Quantum Biopharma Ltd.

We have adopted the Code that is applicable to all of our directors, executive officers, and employees, including our principal executive officer, principal financial officer, principal accounting officer and controller. A copy of the Code is available on our website at https://www.quantumbiopharma.com.

During 2025, except for the CEO Mortgage Loan, no provision of the Code applicable to our principal executive officer, principal financial officer, principal accounting officer or controller was amended (other than technical, administrative, or other non-substantive amendments), nor did we grant any waiver (including an implicit waiver) of any provision of the Code to any such officer. During fiscal year 2025, the CEO made a payment and thereby fully extinguishing the CEO Mortgage Loan. As of the date of this annual report, the CEO has no further outstanding debt owed to the Company.

We intend to disclose any amendments to the Code applicable to our principal executive officer, principal financial officer, principal accounting officer or controller (other than technical, administrative, or other non-substantive amendments) and any waiver of the Code for any such officer on our website within five business days following the date of the amendment or waiver. We expect to maintain any such disclosure on our website for a period of at least twelve months from the date of posting.