Newton Golf Company, Inc.

Risk Management and Strategy

The Company maintains policies and processes designed to identify, assess, and manage cybersecurity risks that could affect its information systems and business operations. Cybersecurity risk management is integrated into the Company’s overall risk management processes and is considered as part of its broader operational and strategic decision-making.

The Company’s processes include periodic assessments of potential cybersecurity threats, evaluation of vulnerabilities, and implementation of safeguards designed to protect the confidentiality, integrity, and availability of its information systems and data. These activities are informed by industry practices and may include the use of internal resources as well as third-party service providers.

The Company relies on third-party platforms and service providers, including e-commerce, payment processing, and cloud-based systems, and considers risks associated with such providers as part of its cybersecurity risk management processes. The Company evaluates third-party service providers, where appropriate, and monitors for potential risks arising from such relationships.

The Company may engage external consultants or service providers from time to time to assist with evaluating cybersecurity risks, implementing security measures, and responding to potential incidents.

While the Company has not identified cybersecurity risks that have materially affected its business, results of operations, or financial condition, it cannot provide assurance that such risks will not have a material impact in the future.

The Company maintains policies and processes designed to identify, assess, and manage cybersecurity risks that could affect its information systems and business operations. These processes include periodic reviews of potential cybersecurity threats and evaluation of safeguards designed to protect the confidentiality, integrity, and availability of the Company’s information systems.

The Company may engage third-party consultants or service providers to assist with evaluating cybersecurity risks and implementing appropriate security measures.

The Company hasnot experienced any cybersecurity incidents and has not identified any risks from cybersecurity threats that have materially affected, or are reasonably likely to materially affect, its business strategy, results of operations, or financial condition.

Governance

The Company’s Board of Directors has oversight responsibility for cybersecurity risk as part of its overall risk oversight function. The Board of Directors receives periodic updates from management regarding cybersecurity risks, including potential threats, mitigation efforts, and the status of the Company’s information security controls.

The Company’s Chief Financial Officer is responsible for overseeing the Company’s cybersecurity risk management processes, including monitoring cybersecurity risks, coordinating mitigation efforts, and engaging third-party service providers, as appropriate. The Chief Financial Officer reports to the Board of Directors periodically on cybersecurity matters as part of the Company’s broader risk management framework.

The Company’s executive management team, including the Chief Financial Officer, periodically reviews cybersecurity risks and the effectiveness of related safeguards. While the Company does not maintain a dedicated cybersecurity committee, cybersecurity risks are considered as part of the Board’s and management’s ongoing oversight of enterprise risk.

The Company’s leadership has experience managing financial, operational, and technology-related risks, including oversight of third-party service providers and information systems. In addition, the Company may engage external consultants or advisors with relevant cybersecurity expertise to assist in evaluating risks and implementing appropriate safeguards.