Sustainability

Ethics Guideline

ImCut Holding AG · Effective April 1, 2026 · Version 1.0

Our Ethical Foundation

At ImCut Holding AG, we believe that ethical conduct is the bedrock of lasting business success. Our reputation depends not only on what we achieve but on how we achieve it. This guideline establishes the behavioral expectations for all employees, directors, and representatives of our organization. We are committed to operating with unwavering integrity, fostering transparency, and maintaining the trust of our stakeholders across all markets in which we operate.

Core Ethical Principles

1.Integrity in Action

Every member of our organization is expected to demonstrate honesty and moral courage in all professional interactions. Truthfulness is non-negotiable. We hold ourselves accountable for our words and actions, recognizing that ethical lapses undermine both individual credibility and organizational reputation.

2.Transparent Communication

Openness is central to our culture. We encourage candid dialogue, responsible information sharing, and the free flow of accurate data across all levels of the organization. Concealment of material facts or deliberate obfuscation contradicts our fundamental values.

3.Legal and Regulatory Compliance

Adherence to applicable laws, regulations, and internal policies is mandatory. No business objective justifies unlawful conduct. Violations will be addressed decisively, regardless of seniority or performance metrics.

4.Zero Tolerance for Corruption

We maintain an absolute prohibition on all forms of corrupt activity, including but not limited to bribery, kickbacks, facilitation payments, fraud, and embezzlement. Any breach of this principle will result in immediate disciplinary measures, up to and including termination and referral to law enforcement authorities.

5.Competitive Fairness

We compete vigorously but fairly. Anticompetitive behaviors such as bid-rigging, market manipulation, price-fixing, or collusion with competitors are strictly forbidden. Our success must be earned through innovation, quality, and value — not through unethical shortcuts.

6.Conflict of Interest Management

Employees must prioritize the interests of ImCut Holding AG above personal gain. Situations where private interests could influence, or appear to influence, professional judgment must be disclosed immediately to compliance leadership. Failure to disclose conflicts constitutes a breach of this guideline.

7.Safeguarding Organizational Resources

Company assets — including intellectual property, financial resources, data, and physical infrastructure — must be used solely for legitimate business purposes. Unauthorized access, misappropriation, or disclosure of proprietary information is prohibited and will be pursued to the fullest extent of the law.

8.Protection of Reporters

We foster a speak-up culture. Individuals who raise concerns about potential violations of this guideline, applicable laws, or company policies will be protected from retaliation. All reports will be investigated impartially, confidentially, and with due diligence.

Reports may be submitted through: imcut@imcut.ch

Accountability and Enforcement

Adherence to these principles is a condition of employment and engagement with ImCut Holding AG. Management is responsible for modeling ethical behavior and ensuring that these standards are communicated, understood, and enforced throughout the organization. Violations will be met with proportionate consequences, ranging from corrective action to termination and legal prosecution where warranted.

Continuous Evolution

This guideline is a living document. We will periodically review and update its provisions to reflect changes in legislation, industry standards, and societal expectations. Our commitment to ethical excellence is permanent; our methods of achieving it evolve with the times.

Executive Endorsement

Niklaus Boss

Managing Director

ImCut Holding AG

Joel Sagliocco

Managing Director

ImCut Holding AG