ALLIANCE ENTERTAINMENT HOLDING CORP

During the three months ended March 31, 2024, the Company formally adopted an Insider Trading Policy. This policy outlines guidelines and restrictions related to the trading of the Company’s securities by individuals deemed to be “insiders,” including officers, directors, andemployees who have access to material nonpublic information about the Company.

The Insider Trading Policy is designed to ensure compliance with securities laws and regulations, including those set forth by the Securities and Exchange Commission (SEC). It prohibits insiders from trading in the Company’s securities while in possession of material nonpublic information and imposes pre-clearance requirements for certain transactions. Additionally, the policy provides guidelines for reporting and disclosing transactions in accordance with regulatory requirements.

The adoption of this Insider Trading Policy underscores the Company’s commitment to maintaining the highest standards of integrity, transparency, and corporate governance. We believe that adherence to these guidelines not only promotes fair and equitable treatment of all shareholders but also helps to safeguard the Company’s reputation and fiduciary responsibilities.