Xanadu Quantum Technologies Ltd

Our Board has adopted a code of ethics applicable our principal executive officer, principal financial officer, principal accounting officer or controller, and persons performing similar functions. This code is intended to qualify as a “code of ethics” within the meaning of the applicable rules of the SEC. Our code of ethics is available on our website athttps://investors.xanadu.ai/corporate-governance/documents-charters. Information contained on, or that can be accessed through, our website is not incorporated by reference into this Annual Report.