10b5-1 Survey Results from BEDC members

Thank you all for responding to the 10b5-1 questions. As always, a pleasure collaborating with you all.

1) Do you have a 10b5-1 Plan? Of the 12 responses, 5 companies had plans in place, and I
will also include what Ardea’s provisions in the responses below for a total of n=6.

2) What is the cooling off period after implementation?

• N/A or zero
• 60 days
• 0
• Typically 30 days though it can vary
• 60 days
• 0

3) Do you allow participation in the plan beyond section 16 officers and/or VP level staff?

• Open
• Open, though not aware of anyone below the VP level participating
• Open, but not practically speaking
• All participants have been VPs, but no actual restrictions
• Available to Mgmt/Sr Scientist level
• At the discretion of our Committee (CBO/CFO) to allow participation, i.e. key covered employees

4) Up to what % of total holdings do you allow participants to sell through the plan annually?

• 20%
• Up to 100% of vested shares (RSUs only)
• No restriction, but there are weekly volume limitations
• 10%
• Case-by-case basis
• No limits

5) Do you allow participants to exercise outside of the 10b5-1 plan, or do they practically
speaking?

• Legally allowable, but typically, no.
• If the 10b5-1 is in place, then no.
• Legally allowable, but typically, no.
• Yes, allowed, and it has occurred.
• Yes, participants can sell outside of the plan, the plan is for RSU’s only.
• Legally allowable, but typically, no, or at least subject to review by our legal team.