SurgePays, Inc.

No officers or directors adopted orterminated Role 10b5-1 trading arrangements during the year ended 2025.

During the year ended December 31, 2024, certain of our officers and directors adopted orterminated Rule 10b5-1 trading arrangements as follows:

On March 14, 2024, Kevin Brian Cox, our President and Chief Executive Officer, adopted a trading plan that is intended to satisfy the conditions under Rule 10b5-1(c) of the Exchange Act. Mr. Cox’s trading plan is equal to the number of shares of the Company’s common stock as reasonably estimated by the designated broker such that the net proceeds from their sale are sufficient to cover the withholding taxes resulting from the vesting of RSA grants previously issued to Mr. Cox, in amounts and prices determined in accordance with a formula set forth in the plan. The plan was terminated on December 3, 2024.

In the quarter ended December 31, 2024, 250,000 shares were received and vested from RSA grants as provided for in Mr. Cox’s employment agreement and 97,380 shares were sold.

On March 14, 2024, Anthony Evers, our Chief Financial Officer, adopted a trading plan that is intended to satisfy the conditions under Rule 10b5-1(c) of the Exchange Act. Mr. Evers’ trading plan is equal to the number of shares of the Company’s common stock as reasonably estimated by the designated broker such that the net proceeds from their sale are sufficient to cover the withholding taxes resulting from the vesting of RSA grants previously issued to Mr. Evers, in amounts and prices determined in accordance with a formula set forth in the plan. The plan was terminated on December 31, 2024.

For the quarter ended December 31, 2024, 199,998 shares were received and vested from RSA grants as provided for in Mr. Evers’ employment agreement and 110,000 shares were sold.

Except as disclosed above, none of our directors or executive officers adopted, modified or terminated any contract, instruction or written plan for the purchase or sale of our securities that was intended to satisfy the affirmative defence conditions of Rule 10b5-1(c) or any “non-Rule 10b5-1 trading arrangement” (as defined in Item 408 of Regulation S-K).

Issuer Purchases of Equity Securities

On August 13, 2024, the Company entered into a share repurchase program with ThinkEquity LLC for up to $5,000,000 shares of its common stock. No shares were repurchased during the three months ending December 31, 2024.

On October 1, 2024, the Company decided to terminate the share repurchase program and will no longer be making any reacquisitions.