Extract to table

CONFIDENTIAL — DRAFT — ATTORNEY-CLIENT PRIVILEGED BOARD INFORMATION FLOW POLICY OF BELMONT RIDGE BANK NA DRAFT — Prepared by Calderwood & Harkness LLP Matter Number: 1045-00003 July 2025 For Consideration and Adoption by the Board of Directors of Belmont Ridge Bank NA This policy is presented for review by the Board of Directors at its next regularly scheduled meeting and, upon adoption, shall be effective immediately

1 Adoption and Authority This Policy shall be adopted by formal resolution of the Board of Directors of Belmont Ridge Bank NA

The Board resolution adopting this Policy shall be recorded in the minutes of the Board meeting at which adoption occurs and shall reference this Policy by title and date

Questions regarding the application of this Policy to specific circumstances — including the determination of whether a particular event constitutes a Material Event within the meaning of Section 5 — shall be resolved by the General Counsel, with the understanding that close questions shall be resolved in favor of reporting and escalation rather than non-reporting

2 Annual Review This Policy shall be reviewed by the Governance & Nominating Committee at least annually, and any recommended amendments shall be presented to the full Board of Directors for consideration and approval

The General Counsel shall coordinate the annual review process and shall consult with outside counsel (currently Calderwood & Harkness LLP) and the regulatory consultant (currently Ashford Pike Advisory LLC, Kenneth R