This Policy is designed to set the guidelines for recovery of certain forms of executive compensation in the case of accounting restatements resulting from a material error in an issuer’s financial statements. This Policy shall be administered by the Board of Directors of the Company or, if so designated by the Board, the Corporate Governance & Nominating Committee. This Policy was adopted by the Corporate Governance & Nominating Committee on October 23, 2023 and replaces the previous Clawback Policy which was in force since January 1, 2015.