosures. Except as described below, I am not aware of any conduct by me that would constitute a violation of the policy, and I have reported any suspected violations by others through an approved channel. (Describe any exceptions, or state “None”: {{exceptions}})
I understand that this certification does not insulate me from personal civil or criminal liability, and that knowingly false statements in this certification are themselves grounds for disciplinary action up to and including termination.

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Signature

Signature: _______________________________ Printed Name: {{worker_name}} Title: {{worker_role}} Date: ___________________________________

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Variables

VariableDescription
{{worker_name}}Certifier’s full legal name
{{worker_role}}Certifier’s title or role
{{period_start}}Start of the certification period (YYYY-MM-DD)
{{period_end}}End of the certification period (YYYY-MM-DD)
{{rule_10b5_1_plans}}List of active 10b5-1 plans, or “None”
{{exceptions}}Description of any exceptions or disclosures, or “None”

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Cross-references

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Version history

VersionDateDescriptionAuthorApproved by
1.0June 14, 2026Initial versionCameron WolfeIshan Jadhwani