Beeline Holdings, Inc.

Risk Management and Strategy

Like all companies that utilize electronic technology, we are subject to threats of breaches of our technology systems. To mitigate the threat to our business, we take a comprehensive approach to cybersecurity risk management. Our Board and our management oversee our risk management program, including the management of cybersecurity risks. In early 2025, the Company hired a senior cybersecurity and cloud infrastructure leader. Since this hire, the Company hasestablished policies, standards, processes and practices for assessing, identifying, and managing material risks from cybersecurity threats, including those discussed in our Risk Factors in this Report. In addition to this devoted resource, we intend to have devoted financial resources to implement and maintain security measures to meet regulatory requirements and stockholder expectations, and we intend to continue to make investments to maintain the security of our data and cybersecurity infrastructure. We plan to validate the maturity of our Cybersecurity policies, standards and processes against industry certifications in the near future. While there can be no guarantee that our policies and procedures will be properly followed in every instance or that those policies and procedures will be effective, we believe that the Company’s sustained investment in people and technologies will have contributed to a culture of continuous improvement that has put the Company in a position to protect against potential compromises and we do not believe that risks from prior cybersecurity threats have materially affected our business to date. We can provide no assurance that there will not be incidents in the future or that past or future attacks will notmaterially affect us, including our business strategy, results of operations, or financial condition. We are committed to addressing all incidents in a timely and transparent manner as well as ensuring the appropriate engagement of third-party partners.