PALVELLA THERAPEUTICS, INC.

(a)

None.

(b)

None.

(c)

Consistent with Item 408 of Regulation S-K, the following table reflects Rule 10b5-1 trading arrangements and non-Rule 10b5-1 trading arrangements (as defined in Item 408 of Regulation S-K) entered into by any director or officer (as defined in Rule 16a-1(f) of the Exchange Act) during the quarter ended June 30, 2026:

Our officers and directors from time to time may adopt trading plans to transact in our securities for reasons such as satisfying vesting-related income tax requirements, investment diversification, or other personal reasons. On June 12, 2026, George Jenkins, a member of our Board of Directors, entered into a Rule 10b5-1 trading plan that provides for the potential future sale of a limited portion of his Common Stock, as part of Mr. Jenkins long-term financial planning objectives. The plan was adopted during an open trading window, at a time when Mr. Jenkins was not in possession of material non-public information and was reviewed and approved in accordance with the Company’s Insider Trading Policy. The plan establishes fixed criteria for potential transactions and removes discretion over the timing of trades.

Other than as disclosed above, no director or officer (as defined in Rule 16a-1(f) of the Exchange Act)adopted orterminated a Rule 10b5-1 trading arrangement or non-Rule 10b5-1 trading arrangement (as defined in Item 408 of Regulation S-K) during the quarter ended June 30, 2026.

(d) On August 3, 2026, the Board of Directors approved the Change in Control Acceleration Policy (the “Policy”), effective August 3, 2026, to provide for accelerated equity vesting benefits to eligible employees in the event of certain qualifying terminations following a Change in Control (as defined in the Policy), subject to the employee signing a general release of claims. Participants under the Policy include all Vice Presidents and above, including the Company’s current named executive officers (the “Eligible Employees”).

Under the Policy, in the event of an Eligible Employee’s termination (i) by the Company or its successor without Cause or (ii) by the Eligible Employee for Good Reason (as such terms are defined in the Policy) during the period beginning three months prior to the effective date of a Change in Control (as defined in the Policy) and continuing for the 12 months immediately following such Change in Control (the “Change in Control Period”), subject to (i) the Eligible Employee signing a general release of claims (the “Release”), and (ii) the Release becoming effective within 60 days after the date of the Eligible Employee’s termination (the “Date of Termination”), all then unvested and outstanding equity awards (collectively, the “Equity Awards”), shall become fully vested; provided that, any awards subject to performance-based vesting shall vest based on target performance unless otherwise explicitly set forth in the applicable award agreement.

If the Release has not become effective as of such Date of Termination, then acceleration of vesting shall be tolled until the earlier of (x) the effective date of the Release, at which point the Equity Awards will be automatically fully vested, or (y) the date upon which the Release can no longer become fully effective, at which time the unvested portion of the Eligible Employee’s Equity Awards will be forfeited. The forfeiture of such awards shall be delayed until the earlier of (A) the effective date of the Release or (B) the date that the Release can no longer become fully effective.

The foregoing description of the Policy does not purport to be complete and is qualified in its entirety by reference to the full text of the Policy, a copy of which will be filed as an exhibit to the Company’s Quarterly Report on Form 10-Q for the quarter ending September 30, 2026.