Your compliance with this Policy is of the utmost importance both for you and for the Company. If you have any questions about this Policy or its application to any proposed transaction, you may obtain additional guidance from the Company’s Chief Legal Officer, Lynn Feldman (the “Compliance Officer”), at LynnFeldman@clearchannel.com. Do not try to resolve uncertainties on your own, as the rules relating to insider trading are often complex, not always intuitive and carry severe consequences.

It is important that you understand the breadth of activities that constitute illegal insider trading and the consequences thereof, which can be severe. The U.S. Securities and Exchange Commission (the “SEC”) investigates insider trading violations. The SEC, together with the U.S. Department of Justice, pursue insider trading violations vigorously. Cases have been successfully prosecuted against employees with material, nonpublic information, including instances of trading by employees through foreign accounts, trading by family members and friends, trading by Entities, trading in the securities of an economically-linked or otherwise related-company, and trading involving only a small number of shares, with significant monetary and/or criminal consequences.

Civil and Criminal Penalties. Potential penalties for insider trading violations include (1) imprisonment for up to 20 years, (2) criminal fines of up to $5 million for an individual, and (3) civil fines of up to the greater of $2,166,2791 and three times the profit gained or loss avoided, in each case, as of the date of this Policy.

Controlling Person Liability. If the Company fails to take appropriate steps to prevent illegal insider trading, the Company may have “controlling person” liability for a trading violation, with civil penalties of up to the greater of $2,166,2791 and three times the profit gained or loss avoided, as well as criminal penalties of up to $25 million, in each case, as of the date of this Policy. The civil penalties can extend personal liability to the Company’s Directors, officers and other supervisory personnel if they fail to take appropriate steps to prevent insider trading.

1 The Federal Civil Penalties Inflation Adjustment Act of 2015 requires all federal agencies to annually adjust the civil monetary penalties that can be imposed by such agencies for inflation. Accordingly, this figure is likely to change year-over-year.

Company Sanctions. Failure to comply with this Policy may also subject you to Company-imposed sanctions, which may include ineligibility for future participation in the Company’s equity incentive plans or termination of employment, regardless of whether your failure to comply with this Policy results in a violation of law.

Persons Covered. This Policy applies to all Directors, Executive Officers and employees of, or consultants or contractors to, the Company who receive or have access to material nonpublic information. The same restrictions that apply to you apply to your Family Members and to any Entities. You are responsible for making sure that the purchase or sale of any security covered by this Policy by any such person complies with the terms of this Policy. In addition, you may not direct anyone else to engage in a transaction on your behalf if you would be prohibited by this Policy from entering into the transaction directly.

Companies Covered. The prohibition on insider trading in this Policy is not limited to trading in the Company’s securities. It includes trading in the securities of customers or suppliers of the Company and those with which the Company may be negotiating business relationships or major transactions, such as an acquisition, investment or sale. Information that is not material to the Company may nevertheless be material to one of those other entities.

Transactions Covered. This Policy applies to all transactions (including, but not limited to, purchases, sales and bona fide gifts) in the Company’s securities, as well as the securities of publicly traded companies with whom we have a business relationship, including common stock, options for common stock and any other securities the Company may issue from time to time, such as preferred stock, warrants and convertible debentures. This Policy also applies to any arrangements that affect economic exposure to changes in the prices of these securities (such as exchange-traded put or call options), hedging transactions and short sales. Trading also includes certain transactions under Company plans, as follows:

•Stock Option Exercises. This Policy’s trading restrictions generally do not apply to the exercise of a stock option. The trading restrictions do apply, however, to any sale of the underlying stock or to a cashless exercise of the option through a broker, as this entails selling a portion of the underlying stock to cover the costs of exercise.

•Vesting of Restricted Stock and Performance Awards. This Policy’s trading restrictions do not apply to the vesting of restricted stock, performance stock units, restricted stock units or the exercise of a tax withholding right pursuant to which you elect to have the Company withhold shares of stock to satisfy tax withholding requirements upon the vesting of any restricted stock, performance stock units or restricted stock units. The trading restrictions do apply, however, to any sale of the Company’s securities received upon such vesting.

•401(k) Plan. If applicable, this Policy’s trading restrictions do not apply to purchases of the Company’s securities in the Company’s 401(k) plan resulting from your periodic contribution of money to the plan pursuant to your payroll deduction election. The trading restrictions would apply, however, to certain elections you may make under the 401(k) plan, including: (a) an election to increase or decrease the percentage of your periodic contributions that will be allocated to the Company stock fund; (b) an election to make an intra-plan transfer of an existing account balance into or out of the Company stock fund; (c) an election to borrow money against your 401(k) plan account if the loan will result in a liquidation of some or all of your Company stock fund balance; and (d) an election to pre-pay a plan loan if the pre-payment will result in allocation of loan proceeds to the Company stock fund.

Transaction Not Covered. If you own shares of a mutual fund that invests in the Company’s securities, there are no restrictions on trading the shares of the mutual fund at any time.

No Trading on Inside Information. You may not trade in the securities of the Company, directly or through Family Members or other persons or Entities, if you are aware of any material nonpublic information relating to the Company. Similarly, you may not trade in the securities of companies with whom we have a business relationship if you are aware of any material nonpublic information about that company which you obtained in the course of your employment with the Company.

No Tipping. You may not pass material nonpublic information on to others, and you may not recommend to anyone or express opinions about the purchase or sale of any securities when you are aware of material nonpublic information. This practice, known as “tipping,” also violates the securities laws and can result in the same civil and criminal penalties that apply to insider trading, even though you did not trade and did not gain any benefit from another’s trading.

No Disclosure of Non-public Information. Non-public information relating to the Company and other companies or persons that it does business with, such as its vendors, customers, collaborators and suppliers, is the property of the Company, and the unauthorized disclosure of that information is prohibited. All unauthorized persons are prohibited from disclosing information about the Company on the Internet, in forums such as chat rooms, X (formerly known as Twitter), Facebook, Instagram, Reddit, etc., or on blogs where companies and their prospects are discussed, regardless of the situation.

Obligation to Disclose Material Nonpublic Information to the Company. You may not enter into any transaction, unless you have disclosed any nonpublic information that could reasonably be deemed material that you become aware of in the course of your service with the Company, and that senior management is not aware of, to the Compliance Officer. If you are a member of senior management, the information must be disclosed to the Chief Executive Officer, and if you are the Chief Executive Officer or a Director, you must disclose the information to the board of directors, before any transaction is permissible.

No Exception for Hardship. The existence of a personal financial emergency does not excuse you from compliance with this Policy. Every Director, Executive Officer, employee, consultant and contractor of the Company has the individual responsibility to comply with this Policy against insider trading. From time to time, you may have to forego a proposed transaction in the Company’s securities even if you planned to make the transaction before learning of the material nonpublic information and even though you believe that you may suffer from an economic loss.

Blackout and Pre-Clearance Procedures. To help prevent inadvertent violations of the federal securities laws and to avoid even the appearance of trading on the basis of inside information, the Company’s Board of Directors has adopted an Addendum to Insider Trading Policy that applies to Directors, Executive Officers and certain other designated individuals who usually have access to material nonpublic information about the Company (the “Addendum”). The Company will notify you if you are subject to the Addendum. The Addendum generally prohibits persons covered by it from trading in the Company’s securities during quarterly blackout periods (beginning 15 days before the end of a quarter and ending after the second full business day following the release of the Company’s earnings for that quarter) and during certain event-specific blackouts. Directors and Executive Officers of the Company must also pre-clear all transactions in the Company’s securities with the Compliance Officer.

Rule 10b5-1 provides an affirmative defense from insider trading liability under the U.S. federal securities laws for trading plans that meet certain requirements. In order to be eligible to rely on this defense, a person subject to this Policy must enter into a Rule 10b5-1 plan for transactions in the Company’s securities that meets the conditions specified in the Rule (a “Rule 10b5-1 Plan”). If the plan meets the requirements of Rule 10b5-1, the Company’s securities may be purchased or sold without regard to certain insider trading restrictions described in this Policy.

To comply with the Policy, the adoption, modification or early termination of a Rule 10b5-1 Plan must be approved by the Compliance Officer, and all Rule 10b5-1 Plans must meet the requirements of Rule 10b5-1. Any Rule 10b5-1 Plan must be submitted for approval five business days prior to the entry into the Rule 10b5-1 Plan, and any proposed modifications or terminations thereof must be submitted for approval at least three business days prior to the consummation of such actions. No further pre-approval of transactions conducted pursuant to the Rule 10b5-1 Plan will be required.

In addition, a Rule 10b5-1 Plan must be entered into or modified only (i) at a time when the person entering into or modifying the plan is not aware of material nonpublic information about the Company or the Company’s securities and (ii), in the case of individuals subject to the restrictions set forth in the Addendum relating to pre-clearance procedures and blackout periods, outside of a blackout period. Once the plan is adopted, the person must not exercise any influence over the amount of securities to be traded, the price at which they are to be traded or the date of the trade(s). The plan must either specify (including by formula) the amount, pricing and timing of transactions in advance or delegate discretion on these matters to an independent third party.

Material Information. It is not possible to define all categories of material information. However, information should be regarded as material if there is a reasonable likelihood that it would be considered important to an investor in deciding whether to buy, hold or sell a security.

•Projections of future earnings or losses or other earnings guidance.

•Financial results.

•Earnings that are inconsistent with the consensus expectations of the investment community.

•A pending or proposed merger, acquisition or tender offer or an acquisition or disposition of significant assets.

•A change in management.

•Major events regarding the Company’s securities, including the declaration of a stock split, the offering of debt or equity securities or the commencement of any debt or equity repurchase program.

•Financial or liquidity problems.

•Actual or threatened litigation, or the resolution of such litigation.

•New major contracts, orders, suppliers, customer or finance sources, or the loss thereof.

•Changes in subscription rates.

•Significant developments related to intellectual property.

•Significant cybersecurity incidents or threats.

Nonpublic Information. Nonpublic information is information that is not generally known or available to the public. One common misconception is that material information loses its “nonpublic” status as soon as a press release is issued disclosing the information. In fact, information is considered to be available to the public only when it has been released broadly to the marketplace (such as by a press release or an SEC filing) and the investing public has had time to absorb the information fully.

Short Sales. You may not engage in short sales of the Company’s securities (sales of securities that are not then owned), including a “sale against the box” (a sale with delayed delivery).

Hedging Transactions. You may not engage in transactions in publicly traded options related to the Company’s equity securities (such as puts or calls) or engage in transactions involving any other financial instruments (such as forward contracts, equity swaps, collars or exchange funds) that are designed to hedge or offset any decrease in the market value of the Company’s equity securities.

Standing and Limit Orders. Standing and limit orders (except standing and limit orders under approved Rule 10b5-1 Plans, as described above) should be used only for a very brief period of time and, in the case of Directors and Executive Officers who are required to pre-clear their transactions with the Compliance Officer, for no longer than the duration of the pre-clearance. A standing order placed with a broker to sell or purchase stock at a specified price leaves you with no control over the timing of the transaction. A standing order transaction executed by the broker when you are aware of material nonpublic information may result in unlawful insider trading.

Margin Accounts and Pledges. Securities held in a margin account or pledged as collateral for a loan may be sold without your consent by the broker if you fail to meet a margin call or by the lender in foreclosure if you default on the loan. Because a margin or foreclosure sale may occur when you are aware of material nonpublic information or otherwise are not permitted to trade in Company securities, you are prohibited from holding Company securities in a margin account or pledging Company securities as collateral for a loan. An exception to this general prohibition may be granted where you wish to pledge Company securities as collateral for a loan (not including margin debt) and clearly demonstrate the financial capacity to repay the loan without resorting to the pledged securities. If you wish to pledge Company securities as collateral for a loan, you must submit a request for approval to the Compliance Officer of the Company at least two weeks prior to the proposed execution of documents evidencing the proposed pledge.

You must use all reasonable efforts to safeguard nonpublic information in the Company’s possession. You may not disclose nonpublic information about the Company or any other company with which the Company does business, unless required by law, or unless (i) you are authorized to disclose the information and (ii) appropriate steps have been taken to prevent misuse of that information (including entering an appropriate nondisclosure agreement that restricts the disclosure and use of the information, if applicable). This restriction also applies to internal communications within the Company and to communications with agents of the Company. In cases where disclosing nonpublic information to third parties is required, you should coordinate with the Legal Department.

To help prevent inadvertent violations of the federal securities laws and to avoid even the appearance of trading on inside information, the Board of Directors of Clear Channel Outdoor Holdings, Inc. (the “Company”) has adopted this addendum (this “Addendum”) to that certain Insider Trading Policy, dated as of July 24, 2024 (the “Policy”). This Addendum applies to Directors, executive officers subject to Section 16 of the Securities Exchange Act of 1934, as amended (“Executive Officers”), and certain designated employees and consultants of the Company and its subsidiaries who have access to material nonpublic information about the Company (collectively, “Covered Persons”), as well as any Family Members of any Covered Person. “Family Members” means children, stepchildren, parents, stepparents, spouses, siblings, mothers-in-law, fathers-in-law, daughters-in-law, sons-in-law, sisters-in-law and brothers-in-law, persons (other than tenants or employees) sharing a household, and any family members who do not share a household but whose transactions in Company securities are directed by an individual covered by this Addendum or are subject to such individual’s influence or control (such as parents or children who consult with such individual’s before they trade in Company securities).

Covered Persons subject to this Addendum include all Directors, Executive Officers, accounting employees with the title of vice president or higher, investor relations employees that assist with earnings releases, legal department employees that assist with preparing U.S. Securities and Exchange Commission (“SEC”) filings, any employees on the Company’s disclosure committee, and any other persons designed by the Legal Department as being subject to these procedures.

Directors and Executive Officers, together with their Family Members, may not engage in any transaction involving the Company’s securities (including a stock plan transaction such as an option exercise, or a gift, loan, pledge, contribution to a trust or any other transfer) without first obtaining pre-clearance of the transaction from the Company’s Chief Legal Officer (the “Compliance Officer”). A request for pre-clearance should be submitted to the Compliance Officer at least two business days in advance of the proposed transaction. The Compliance Officer is under no obligation to approve a transaction submitted for pre-clearance, and may determine not to permit the transaction. The Compliance Officer may not transact in Company securities unless the Chief Executive Officer of the Company has approved the transaction in accordance with the procedures set forth in this Addendum. If pre-clearance is denied, that denial must be kept confidential by the person requesting pre-clearance. Unless otherwise provided, pre-clearance of a transaction is valid for three business days. If the transaction is not executed within that time, the person must request pre-clearance again before executing the transaction. Pre-clearance of a trade, however, is not a defense to a claim of insider trading and does not excuse you from otherwise complying with insider trading laws, this Addendum and the Policy.

Quarterly Blackout Periods. The Company’s announcement of its quarterly financial results almost always has the potential to have a material effect on the market for the Company’s securities. Therefore, to avoid even the appearance of trading on the basis of material nonpublic information, regardless of whether or not you are aware of any material nonpublic information, you may not trade in the Company’s securities during the period beginning 15 days before the end of a quarter and ending after the second full business day following the release of the Company’s earnings for that quarter. All persons who are informed by the Compliance Officer or her designee(s) that they are subject to the quarterly blackout periods are subject to these quarterly blackout periods.

Interim Earnings Guidance and Event-Specific Blackouts. The Company may on occasion issue interim earnings guidance or other potentially material information by means of a press release, SEC filing or other means designed to achieve widespread dissemination of the information. You should anticipate that trading will be prohibited while the Company is in the process of assembling the information to be released and until the information has been released and fully absorbed by the market.

A Form 4 must be filed to report acquisitions and dispositions of Company securities, including, but not limited to, (a) any open market or private sale or purchase of Company securities, (b) any grant, exercise or conversion of Company restricted stock, restricted stock units, or derivative securities (e.g., stock options or performance stock units), (c) any bona fide gift, and (d) any intra-plan transfers involving Company securities held under pension or retirement plans. A Form 4 must generally be filed within two business days of the date of execution of the transaction (not the settlement date or subsequent closing or delivery date). Forms 4 for sales made pursuant to Rule 10b5-1 Plans should specifically note that the sales were made pursuant to a previously-established trading plan. It is important that Executive Officers and Directors ensure that their brokers and any applicable plan administrator notify them promptly of any transaction. A Form 4 must also be filed after a person ceases to be an Executive Officer or Director of the Company if there is a non-exempt, “opposite-way” transaction within six months of such person’s last transaction while an Executive Officer or Director (e.g., an open market sale within six months of a purchase).