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.
Furthermore, on June 10, 2025, the Board of Directors approved an amendment and restatement of the Code with additional technical, clarifying and non-substantive changes to enhance readability and clarity.
On April 1, 2026, the Board of Directors approved an amendment and restatement of the Code. The revisions to the Code serve to, among other things, clarify record retention responsibilities for certain service providers and formalize the Code waiver process for non-executive personnel. 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 (April 2026).