Exhibit 19.1

Savara Inc.

Insider Trading and Disclosure Policy

This Insider Trading and Disclosure Policy (this “Policy”) sets forth the policy of Savara Inc. (f/k/a Mast Therapeutics, Inc.) (the “Company”) regarding transactions by certain individuals and entities involving securities of the Company and, where applicable, the disclosure of such transactions. All references to the “Company” in this Policy include any subsidiaries of Savara Inc.

Persons Subject to the Policy

This Policy applies to all officers and employees of the Company, all members of the Company’s Board of Directors (the “Board”), and any consultants, advisors or contractors to the Company that the Company designates as subject to this Policy (collectively, these persons are referred to as “Covered Persons”). In addition, Covered Persons will be held responsible for actions of family members and other individuals who reside with them, as well as family members and entities whose transactions in Company securities are directed by the Covered Person or subject to their influence or control, as described below in paragraphs 9 and 10 under “General Policies.”

General Statement

Unlawful insider trading occurs when a person uses material nonpublic information obtained through his or her employment or other involvement with the Company to make decisions to purchase, sell or otherwise trade in the Company’s securities or to provide that information to persons outside of the Company who trade in the Company’s securities on the basis of that information. The prohibitions against insider trading apply to trading, tipping and making recommendations to trade if the information involved is material and nonpublic and the person using or disclosing the information owes a duty of trust or confidence to the Company or to the person who is the source of the information.

Nonpublic information concerning the Company or its business is the property of the Company. The Company prohibits the unauthorized use or disclosure of any such nonpublic information, whether acquired in the workplace as a result of an individual’s employment or other relationship with the Company, including the unauthorized use or disclosure of any information concerning the Company or its business in connection with securities transactions.

Compliance Officer

Dave Lowrance, the Company’s Chief Financial Officer, shall serve as the Compliance Officer with respect to this Policy. In his absence, another employee designated by the Company’s Chief Executive Officer or Chief Financial Officer shall be responsible for administration of this Policy.

Individual Responsibility

Covered Persons have legal obligations to maintain the confidentiality of information about the Company and to not engage in transactions in Company securities while aware of material nonpublic information. Each individual is responsible for making sure he or she understands and complies with this Policy, and that any family member, household member or entity whose transactions are subject to this Policy, as discussed below, also complies with this Policy. This Policy is intended to assist you in complying with laws against insider trading, but, ultimately, it is your individual responsibility to comply with those laws. In all cases, the responsibility for determining whether you are aware of material nonpublic information rests with you and any action on the part of the Company, the Compliance Officer or any other employee or director pursuant to this Policy or otherwise does not in any way constitute legal advice or insulate you from liability under applicable securities laws. You could be subject to disciplinary action by the Company (up to and including termination of your employment or other relationship with the Company for cause) and severe legal penalties (including fines and imprisonment) if you engage in conduct prohibited by this Policy or applicable securities laws, as described in more detail below under “Consequences of Violations.”

General Policies

The following are the general policies underlying this Policy that apply to all Covered Persons. Officers, members of the Board and other individuals designated by the Company from time to time are subject to certain additional policies and restrictions. You will be notified if you are subject to these additional policies and restrictions and provided a copy of them.

The terms “material information,” “nonpublic information,” “blackout period” and “trading window” are defined below under “Definitions Used in this Policy.”

1. Do not trade while in possession of material nonpublic information. From time to time you may come into possession of material nonpublic information concerning the Company. You may not engage in transactions involving securities of the Company at any time while you are aware of material nonpublic information concerning the Company (whether during a “trading window” or at any other time). You must wait to engage in any such transactions until the material information has been public for at least two (2) full trading days (a trading day is a day on which the stock markets generally are open). In order to ensure compliance with this policy, you are required contact the Compliance Officer to pre-clear any such proposed transaction.

2. Do not trade during “blackout periods.” The Company prohibits all persons to which this Policy applies from engaging in transactions during blackout periods (whether regularly-scheduled blackout periods, or special blackout periods that may be implemented from time to time). It is your responsibility to know when the Company’s regularly-scheduled blackout periods begin and end, regardless of whether the Company typically notifies you when a blackout period begins or ends. If you are informed that the Company has implemented a special blackout period, you may not disclose that fact to anyone, including family members, friends and brokers, other than those family members, household members and entities whose transactions in Company securities would be attributed to you under this Policy. You should treat the imposition of a special blackout period as material nonpublic information concerning the Company.

Remember to cancel any “limit” orders or other pending transactions you have in place during a blackout period (unless the orders were made pursuant to an approved Rule 10b5-1(c) trading program – see “Exceptions for Blind Trusts and Pre-Arranged Trading Programs” below under “Exceptions to General Policies”).

Under very limited circumstances, a Covered Person may be permitted to trade during a regularly-scheduled blackout period, but only if the Covered Person does not in fact possess material nonpublic information and the Compliance Officer has pre-cleared the transaction with the approval of the Company’s Chief Executive Officer. Covered Persons who wish to trade during a regularly-scheduled blackout period must contact the Compliance Officer for approval and follow the pre-clearance procedures set forth below.

3. Do not give material nonpublic information to others. Do not disclose material nonpublic information to persons within the Company whose jobs do not require them to have that information, or to persons outside of the Company, including, but not limited to, family members, friends, business associates, investors and consultants, unless any such disclosure is (a) made in accordance with a confidentiality agreement approved by the Company’s Chief Financial Officer, (b) otherwise in accordance with the Company’s policies regarding the protection or authorized external disclosure of the Company’s confidential information, or (c) reasonably necessary to ensure that transactions in Company securities by those family members, household members and entities for which you are responsible under this Policy comply with this Policy.

Providing material nonpublic information to outsiders may subject you to insider trading liability for “tipping.” In addition, if you disclose any nonpublic information about the Company (other than in accordance with a confidentiality agreement approved by the Company’s Chief Financial Officer or otherwise in accordance with the Company’s policies regarding the protection or authorized external disclosure of the Company’s confidential information), even if that information is not material, you may be in breach of your confidentiality obligations to the Company.

4. Do not recommend the purchase or sale of Company securities. To avoid the appearance of impropriety and unlawful “tipping,” you should refrain from making recommendations and expressing opinions about engaging in transactions involving the Company’s securities under any circumstances.

5. Do not discuss Company information with the press, analysts or other persons outside of the Company. The announcement of information concerning the Company is regulated by Company policy (separate from this Policy) and may only be made by persons specifically authorized by the Company to make such announcements. Laws and regulations govern the nature and timing of such announcements to outsiders or the public and unauthorized disclosure could result in substantial liability for you, the Company and its management. If you receive inquiries about the Company from anyone outside the Company, you should follow the procedures set forth in the Company’s Information Disclosure Policy or notify the Compliance Officer.

6. Do not use material nonpublic information to trade in other public companies’ securities. If you become aware of material nonpublic information about a publicly traded company with which the Company does business (including a customer, vendor, supplier or other business partner), you may not trade in that company’s securities until that information becomes public or no longer material. Any such transaction may result not only in violations of this Policy and securities laws, but also breach of confidentiality agreements with the Company and the third party.

7. Do not engage in speculative transactions involving the Company’s securities. Don’t engage in any transactions that suggest you are speculating in the Company’s securities (that is, that you are trying to profit in short-term movements, either increases or decreases, in the price of the Company’s securities). You may not engage in any short sale, “sale against the box” or any equivalent transaction involving the Company’s securities (or the securities of any of the Company’s customers, vendors, suppliers or other business partners). A “short sale” involves selling securities that you borrow with the expectation that the price will go down so you can buy the shares at a lower price before you have to return them.

In addition, the Company prohibits you from engaging in hedging transactions involving the Company’s securities, such as “cashless” collars, forward sales, equity swaps and other similar arrangements.

Finally, the Company prohibits you from hypothecating or pledging Company securities to secure a loan and that you not purchase Company securities “on margin” (that is, borrow funds to purchase securities, including in connection with exercising any Company stock options). Securities hypothecated or pledged as collateral for a loan may be sold in foreclosure if the borrower defaults on the loan. Similarly, securities held in a margin account as collateral for a margin loan may be sold by the broker without the customer’s consent if the customer fails to meet a margin call. Because a foreclosure sale or margin sale may occur at a time when you are aware of material nonpublic information or otherwise not permitted to trade in Company securities, the Company prohibits these transactions.

8. Make sure close family members and anyone residing in your household do not violate this Policy. This Policy is intended to prevent the appearance of unlawful insider trading as well as actual unlawful insider trading. Insider trading cases pursued by federal and state authorities frequently involve close family members of a company insider alleged to have been tipped by the insider. In addition, under federal securities laws, certain close family members who engage in transactions in company securities may be found liable of unlawful insider trading regardless of the insider’s liability for tipping them. To help protect the Company and its directors, officers and employees, under this Policy, transactions involving Company securities by any family member who resides with you, anyone else who resides with you, and any family member (including your spouse or domestic partner, children (including children away at college), grandchildren, parents, grandparents, siblings, and any such relationship that arises through marriage or by adoption) who does not reside with you but whose transactions in Company securities are directed by you or are subject to your influence or control, such as a parent, sibling or child who consults with you before trading in Company securities (collectively referred to as “Family Members”) will be treated as if they were transactions by you. Therefore, you should make your Family Members aware of this Policy and the need to confer with you before they trade in Company securities. This Policy does not, however, apply to personal securities transactions of Family Members where the purchase or sale decision is made by a third party not controlled or influenced by or related to you or your Family Members. Please contact the Compliance Officer if you have questions regarding the application of this Policy to Family Members, including whether the above exception is available.

9. Make sure any entity that you or your Family Members influence or control does not violate this Policy. Transactions involving Company securities by any entity (such as a corporation, partnership or trust) that you or your Family Members influence or control (collectively referred to as “Controlled Entities”) will be treated as if they are transactions by you. Therefore, you should take steps to ensure that Controlled Entities do not engage in any transaction that would violate this Policy if you engaged in such transaction directly. An exception to this general policy may be available in cases of Controlled Entities where you or your Family Members have delegated investment control to an

independent third party, such as an institutional or professional trustee, and you do not share information concerning the Company with such third party. See “Exceptions for Blind Trusts and Pre-Arranged Trading Programs” under “Exceptions to General Policies” below for additional information. Please contact the Compliance Officer to discuss the application of this Policy and the availability of any exceptions to transactions by Controlled Entities.

10. Make sure you do not violate this Policy while conducting Internet-based activities. This Policy applies regardless of the means by which you trade securities or communicate information. Any verbal or written statement that would be prohibited under the law or under this Policy is equally prohibited if made on the Internet, including through social media. If you, your Family Members or Controlled Entities engage in any Internet-based activities, such as blogging, microblogging (e.g., Twitter), social networking (e.g., Facebook, LinkedIn), or participating in online “chat rooms” and message boards, take care to ensure that you, your Family Members and your Controlled Entities do not violate this Policy while conducting those activities.

Exceptions to the General Policies

The following are exceptions to the foregoing general policies:

1. Exceptions for Transactions under Company Plans

a. Stock Option Exercises. This Policy does not apply to the exercise of an employee stock option acquired pursuant to the Company’s plans, or to the exercise of a tax withholding right pursuant to which a person has elected to have the Company withhold shares subject to an option to satisfy tax withholding requirements. This Policy does apply, however, to any sale of stock as part of a broker-assisted cashless exercise of an option, or any other market sale for the purpose of generating the cash needed to pay the exercise price of an option. In addition, any subsequent sale of shares acquired upon exercise of a stock option is subject to this Policy.

b. Restricted Stock Awards. This Policy does not apply to the vesting of restricted stock, or the exercise of a tax withholding right pursuant to which you elect to have the Company withhold shares of stock to satisfy tax withholding requirements upon the vesting of any restricted stock. The Policy does apply, however, to any disposition of restricted stock other than to the Company.

c. Employee Stock Purchase Plan. Although the Company does not currently have an employee stock purchase plan, this Policy does not apply to purchases of Company securities in any employee stock purchase plan resulting from your periodic contribution of money to the Company plan pursuant to the election you made at the time of your enrollment in the plan. This Policy also does not apply to purchases of Company securities resulting from lump sum contributions to the plan, provided that you elected to participate by lump sum payment at the beginning of the applicable enrollment period. This Policy does apply, however, to your election to participate in the plan for any enrollment period, and to your sales of Company securities purchased pursuant to the plan.

d. 401(k) Plan. Although the Company does not currently have a 401(k) plan that permits the purchase of the Company’s common stock, this Policy does not apply to purchases of Company securities in the Company’s 401(k) plan resulting from your periodic contribution of money to the plan pursuant to your payroll deduction election. This Policy does apply, however, to certain elections you may make under the 401(k) plan, including: (a) an election to increase or decrease the percentage of your periodic contributions that will be allocated to the Company stock fund, if any; (b) an election to make an intra-plan transfer of an existing account balance into or out of the Company stock fund, if any; (c) an election to borrow money against your 401(k) plan account if the loan will result in a liquidation of some or all of the balance of your Company stock fund, if any; and (d) an election to pre-pay a plan loan if the pre-payment will result in allocation of loan proceeds to the Company stock fund, if any.

2. Exceptions for Blind Trusts and Pre-Arranged Trading Programs

Rule 10b5-1(c) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), provides an affirmative defense against insider trading liability under federal securities laws for a transaction effected pursuant to “blind trusts” (generally, trusts or other arrangements in which investment control has been completely delegated to a third party, such as an institutional or professional trustee) or pursuant to a written plan, or a binding contract or instruction, entered into in good faith at a time when the relevant individual was not aware of any material nonpublic

information, even though the transaction in question may occur at a time when the person is aware of material nonpublic information.

If you wish to enter into a blind trust arrangement or a pre-arranged trading program, you must notify the Compliance Officer. The Compliance Officer will review proposed arrangements to determine whether they are consistent with the intent of this Policy and Rule 10b5-1. The Company reserves the right to bar any transactions in Company securities, even those pursuant to arrangements previously approved, if the Company determines that such a bar is in the best interests of the Company.

3. Exceptions for Transactions Not Involving a Purchase or Sale

a. Bona fide gifts. Bona fide gifts by you of Company securities are not transactions subject to this Policy, unless you have reason to believe that the donee intends to sell the securities while you are aware of material nonpublic information or during a blackout period; however, gift transactions involving Company securities are subject to pre-clearance by the Compliance Officer.

b. Transactions in mutual funds. Transactions in mutual funds that are invested in Company securities are not transactions subject to this Policy.

Pre-Clearance Procedures

A request for pre-clearance should be submitted to the Compliance Officer at least three (3) business days in advance of a proposed transaction covered by this Policy to allow sufficient time for pre-clearance procedures. To begin the pre-clearance process, complete and submit to the Compliance Officer an Application for Approval of Transactions in Company Securities in the form attached as Attachment Ato this Policy. When making a request for pre-clearance, you should carefully consider whether you may be aware of any material nonpublic information about the Company and you should describe fully those circumstances to the Compliance Officer.

The Compliance Officer is under no obligation to approve a transaction submitted for pre-clearance and may determine not to permit the proposed transaction. If you seek pre-clearance and permission to engage in the transaction is denied, you must refrain from initiating any transaction in the Company’s securities, and you should not inform any other person of the restrictions.

Each approved Application for Approval of Transactions in Company Securities is valid only until the close of markets on the third (3rd) calendar day following the date of such approval (as indicated on the application) or such other period approved by the Compliance Officer and only on the terms approved in such application (which may not be the same as the terms originally submitted in such application). Approval of a transaction may be cancelled at any time (e.g., in the event of a special blackout period). After this approved period or upon cancellation of a prior approval, transactions are again subject to the pre-clearance procedures.

The Compliance Officer’s approval of a transaction submitted for pre-clearance does not constitute legal advice, does not constitute confirmation that you do not possess material nonpublic information and does not relieve you of any of your legal obligations.

Post-Termination Transactions

If you are in possession of material nonpublic information concerning the Company or its customers, vendors, suppliers or other business partners when your employment or other relationship with the Company terminates, you may not engage in transactions based on that information until it has become public or is no longer material. If you have questions as to whether you possess material nonpublic information after your employment or other relationship with the Company has ended, you should direct such questions to the Compliance Officer.

Consequences of Violations

The penalties for “insider trading” include civil fines of up to three times the profit gained or loss avoided, and criminal fines of up to $5,000,000 for individuals, or up to $25 million for entities, and up to twenty years in jail for each violation. You can also be liable for improper transactions by any person to whom you have disclosed material nonpublic

information or made recommendations on the basis of such information as to trading in the Company’s securities (commonly referred to as “tippee liability”). The U.S. Securities and Exchange Commission (the “SEC”) has imposed large penalties even when the disclosing person did not profit from the underlying trading. The SEC, the stock exchanges and the Financial Industry Regulatory Authority (FINRA) use sophisticated electronic surveillance techniques to uncover insider trading and are very effective at detecting insider trading. Covered Persons who violate this Policy also shall be subject to disciplinary action by the Company whether or not their failure to comply with this Policy resulted in a violation of law, which action may include Company-imposed sanctions such as ineligibility for future participation in the Company’s equity incentive plans, up to termination of employment or other relationship with the Company for cause.

Definitions Used in this Policy

In addition to the quarterly blackout periods, the Company may from time to time designate other periods of time as special blackout periods (for example, if there is some development with the Company’s business that merits a suspension of trading by Company personnel). The Company may not widely announce the commencement of a special blackout period, as that information can itself be sensitive information. For this reason, it is extremely important that you adhere to the pre-clearance procedures outlined in this Policy, to the extent applicable to you or the transaction you are contemplating, to ensure that neither you, your Family Members or Controlled Entities trade during any special blackout period. You will be notified by the Compliance Officer if a special blackout period applies to you.

2. Material Information. Information should be regarded as “material” if it is likely that it would be considered important to a reasonable investor in making a decision to buy, hold or sell Company securities. There is no bright-line standard for assessing materiality; rather it is based on an assessment of all the facts and circumstances, and is often evaluated by enforcement authorities with the benefit of hindsight. Any information that could be expected to affect the Company’s stock price, whether positively or negatively, should be given particular consideration.

While it is not possible to define all categories of material information, some examples of information that are particularly sensitive and that should almost always be considered material are:

Either positive or negative information may be material. If you have any questions regarding whether information you possess is material, you should contact the Compliance Officer.

3. Nonpublic Information. Information is considered to be “nonpublic” if it has not yet been disclosed to the general public. The Company generally discloses information to the public via press release or in the periodic, quarterly and annual reports that the Company files with the SEC. The Company may set forth its information disclosure practices in a separate policy. For purposes of this Policy, information is considered “public” only after it has been publicly disclosed, through press release or otherwise per the Company’s disclosure practices, for at least two (2) full trading days. If you have any questions regarding whether any information you possess is nonpublic or has been publicly disclosed, you should contact the Compliance Officer.

4. Trading Window. The period outside a blackout period is referred to as the “trading window.” Trading windows that occur between the regularly-scheduled blackout periods can be “closed” by the imposition of a special blackout period if there are developments meriting a suspension of trading by Company personnel.

Questions

Please direct any questions you have regarding this Policy and any transactions in Company securities to Dave Lowrance, the Compliance Officer, who can be reached at (512) 614-1848 or [email protected].

Certification

All Covered Persons must certify their understanding of and intent to comply with this Policy.

Last amended: April 24, 2025

Attachment A

[Intentionally omitted. To be provided to the Securities and Exchange Commission upon request.]

SAVARA INC.

INSIDER TRADING AND DISCLOSURE POLICY

Additional Policies and Restrictions Applicable to Officers,

Directors and Others Specified by the Company

The following additional policies and restrictions (these “Additional Policies”) apply to officers, members of the Company’s Board of Directors (the “Board”) and certain other employees of and consultants, advisors and contractors to the Company, as designated from time to time by the Company. You have received these Additional Policies because either (i) you are a “Section 16” reporting person, in which case you are listed in Appendix Ato these Additional Policies, or (ii) the Company believes that, in the normal course of your performing your duties, you have or are likely to have regular access to material nonpublic information, in which case you are listed in Appendix B to these Additional Policies. You will continue to be subject to these Additional Policies until you are notified by the Compliance Officer that they no longer apply to you. The Compliance Officer is authorized to add and subtract individuals from Appendix B as appropriate in his/her discretion.

If you violate these Additional Policies, you may be subject to disciplinary action by the Company (up to and including termination of your employment or other relationship with the Company for cause). In addition, you could be in violation of applicable securities laws and subject to civil and criminal penalties, including significant fines and imprisonment. Ultimately, it is your individual responsibility to comply with the laws prohibiting insider trading. These Additional Policies are intended to assist you in complying with these laws, but you must always exercise appropriate judgment in connection with any transaction involving the Company’s securities.

Persons subject to these Additional Policies are also subject to the general policies described in the Savara Inc. Insider Trading and Disclosure Policy (the “Policy”), with the more restrictive policy applying in any case where there is a conflict. Terms used in these Additional Policies have the meanings given such terms in the Policy.

1. You must pre-clear alltransactions involving the Company’s securities. You must refrain from transactionsinvolving the Company’s securities, even during an open trading window, unlessyou first comply with the Company’s pre-clearance procedures, as set forth in the Policy. To pre-clear a transaction, you must obtain the written approval of the Compliance Officer beforeyou enter into the transaction. In pre-clearing a transaction, in addition to reviewing the substance of the proposed transaction, the Compliance Officer may consider whether it will be possible for both the individual and the Company to comply with any applicable public reporting requirements.

2. Do not engage in hedging or derivative transactions involving Company securities. You may not engage in hedging or derivative transactions involving Company securities, such as “cashless” collars, forward contracts, equity swaps or other similar or related transactions.

3. Observe the Section 16 liability rules applicable to officers, directors and 10% stockholders. Members of the Board, certain officers of the Company, and 10% stockholders must also conduct their transactions in Company securities in a manner that complies with the “short-swing” trading rules of Section 16(b) of the Exchange Act. The practical effect of these provisions is that such officers and members of the Board who purchase and sell, or sell and purchase, Company securities within a six-month period must disgorge all profits to the Company, whether or not they were aware of any material nonpublic information at the time of the transactions.

Appendix A to these Additional Procedures contains a list of the Company’s directors and officers who are subject to Section 16(b) of the Exchange Act.

4. Comply with federal securities law reporting requirements. Federal securities laws require that members of the Board, certain officers of the Company, large stockholders and affiliates of the Company publicly report transactions in Company securities (on Forms 3, 4 and 5 under Section 16, Form 144 with respect to restricted and control securities, and, in certain cases, Schedules 13D and 13G). The Company takes these reporting requirements very seriously and requires that all persons subject to public reporting of transactions in Company securities adhere to the rules applicable to these forms and schedules. Where issues arise as to whether reporting is technically required (particularly issues that turn on facts specific to the transaction and the individuals involved (e.g., transactions involving Family Members or Controlled Entities), or on unsettled issues of law), you should contact the Compliance Officer for assistance. The Company encourages its insiders to choose to comply with the spirit and not the letter of the law – in other words, to err on the side of fully and promptly reporting the transaction even if not technically required to do so.

5. Comply with trading restrictions imposed in connection with pension plan blackout periods. Federal securities laws prohibit “Section 16” officers and members of the boards of directors of public companies from trading in company securities during a “pension plan blackout period.” The Company is required to provide you with advance notice of a pension plan blackout period. If you receive such a notice, you must refrain from engaging in most transactions involving Company securities (including exercising stock options, notwithstanding the provisions contained in “Exceptions for Transactions under Company Plans” in the Policy) until the pension plan blackout period has terminated. If you engage in a prohibited transaction during a pension plan blackout period, you will be required to disgorge profits on the transaction (which may include amounts in excess of actual economic profits you realize on the transaction) to the Company.

In addition, where the Company is required to report transactions by individuals, the Company expects full and timely cooperation by the individual.

Exceptions for Emergency, Hardship or Other Special Circumstances.

In order to respond to emergency, hardship or other special circumstances, exceptions to the prohibition against trading during blackout periods are possible but will require the approval of the Compliance Officer and the Company’s Chief Executive Officer, or, if the proposed transaction involves the Company’s Chief Executive Officer, the chair of the Audit Committee of the Board.

Application of Additional Policies After Employment or Other Relationship Terminates

If you are subject to these Additional Policies and your employment or other relationship with the Company terminates while you are in possession of material nonpublic information, you will continue to be subject to the Policy, including these Additional Policies, until the close of the second (2nd) full trading day following public announcement of the material nonpublic information.

Last amended: April 24, 2025

APPENDIX A

SAVARA Inc.

PERSONS SUBJECT TO SECTION 16

[Intentionally omitted. To be provided to the Securities and Exchange Commission upon request.]

APPENDIX B

SAVARA INC.

PERSONS SUBJECT TO THE ADDITIONAL RESTRICTIONS AND PROCEDURES

OF THE INSIDER TRADING AND DISCLOSURE POLICY

AS OF April 23, 2025

[Intentionally omitted. To be provided to the Securities and Exchange Commission upon request.]