GALECTO, INC.

STATEMENT OF COMPANY POLICY ON INSIDER TRADING AND DISCLOSURE

This memorandum sets forth the policy of Galecto, Inc. and its subsidiaries (collectively, the “Company”) regarding trading in the Company’s securities and the disclosure of information concerning the Company. This Statement of Company Policy on Insider Trading and Disclosure (the “Insider Trading Policy”) is designed to prevent insider trading or the appearance of impropriety, to satisfy the Company’s obligation to reasonably supervise the activities of Company personnel, and to help Company personnel avoid the severe consequences associated with violations of insider trading laws. It is your obligation to understand and comply with this Insider Trading Policy.1

This Insider Trading Policy is applicable to the Company’s directors, officers, employees, and designated consultants and contractors. The same restrictions that apply to you also apply to your spouse, significant other, child, parent or other family member, in each case, living in the same household, and to any investment fund, trust, retirement plan, partnership, corporation or other entity over which you have the ability to influence or direct investment decisions concerning securities. You are responsible for ensuring compliance with this Insider Trading Policy by all such persons affiliated with you.

All of the Company’s directors, officers, employees and designated consultants and contractors also must comply with the Company’s Special Trading Procedures for Insiders (the “Trading Procedures”)2, which supplement and shall be deemed a part of this Insider Trading Policy, except in limited circumstances where you have been notified otherwise.3 Generally, the Trading Procedures require the pre-clearance of all transactions in the Company’s securities by such persons, provided, however, that this policy shall not apply to any entity that engages in the investment of securities in the ordinary course of its business (e.g., an investment fund or partnership) if such entity has established its own insider trading controls and procedures in compliance with applicable securities laws and the relevant director, officer, employee or designated consultant, as the case may be, has informed the Company of the names of such entity or entities..

In the event that you leave our Company for any reason, insider trading laws and regulations will continue to apply to you, and you should refrain from conducting transactions or sharing information that violate such laws or regulations (or that violate your agreement with, or an obligation to, the Company).

1 Please contact Garrett Winslow, the Company’s General Counsel, who is the Compliance Officer of the Company, at if you have any questions regarding the policy

2 Please refer to the Special Trading Procedures for Insiders.

3 You should assume the Special Trading Procedures for Insiders apply to you unless you have received a written notification from the Company’s Compliance Officer that you are excepted from these procedures.

It is generally illegal for you to trade in the securities of the Company, whether for your account or for the account of another, while in the possession of material, nonpublic information about the Company. It is also generally illegal for you to communicate material, nonpublic information about the Company to others who may trade on the basis of that information. These illegal activities are commonly referred to as “insider trading.” These prohibitions also prohibit you from trading or tipping another company’s stock where you learned material, non-public information about that company because of your position with the Company.

From time to time, you may, in your capacity working for the Company, acquire material, nonpublic information regarding other companies. Our policy is that such information is subject to the same restrictions in this Policy that applies to material, nonpublic information about the Company. Accordingly, such information is confidential, should not be disclosed to any person who may take advantage of such information, and no Insider may engage in any transaction in such other companies’ securities unless the transaction has be precleared by the Compliance Officer.

Your failure to observe this Insider Trading Policy could lead to significant legal problems, including fines and/or imprisonment, and could have other serious consequences, including the termination of your employment or service relationship with the Company.

Prohibited Activities

When you know or are in possession of material, nonpublic information about the Company, whether positive or negative, you generally are prohibited from the following activities:

As noted above, these prohibitions also apply to your spouse, significant other, child, parent or other family member, in each case, living in the same household; and any investment fund, trust,

retirement plan, partnership, corporation or other entity over which you have the ability to influence or direct investment decisions concerning securities.

This Insider Trading Policy does not apply to an exercise of an employee stock option when payment of the exercise price is made in cash. The Policy does apply, however, to the use of outstanding Company securities to pay part or all of the exercise price of an option, 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.

These prohibitions continue whenever and for as long as you know or are in possession of material, nonpublic information. Remember, anyone scrutinizing your transactions will be doing so after the fact, with the benefit of hindsight. As a practical matter, before engaging in any transaction, you should carefully consider how enforcement authorities and others might view the transaction in hindsight.

Definition of Material, Nonpublic Information

This Insider Trading Policy prohibits you from trading in the Company’s securities if you are in possession of information about the Company that is both “material” and “nonpublic.” If you have a question whether certain information you are aware of is material or has been made public, you are encouraged to consult with the Compliance Officer.

What is “Material” Information?

Information about the Company is “material” if it could reasonably be expected to affect the investment or voting decisions of a stockholder or investor, or if the disclosure of the information could reasonably be expected to significantly alter the total mix of information in the marketplace about the Company. In simple terms, material information is any type of information that could reasonably be expected to affect the market price of the Company’s securities. Both positive and negative information may be material. While it is not possible to identify all information that would be deemed “material,” the following items are types of information that should be considered carefully to determine whether they are material:

The Securities and Exchange Commission (the “SEC”) has stated that there is no fixed quantitative threshold amount for determining materiality, and that even very small quantitative changes can be qualitatively material if they would result in a movement in the price of the Company’s securities.

What is “Nonpublic” Information?

Material information is “nonpublic” if it has not been disseminated in a manner making it available to investors generally. To show that information is public, it is necessary to point to some fact that establishes that the information has become publicly available, such as the filing of a report with the SEC, the distribution of a press release through a widely disseminated news or wire service, or by other means that are reasonably designed to provide broad public access. Before a person who possesses material, nonpublic information can trade, there also must be adequate time for the market as a whole to absorb the information that has been disclosed. For the purposes of this Insider Trading Policy, information will generally be considered public after the close of trading on the two full trading day following the Company’s public release of the information.

For example, if the Company announces material information of which you are aware before trading begins on a Tuesday, the first time you can buy or sell Company securities is the opening of the market on Thursday. However, if the Company announces this material information after trading begins on that Tuesday, the first time that you can buy or sell Company securities is the opening of the market on Friday.

Both the SEC and the national securities exchanges, through the Financial Industry Regulatory Authority (“FINRA”), investigate and are very effective at detecting insider trading. The SEC, together with the U.S. Attorneys, pursue insider trading violations vigorously. For instance, cases have been successfully prosecuted against trading by employees in foreign accounts, trading by family members and friends, and trading involving only a small number of shares.

The penalties for violating insider trading or tipping rules can be severe and include:

The Company and/or the supervisors of the person engaged in insider trading may also be required to pay civil penalties of up to the greater of approximately $2 million (subject to periodic inflation adjustments) or three times the profit made or loss avoided, as well as criminal penalties of up to $25,000,000, and could under certain circumstances be subject to private lawsuits.

Violation of this Insider Trading Policy or any federal or state insider trading laws may subject the person violating such policy or laws to disciplinary action by the Company up to and including termination. The Company reserves the right to determine, in its own discretion and on the basis of the information available to it, whether this Insider Trading Policy has been violated. The Company may determine that specific conduct violates this Insider Trading Policy, whether or not the conduct also violates the law. It is not necessary for the Company to await the filing or conclusion of a civil or criminal action against the alleged violator before taking disciplinary action.

The Company also has strict policies relating to safeguarding the confidentiality of its internal, proprietary information and the use of social media and other online platforms. These policies include procedures regarding identifying, marking and safeguarding confidential information and employee confidentiality agreements. You should comply with these policies at all times.

If you violate this Insider Trading Policy or any federal or state laws governing insider trading, or know of any such violation by any director, officer or employee of the Company, you must report the violation immediately to the Compliance Officer or through one of the other approved communication channels provided in our Code of Business Conduct and Ethics, which are as follows:

By e-mail to the Compliance Officer (anonymity will not be maintained if your email address identifies you; please mark your email “Confidential”);

In writing (which can be done anonymously as set forth below under “Anonymity”), addressed to the Compliance Officer and/or Chairperson of the Audit Committee, by mail to ******** (please mark complaints forwarded by mail “Confidential”);

Online at https://www.whistleblowerservices.com/galecto (which is operated by a third party, and may be done anonymously as set forth below under “Anonymity”); or

By phoning and leaving a voicemail to a hotline, which is operated by a third party. The voicemail can be reached at ********* and messages can be left anonymously as set forth below under “Anonymity.”

Note: The hotline is operated on our behalf by Intrado, an independent firm based in the United States. You need not identify yourself by name when you phone the hotline. If you choose to give your name, they will keep that confidential unless, as in the case of certain crimes, a law requires that any name you supple be provided to enforcement officials or a court.

The Company may at any time change this Insider Trading Policy or adopt such other policies or procedures which it considers appropriate to carry out the purposes of its policies regarding insider trading and the disclosure of Company information. Notice of any such change will be delivered to you by regular or electronic mail (or other delivery option used by the Company) by the Company. You will be deemed to have received, be bound by and agree to revisions of this Insider Trading Policy when such revisions have been delivered to you, unless you object to any revision in a written statement received by the Compliance Officer within two

(2) business days of such delivery.

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Adopted October 7, 2020

Updated June 14, 2021 (updating Compliance Officer to General Counsel)