Optinose does not have any formal policy that requires Optinose to grant, or avoid granting, equity-based compensation at certain times. Consistent with its annual compensation cycle, the Compensation Committee and the Board of Directors have for several years granted annual equity awards to eligible executive officers and other employees in the first quarter of each year and to directors on the date of the Company’s annual meeting of stockholders in June. The timing of any equity grants to executive officers and other employees in connection with new hires, promotions or other non-routine grants and to directors in connection with their initial appointment or election to the Company’s Board of Directors is tied to the event giving rise to the award (such as an executive officer’s commencement of employment or promotion effective date). As a result, the timing of grants of equity awards, including stock options, occurs independent of the release of any material non-public information, and Optinose does not time the disclosure of material non-public information for the purpose of affecting the value of equity-based compensation.

During the year ended December 31, 2024, no stock options were granted to the named executive officers during any period beginning four business days before and ending one business day after the filing or furnishing of any Form 10-Q, Form 10-K, or Form 8-K that disclosed material non-public information.