On October 29, 2026, the Board of Directors of Medallion Bank (the “Bank”) approved amendments to the Bank’s Code of Ethical Conduct and Insider Trading Policy. The amendments, among other things, add a prohibition concerning the use of confidential information in connection with prediction markets and similar platforms, as well as clarify the applicability of certain provisions to directors and employees, including executive officers. The amendments also specify who is responsible for the grant of any waivers and include certain other clarifying and administrative changes.