Zevia PBC

In June 2025, the independent compensation consultant, Pearl Meyer, conducted a risk assessment of Zevia’s policies and programs relating to the compensation of employees, including those that apply to our executive officers. The Compensation Committee concluded that such programs and practices do not create risks that are reasonably likely to have a material adverse effect on us.

We have programs and features that are designed to ensure that our employees, including the NEOs, are not encouraged to take unnecessary risks in managing our business, including:

We periodically monitor our incentive programs throughout the year to ensure that such programs do not encourage undue risk taking and appropriately balance risk and reward consistent with our enterprise risk management efforts.

Compensation Policies

Until they achieve the requisite ownership level, individuals subject to the stock ownership guidelines are required to hold 50% of all shares received, net of taxes, after vesting or exercise of equity awards granted in 2023 or thereafter. Shares of Class A common stock held directly or by immediate family members and shares subject to outstanding RSUs (whether or vested or unvested) count towards satisfaction of the guidelines; however, shares subject to unexercised stock options (regardless of vesting) or unearned performance awards do not count. All of our currently employed NEOs and non-employee directors have achieved the requisite ownership guidelines or are in compliance with the holding requirements and on track to achieve the guidelines.

Rule 10D-1 Clawback Policy. We maintain the Zevia PBC Clawback Policy, which is intended to comply with the requirements of the New York Stock Exchange Listing Standard 303A.14 implementing Rule 10D-1 under the Exchange Act. In the event the Company is required to prepare an accounting restatement of the Company’s financial statements due to material non-compliance with any financial reporting requirement under the federal securities laws, the Company will recover, on a reasonably prompt basis, the excess incentive-based compensation received by any covered executive, including the NEOs, during the prior three fiscal years that exceeds the amount that the executive otherwise would have received had the incentive-based compensation been determined based on the restated financial statements.

Misconduct Clawback Policy. In February 2024, we adopted the Zevia PBC Executive Leadership Recoupment Policy, which provides the Compensation Committee with the ability to recoup time-based and performance-based equity awards and all cash bonuses received during the prior three years in the event any covered executive, including the currently employed NEOs, engages in conduct that constitutes (a) fraud or ethical misconduct contributing to the need for a financial restatement, (b) a willful violation of applicable law or material Company policy, or (c) an act of fraud, breach of fiduciary duty, material act of dishonesty, material misrepresentation or other willful misconduct.

Insider Trading Policy and Prohibition on Hedging and Pledging. We have adopted an insider trading policy (the “Insider Trading Policy”) governing the purchase, sale and other dispositions of our securities that applies to all company personnel, including directors, officers, employees, consultants and other insiders, as well as to the Company. We believe that our insider trading policy and repurchase procedures are reasonably designed to promote compliance with insider trading laws, rules and regulations, and listing standards applicable to us. The Insider Trading Policy was filed as Exhibit 19.1 to our Annual Report on Form 10-K for the fiscal year ended December 31, 2025. Under our Insider Trading Policy our employees, including our NEOs, officers, directors and consultants, are prohibited from engaging in short-term or speculative transactions in Company securities, including (a) short-term trading (generally defined as selling Company securities within six months following a purchase); (b) short sales (selling Company securities they do not own); (c) transactions involving publicly traded options or other derivatives, such as trading in puts or calls with respect to Company securities; and (d) hedging transactions. Additionally, the Company prohibits its directors and Section 16 officers from pledging Company securities.

Equity Grant Timing. The Company currently approves annual equity awards to our executive officers during the open trading window under our Insider Trading Policy that follows the filing of our Annual Report on Form 10-K each March. In addition to annual equity grants, equity awards may be granted at other times during the year to new hires and in other special circumstances. Such off-cycle equity grants are generally issued quarterly in June, September, and December. During 2025, the Company didnot take material nonpublic information into account when determining the timing and terms of equity awards and did not time the disclosure of material nonpublic information for the purpose of affecting the value of executive compensation in 2025. During 2025, no stock options were granted during the period beginning four business days before the filing of a Form 10-Q or Form 10-K or the filing or furnishing of a Form 8-K that discloses material nonpublic information.