Adagio Medical Holdings, Inc.

Risk Management and Strategy

We have implemented and maintain various information security processes designed to identify, assess, and manage material risks from cybersecurity threats to our critical computer networks, third party hosted services, communications systems, hardware and software, and our critical data, including intellectual property, and confidential information that is proprietary, strategic or competitive in nature (“Information Systems and Data”).

We leverage third-party information and technology service providers to help assess, identify, and manage the Company’s cyber risk and information security threats by monitoring and evaluating our threat environment using various methods including, for example: manual tools, automated tools, subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and actors, conducting scans of the threat environment, evaluating threats reported to us, audits, conducting threat assessments, conducting vulnerability assessments to identify vulnerabilities, use of external intelligence feeds and tabletop incident response exercises.

Depending on the environment, systems, and data at issue, we implement and maintain various technical, physical, and organizational measures, processes, and policies designed to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data, including, for example: an incident response policy, incident detection and response processes, a vulnerability management processes, disaster recovery/business continuity plans, risk assessments, encryption of data, network security controls, access controls, physical security, systems monitoring, vendor risk management processes, employee training, penetration testing, and cybersecurity insurance.

Our assessment and management of material risks from cybersecurity threats are integrated into the Company’s overall risk management processes. For example, cybersecurity risk is addressed as a component of the Company’s enterprise risk management program.

We use third-party service providers to assist us to identify, assess, and manage material risks from cybersecurity threats, including for example: cybersecurity software providers, managed cybersecurity service providers, and penetration testing firms.

We use third-party service providers to perform a variety of functions throughout our business, such as application providers and hosting companies. We also have vendor management processes to help manage cybersecurity risks associated with our use of these providers. Depending on the nature of the services provided, the sensitivity of the Information Systems and Data at issue, and the identity of the provider, our vendor management process may involve questionnaires to help identify cybersecurity risks associated with a provider and the use of contractual obligations related to cybersecurity on the provider.

For more information onour cybersecurity-related risks that may materially affect the Company and how they may do so, see our “Risk Factors” in Item 1A. of Part I. of this Annual Report on Form 10-K, including the risk factor entitled“If we or the third parties with whom we work experience disruption in our information technology systems, data, or security incidents, our business could be adversely affected, including our ability to operate, the loss of confidential and proprietary information, increased remediation costs, and reputational damage.”

Governance

Our Board of Directors addresses the Company’s cybersecurity risk management as part of its general oversight function. The board of directors’Audit Committee is responsible for overseeing Company’s cybersecurity risk management processes, including oversight of mitigation of risks from cybersecurity threats.

Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management, including our Chief Executive Officer (CEO) and Chief Financial Officer (CFO). Our CEO and CFO are responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into the Company’s overall risk management strategy, and communicating key priorities to relevant personnel. Our CEO and CFO are responsible for approving budgets, helping prepare for cybersecurity incidents, approving cybersecurity processes, and reviewing security assessments and other security-related reports.

Our cybersecurity incident response and vulnerability management processes are designed to escalate certain cybersecurity incidents to members of management depending on the circumstances, including our CEO and CFO. In addition, the Company’s incident response and vulnerability management processes include reporting to the Board of Directors for certain cybersecurity incidents. The Board of Directors also has access to reports from our CEO and CFO on significant enterprise-wide cybersecurity threats and risk and the processes the Company has implemented to address them at each of its periodically scheduled meetings. Our CEO and CFO have extensive experience managing risks at our company and at similar companies in the past, including risks arising from cybersecurity threats.