Map Policy

Minimum Advertised Pricing Policy 

As updated September 5, 2025

Effective Immediately, this shall serve as the Minimum Advertised Price policy for Pendulum Therapeutics, Inc. (“Pendulum”) Products, as defined in Pendulum’s Terms and Conditions on www.pendulumlife.com (herein referred to as "MAP Policy").

As used in this MAP Policy, i) “Reseller” means any entity, including but not limited to, distributors, retailers, sales representatives, and dealers, that buys Products from Pendulum or other party and sells them to any other party and;  ii) “Advertisement” shall mean the display of a price for a Product(s) in any and all media, including but not limited to flyers, posters, coupons, mailers, inserts, newspapers, magazines, catalogs, direct-mail advertising, advertising stuffers in monthly statements, phone solicitation, television, radio, and public signage, as well as Internet sites (e.g. email, banner, pop-up, pop-under, websites, social media sites, apps, or any other electronic media) and geo-location services.

Pendulum is disrupting the health industry. Pioneering the next frontier of microbiome science, Pendulum works to develop revolutionary and effective products that address imbalances in the microbiome, transforming people’s lives from the inside out. Led by Colleen Cutcliffe, Co-founder and CEO who received her Ph.D. in Biochemistry and Molecular Biology from Johns Hopkins University, Pendulum was founded in 2012 by a diverse team of scientists with deep microbiology, biochemistry, computational and clinical expertise. Pendulum’s investors include Sequoia Capital, True Ventures, Meritech Capital, and the Mayo Clinic. 

Pendulum has spent the last several years building a brand of strong recognition and high perceived value. By not adhering to the established MAP Policy, a Reseller can dramatically diminish or detract from the perceived value of Pendulum’s brand and Products. The global impact of the internet can cause great harm to any company's products if they are subject to Advertisement at prices that will eliminate legitimate retail competition. 

The MAP Policy has been established by Pendulum to help preserve and protect the reputation of Pendulum's name, brand, and Products. The MAP policy is also designed to ensure Resellers have the incentive to invest resources into services for Pendulum's customers and is intended to allow consumers to purchase from Resellers based on loyalty and customer experience. In the interest of protecting both Resellers and consumers, it is necessary to abide by the following requirements. 

The Minimum Advertised Price for any one (1) month supply Pendulum Products shall be no less than as listed herein:

 

This Minimum Advertised Price for each Product is established by Pendulum and may be adjusted by Pendulum at such time and in such amounts as it may determine at its sole discretion.

1. 1. As per Section 5.2 of Pendulum’s Terms and Conditions, you shall not place Advertisement for Pendulum’s Products on any third-party website, including but not limited to Google.com, Amazon.com, Walmart.com, without prior written consent from Pendulum. Advertising Pendulum’s Products on one’s own website associated directly with one’s store(s)/practices is permissible so long as this MAP Policy is adhered to.
      

   2. This MAP Policy applies to all Advertisement prices for the Products. The MAP Policy is not, and is not intended to be, an agreement or understanding of any kind, express or implied, regarding the price at which the Reseller may sell the Products. A Reseller may sell the Products at any price it chooses. No officer, employee, representative or agent of Pendulum has authority to (i) enter into any agreement or understanding with respect to the price at which the Reseller sells the Products; or (ii) coerce or otherwise force the Reseller to price the Products at any level other than that unilaterally determined by the Reseller. The Reseller within its own discretion can choose to acquiesce or not acquiesce with this MAP Policy. Pendulum will not discuss conditions of acceptance related to this MAP Policy. This Policy is non-negotiable and will not be altered, modified or amended for any Reseller. Please note that following the actions of another Reseller is not an exception to this MAP Policy and will be considered a violation.
      

   3. The inclusion in Advertisement of free or discounted Products, with a Product covered by this MAP Policy, would be contrary to the MAP Policy if it has the effect of discounting the Advertisement price of the covered Product below the Minimum Advertised Price. 

   4. If pricing is displayed anywhere other than a brick-and-mortar-retail store, any strike-through or other alteration of the Minimum Advertised Price is prohibited.
      

   5. This MAP Policy does not establish maximum advertised prices. All Resellers may offer Pendulum products at any price in excess of the Minimum Advertised Price.
      

   6. The MAP Policy does not, in any way, limit the ability of any Reseller to advertise that "they have the lowest prices" or, they "will meet or beat any competitors’ price," that consumers should "call for a price" or phrases of similar meaning as long as the price in an Advertisement for the Product is not less than the Minimum Advertised Price.
      

   7. Pendulum maintains the right to run a temporary sale for any and all Products at its discretion, and in such case, may but is not required to, adjust the Minimum Advertised Price accordingly for such period of time. 
      

   8. If a Reseller with multiple store locations violates this MAP Policy at any one store location, or on any associated website, then Pendulum will consider this to be a violation of this MAP Policy by the Reseller.
      

   9. Pendulum may, from time to time, enable third-party end user sellers, primarily health care practitioners, with coupon codes for purchase of initial units of its Products. If an end-seller uses such coupon codes applied as a discount to MAP price they must not be listed publicly and may only be used one time for one purchase.
      

   10. Pendulum reserves the right to cancel any pending orders, restrict future orders, or suspend a Reseller's account if Pendulum reasonably believes: (i) a Reseller has violated the provisions of the MAP policy; or (ii) a Reseller intends to violate the MAP Policy.

   11. Pendulum’s' MAP Policy Administrator is solely responsible for determining whether a violation of the MAP Policy has occurred, as well as for determining appropriate consequences and sanctions.
       

   12. Waiver to the MAP Policy may be granted in Pendulum's sole discretion by the MAP Policy Administrator in a written waiver. Pendulums' sales and marketing personnel, or any other personnel, are not authorized to modify or grant exceptions to the MAP Policy. If the MAP Policy Administrator authorizes a waiver of the MAP Policy, resellers must strictly adhere to the terms of the written waiver. Deviation from the terms of the written waiver is a violation of the MAP Policy.
       

   13. Pendulum monitors the Advertisement prices of Resellers, either directly or via the use of third-party agencies or tools. Resellers are expected to provide reasonable cooperation in any Pendulum investigations regarding possible MAP Policy violations. Hindering, obstructing, delaying, or otherwise failing to cooperate with a Pendulum MAP Policy investigation is a violation of the MAP Policy.
       

   14. The MAP Policy will be enforced by Pendulum (and its contractual partners) in its sole discretion and without notice. Resellers have no right, unless explicitly granted in writing, to enforce the MAP Policy. Violations of the MAP Policy may result in any of the aforementioned sanctions up to and including termination of our business relationship, as well as any available remedies at law.

All questions related to the MAP policy should be directed to: BrandProtection@pendulumlife.com