Insider Trading Arrangements - Mr.Gangadharan

3 Months Ended

Jun. 30, 2023

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Trading Arrangements, by Individual

Material Terms of Trading Arrangement

On May 31, 2023, Mr. Gangadharan, Adtalem’s Chief Accounting Officer, entered in a 10b5-1 Preset Diversification Program (the “10b5-1 Plan”). Mr. Gangadharan’s 10b5-1 Plan is intended to satisfy the affirmative defense of Rule 10b5-1(c). The estimated selling start date under Mr. Gangadharan’s 10b5-1 Plan is August 28, 2023. The 10b5-1 Plan end date is June 1, 2026. The 10b5-1 Plan governs Mr. Gangadharan’s sale of 2,222 restricted stock units (“RSUs”) that will vest over the duration of the 10b5-1 Plan. The RSUs will be acquired in connection with Adtalem’s Fourth Amended and Restated Incentive Plan of 2013 for directors, key executives, and managerial employees. A portion of the shares will be withheld by Adtalem or sold to cover withholding taxes. Transactions under Section 16 officer trading plans will be disclosed publicly through Form 144 and Form 4 filings with the Securities and Exchange Commission to the extent required by law.

Name

Mr. Gangadharan

Title

Chief Accounting Officer

Rule 10b5-1 Arrangement Adopted

true

Adoption Date

May 31, 2023

Aggregate Available

2,222

Expiration Date

June 1, 2026