CODE OF ETHICS AND BUSINESS CONDUCT
We are committed to quality, innovation and above all, ethical professional conduct. Our Code of Ethics and Business Conduct, as amended and restated in September 2025 (the “Code”), applies to all directors, officers and employees of the Company, including our principal executive officer, principal financial officer, principal accounting officer and controller or persons performing similar functions, and contains the general guidelines for conducting the business of the Company and its subsidiaries and affiliates.
It is the policy of the Company to conduct its business in a matter that meets the highest ethical and moral standards and to strictly comply with all laws and regulations governing its operations. The overall purpose of the Code is to promote compliance with general guidelines for conducting the business of the Company consistent with the understanding of Company personnel of the Company’s standards of ethical business practices, laws, rules and regulations. The Code includes provisions related to compliance with all laws and regulations governing its operations, compliance with Regulation FD promulgated under the Exchange Act, conduct regarding business activity (including conflicts of interest, corporate opportunities, loans to directors, officers and employees, entertainment and gifts, political contributions, insider trading and tipping, communications, acting in the best interest of the Company and non-disparagement, confidentiality, fair dealing, antitrust, accuracy of Company records and representations, record retention, environment, health and general safety matters, including the Company’s commitment to providing a safe, orderly, diverse and tolerant work environment that is free of any discrimination or harassment), conduct regarding outside activity (including responsible citizenship and political activity), conduct regarding the use and protection of the Company’s assets (including professional and personal use of the Company’s information systems and assets), waivers of the Code, administration of the Code, and encourages contact with the Company’s Corporate Compliance Officer.
All of our directors, officers and employees annually acknowledge, and are expected to be familiar with, the Code and to adhere to those principles and procedures set forth in the Code that apply to them. The Company has posted the Code, and will post any amendments to the Code, as well as any waivers that are required to be disclosed by the rules of the SEC, on the Company’s website at www.admabiologics.com.
Insider Trading Policy
The Company’s Insider Trading Policy, effective September 2025, applies to all employees, directors, and officers of the Company and its subsidiaries, among others. Under the Insider Trading Policy, transactions in puts, calls, or other derivative securities involving the Company’s equity securities, as well as hedging transactions involving the Company’s equity securities, such as collars and forward sale contracts, are prohibited. The Company believes that the Insider Trading Policy is reasonably designed to promote compliance with insider trading laws, rules and regulations, and any listing standards applicable to the Company. A copy of our Insider Trading Policy is filed with the Company’s Annual Report filed with the SEC on February 25, 2026, as Exhibit 19.1. In addition, with respect to the Company transacting in its own securities, it is the Company’s policy to comply with federal securities laws.
No Hedging Policy
The Company has no standalone policy regarding hedging the economic risks designed to hedge or offset any decrease in the market value of the Company’s common stock of equity ownership for its employees, including the executive team, or directors of the Company.
The Company’s Insider Trading Policy prohibits employees, including executive officers, and directors from engaging in transactions where such insider is aware of material non-public information. The policy also prohibits directors and executive officers from engaging in short sale transactions in the Company’s common stock.
