Star Equity Holdings, Inc.

Disclosure Controls and Procedures

The Company’s management, with the participation of the Company’s Chief Executive Officer and Principal Financial Officer, has conducted an evaluation of the design and operation of the Company’s disclosure controls and procedures, as such term is defined under Rule 13a-15(e) of the Securities Exchange Act of 1934, as amended. Based on this evaluation, the Company’s Chief Executive Officer and Principal Financial Officer concluded that the Company’s disclosure controls and procedures were effective as of June 30, 2026. However, such controls and procedures are designed only to provide reasonable assurance. There is no complete assurance that these controls and procedures will operate effectively under all circumstances.

Management has determined that the effectiveness of ADT’s controls will be assessed in the second half of 2026.

Changes in Internal Control Over Financial Reporting

There were no changes in the Company’s internal control over financial reporting that occurred during the six months ended June 30, 2026 that have materially affected, or are reasonably likely to materially affect, the Company’s internal control over financial reporting, except as noted below.

On August 22, 2025 we completed the merger with Star Operating Companies ("SOC"). As a result of this transaction, we have begun integrating the operations, systems, and internal controls of SOC into our existing processes. This integration is ongoing and includes aligning accounting policies, consolidating financial reporting systems, and implementing our internal control framework across the combined entity. These activities represent a change to our internal control over financial reporting. While we do not believe these changes have materially affected our internal control over financial reporting at this time, the integration process may result in additional changes in future periods.

As part of the SOC merger, we acquired Alliance Drilling Tools ("ADT"). Consistent with SEC guidance permitting the exclusion of an acquired business from an assessment of internal control over financial reporting for a period not to exceed one year from the date of acquisition, management's assessment of internal control over financial reporting as of June 30, 2026 continues to exclude the internal controls of ADT. ADT's operations continue to be integrated into the Company's internal control framework, and management expects to include ADT in its assessment of internal control over financial reporting no later than the third quarter of fiscal year 2026. ADT represented approximately 13% of total assets and 7% of revenues as of and for the six months ended June 30, 2026.

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