COMPASS Pathways plc

Strategic Reorganization

On October 28, 2024, our board of directors authorized a strategic reorganization to better position and refocus the organization and its capital resources on completing our COMP360 phase 3 program in TRD and, if approved, launching COMP360 in the United States. Management, with the oversight and guidance of our board of directors, will begin to implement this strategic reorganization program in the fourth quarter of 2024 (subject to consultation with staff where required under applicable law), resulting in a reduction of the total employee base by approximately 30% from current levels. Our non-COMP360 preclinical efforts will be stopped and we are exploring a potential externalization of our digital technologies, intellectual property and associated employees. As part of the strategic reorganization, we will be scaling back our general and administrative functions, including the elimination of two senior management roles, our chief legal officer and general counsel and our chief communications officer.

In connection with the strategic reorganization, our chief legal officer and general counsel, Matthew Owens, will leave his role on December 31, 2024 and commence garden leave. Pursuant to his existing employment agreement, Mr. Owens has a 9-month contractual notice period, and his employment will terminate on September 30, 2025. While on garden leave, Mr. Owens will receive his normal salary and benefits, as required by the terms of his previously disclosed employment agreement, but will not qualify for any bonus for fiscal year 2025. Additionally, we have mutually agreed that Mr. Owens will receive his annual bonus for fiscal year 2024, which will be payable at the target amount, a separation payment of £30,000, a statutory redundancy payment and professional assistance with filing certain of his tax returns for fiscal 2024/2025. During his garden leave, all outstanding equity awards previously granted to Mr. Owens will continue to vest in accordance with their terms, and no further equity awards will be awarded to him.

Rule 10b5-1 Trading Plans

During the three months ended September 30, 2024, none of our directors or executive officers adopted, terminated or modified the amount, pricing or timing provisions in any contract, instruction or written plan for the purchase or sale of our securities that was intended to satisfy the affirmative defense conditions of Rule 10b5-1(c) or any “non-Rule 10b5-1 trading arrangement.”