On April 11, 2025, the Board of Directors (the “Board”) of Mind Medicine (MindMed) Inc. (the “Company”) amended and restated the Company’s Code of Business Conduct & Ethics (the “Amended Code”), which applies to all directors, officers and employees. The Amended Code includes certain enhancements to the Company’s procedures to promote compliance with the Amended Code, including providing periodic compliance training as a supplement to the Amended Code and requiring that all directors, officers and employees annual certify compliance with the Amended Code. The Amended Code also reflects the Company’s commitment to take reasonable steps to monitor compliance with the Amended Code and periodically review the Amended Code, and when necessary or desirable, make recommendations to ensure (a) its continued conformance to applicable law, (b) that it meets or exceeds industry standards and (c) that any weaknesses revealed through monitoring and reporting systems are eliminated or corrected. The Amended Code also (a) expressly states that the Audit Committee of the Board shall review any potential or actual conflicts of interest involving the Company’s directors and/or officers and (b) includes additional sections that (i) describe the Company’s expectations of employees with respect to workplace safety laws and regulations, discrimination and harassment, and conduct of clinical trials and (ii) describe policies related to political contributions by employees, officers and directors, including certain pre-approval requirements.
The Amended Code was effective upon adoption by the Board and did not result in any waiver, explicit or implicit, of any provision of the Company’s previous Code of Business Conduct & Ethics. The above summary of the Amended Code is qualified in its entirety by reference to the full text of the Amended Code, which is available on the Company’s website at https://ir.mindmed.co/corporate-governance/governance-documents.