Code of Business Conduct and Ethics

On June 13, 2024, the Board of Directors of Olema Pharmaceuticals, Inc. (the “Company”) approved an amendment and restatement of the Company’s Code of Business Conduct and Ethics (the “Code”). The revisions to the Code include, among other things: clarifying classes of persons covered by and subject to the Code; providing more robust examples of potential conflicts of interest and specifying certain actions that may not constitute a conflict of interest or a waiver of the Code; specifying parties responsible for evaluating and preapproving opportunities that may be deemed to be corporate opportunities; and adding language to clarify that certain communications with certain government entities are not restricted by the Code or any other confidentiality or nondisclosure agreement entered into with the Company. In addition, technical, clarifying and non-substantive changes were made to the Code to enhance readability and clarity.

To view an amended and restated version of the Code, see Code of Business Conduct and Ethics (June 2024).