Borealis Foods Inc.

We maintain processes designed to assess, identify, and manage material risks from cybersecurity threats. These processes areintegrated into our broader enterprise risk management activities and are overseen by our Director of Operations, with support from external information technology consultants.

Our cybersecurity risk management processes include:

We engage third-party information technology consultants to assist with monitoring, vulnerability assessments, and incident response support. We do not currently maintain a dedicated internal cybersecurity function, which reflects our current size and stage of development.

We have experienced cybersecurity incidents in the past. While such incidents have not had a material impact on our business, results of operations, or financial condition to date, there can be no assurance that future incidents will not have a material adverse effect. We continue to evaluate and seek to enhance our cybersecurity practices in light of evolving threats and our operational requirements.

As of the date of this Annual Report, we arenot aware of any cybersecurity threats that have materially affected or are reasonably likely to materially affect the Company, including its business strategy, results of operations, or financial condition. However, as described in Part I, Item 1.A, “Risk Factors,” under the heading “Cybersecurity incidents or disruptions to our information technology systems could adversely affect our business,” cybersecurity risks could, in the future, materially affect the Company.

Governance

Board Oversight

Our Board of Directors is responsible foroversight of risks from cybersecurity threats. The Board receives periodic updates from management regarding cybersecurity matters, including the status of any material cybersecurity incidents, the results of risk assessments, and any changes to the Company’s cybersecurity risk profile.

Management’s Role

Our Director of Operations, Mike Wells, oversees the Company’s day-to-day coordination of cybersecurity matters and works with external service providers and consultants responsible for identifying, assessing and responding to cybersecurity risks and incidents. Management relies on the expertise of these external providers for technical cybersecurity monitoring, support and incident response capabilities.

The Company relies significantly on third-party service providers and external information technology consultants to support its information technology infrastructure and cybersecurity functions, including network monitoring, system maintenance, data protection, and cybersecurity risk management.

Management isresponsible for implementing and maintaining the Company’s cybersecurity risk management processes, including incident response procedures, and for reporting material cybersecurity matters to the Board on a periodic basis or on an accelerated basis in the event of a material or potentially material incident