Xarelto Class Action / Recours Collectif Xarelto (Bayer)

FOR RESIDENTS OF ALL CANADIAN PROVINCES, EXCEPT QUEBEC:

SASKATCHEWAN CERTIFICATION AND
SETTLEMENT APPROVAL HEARING NOTICE

NOTICE OF CERTIFICATION AND PROPOSED SETTLEMENT OF XARELTO® LITIGATION

This Notice contains a summary of some of the terms of the Settlement Agreement dated October 27^th, 2025. All capitalized terms not otherwise defined have the meaning ascribed to them in the Settlement Agreement. If there is a conflict between the provisions of this Notice and the Settlement Agreement, the terms of the Settlement Agreement shall prevail.

NOTICE OF CERTIFICATION

A Canada-wide settlement has been reached in a proposed class action relating to the prescription drug Xarelto® (the “Settlement”). This notice advises you that the following lawsuit was certified as a class action and that the Parties have now agreed to settle with a similar class action in Québec, without any admission of liability, and subject to Court approval in both provinces: Tluchak (Estate) et al. v. Bayer Inc. et al., commenced in the Court of King’s Bench for Saskatchewan, Docket QBG-RG-00517-2015 (the “Proceeding”).

The Proceeding raised various allegations against the Defendants and sought damages on behalf of Canadians outside of Québec for harm and injuries that were allegedly related to the use of Xarelto®. The Defendants deny the allegations made in the Proceedings, make no admission as to the truth of these allegations, and deny any wrongdoing.

The allegations made by the Plaintiffs have not been proven in Court and should not be considered in any way to be medical advice. This Notice advises you of the certification of the Proceeding as a class action and of the hearing that will be held to decide whether the Settlement Agreement should be approved (the “Settlement Approval Hearing”). You may attend the Settlement Approval Hearing. You can review the originating documents for the Proceeding, the certification order, as well as the Settlement Agreement and related documents at the settlement website: www.mnp.ca/xareltosettlement, or you can contact the Court appointed Claims Administrator, MNP Ltd., at the address listed below.

WHO IS INCLUDED?

A certification order has been granted for the following class (the “Saskatchewan Class”) and, if the Settlement Agreement is approved, it will apply to:

Canadian residents, other than residents of Québec, who were prescribed and ingested Xarelto® in Canada on or before October 27^th, 2025 (“Primary Class Members”), and individuals who may make a claim pursuant to Family Compensation Legislation because of their relationship with a Primary Class Member (“Family Class Members”).

A separate notice that applies to certain residents of Québec who were prescribed and ingested Xarelto® can be found at www.mnp.ca/xareltosettlement.

WHAT IS THE PROPOSED SETTLEMENT?

The Settlement provides for the creation of a settlement fund of at least $4.5 million (CDN), and up to $5.25 million (CDN) depending on the number of Approved Claims, which will be used to pay compensation for Approved Claims, Provincial Health Insurer Claims, Administration Expenses, Class Counsel Fees and Disbursements and any applicable taxes. Payments to approved Claimants will be made to Class Members who meet the criteria described below within the specified timeframes. Each category of injury will be assigned points by the Claims Administrator subject to various eligibility criteria. Net settlement proceeds will be allocated among the Approved Claims in proportion to the cumulative points each Claimant is awarded under the Compensation Protocol described in the Settlement Agreement. Not all Class Members will be eligible for compensation.

If you are a member of the Saskatchewan Class as described above, you may be eligible for compensation if, on or before the expiry of the Claim Period, which will be posted on the settlement website, you submit a Claim Form with supporting medical, pharmaceutical, or other documentation that establishes that you or a family member was prescribed Xarelto® in Canada before October 27^th, 2025 (“Primary Claimant”), and the Primary Claimant:

• experienced a bleeding event that led to the Primary Claimant’s death, resulted in a brain injury or other significant organ damage with long-term cognitive or physical impairment, or required at least 24 hours of hospitalization; and
• used Xarelto® within 24 hours before experiencing the bleeding event.

Supporting documentation to establish the prescription and use of Xarelto® includes medical, pharmacy, and other records that Xarelto® (or before November 2023, rivaroxaban) was prescribed and dispensed by a pharmacy. As more fully described in the Compensation Protocol, in some cases, a statement by a Claimant or his or her physician may suffice to establish the prescription and use of Xarelto®.

To be eligible for compensation as a family member of a Primary Claimant, evidence must be provided of the requisite relationship, which differs by province. A comprehensive list of eligible Family Claimants is located at www.mnp.ca/xareltosettlement.

The Claims Administrator is responsible for determining the validity of Claims and for allocating points to Approved Claims based upon the severity of the bleeding events. In special circumstances, such as young age of the primary claimant, devastating injuries, complete loss of ability to work, etc., an additional amount may be awarded from a Special Circumstances Fund. The Claims Administrator’s decisions are final and may not be appealed.

If the Settlement is approved, Class Counsel will make an application for Class Counsel Fees and Disbursements of at least $1,350,000 and up to $1,575,000, plus taxes, to be paid from the Settlement Amount. Approval of the Settlement Agreement is not contingent on the outcome of any application regarding Class Counsel Fees and Disbursements. The Saskatchewan Plaintiffs will also seek approval of a $25,000 Honorarium for their contribution to advancing the class action on behalf of the Class.

RIGHT TO PARTICIPATE OR OPT OUT

If you are a member of the Saskatchewan Class and wish to participate in the Settlement, you do not need to do anything at this time. Members of the Saskatchewan Class who do not opt out will be bound by the Settlement Agreement and the releases in it and will be entitled to share in any of the benefits that may become available to them as Saskatchewan Class Members, provided that they submit a Claim Form in the process described above. If you are a member of the Saskatchewan Class and you do not wish to participate in the Settlement, then you must opt out. Opt-Out Forms are available at www.mnp.ca/xareltosettlement or by contacting MNP Ltd. at the address below. The deadline to opt out of the Settlement and the Proceeding is March 10, 2026.

Class Members who opt out will not be bound by the Settlement Agreement or the releases in the Settlement Agreement but will also not be entitled to share in any of the proceeds that may become available to Class Members as part of the Settlement.

The Proceeding will be dismissed as part of the Settlement Agreement. There will be no further opportunity to opt out of the Settlement Agreement or the Proceeding.

SETTLEMENT APPROVAL HEARING

In order for the Settlement to become effective, it must be approved by the Saskatchewan Court. The Saskatchewan Court must be satisfied that the Settlement Agreement is fair, reasonable, and in the best interest of the Class Members. The Settlement Approval Hearing has been scheduled on April 1, 2026.

If the Settlement Approval Hearing is adjourned and/or if the hearing will be held virtually, details will be posted on the settlement website: www.mnp.ca/xareltosettlement.

If the Settlement Agreement is not approved by the Saskatchewan Court in a form agreed to by the Parties to the Proceeding, the Settlement Agreement shall terminate and its terms shall no longer be binding on Class Members. In that case, all parties shall be restored to their pre-Settlement Agreement positions.

OBJECTING TO THE PROPOSED SETTLEMENT AND OPPORTUNITY TO APPEAR

If you wish to object to the proposed Settlement Agreement, you must submit a written objection no later than 5:00 pm PST on March 10, 2026. The following information must be included in the written objection delivered to Class Counsel:

• Your full name, current mailing address, fax number, telephone number, and email address;
• A brief statement of your reasons for the objection;
• A declaration that you believe you are a member of the Saskatchewan Class and the reason for that belief; and
• A statement about whether you intend to appear at the Saskatchewan Settlement Approval Hearing and, if so, if you intend to appear by legal counsel and, if by counsel, the name, address, telephone number, fax number, and email address of your legal counsel.

Your written objection must be sent to the Claims Administrator by no later than March 10, 2026 at the address listed at the end of this Notice. The Claims Administrator will file copies of all objections with the Saskatchewan Court.

You may also attend the Saskatchewan Settlement Approval Hearing on the date noted above and, if you have submitted a written objection, you may request to make oral submissions to the Saskatchewan Court.

NOTICE OF SETTLEMENT APPROVAL

If the proposed Settlement Agreement is approved by the Courts, a notice of approval will be published at www.mnp.ca/xareltosettlement and otherwise made available as ordered by the Saskatchewan Court. Class Members will have a limited amount of time to submit a claim for compensation. If the proposed Settlement Agreement is approved, a downloadable version of the Claim Package, including the Claim Form, will be made available online at www.mnp.ca/xareltosettlement or, alternatively, a Claim Package can be requested from the Claims Administrator by e-mail at: xareltosettlement@mnp.ca, by telephone at (877) 500-0792 or by regular mail at the address listed below. If you intend to submit a claim under the proposed Settlement Agreement, you must do so on or before the expiry of the Claim Period, which will be posted on the settlement website if the proposed Settlement Agreement is approved: www.mnp.ca/xareltosettlement.

LEGAL REPRESENTATION

Verna Tluchak of Lloydminster, Saskatchewan is the Representative Plaintiff in the class action, and is represented by Merchant Law Group LLP, who act as Class Counsel for this class action. You may contact Class Counsel directly with any questions:

Merchant Law Group LLP
2401 Saskatchewan Drive, Suite 100
Regina, SK S4P 4H8
Tel: 306-359-7777
Fax: 306-522-3299
Evatt Merchant, K.C.
Email: xarelto@merchantlaw.com

CLAIMS ADMINISTRATOR AND MORE INFORMATION

For more information on the status of the Saskatchewan Settlement Approval Hearing or on how to opt out of, comment on, or object to the Settlement Agreement, or to view the Settlement Agreement, visit www.mnp.ca/xareltosettlement which will be periodically updated with information on the settlement approval process and the Proceeding.

You should consult the Settlement Agreement at the settlement website www.mnp.ca/xareltosettlement or contact Class Counsel or MNP Ltd. for specific details as to your rights and obligations under the Settlement Agreement.

MNP LTD.

Suite 2000, 112 – 4^th Avenue SW
Calgary, Alberta
T2P 0H3
Tel: (877) 500-0792
Fax: (403) 537-8437
www.mnp.ca/xareltosettlement

PLEASE DO NOT CONTACT THE DEFENDANTS OR THE COURTS ABOUT THESE PROCEEDINGS.

This Notice has been approved by the Court of King’s Bench for Saskatchewan.

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