Rollins, Inc. Standard Operating  Procedures  Insider Trading Policy       1  Last Updated 12/4/2024  PROPERTY OF ROLLINS, INC. 2170 PIEDMONT ROAD NE., ATLANTA, GA 30324  Page #:     Rollins, Inc. Insider Trading Policy  Purpose  Rollins, Inc. (“Rollins” or the “Company”) is a public company with stock that trades on the New  York Stock Exchange under the symbol “ROL.”  a. The purpose of this Policy is to keep all directors, officers, and employees of Rollins and its  subsidiaries in compliance with the legal and practical requirements associated with having  stock that trades on one or more national securities exchanges.  b. Securities laws make it illegal for a person to trade in a company’s publicly traded securities  while in possession of Material Nonpublic Information (defined below) relating to that  company or to gift such securities while in possession of Material Nonpublic Information  under circumstances in which it is reasonably likely that the gift recipient will sell the  securities. This conduct is known as “insider trading.” It is also illegal for a person to disclose  Material Nonpublic Information to another who may use this information to trade. This  conduct is known as “tipping.”    Applicability  This Policy applies to all directors, officers, and employees of Rollins and its subsidiaries. Each of  the individuals is also responsible for compliance by Family Members (defined below).    Definitions  The following are definitions of key terms used in this Policy:  a. Blackout Period means the period beginning 15 calendar days preceding the close of each  of the four (4) fiscal quarters and ending not less than 24 hours following the public release  of quarterly financial information by the Company. Exceptions to this Blackout Period may  only be granted by the General Counsel.  In addition, special Blackout Periods may be  imposed by the General Counsel from time to time which will apply to all persons  specifically designated by the General Counsel.  b. Covered Persons are all directors, officers, group vice presidents, division presidents,  certain members of the financial reporting organization as identified by the Chief  Financial Officer (the “CFO”), all administrative assistants reporting to officers, and other  designated employees of the Company or any subsidiary of the Company.  A list of  Covered Persons is maintained by the CFO office.  c. Covered Securities are all equity and debt securities of the Company including Common  Stock, as well as other derivative securities that use Covered Securities as reference  securities. Shares of stock received through a restricted stock grant are considered Covered  Securities. 
 
 
PROPERTY OF ROLLINS, INC. 2170 PIEDMONT ROAD NE., ATLANTA, GA 30324  Rollins, Inc. Standard Operating  Procedures  Insider Trading Policy       2  Last Updated 12/4/2024  Page #:       d. Family Members means members of your family who reside with you (including a  spouse, children (including children in college), stepchildren, grandchildren, parents,  stepparents, grandparents, siblings, and in-laws); anyone else who resides in your  household; any family members who do not live in your household, but whose  transactions in any Covered Securities are directed by you or are subject to your  influence or control; and any entities that you influence or control, including any  corporations, partnerships, and trusts.  e. Material Nonpublic Information is any information concerning the business or operations  of the Company which has not been disclosed to the public, but which could influence  reasonable investors to buy, sell, or hold Covered Securities. Common examples of  information which may be material include dividend announcements, financial results,  financial forecasts (especially earnings estimates), mergers or acquisitions, proposed  issuances of new securities, major marketing changes, significant new contracts, major  litigation, governmental investigations, planned material restructurings, significant  cybersecurity incidents, or significant changes in management.  Information that has not been disclosed to the public is generally considered to be  nonpublic information. To establish that the information has been disclosed to the  public, it may be necessary to demonstrate that the information has been widely  disseminated on a broad-based non-exclusionary basis (e.g., through a Form 8-K filing,  press release, or webcast/conference call open to the public).  Once information is  widely disseminated, it is still necessary to provide the investing public with sufficient  time to absorb the information. As a general rule, information should have been publicly  released for at least 24 hours before it should be considered to no longer be Material  Nonpublic Information.  f. 10b5-1 Plan is a trading plan with respect to Covered Securities that is set up pursuant to  Rule 10b5-1 under the Securities Exchange Act of 1934 (the “Act”), where the person  entering into the trading plan is entitled to certain affirmative defenses if the plan is set  up as a binding contract and is not entered into while in possession of Material  Nonpublic Information.  More information on and key features of 10b5-1 Plans may be  obtained from the General Counsel’s office.  A 10b5-1 Plan must be pre-approved by the  General Counsel or the Senior Managing Attorney – SEC and Corporate Governance.    Policy  a. You may not purchase or sell Covered Securities while in the possession of Material  Nonpublic Information other than pursuant to a 10b5-1 Plan. Further, the Company may  notify you that it is disallowing trades during periods when Material Nonpublic  Information exists, whether known to you or not. In addition, you may not use Material  Nonpublic Information learned through your relationship with the Company to trade in  another company’s stock. All prohibitions related to trading of Covered Securities have  equal applicability to trading in stock of the Company’s business partners. You are  
 
 
PROPERTY OF ROLLINS, INC. 2170 PIEDMONT ROAD NE., ATLANTA, GA 30324  Rollins, Inc. Standard Operating  Procedures  Insider Trading Policy       3  Last Updated 12/4/2024  Page #:     responsible for the transactions of your Family Members and should make them aware of  the need to confer with you before they trade any Covered Securities.  b. In addition to the prohibitions in paragraph (a) above, Covered Persons are prohibited  from purchasing or selling Covered Securities during any Blackout Period other than  pursuant to a 10b5-1 Plan.  c. While in possession of Material Nonpublic Information (and for Covered Persons also  during any Blackout Period), you will not be allowed to take certain actions involving the  Company’s employee stock purchase plan, dividend reinvestment plan, or the Rollins  Stock Fund in the Rollins 401(k) plan. You will not be permitted to:  i. Make an election or amend an election to purchase Rollins stock in any  employee stock purchase plan;   ii. Increase or decrease the amount of your before-tax contributions being made to  any benefits plan if any portion of these contributions would be invested in the  Rollins Stock Fund;  iii. Increase or decrease the percentage of matching contributions being invested in  the Rollins Stock Fund; or  iv. Take a distribution or withdrawal that includes amounts invested in the Rollins  Stock Fund.  d. Certain transactions are not subject to this Policy and are allowed at any time, including  during a Blackout Period as follows:  i. Grants or vestings of restricted stock or performance share units are allowed;  however, the sale of vested restricted stock or performance share units is subject to  this Policy.  ii. The acquisition of Rollins stock pursuant to the normal operation of the Company’s  employee stock purchase plan, dividend reinvestment plan, or 401(k) plan.  iii. 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 or performance share units.  e. You are required to maintain in confidence all Material Nonpublic Information. The  only exception to this shall be the release of information by officers of the Company  specifically authorized to disclose Material Nonpublic Information.  f. Directors and officers subject to Section 16 of the Act and certain other persons  designated by the General Counsel are required to pre-clear all trades with the Senior  Managing Attorney – SEC and Corporate Governance.    g. Directors and officers subject to Section 16 of the Act must report in a timely fashion  purchases, sales, and gifts of Covered Securities, grants, and transactions in restricted  stock on Forms 4 and 5, as appropriate. Copies are to be filed promptly with the  
 
 
PROPERTY OF ROLLINS, INC. 2170 PIEDMONT ROAD NE., ATLANTA, GA 30324  Rollins, Inc. Standard Operating  Procedures  Insider Trading Policy       4  Last Updated 12/4/2024  Page #:     Securities and Exchange Commission in accordance with the Act and maintained by the  Senior Managing Attorney – SEC and Corporate Governance.   h. “Tipping” occurs when an insider communicates Material Nonpublic Information to  another individual (other than another insider with a need to know). Do not disclose  Material Nonpublic Information concerning the Company to any other person, including  Family Members.  If the individual receiving the tip purchases or sells Covered Securities  in violation of this Policy, both the insider and the individual receiving the tip may be  liable for a violation of federal securities laws.   i. Gifts of Covered Securities to a person, entity, or charity are covered by this Policy. All  bona fide gifts of Covered Securities by directors and officers subject to Section 16 of the  Act, and certain other persons designated by the General Counsel, are required to pre- cleared with the Senior Managing Attorney – SEC and Corporate Governance.  j. Directors and officers subject to Section 16 of the Act are prohibited from pledging  Covered Securities or otherwise subjecting Covered Securities to margin call.  For all  others, pledging Covered Securities or otherwise subjecting Covered Securities to  margin call is strongly discouraged.    k. Hedging of financial risk with respect to Covered Securities and similar monetization  transactions are prohibited by this Policy. This includes, but is not limited to, the use of  financial instruments such as prepaid variable forwards, equity swaps, collars, and  exchange funds.   l. You may not sell Covered Securities short and may not purchase or sell puts, calls, or other  derivative securities at any time.       m. This Policy continues to apply to transactions in Covered Securities even after your  termination of service from the Company. If you are in possession of Material Nonpublic  Information when your service terminates, you may not engage in transactions in Covered  Securities until that information has become public or is no longer material.     Violation of Policy  a. Violation of this Policy may result in discipline by the Company, up to and  including termination of employment.  b. The penalties for insider trading include fines and significant jail time.    c. You should keep in mind that if your securities transactions ever become the subject of  scrutiny, these transactions may be viewed after the fact and in the bright light of  hindsight. Any concerns or questions about this Policy should be discussed with the  General Counsel or the Senior Managing Attorney – SEC and Corporate Governance.