{"url_path":"/sec/mdt/10-k/2026/item-9b","section_key":"item-9b","section_title":"Item 9B Other Information","topic":"sec","document":{"doc_type":"10-K","doc_date":"2026-06-18","source_url":"https://www.sec.gov/Archives/edgar/data/1613103/0001628280-26-044354-index.html","accession_number":"0001628280-26-044354","cik":"0001613103","ticker":"MDT","issuer_name":"Medtronic plc","edgar_url":"https://www.sec.gov/Archives/edgar/data/1613103/0001628280-26-044354-index.html","primary_entity_key":"0001613103","primary_entity_name":"Medtronic plc"},"word_count":421,"has_tables":true,"body_markdown":"Item 9B. Other Information\n\nRule 10b5-1 Director and Officer Trading Arrangements\n\nDuring the three months ended April 24, 2026, certain of our officers adopted “Rule 10b5-1 trading arrangements,” intended to satisfy the affirmative defense of Rule 10b5-1(c) under the Exchange Act as follows.\n\nOn February 19, 2026, Michael Marinaro, Executive Vice President and President Medical Surgical Portfolio, Americas, and Global Commercial Operations, adopted a Rule 10b5-1 trading plan. Subsequently, on March 17, 2026, Mr. Marinaro amended the trading plan's starting and termination date and to provide a limit price for sales subject to the plan. The trading plan provides for the sale of up to 10,420 shares of the Company’s common stock starting as early as June 15, 2026, prior to the plan's December 15, 2026, termination date.\n\nOn February 27, 2026, Matthew Walter, Senior Vice President, Human Resources, IT, and Global Communications & Corporate Marketing, adopted a Rule 10b5-1 trading plan. Subsequently, on April 7, 2026, Mr. Walter amended the trading plan's starting and termination date. The trading plan provides for the sale of up to 3,102 shares of the Company’s common stock starting as early as July 8, 2026, prior to the plan's July 10, 2026, termination date.\n\nExchange Act Section 3(r) Disclosure\n\nAs reported in our Quarterly Reports on Form 10-Q for the first and second quarters, and during the fourth quarter, of fiscal year 2026, Medtronic has engaged in certain activities that it is required to disclose pursuant to Section 13(r)(1)(D)(ii) of the Securities Exchange Act of 1934, as amended. In particular, during the first, second and fourth quarters of fiscal year 2026, Medtronic engaged in certain regulatory activities involving Russia’s Federal Security Service (“FSB”) related to its medical devices that were expressly authorized by the U.S. Government under applicable economic sanctions regulations.\n\nDuring the first, second, and fourth quarters of fiscal year 2026, in the normal course of business and consistent with the OFAC authorizations as in effect at the time, Medtronic Russia filed a total of eleven notifications with the FSB, as required under local Russian law for the import of medical devices that make use of encryption functionality. This activity did not directly result in any revenues or profits for Medtronic. Medtronic did not engage in these activities during the third quarter of fiscal year 2026. To the extent that notifications with the FSB remain permissible under U.S. law, Medtronic may decide to continue engaging in such activities for the limited purposes of complying with local law requirements in Russia.\n\n115\n\n[Table of Contents](#i8ac9545bba26417b86662fb12ca4cf78_7)"}