Celcuity : Code of Ethical Business Conduct for Employees

Published: 2025-06-10 13:31:05 ET CELC

Published on 06/10/2025 at 13:31

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March 2025

Dear Celcuity Associates:

It is Celcuity's Mission to extend the lives of cancer patients by developing potential first-in-class therapies. Guiding us to achieve this Mission and providing the foundation for our culture and the decisions we make are Celcuity's Core Values: Respectful, Rigorous, Responsible and Relentless. It is important for each of us to understand these Core Values and how they apply to the work we do, and the way we do the work.

Our Mission is rooted in the patients whose lives we seek

to positively impact. There are no shortcuts to achieving this Mission. No matter what role we occupy within the Company, each of us must conduct our activities in full compliance with all applicable laws, regulations, and industry guidance. We commit to maintaining the highest standards in our dealings with everyone we interact with-our fellow associates, vendors, customers, and members of the communities in which we live. At all times, we are expected to know the laws and Company policies that apply to our roles--and to perform our jobs with honesty and integrity and in a manner that puts the best interest of patients first.

This Code of Ethical Business Conduct summarizes the basic principles that apply to our business and identifies resources to help answer questions or address concerns that may arise. It is important that each of you carefully reads this Code and thoughtfully considers the information provided. Also, please remember that while we have an Ethics Hotline available to you, I want to emphasize that we have an Open Door Policy at Celcuity--associates should always feel empowered to speak up if you hear or see something that you believe is contrary to our Core Values.

Finally, I ask that each associate make a personal commitment to follow this Code of Ethical Business Conduct and all supporting policies, procedures and guidance documents which currently exist or which may be issued in the future. It is only through your diligence and commitment that we will achieve our Mission to develop first-in-class therapies that will extend the lives of the cancer patients we serve.

Brian Sullivan

Chief Executive Officer and Co-Founder

Reader's Guide to the Code of Ethical Business Conduct 4

Equal Employment Opportunity 10

Prohibition on Discrimination, Harassment & Offensive Behavior 11

Associate Safety 12

Acceptance of Gifts 13

Policy on Conflicts of Interest 14

Commitment to Our Community 15

Environment, Political Activity, Charitable Activity 15

Compliance with Laws 16

Government Healthcare Programs 17

Antitrust and Fair Competition 18

Ethical Product Promotion 19

Ethical Customer Interactions 20

Patient Safety and Product Quality 22

Insider Trading 24

Anti-corruption and Anti-bribery 25

Trade Compliance 27

Accuracy and Integrity of Company Records and Information 28

Records Management 29

Use of Company Resources 31

Protection and Management of Company Resources 31

Electronic Media Usage and Data Privacy 33

Social Media 34

Corporate Communications 36

Associate Responsibility 38

Upholding the Code of Ethical Business Conduct 39

At Celcuity, our emphases on high ethical standards and product quality are key to our success. These fundamental characteristics inspire physician, patient and regulator trust and confidence in our Company and our products, and support a culture at Celcuity that is consistent with our Core Values.

Celcuity has developed this Code of Ethical Business Conduct to reinforce these high standards. This Code will help each associate understand the Company's expectations around lawful and ethical behavior, and help ensure that we remain compliant with the laws and regulations that apply to our business.

We operate in an ever-changing business environment. The rules and regulations applicable to the pharmaceutical industry are numerous and complex. Because of this, it may be challenging to fully appreciate the legalities and implications of the decisions we make. The expectation is that we each make the best possible decisions based on our training, experience and good judgment.

While no document can provide guidance to cover every situation that an associate may encounter, this Code provides general guidelines to assist your decision-making process.

When used in conjunction with the Celcuity Associate Handbook and other Celcuity

policies and procedures, this Code will help each of us make sound decisions and act in a manner that is consistent with the requirements of our complex industry and in line with our culture of compliance.

This Code of Ethical Business Conduct applies to all Celcuity Board Members, associates and contingent workers (independent contractors and temporary employees), as well as other companies and individuals who conduct business on behalf of Celcuity.

All of us are responsible for adhering to the values and standards outlined in the Code as well as the policies and guidelines set forth in Celcuity's Associate Handbook and the Celcuity policies and procedures applicable to your role within the Company. You are also responsible for raising questions if you are uncertain about any part of this Code, and for bringing forward any actual or potential violations of this Code or any Celcuity policy or procedure.

The CEO, CFO, and other senior financial officers designated by Celcuity are subject to this Code, as well as the more particular requirements of Celcuity's Code of Ethical Business Conduct for Senior Financial Officers.

The Celcuity Code of Ethical Business Conduct functions as a reference tool. Throughout this document, you will find boxes containing FAQs and references to related resources that may provide more specific guidance. You will recognize some overlap with the Associate Handbook, and between sections within the Code. The overlap is intentional and is meant to ensure that key principles are highlighted.

Frequently asked Question:

If I report a possible violation of the Code of Ethical Business Conduct, will my job be impacted in a negative way?

Celcuity strictly prohibits any form of retaliation against an associate that, in good faith, raises a concern, reports a violation or cooperates with an investigation. The Company will take appropriate action against an associate who is found to have engaged in retaliatory behavior or actions. If you believe you have experienced retaliation due to reporting a potential violation or participating in an investigation of a potential violation, it is important that you contact Human Resources or the Legal Department to report this.

Disclaimer

Celcuity Inc. published this content on June 10, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on June 10, 2025 at 17:30 UTC.