Exhibit 97
SAVARA INC.
POLICY REGARDING THE MANDATORY RECOVERY OF COMPENSATION
EFFECTIVE NOVEMBER 28, 2023
Except as provided herein and subject to Section II(b) below, in the event that the Company is required to prepare a Financial Restatement, the Company’s Board of Directors (the “Board”) shall recover any Recoverable Amount of any Incentive Compensation received by a current or former Executive Officer during the Look-Back Period. The Recoverable Amount shall be repaid to the Company within a reasonable time after the current or former Executive Officer is notified of the Recoverable Amount as set forth in Section II(c) below. For the sake of clarity, the recovery rule in this Section II(a) shall apply regardless of any misconduct, fault, or illegal activity of the Company, the Executive Officer, the Board, or any committee thereof.
The Company or a delegate thereof must recover the Recoverable Amount of Incentive Compensation as stated above in Section II(a), unless the Company’s Compensation Committee, or in the absence of such a committee, a majority of the independent directors serving on the Board makes a determination that recovery would be impracticable, and at least one of the following applies: