Neuromation Confirms Insider Trading Policy

The NeuroToken (“NTK”) is a utility token minted under the laws of Estonia to serve as the method of exchange on the Neuromation Platform, specifically for the purchase/sale of products and services in Artificial Intelligence.

In order to take an active role in ensuring a fair and efficient NTK, Neuromation is adopting an Insider Trading Policy (“Policy”). Neither the existence of the Policy, nor anything contained in the Policy, is intended as an admission, acknowledgement or statement of opinion that NTK are “securities” for the purposes of the laws of the United States of America, “transferable securities” for the purposes of the laws of Estonia and the European Union, or any equivalent designation for the purposes of the laws of any other nation.

Below is a non-exhaustive brief of key elements of the Neuromation Insider Trading Policy:

• “Insiders” are officers, directors, and all other employees of, or consultants, advisors or contractors to, the Company or its subsidiaries, as well as their immediate families, and members of their households.
• The Policy applies to all transactions in NTK, including any derivative instruments relating to NTK, whether or not issued by the Company.
• No Insider shall engage in transactions involving a purchase or sale of NTK during any period commencing while the Insider possesses material nonpublic information.
• No Insider shall disclose (“tip”) material nonpublic information that may be used by third parties to profit from transactions in NTK.
• No Insider shall trade NTK during company-imposed “black-out” periods.
• An Insider shall consult the company Compliance Officer before engaging in NTK transactions.
• Insiders who violate this policy are subject to severe disciplinary action by the Company and/or action by relevant regulatory authorities.

Neuromation reserves the right to update the Policy at any time without notice.