Owner: General Counsel
Effective Date: 2026-06-14
Reviewed: Annually
Collection surface: Submitted to legal@neuroscale.ai; decision recorded in the restricted SharePoint folder owned by the CFO (
Retention: 7 years from disposition
Effective Date: 2026-06-14
Reviewed: Annually
Collection surface: Submitted to legal@neuroscale.ai; decision recorded in the restricted SharePoint folder owned by the CFO (
compliance.insider/preclearance/<year>/) Retention: 7 years from disposition
Complete one form per contemplated transaction. Pre-clearance, if granted, is valid for five (5) business days unless extended or revoked in writing. Pre-clearance is a procedural check, not a substantive defense — you remain personally responsible for compliance with the no-trading and no-tipping rules. See the Insider Trading Policy → Pre-clearance.
Who must use this form
Any Access Person — directors and executive officers; members of the Finance, Legal, and Executive teams; members of Sales, Business Development, Customer Success, and Corporate Development whose roles routinely expose them to MNPI; Investor Relations; and anyone designated in writing — before any of the transactions listed in §2 below. The Access Persons list is maintained by the General Counsel in coordination with the CFO.1. Requestor
| Field | Value |
|---|---|
| Full legal name | {{requestor_name}} |
| Role / title | {{requestor_title}} |
| Access Person category | {{access_person_category}} |
| Date of request | {{request_date}} |
2. Transaction requiring pre-clearance
Select the category that applies (pre-clearance is required for all three):- Any transaction in Neuroscale securities, regardless of amount.
- A transaction in the securities of a company on the active Restricted List (a public Neuroscale customer, prospect, partner, integration counterparty, or acquisition target).
- A Rule 10b5-1 plan adoption, modification, or termination affecting either category above.
Proposed transaction details
| Field | Value |
|---|---|
| Issuer / company | {{issuer_name}} |
| Security type (stock, option, RSU, warrant, debt, derivative) | {{security_type}} |
| Side (buy / sell / gift / pledge / option exercise) | {{transaction_side}} |
| Approximate size (shares / units / notional) | {{transaction_size}} |
| Intended counterparty / venue | {{counterparty}} |
| Intended timing | {{intended_timing}} |
| Account in which the transaction will occur | {{account}} |
3. MNPI confirmation
By submitting this request, I confirm: a. I am not aware of any material non-public information (“MNPI”) about the issuer named above. I understand the definition of MNPI and the market-digestion safe harbor in the Insider Trading Policy → Definitions. b. I am not currently in a blackout period applicable to this transaction. See Insider Trading Policy → Blackout periods.For Restricted-List trades only
| Field | Value |
|---|---|
| My most recent date of contact with the issuer | {{last_contact_date}} |
| Nature of any non-public information I received from that contact | {{nonpublic_info_nature}} |
4. Requestor signature
By signing, I certify that the statements above are true and complete, that I have read the Insider Trading Policy, and that I will not transact unless and until written pre-clearance is granted and remains valid. Requestor Signature: _______________________________ Printed Name: {{requestor_name}} Title: {{requestor_title}} Date: ___________________________________5. General Counsel decision (office use)
| Field | Value |
|---|---|
| Decision | {{decision}} (Approved / Denied) |
| Conditions or notes | {{decision_notes}} |
| Pre-clearance valid through (5 business days unless extended) | {{valid_through_date}} |
If the General Counsel becomes aware of MNPI about the issuer during the validity window, this pre-clearance is revoked automatically and the requestor will be notified.
Variables
| Variable | Description |
|---|---|
{{requestor_name}} | Requestor’s full legal name |
{{requestor_title}} | Requestor’s title or role |
{{access_person_category}} | Access Person category (e.g., “Executive officer”, “Sales — public counterparty exposure”) |
{{request_date}} | Date the request is submitted (YYYY-MM-DD) |
{{issuer_name}} | Name of the company whose securities will be traded |
{{security_type}} | Type of security |
{{transaction_side}} | Buy / sell / gift / pledge / option exercise |
{{transaction_size}} | Approximate size of the transaction |
{{counterparty}} | Intended counterparty or trading venue |
{{intended_timing}} | When the transaction is expected to occur |
{{account}} | Account in which the transaction will occur |
{{last_contact_date}} | (Restricted-List only) Most recent contact date with the issuer |
{{nonpublic_info_nature}} | (Restricted-List only) Nature of any non-public information received |
{{decision}} | ”Approved” or “Denied” |
{{decision_notes}} | Conditions or notes on the decision |
{{valid_through_date}} | Last day the pre-clearance is valid |
{{gc_name}} | General Counsel’s printed name |
{{gc_title}} | General Counsel’s title |
Cross-references
- Insider Trading Policy — Covered/Access Persons, pre-clearance, blackout periods, 10b5-1 plans.
- Restricted List — public counterparties subject to pre-clearance, refreshed at least weekly.
- Insider-Trading Annual Certification — annual Access Person certification.
- Records Retention Schedule — 7-year retention of insider-trading records.
Version history
| Version | Date | Description | Author | Approved by |
|---|---|---|---|---|
| 1.0 | June 14, 2026 | Initial version | Cameron Wolfe | Ishan Jadhwani |