On November 19, 2020, our Board of Directors adopted and approved an updated Code, which applies to all of our directors, employees (including officers) and contractors, including those of our affiliates. Besides making technical, administrative and other non-substantive amendments to the Code, the updated Code (a) updates our policies with respect to compliance with laws, including laws regarding nondiscrimination, insider trading, U.S. and international regulatory matters, competition, privacy, conduct of clinical trials and compliance with government inquiries; (b) updates our policies on financial record keeping and reporting and the ability of employees to anonymously report issues and concerns regarding corporate fraud or other potential violations of law; (c) updates our policies and guidelines with respect to potential conflicts of interest, including with respect to gifts and entertainment; (d) updates our ethical business practices, including rules regarding improper payments or bribes; and (e) updates the reporting and waiver procedures under the Code and our non-retaliation policy. The foregoing summary is qualified in its entirety by reference to the Code, a copy of which is available above.