GLOBUS MEDICAL INC

On February 18, 2024, the Company adopted an updated insider trading policy (the “Insider Trading Policy”) in order to facilitate the mitigation of insider trading risks within the Company. The Insider Trading Policy applies to all transactions in the Company’s securities by the Company’s employees, officers, directors and consultants, as well as members of their immediate families and members of their households and was designed to promote compliance with insider trading laws, rules and regulations, and listing standards applicable to the Company. A copy of the Insider Trading Policy is filed as Exhibit 19.1 to this Annual Report on 10-K.

During the three months ended December 31, 2024, several of the Company's directors and officers adopted, modified or terminated a “Rule 10b5-1 trading arrangement” or a “non-Rule 10b5-1 trading arrangement” as each term is defined under Item 408 of Regulation S-K.

On November 11, 2024, Ann D. Rhoads, Director, adopted a trading arrangement for the sale of securities of the Company’s Class A Common that is intended to satisfy the affirmative defense conditions of Securities Exchange Act Rule 10b5-1(c) (a “Rule 10b5-1 Trading Plan”). Ms. Rhoads’ Rule 10b5-1 Trading Plan, which has a term ending upon the earlier of February 28, 2026, or the sale of all shares subject to the plan, provides for the sale of up to 27,500 shares of Class A Common pursuant to the terms of the plan.

On December 10, 2024, Daniel T. Scavilla, the Company’s President and Chief Executive Officer, adopted a Rule 10b5-1 Trading Plan for the sale of securities of the Company’s Class A Common. Mr. Scavilla’s Rule 10b5-1 Trading Plan, which has a term ending upon the earlier of December 31, 2025, or the sale of all shares subject to the plan, provided for the sale of up to 80,000 shares of Class A Common pursuant to the terms of the plan.

On December 4, 2024, Kelly Huller, Executive Vice President and General Counsel, adopted a Rule 10b5-1 Trading Plan for the sale of securities of the Company’s Class A Common. Ms. Kelly’s Rule 10b5-1 Trading Plan, which has a term ending upon the earlier of December 31, 2025, or the sale of all shares subject to the plan, provided for the sale of up to 37,500 shares of Class A Common pursuant to the terms of the plan.