Insider Trading Policy

1. Purpose

Maverick Trading is committed to conducting its business with integrity and in compliance with applicable securities laws. This policy explains the firm's absolute prohibition on trading while in possession of material non-public information ("MNPI") and the obligations of everyone associated with the firm.

2. Who This Policy Applies To

This policy applies to all Maverick Trading members, traders, trainees, risk managers, officers, employees, contractors, and consultants, as well as their immediate family members, household members, and any entity whose trading they control or influence. It applies to trading in firm capital and to trading in personal accounts.

3. What Is Material Non-Public Information

Information is material if a reasonable investor would consider it important in deciding whether to buy, hold, or sell a security, or if it would be likely to affect the market price of that security.

Information is non-public until it has been broadly disseminated to the investing public and the market has had a reasonable opportunity to absorb it.

Examples may include:

• Unreleased earnings, revenue, or guidance, or knowledge that results will differ materially from expectations.
• Pending mergers, acquisitions, tender offers, joint ventures, or divestitures.
• Significant new products, contracts, customers, clinical or regulatory outcomes, or the loss of any of these.
• Changes in senior leadership, auditors, or a pending restatement.
• Impending bankruptcy, liquidity problems, or significant litigation or regulatory action.
• Stock splits, dividend changes, buybacks, or planned securities offerings.
• Knowledge of a large pending order or trade that could move the market in a security.

4. Prohibited Conduct

No person covered by this policy may, directly or indirectly:

• Trade any security, option, or derivative while in possession of MNPI relating to that security or its issuer.
• Tip — disclose MNPI to any other person, including other traders, family members, friends, or chat and social media communities, where that person might trade on it.
• Recommend or suggest that anyone buy or sell a security while in possession of MNPI about it, even without disclosing the information itself.
• Trade ahead of or alongside a firm order in a way that disadvantages the firm or its traders (front-running).
• Participate in market manipulation, including spoofing, layering, wash trading, marking the close, or coordinated promotional schemes.
• Misappropriate confidential information obtained from an employer, client, counterparty, or any relationship of trust.

These prohibitions apply regardless of how the information was obtained and regardless of the size of the trade. There is no exception for small positions or for trades you believe are unlikely to be noticed.

5. Confidentiality

Firm proprietary information — including trading methodology, position data, capital allocations, risk parameters, trainee records, and internal communications — must be kept confidential and used only for legitimate firm purposes. Confidentiality obligations continue after your association with the firm ends.

6. If You Think You Have MNPI

If you believe you may possess MNPI:

• Do not trade in the affected security.
• Do not discuss the information with anyone else.
• Contact your risk manager or the firm immediately at support@mavericktrading.com for guidance before taking any action.

When in doubt, treat the information as material and non-public and seek guidance first.

7. Reporting Violations

Anyone who becomes aware of a potential violation of this policy must report it promptly to the firm at support@mavericktrading.com. The firm prohibits retaliation against anyone who reports a suspected violation in good faith.

8. Consequences

Violations of this policy may result in immediate termination of your relationship with Maverick Trading, forfeiture of capital allocations and profit participation, and referral to the appropriate authorities. Insider trading is also a serious violation of law that can result in civil penalties, disgorgement, fines, and imprisonment for the individuals involved.

9. Acknowledgment

Members and traders may be required to acknowledge this policy in writing upon joining the firm and periodically thereafter. Failure to acknowledge does not excuse compliance.

10. Contact

Maverick Trading
P.O. Box 900802
Salt Lake City, UT 84090
support@mavericktrading.com