ORTHO MOLECULAR PRODUCTS UNILATERAL MINIMUM ADVERTISED PRICE (MAP) POLICY

Effective Date: August 22, 2025

There are certain advertising practices that undermine the reputation, brand, goodwill, and premium image of Ortho Molecular Products (the “Company”) products with the Company’s target patient population and discourage our licensed health care resellers from investing in our products and providing the best possible service and support to patients. To protect the integrity of our brand, the Company has unilaterally adopted and implemented this Unilateral Minimum Advertised Price Policy (the “MAP Policy”), which applies to all licensed health care resellers (collectively, “Resellers”), who advertise the Covered Products (as defined below) to patients located in the United States.

The MAP Policy is effective August 22, 2025 and supersedes all of the Company’s prior policies or representations regarding minimum advertised prices or minimum resale prices for the Covered Products applicable to Resellers.

The “minimum advertised price” (“MAP”) is the lowest price at which the Covered Products may be advertised. The Company is solely responsible for (a) establishing the MAP for each Covered Product and (b) communicating the MAP Policy to all Resellers (including via directing any distributors to pass down the MAP Policy to their resellers). The Company will, from time to time, publish a MAP Schedule and make the MAP Schedule available to all Resellers. The MAP Policy applies to advertisements of the products on the MAP Schedule (“Covered Products”). The MAP Schedule may be amended or adjusted by the Company at any time in its sole discretion. Resellers are responsible for reviewing the current MAP Schedule, but the Company will work to notify Resellers promptly when updates are made to it. Advertising a price less than the MAP is a violation of the MAP Policy. The MAP Schedule is included as Exhibit A to this MAP Policy.

The MAP Policy applies to all advertisements of Covered Products in any and all media, including, but not limited to, flyers, brochures, posters, coupons, mailers, inserts, newspapers, magazines, catalogs, mail order catalogs, email, newsletters, email solicitations, telephone solicitations, websites, blogs, social media, affiliate marketing networks/comparison shopping engines, Reseller-initiated text messages or emails to customers or prospective customers, mobile/smart phone applications, banner ads, online product ads, paid search ads, pay-per-click ads, display ads, mobile ads, product listing ads, sponsored links, television, radio, billboards, and public signage.

This MAP Policy applies only to advertised prices and does not apply to the price at which the Covered Products are actually sold or offered for sale to an individual patient within Resellers’ clinic locations. The MAP Policy also does not apply to pricing information displayed at the price displayed for a Covered Product once it has been placed in a customer’s virtual “shopping cart.”

Please note that pricing information at the in-cart or subsequent checkout stages must be obscured technically so that it is not retrievable by shopping and pricing engines and not displayed on search page results within the Reseller’s own website.

While Resellers remain free to advertise and sell all of Company’s products (including the Covered Products) at any prices they choose, it is a violation of this MAP Policy for a Reseller to advertise any Covered Product at a price lower than the MAP unless otherwise set forth herein.

Direct or indirect attempts to circumvent this MAP Policy violate this MAP Policy. The following non-exclusive list of advertisements is contrary to the MAP Policy:

• The inclusion in advertising of free or discounted products (whether made by the Company or another manufacturer) with a Covered Product, if such inclusion has the effect of discounting the advertised price of the Covered Product below the MAP;
• Discounts, coupons, rebates, and other promotions that lower the advertised price below the MAP, including through use of a storewide sale, category-wide sale, website-wide sale, promotional code, or other similar provision that can be applied to the Covered Products;
• Any strike-through or other alteration of the advertised pricing information of a Covered Product suggesting a price lower than the MAP;
• Permitting any third party to alter the advertised price for any Covered Product; and
• With respect to any Covered Product, any advertisement by any Reseller that “they have the lowest prices,” that they “will meet or beat any competitor’s price,” or that the price is “too low to show.”

Notwithstanding the prior advertisements that constitute violations, it is not a violation to advertise the following:

• That consumers may “call for a price” or phrases of similar import or meaning, so long as no price is listed and no automated call, text message, or bounce-back email is used in response;
• Advertisements such as “add to cart for price,” or other similar phrases are permissible, provided the ultimate price is not displayed in the advertisement itself;
• A free or reduced-price shipping advertisement, as long as such offer applies to all or almost all other products offered by the Reseller in the same product category;
• “Subscribe and Save,” “Auto-ship and Save,” “Repeat Delivery,” or other subscription or auto-replenishment loyalty discount programs which result in a Covered Product being advertised at a price lower than the MAP, provided that such programs do not advertise a discount of more than ten percent (10%) below the Covered Product’s MAP;
• Advertisements of discounts triggered by reaching certain quantity levels of products (including at least one Covered Product) for a single proposed purchase, provided such multi-item discount, when pro-rated among the products included in the purchase, does not result in an advertised price for the Covered Product(s) more than ten percent (10%) below the Covered Product’s MAP; and
• A coupon or coupon code that can be applied to the first-time purchase of a Covered Product, provided that such coupon or coupon code does not provide a discount of more than fifteen percent (15%) below the MAP.

The MAP Policy does not establish maximum advertised prices. Covered Products may be offered at any price in excess of the MAP.

This MAP Policy is not an agreement between the Company and any other entity. The Company does not seek and will not accept any promise or assurance of compliance with this MAP Policy from any Reseller or other party, and each Reseller must independently choose whether to comply with this MAP Policy.

This MAP Policy is not negotiable and will not be altered for any individual Reseller. This MAP Policy is solely within the Company’s discretion and authority acting through the duly authorized managers of the Company. No employee or sales representative of the Company has any authority to discuss, interpret, modify or grant exceptions to this MAP Policy; to solicit or obtain the agreement of any person or entity to comply with this MAP Policy; or to otherwise discuss any aspect of this MAP Policy w...

All questions about this MAP Policy should be in writing and directed via U.S. Mail to:

The MAP Policy Administrator will respond only in writing; no oral communications about this MAP Policy are authorized. The MAP Policy Administrator shall be solely responsible for determining whether a violation of the MAP Policy has occurred, communicating decisions to Resellers regarding the MAP Policy and receiving any communications regarding sanctions imposed under this MAP Policy. Any action taken by the Company under this MAP Policy shall be without liability to the Company.

From time to time, the Company may choose to offer special promotions on certain Covered Products. In such an event, the Company reserves the right to modify or suspend this MAP Policy in whole or in part by notifying all Resellers of the duration and nature of the change. The Company further reserves the right to adjust the MAP with respect to all or certain Covered Products at its sole discretion. Such changes shall apply equally to all Resellers.

As part of the Company’s monitoring of this MAP Policy, the Company and its partners may, from time to time, utilize a range of human and computer technologies to monitor the pricing and placement of Covered Products across the internet. This monitoring may include, without limitation, visiting the website(s) of any Reseller and/or tracking compliance with the MAP Policy by any Reseller. Any attempt by a Reseller to redirect, mask, or otherwise interfere with these monitoring efforts or any other e...

The Company will take the following actions against any Reseller that does not comply with this MAP Policy:

• First Violation: Written notice.
• Second Violation: Written notice and a ninety (90)-day shipping hold. The Company will revoke its acceptance of any pending orders, cancel any pending shipments to Reseller, and not accept any new orders from Reseller during this ninety (90)-day period. All distributors will be notified that Reseller is not authorized to purchase products during this period.
• Third Violation: Termination of business relationship and revocation of “authorized” status. The Company will revoke its acceptance of any pending orders and cancel any pending shipments to Reseller. Reseller will no longer be an “authorized” Reseller of the Company Products. All distributors will be notified that Reseller’s authorized status has been revoked.

The Company will enforce this MAP Policy in its sole discretion. Resellers have no rights to enforce this MAP Policy. Resellers are solely responsible for compliance with the MAP Policy and their affiliates’ compliance with the MAP Policy. If any location within a Reseller’s organization violates any component of the MAP Policy, sanctions will be unilaterally imposed upon the entire organization of the Reseller. The Company need not provide prior notice or issue warnings before taking any action unde...

The Company may update, revise, suspend, or otherwise modify this MAP Policy at any time in its discretion, and any modifications will be made available to all Resellers.

Distributors of the Covered Products shall supply a copy of this MAP Policy to any new or existing Resellers for their records.

This Policy is not intended to be enforced, and will not be enforced, in any state or jurisdiction in a manner that would violate that jurisdiction’s applicable laws. The Company reserves the right, in its unilateral discretion, to not enforce this Policy with respect to Resellers in any jurisdiction where the Policy may be impermissible under local law.