Dated: August 27th, 2025

Version: 1.2

Updated: Annually

It is in the best interest of Akili Ventures (“Akili”) to identify, disclose, and properly manage all actual, potential, and perceived conflicts of interest. This Policy is designed to help directors, officers, partners, and employees recognize situations that may present conflicts of interest and to provide a framework to appropriately manage them in accordance with legal requirements and Akili’s commitment to accountability and transparency.

1. Conflict of Interest Defined

A conflict of interest arises when an individual’s personal, professional, or financial interests interfere — or appear to interfere — with the interests of Akili.

For purposes of this Policy, a conflict of interest exists when:

• A director, officer, partner, or employee (or a Family Member) is a party to a contract, or involved in a transaction with Akili for goods or services.
• A director, officer, partner, or employee (or a Family Member) has a material financial interest in an entity engaged in a transaction with Akili.
• A director, officer, partner, or employee (or a Family Member) is engaged in, or has a material financial interest in, a business that competes with Akili.

Other situations may create the appearance of a conflict, even if no actual conflict exists. Such situations must also be disclosed so that Akili can make an appropriate determination.

2. Gifts, Gratuities, and Entertainment

Accepting gifts, entertainment, or other favors from individuals or entities can result in a conflict when such actions could be seen as intended to influence business decisions.

• Prohibited: Cash or cash equivalents, gifts given in secret, or lavish or excessive hospitality.
• Permissible: Items of nominal value (e.g., pens, mugs, shirts) or modest hospitality consistent with business practice, provided they are not linked to a specific decision or transaction.

All gifts or hospitality must be transparent, appropriate, and reported in accordance with Akili’s expense and compliance procedures.