{"url_path":"/sec/aixi/10-k/2026/item-16","section_key":"item-16","section_title":"Item 16 J. Insider Trading Policies.","topic":"sec","document":{"doc_type":"20-F","doc_date":"2026-05-15","source_url":"https://www.sec.gov/Archives/edgar/data/1935172/0001213900-26-057986-index.html","accession_number":"0001213900-26-057986","cik":"0001935172","ticker":"AIXI","issuer_name":"Xiao-I Corp","edgar_url":"https://www.sec.gov/Archives/edgar/data/1935172/0001213900-26-057986-index.html","primary_entity_key":"0001935172","primary_entity_name":"Xiao-I Corp"},"word_count":719,"has_tables":true,"body_markdown":"Item 16.J. Insider Trading Policies.\n\n \n\nWe have adopted an insider trading policy (the\n“Policy”) to promote compliance with applicable securities laws and regulations, including those that prohibit insider trading.\nThe Policy applies to all officers, directors, and employees of the Company. As someone subject to the Policy, individuals are responsible\nfor ensuring that members of their immediate family and household also comply with the Policy. The Policy also applies to any entities\nthat individuals control, including any corporations, partnerships, or trusts, and transactions by such entities should be treated for\nthe purposes of the Policy and applicable securities laws as if they were for their own account. The Company may determine that the Policy\napplies to additional persons with access to material nonpublic information, such as contractors or consultants. The Policy extends to\nall activities within and outside individuals’ Company duties.\n\n \n\n140\n\n \n\n \n\nThe insider trading policy establishes the following\nguidelines and procedures:\n\n \n\n●No officer, director, or employee\n(or any other person designated as subject to this Policy) shall purchase or sell any type of security while in possession of material\nnonpublic information relating to the security or the issuer of such security, whether the issuer of such security is the Company or\nany other company.\n\n \n\n●Additionally, no officer, director\nor employee shall purchase or sell any security of the Company during the period beginning on the 14th calendar day before the end of\nany fiscal quarter of the Company and ending upon completion of the second full trading day after the public release of earnings data\nfor such fiscal quarter or during any other trading suspension period declared by the Company.\n\n \n\n●From time to time, events will\noccur that are material to the Company and cause certain officers, directors, or employees to be in possession of material nonpublic\ninformation. When that happens, the Company will recommend that those in possession of the material nonpublic information suspend all\ntrading in the Company’s securities until the information is no longer material or has been publicly disclosed.\n\n \n\n●When such event-specific blackout\nperiods occur, those subject to it will be notified by the Company. The event-specific blackout period will not be announced to those\nnot subject to it, and those subject to it or otherwise aware of it should not disclose it to others.\n\n \n\n●Even if the Company has not\nnotified you that you are subject to an event-specific blackout period, if you are aware of material nonpublic information about the\nCompany, you should not trade in Company securities. Any failure by the Company to designate you as subject to an event-specific blackout\nperiod, or to notify you of such designation, does not relieve you of your obligation not to trade in the Company’s securities\nwhile possessing material nonpublic information.\n\n \n\n●No officer, director, or employee\nshall directly or indirectly communicate (or “tip”) material nonpublic information to anyone outside the Company (except\nin accordance with the Company’s policies regarding the protection or authorized external disclosure of Company information) or\nto anyone within the Company other than on a “need-to-know” basis.\n\n \n\n●Insiders may be liable for\ncommunicating or tipping material nonpublic information to a third party (“tippee”), and insider trading violations are not\nlimited to trading or tipping by insiders. Persons other than insiders can also be liable for insider trading, including tippees who\ntrade on material nonpublic information tipped to them or individuals who trade on material nonpublic information that has been misappropriated.\nInsiders may be held liable for tipping even if they receive no personal benefit from tipping and even if no close personal relationship\nexists between them and the tippee.\n\n \n\n●Tippees inherit an insider’s\nduties and are liable for trading on material nonpublic information illegally tipped to them by an insider. Similarly, just as insiders\nare liable for the insider trading of their tippees, so are tippees who pass the information along to others who trade. In other words,\na tippee’s liability for insider trading is no different from that of an insider. Tippees can obtain material nonpublic information\nby receiving overt tips from others or through, among other things, conversations at social, business, or other gatherings.\n\n \n\nWe are committed to maintaining the highest standards\nof ethical conduct and have implemented these insider trading policies and procedures to ensure compliance with applicable securities\nlaws and to protect the interests of our shareholders."}