Nuvo Pharmaceuticals : Supplemental Information

NUVO PHARMACEUTICALS INC. d/b/a MIRAVO

HEALTHCARE

CODE OF BUSINESS CONDUCT AND ETHICS

The following code of business conduct and ethics (the "Code") was adopted by the board of directors of Nuvo Pharmaceuticals Inc. d/b/a Miravo Healthcare (the "Company") on March 25, 2022.

The objective of this Code is to provide guidelines for maintaining the integrity, reputation, honesty, objectivity and impartiality of the Company and its subsidiaries (collectively, the "Miravo Entities"). This Code covers a wide range of business practices and procedures. It does not cover every issue that may arise, but sets out basic principles to guide all directors, managers officers and employees of the Miravo Entities (collectively, "Miravo Personnel" or "you"). All Miravo Personnel must conduct themselves accordingly and seek to avoid even the appearance of improper behavior. This Code and specific related policies and guidelines (including the Company's Insider Trading Policy and Disclosure and Confidential Information Policy) put in place from time to time by the Miravo Entities will govern your employment or other relationship with the Miravo Entities.

If a law conflicts with a policy in this Code, Miravo Personnel must comply with the law. If a local custom or policy conflicts with this Code, Miravo Personnel must comply with this Code. If you have any questions about these conflicts, you should ask a senior officer of the Company how to handle the situation. Any questions regarding the Code should be addressed to the Director, Human Resources.

Miravo Personnel who violate the standards in this Code will be subject to disciplinary action, up to and including termination of their employment or other relationship with the Miravo Entities. If you are in a situation that you believe may violate or lead to a violation of this Code, follow the guidelines described below under "Compliance Procedures".

1. The Code

1. Compliance with Laws, Rules and Regulations

Obeying the law, both in letter and in spirit, is the foundation on which the Miravo Entities' ethical standards are built and is critical to our reputation and continued success. All Miravo Personnel must respect and obey the laws of the various jurisdictions in which the Miravo Entities operate and avoid even the appearance of impropriety. Although not all Miravo Personnel are expected to know the details of these laws, it is important to know enough to determine when to seek advice from senior management or other appropriate personnel. The Company's legal department is available to assist Miravo Personnel in determining applicable legal requirements and to seek the advice of outside legal counsel where appropriate.

Miravo Personnel must cooperate fully with those responsible for preparing reports filed withthe securities regulatory authorities and all other materials that are made available to the investing public to ensure those persons are aware in a timely manner of all information that is required to be disclosed. Miravo Personnel should also cooperate fully with the independent auditors in their audits and in assisting with the preparation of financial disclosure.

1

1. Conflicts of Interest

Miravo Personnel are required to act with honesty and integrity and to avoid or fully disclose any interest, relationship or activity that may be harmful or detrimental to the Company's best interests or that may give rise to real, potential or the appearance of a conflict of interest with the interests of any of the Miravo Entities.

A "conflict of interest" exists when a person's private interests interfere, or appear to interfere, in any way from the interests of the Company. A conflict of interest can arise when Miravo Personnel take actions or have interests that may make it difficult for them to perform their work for the Company objectively and effectively. Conflicts of interest also may arise when Miravo Personnel or members of their families receive improper personal benefits as a result of their positions with a Miravo Entity or when Miravo Personnel, members of their family or entities they are associated with enter into transactions or conduct business with Miravo Entities.

Conflicts of interest are prohibited as a matter of policy, except as may be approved as described below. Conflicts of interest may not always be clear-cut. Persons other than directors and executive officers who have questions about a potential conflict of interest or who become aware of an actual or potential conflict should discuss the matter with, and seek a determination and prior authorization or approval from, their supervisor or the Company's Chief Financial Officer. A supervisor may not authorize or approve conflict of interest matters or make determinations as to whether a problematic conflict of interest exists without first providing the Company's Chief Financial Officer with a written description of the activity and seeking the Chief Financial Officer's written approval. If the supervisor is involved in the potential or actual conflict, the matter should instead be discussed directly with the Company's Chief Financial Officer. Directors and executive officers must seek determinations and prior authorizations or approvals of potential conflicts of interest exclusively from the Company's board of directors.

1. Confidentiality

Miravo Personnel must maintain the confidentialityof confidential information entrusted to them by any Miravo Entity and persons with whom the Miravo Entities do business, except when disclosure is authorized under the Disclosure and Confidential Information Policy or required by laws or regulations. Confidential information includes all non-public information that might be of use to competitors or harmful to any Miravo Entity or the person to whom it relates if disclosed. The obligation to preserve the confidentiality of confidential information continues even after Miravo Personnel cease to have a relationship with the Miravo Entities.

Miravo Personnel who have access to confidential information are not permitted to use or share that information for trading purposes or for any other purpose except the conduct of the Miravo Entities' business. All Miravo Personnel should read and abide by the Company's Disclosure and Confidential Information Policy.

1. Corporate Opportunities

Miravo Personnel are prohibited from taking for themselves personally opportunities that are discovered through the use of corporate property, information or positions without the consent of the board of directors and from using corporate property, information or positions for improper

2

personal gain. No Miravo Personnel may compete with any of the Miravo Entities directly or indirectly. Miravo Personnel owe a duty to each Miravo Entity to advance its legitimateinterests when the opportunity to do so arises.

1. Directorships

Officers or directors of Miravo shall not act as a director or officer of any other corporation without prior disclosure to the Miravo Board of Directors. Employees who are not officers or directors shall not act as a director or officer of any other Corporation without prior disclosure to and approval of the President and Chief Executive Officer. However, prior approval is not required to serve on boards of charities or non-profit organizations or in private family businesses that have no relation to the Company and its businesses.

1. Protection and Proper Use of Miravo Entity Assets

All Miravo Personnel should endeavor to protect Miravo Entity assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on the profitability of the Miravo Entities. Any suspected incident of fraud or theft should be reported immediately in accordance with the Company's Whistleblower Policy or to the Company's Chief Financial Officer for investigation.

The obligation of Miravo Personnel to protect the assets of the Miravo Entities includes the Miravo Entities' proprietary information. Proprietary information includes any information that is not known generally to the public or would be helpful to competitors of any of the Miravo Entities. Examples of proprietary information include intellectual property (such as trade secrets, patents, trademarks and copyrights), product registration dossiers and supporting documentation, business, marketing and service plans, designs, databases, salary information and any unpublished financial data and reports. Unauthorized use or distribution of this information would violate Miravo Entity policy and could be illegal and result in civil or criminal penalties.

The obligation to preserve the confidentiality of proprietary information continues even after Miravo Personnel cease to have a relationship with any of the Miravo Entities.

Miravo Entity assets may never be used for illegal purposes.

1. Information Protection

The Miravo Entities have physical and electronic safeguards in place to protect their information and all personal and confidential information entrusted to them. Miravo Personnel should use these safeguards to minimize the risk of unauthorized or accidental disclosure of such information. Unauthorized collection, use or disclosure of personal or confidential information can harm the Miravo Entities and their stakeholders and damage the trust that has been built. Breaches can be verbal, written or electronic and can be caused by error or malicious intent. If you become aware of a potential privacy, confidentiality or information security breach, you must promptly reportit to your supervisor or the Company's Privacy Officer.

3

1. Competition and Fair Dealing

The Miravo Entities seek to excel and to outperform any competitors fairly and honestly through superior performance and not through unethical or illegal business practices. Taking proprietary information without the owner's consent, inducing disclosure of that information by past or present employees of other competitors or using that information is prohibited. Miravo Personnel should respect the rights of, and deal fairly with, the Miravo Entities' competitors and persons with whom the Miravo Entities have a business relationship. No Miravo Personnel should take unfair advantage of anyone through illegal conduct, manipulation, concealment, abuse of proprietary information, misrepresentation of material facts or any other intentional unfair- dealing practice. Nor should any Miravo Personnel act in a manner that may be anticompetitive under anti-trust laws. The Company's Chief Financial Officer is available to assist Miravo Personnel in determining the application of those laws and to seek the advice of legal counsel where appropriate.

1. Gifts and Entertainment

Business gifts and entertainment are customary courtesies designed to build goodwill and constructive relationships among business partners. These courtesies may include such things as meals and beverages, tickets to sporting or cultural events, discounts not available to the general public, accommodation and other merchandise or services. In some cultures, they play an important role in business relationships. However, a problem may arise when these courtesies compromise, or appear to compromise, a Miravo Entity's ability to make fair and objective business decisions or to gain an unfair advantage.

Offering or receiving any gift, gratuity or entertainment that might be perceived to unfairly influence a business relationship should be avoided. These guidelines apply at all times and do not change during traditional gift-giving seasons.

No gift or entertainment should ever be offered, given, provided, authorized or accepted by any Miravo Personnel or their family members unless it is not a cash gift, is consistent with customary business practices, is not excessive in value, cannot be construed as a bribe or payoff and does not violate any laws. If a disinterested third party would be likely to believe that the gift affected your judgment, then it must not be offered, given, provided, authorized or accepted. All business dealings must be on arm's-length terms and free from any favourable treatment resulting from the personal interests of Miravo Personnel.

Strict rules apply when a Miravo Entity does business with governmental agencies and officials (as discussed in more detail below). Miravo Personnel should discuss with their supervisor or department head any gifts or proposed gifts about which they have any questions.

1. Payments to Government Personnel

All Miravo Personnel must comply with all laws prohibiting improper payments to domestic and foreign officials. Other governments have laws regarding business gifts that may be accepted by government personnel. The promise, offer or delivery to an official or employee of various governments of a gift, favour or other gratuity in violation of these laws would not only violate the Miravo Entities' policies but could also be a criminal offence. Illegal payments

4

should not be made to government officials of any country. The Company's Vice President and Chief Financial Officer can provide guidance to Miravo Personnel in this area and seek the advice of legal counsel where appropriate.

1. Lobbying

Any contact with government personnel for the purpose of influencing legislation or rule making, including such activity in connection with marketing or procurement matters, is considered lobbying. You are responsible for knowing and adhering to all relevant lobbying laws and associated gift laws, if applicable and for compliance with all reporting requirements. You must obtain the prior approval of the secretary to lobby or authorize anyone else (for example, a consultant or agent) to lobby on behalf of any Miravo Entity, except when lobbying involves only normal marketing activities and not influencing legislation or rule making.

1. Discrimination and Harassment

The Miravo Entities are committed to providing a workplace free of harassment, violence and discrimination. Miravo Personnel are expected to foster a respectful work environment that adheres to the requirements of applicable human rights law and related workplace legislation. The Miravo Entities will not tolerate acts of discrimination based on age, ancestry, colour, race, citizenship, ethnic origin, creed, disability, family status, marital status, gender, sex, sexual orientation or any other ground of discrimination prohibited by law. Miravo Personnel are encouraged to speak with their supervisor or Human Resources when a co-worker's conduct makes them uncomfortable and to report harassment when it occurs.

1. Health and Safety

The Miravo Entities strive to provide all Miravo Personnel with a safe and healthy work environment. All Miravo Personnel have responsibility for maintaining a safe and healthy workplace by following safety and health rules and practices and reporting accidents, injuries and unsafe equipment, practices or conditions to a supervisor or department head. Being under the influence, and the possession, of illegal drugs in the workplace will not be tolerated. Miravo Personnel should report to work in condition to perform their duties, free from the influence of illegal drugs or alcohol.

1. Accuracy of Records and Reporting

Maintaining information and records accurately and completely is vital to the success of the Miravo Entities. A record is defined as a book, document, or any other data, regardless of the type or form. A record may be written or electronic, including emails. Records may contain financial, medical, or operational data. All Miravo Personnel are obligated to accurately and truthfully document their work and to not make false or misleading oral or written statements about it. The Miravo Entities will not take any action to manipulate, mislead, coerce, or inappropriately influence any independent auditor engaged in an audit of financial statements.

When preparing source documents for financial transactions, it is important for Miravo Personnel to provide accurate information so that costs can be allocated to the appropriate service. No

5