Notice of Amendment: Updated Semrush Code of Business Conduct & Ethics

Effective February 18, 2025, Semrush Holdings, Inc. (the "Company") adopted an updated Code of Business Conduct & Ethics (the “Updated Code”) which amended, restated, and replaced the Company’s previous Code of Business Conduct & Ethics (the “Prior Code”). The Updated Code adds various new provisions, including provisions around acceptance of gifts and the use of artificial intelligence technologies, and updates and clarifies certain existing sections, including around compliance with laws, regulations and the Company's policies and procedures. The Updated Code also reflects changes in style and appearance as well as other non-substantive changes. The Updated Code applies to all of the Company’s directors, officers, and employees, including its principal executive officer, principal financial officer, principal accounting officer and controller, service providers, and persons performing similar functions. The adoption of the Updated Code did not relate to, or result in, any waiver, explicit or implicit, of any provision of the Prior Code. The foregoing description of the changes contained in the Updated Code does not purport to be complete and is qualified in its entirety by reference to the full text of the Updated Code, a copy of which is posted here on the Company’s investor relations website. The Company plans to review the Updated Code periodically and amend it as appropriate. The Company intends to disclose any amendments to our Updated Code, or waivers of its requirements, here on our website or in filings under the Securities Exchange Act of 1934, as amended.