Switzerland corporate.docmorris.com

Foreword by the Board of Directors and Executive Board

Dear Colleagues

As employees of DocMorris, our task is to ensure the long-term success of our company. That way we create sustainable value for our customers, shareholders and staff. To achieve this it is essential that our conduct is legally and ethically beyond reproach. We have therefore developed a code that orients our business activity around the values of integrity, transparency and mutual respect. This code of conduct is a guide for all employees at all levels and in all companies which form part of DocMorris. We expect all employees to live out our values and seek help from their line managers and the specialists in Legal and HR in the event of any questions.

Thank you all for your support.

For the Board of Directors and Executive Board of DocMorris AG

$\mathcal{S}$

Prof. Stefan Feuerstein Chairman of the Board

Mm.

Walter Oberhänsli Executive Director and CEO

not be shareholders in business partners of DocMorris or place orders with related parties, especially family and friends.

Any conflicts of interest must be disclosed to the line manager immediately. The line manager must ensure that the person in question takes no decisions in the relevant area and that conflicts of interest are avoided.

Avoiding corruption and the right way to handle invitations $\boldsymbol{4}$ and gifts

Employees must not give or take bribes.

Employees must follow all applicable legislation on preventing corruption. In particular, no inappropriate benefits may be offered, promised or granted, either directly or indirectly, to members of governing bodies (e.g. supervisory board, board of directors, management board, executive board), employees, representatives or consultants of business partners, or to civil servants or public officials. Employees of DocMorris also may not demand, arrange or accept any inappropriate benefits.

Invitations and gifts in kind may be given and accepted on a socially normal scale bearing in mind local politeness and customs as a normal sign of respect and courtesy between business partners, provided such giving and receiving complies with the relevant legislation. Giving or accepting money or money-like gifts (such as vouchers) is not permitted. Unless stricter statutory provisions or internal rules apply, invitations and gifts in kind worth up to CHF 250 (in Switzerland) and EUR 200 (in the EU) per instance and three times a year at the most and per recipient are permissible. Invitations and gifts in kind must not result in the recipient feeling obliged to take or refrain from a particular action. If invitations and gifts in kind exceed the permitted scale, the Legal department of DocMorris AG must be informed in advance and permission requested.

Using and protecting company property 5

Employees must use the resources provided to them efficiently, carefully and only in the interests of DocMorris, and must protect the company's property. In particular, employees may not use property of DocMorris for private purposes without express permission.

DocMorris

Dealing with confidential information 6

Maintaining confidentiality 6.1

Employees must maintain the confidentiality of business information to which they have access in the course of their duties or for any other reason. This applies in dealing with external parties; for confidential projects and sensitive information, it also applies in dealings with fellow colleagues. The duty to maintain confidentiality continues to apply even when employment at DocMorris has ended.

$6.2$ Dealing with insider information and trading in securities of DocMorris AG

The Insider Trading Policy regulations of DocMorris apply to dealing with insider information and trading in securities of DocMorris AG. These state that employees in possession of price-sensitive confidential information may not use it to buy or sell shares or derivatives of DocMorris. Price-sensitive confidential information may also not be passed on to third parties. In the event of uncertainty about buying or selling shares or derivatives or issues related to the Insider Trading Policy regulations you must contact the CFO or the Legal department of DocMorris AG.

$6.3$ Data protection, protecting personal rights and privacy and the integrity of DocMorris IT systems

DocMorris respects privacy and protects the personal data of its customers, employees and business partners.

Employees must observe the applicable statutory rules on data protection and the internal rules, directives, regulations, etc. on data protection and IT security and must ensure the protection and integrity of personal data in their area.

In their daily work and in the areas over which they have an influence, employees must ensure that the IT systems of DocMorris are not compromised. In particular, passwords must be treated as strictly confidential and suspicious emails identified and reported to the IT department immediately. Similarly, in the event of electronic enquiries or instructions, transactions must only be executed or approved in compliance with the dual-control principle (i.e. checking and approval must be carried out by two employees who, as far as possible, are functionally separate).

Fair competition $\overline{7}$

DocMorris and its employees are committed to the principles and rules of fair competition and comply with the applicable provisions of competition law. In particular, no agreements, deals, arrangements, etc., whether formal or informal in nature, may be made with companies on the same level in the market (e.g. competitors) or upstream or downstream (e.g. manufacturers, wholesalers, retailers) seeking to mutually coordinate market behaviour or set or fix prices. In the event of any uncertainty, the relevant Legal department must be contacted.

Safety, health, ban on discrimination and harassment 8

Employees must comply with all applicable statutory rules on safety and health protection.

DocMorris strives to create a positive atmosphere and culture at work and all employees are expected to contribute towards this. All employees are entitled to be treated politely, respectfully, fairly and without discrimination by line managers, colleagues and business partners. No one may be disparaged, harassed or disadvantaged without good cause, specifically on account of their gender, age, religious, philosophical or political convictions, lifestyle, social position, skin colour, nationality, origin, race, language or physical or mental impairment. All employees must conduct themselves accordingly and respect their colleagues' privacy.

$\boldsymbol{Q}$ Implementation

This Code is provided to all employees, either electronically or in hard copy. Members of Executive Board and managers in the segments must set a conspicuous good example and ensure that the values and standards of conduct at DocMorris are observed and lived out in practice in the areas for which they are responsible. Implementation of this Code will be reviewed at regular intervals.

Whistleblowing 10

To protect DocMorris, all employees must immediately report any misgivings they have about compliance with the law and this Code or instances of discrimination or harassment to their line manager, Human Resources or the Legal department or use the online whistleblowing system. Reports over the whistleblowing system can be sent anonymously. Reports made on the basis of sufficient indications of irregularities have no negative consequences of any kind for the person who submits them. DocMorris does not tolerate any action taken against employees who blow the whistle.

Entry into force 11

This Code of Conduct in the present version was approved by the Board of Directors on 13 December 2021. It comes into effect immediately and replaces the version of 20 June 2017.