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This Insider Trading Policy (the “Policy”) determines acceptable transactions in the securities of certain publicly-traded companies by the directors, officers and employees of Immunovant, Inc. and its consolidated subsidiaries (collectively, “Immunovant”). This Policy is meant to supplement and be read in conjunction with Immunovant’s Policy on Trading Securities Across Roivant Group Companies.

During the course of your directorship, holding office, or employment with Immunovant or a Roivant Group Company, you may receive material information that is not yet publicly available about Immunovant or other publicly-traded companies with which Immunovant has business dealings (“inside information”). Inside information could also include confidential information received from third parties in the course of such third parties exploring business opportunities with Immunovant. Because of your access to inside information, you may be in a position to profit financially by buying or selling, or in some other way dealing, in the securities of Immunovant or another publicly-traded company, or to disclose such information to a third party who does so profit (a “tippee”).

It is always illegal to, and it is a violation of this Policy for you to, buy or sell securities while in possession of inside information and it is also illegal and a violation of this Policy for you to inappropriately communicate or “tip” such information to others who do not have a legitimate business need for acquiring such information. You can be held liable both for your own transactions and for transactions effected by a tippee, or even a tippee of a tippee. Furthermore, it is important that the appearance of insider trading in securities be avoided. The only exception is that transactions directly with Immunovant, e.g., option exercises for cash under the equity incentive plans of the Immunovant, generally are permitted. However, the subsequent sale (including the sale of shares in a cashless exercise program) or other disposition of such shares is fully subject to the restrictions set forth in this Policy. For purposes of this Policy, “trade,” “trading” and “transactions” include not only purchases and sales of Immunovant’s common stock in the public market, but also any other purchases, sales, transfers, gifts or other acquisitions and dispositions of common or preferred equity, options, warrants and other securities (including debt securities) and other arrangements or transactions that affect economic exposure to changes in the prices of these securities, including, but not limited to, engaging in short sales, transactions in put or call options and hedging transactions.

As a practical matter, it is sometimes difficult to determine whether you possess inside information. The key to determining whether nonpublic information you possess about a public company is inside information is whether dissemination of the information would likely affect the market price of the company’s stock (either up or down) or would likely be considered important, or “material,” by investors who are considering trading in that company’s stock. Certainly, if the information makes you want to trade, it would probably have the same effect on others. Remember, both positive and negative information can be material. If you possess inside information about a company, you may not trade in such company’s stock, advise anyone else to do so or communicate the information to anyone else (other than a Non-Covered Person (defined below) in a manner consistent with applicable securities laws, rules and regulations) until you know that the information has been publicly

disseminated. In the case of securities of Roivant Sciences Ltd. or one or more of the publicly-traded subsidiaries of Roivant Sciences Ltd. (each, a “Roivant Group Company” and, collectively, the “Roivant Group Companies”), see Immunovant’s Policy on Trading Securities Across Roivant Group Companies for more information and applicable restrictions. In some circumstances, you may have to forgo a proposed transaction in a company’s securities even if you planned to execute the transaction prior to learning of the inside information and even though you believe you may suffer an economic loss or sacrifice an anticipated profit by waiting.

For information to be considered publicly disseminated, it must be widely disclosed through a press release or filing with the Securities and Exchange Commission or otherwise publicly available, and a sufficient amount of time must have passed to allow the information to be fully disclosed. Generally speaking, information will be considered publicly disseminated after one full trading day has elapsed since the date of public disclosure of the information in a national news medium. For example, if an announcement of inside information concerning a third-party company, of which you were aware, was made prior to trading on Thursday, then you may execute a transaction in the securities of that company on Friday.

Due to the size of Immunovant, all directors, officers and employees of Immunovant are likely to possess inside information regarding Immunovant at one time or another. Therefore, we require all directors, officers and employees of Immunovant (each a “Covered Insider” and, collectively, the “Covered Insiders”) to do more than just refrain from insider trading with respect to Immunovant. Generally, other than a Non-Covered Person (defined below), any (a) immediate family member of a Covered Insider, (b) individuals who share the same address as, or are financially dependent on, any Covered Insider, (c) individual, whether or not a family member, whose trades are subject to the direction of a Covered Insider, and (d) entities whose trading activities are controlled by or influenced by any Covered Insider, including any controlled corporations, partnerships or trusts, are, in the case of (a) through (d), subject to the same restrictions as those of the Covered Insider, and transactions by such entities should be treated for the purposes of this Policy as if they were for the account of the Covered Insider. For purposes of this Policy, a “Non-Covered Person” is any entity (i) of which the Covered Insider is an employee, member or partner, (ii) that engages in the management of investment in securities for investment funds in the ordinary course of its business or is a managed fund of such person, and (iii) that has confirmed to Immunovant in writing that it has established its own policies and procedures for compliance with insider trading restrictions under applicable securities laws. For the avoidance of doubt, a Non-Covered Person shall not be considered a Covered Insider subject to this Policy, and it shall not be a breach of this Policy for a Covered Person to recommend investments or be involved in the investment decision making of a Non-Covered Person in accordance with applicable securities laws, rules and regulations.

Trading in Immunovant’s securities is prohibited during the period beginning on the final business day of each fiscal quarter and ending at the close of business on the second full trading day following the date Immunovant’s financial results for such fiscal quarter are publicly disclosed. During these periods, Covered Insiders generally possess or are presumed to possess material non-public information about Immunovant’s financial results.

From time to time, other types of material non-public information regarding Immunovant (such as negotiation of mergers or acquisitions, or clinical, manufacturing or commercial developments) may be pending and not be publicly disclosed. While such material non-public information is pending, Immunovant may impose special blackout periods during which Covered Insiders are prohibited from trading in Immunovant’s securities. If Immunovant imposes a special blackout period, it will notify the Covered Insiders affected.

1.Option Exercises + RSU Net Settlement. Covered Insiders may, without restriction to any particular period, (i) exercise options for cash granted under the Company’s equity incentive plan and (ii) net settle restricted stock units (“RSUs”) and have the Company withhold common stock to satisfy tax withholding obligations when RSUs settle. However, the subsequent sale of the shares (including sales of shares in a cashless exercise) acquired upon the exercise of options is subject to all provisions of this Policy.

instructed to buy and sell Immunovant securities based on pre-determined criteria (a “Trading Plan”). So long as a Trading Plan is properly established, purchases and sales of Immunovant securities pursuant to that Trading Plan are not subject to this Policy. To be properly established, a person’s Trading Plan must be established in compliance with the requirements of Rule 10b5-1 of the Exchange Act and any applicable 10b5-1 trading plan guidelines of Immunovant at a time when they were unaware of any material nonpublic information relating to Immunovant and when they were not otherwise subject to a trading blackout period. Please see the requirements set forth in the current Immunovant, Rule 10b5-1 trading plan guidelines (if any) for further information.

Officers and directors subject to the reporting obligations under Section 16 of the Exchange Act should take care not to violate the prohibition on short-swing trading (Section 16(b) of the Exchange Act) and the restrictions on sales by control persons (Rule 144 under the Securities Act of 1933, as amended), and should file all appropriate Section 16(a) reports (Forms 3, 4 and 5) and any notices of sale required by Rule 144.

Covered Insiders are permitted to trade in Immunovant’s securities when no blackout period is in effect. Generally this means that Covered Insiders can trade during the period beginning at the close of business on the second full trading day following the date Immunovant’s financial results for such fiscal quarter are publicly disclosed and ending on the final business day of each fiscal quarter. However, even during this trading window, a Covered Insider who is in possession of any material non-public information should not trade in Immunovant’s securities until the information has been made publicly available or is no longer material. In addition, Immunovant may close this trading window if a special blackout period as described above is imposed and will re-open the trading window once the special blackout period has ended.

(b)Subject to the exemption in subsection (d) below, no Covered Insider may, directly or indirectly, purchase or sell (or otherwise make any transfer, gift, pledge or loan of) any Immunovant security at any time without first obtaining prior approval from the Chief Legal Officer. These procedures also apply to transactions by such person's spouse, other persons living in such person’s household and minor children and to transactions by entities over which such person exercises control.

(c)The Chief Legal Officer shall record the date each request is received and the and time each request is approved or disapproved. Unless revoked, a grant of permission will normally remain valid until the close of trading two business days following the day on which it was granted. If the transaction does not occur during the two-day period, pre-clearance of the transaction must be re- requested.

This Policy continues to apply to your transactions in the securities of Immunovant and the Roivant Group Companies or the stock of other public companies engaged in business transactions with Immunovant even after your directorship, holding office or employment with Immunovant has terminated. Namely, if you are in possession of inside information when your relationship with Immunovant concludes, you are still subject to the restrictions contained in this Policy for the later of (a) six months after such termination or (b) the date the information is otherwise publicly disseminated.

Anyone who effects transactions in the securities of Immunovant, the Roivant Group Companies, or the stock of other public companies engaged in business transactions with Immunovant (or provides information to enable others to do so) on the basis of inside information is subject to both civil liability and criminal penalties, as well as disciplinary action by Immunovant, including termination of employment or other service relationship. A Covered Insider who has questions about this policy should contact the Chief Legal Officer of Immunovant.


IMMUNOVANT, INC. AMENDED AND RESTATED INSIDER TRADING POLICY