At On point medicals GmbH (“Onpoint”), we are convinced that sustainable success is based on trust, integrity, and mutual respect. Our Code of Conduct is not a bureaucratic set of rules, but rather an expression of our values and a guide for responsible conduct in our daily work. It demonstrates what we stand for—toward our customers, partners, and in our interactions with one another.

Introduction We are obligated to conduct our business activities ethically, sustainably, and in accordance with applicable law. The principles contained in the Code of Conduct are not intended for the purpose of control, but rather to encourage the conscious assumption of responsibility.

Binding Set of Rules The Code of Conduct forms the basis for guidelines in the following areas, among others:

• Personal responsibility of managers and employees
• Conflicts of interest
• Soliciting, offering, and accepting benefits
• Expenses, donations, and sponsorship
• Handling of property and confidential information
• Data protection and protection of trade secrets
• Use of artificial intelligence
• Fair competition
• Environment, safety, and health

To whom does the Code of Conduct apply? The Code of Conduct is binding on all employees, executives, and management. Everyone is required to adhere to these principles and to actively seek guidance when in doubt.

Fundamentals Compliance We comply with all applicable laws and always adhere to the higher standard when regulations differ. Business success never justifies violations of the rules.

Reporting Channels and Whistleblower Protection Serious violations must be reported immediately—either to the appropriate manager or through the designated confidential or anonymous reporting channels.

•  Reports are treated confidentially.
• There will be no adverse treatment for reports made in good faith.
• Retaliation itself is a serious violation.
• Reports are reviewed objectively, safeguarding the interests of all parties involved and with a focus on proportionality.

We expect employees to address potential violations and contribute to their resolution.

Consequences of Violations Serious or ongoing non-compliance with the principles set forth in the Code of Conduct can damage Onpoint’s reputation and competitiveness and will therefore always result in the necessary consequences under labor law. When assessing violations, the severity, circumstances, and whether the violation is a repeat offense are taken into account. Affected individuals are given the opportunity to comment before any measures are taken.

General conduct Mutual respect, honesty, and integrity We stand for equal opportunity and impartial conduct. Harassment, bullying, abuse of power, and any form of inappropriate behavior have no place here—regardless of the medium.

Nonviolence and respectful communication We reject any form of physical, psychological, or verbal violence. Conflicts are handled objectively, fairly, and with a focus on finding solutions.

Personal Commitment Every individual shapes Onpoint’s reputation. Leaders exemplify our values and ensure clarity and implementation of these principles.

Conflicts of Interest Conflicts of interest can impair judgment and must be avoided. Potential conflicts—such as those arising from personal relationships, outside employment, or financial interests—must be fully disclosed.

Handling Benefits and Corruption We maintain a zero-tolerance policy toward corruption. We do not solicit, offer, or accept any improper benefits.

Gifts and Invitations

• Gifts valued at up to €50 must be assessed at one’s own discretion.
• Gifts valued at over €50 must be approved by a supervisor.
• Gifts valued at over €100 must be reported to management.
• Accepting money, as well as inappropriate or influence-seeking gifts, is prohibited.

Invitations must always be critically examined and evaluated based on the occasion and context. Gifts to public officials are strictly prohibited. Requested or inappropriate benefits must be firmly rejected. In case of doubt, consult your supervisor.

Donations and Sponsorship These must not be used to circumvent the rules outlined above.

Handling of Property and Information Company Property Company property is used exclusively for business purposes and protected against misuse.

Data Protection and Confidentiality We comply with data protection laws (especially the GDPR) and handle data with care. Confidential information and trade secrets must be always protected—even beyond the employment relationship.

Handling Artificial Intelligence KI is a supportive tool; responsibility remains with humans. Therefore:

• Do not enter confidential or personal data into public AI systems.
• Results must be critically reviewed.
• Significant, legal, personal, or business-critical decisions are always made by humans.
• Do not use AI for discrimination or to mislead others.
• Document to an appropriate extent and consult with others in case of uncertainty.

Competition and Market Conduct

We are committed to fair competition and reject any form of market distortion, in particular: price-fixing, market-sharing, the exchange of sensitive information, and the abuse of market power will not be tolerated.

Supplementary Compliance Principles

Our commitment is to act responsibly, transparently, and in accordance with applicable law—even beyond the principles already described. The following additions specify this commitment in key areas of our business operations.

Integrity in Business Transactions

We ensure that all business transactions are documented accurately, completely, and in a traceable manner. Incomplete, misleading, or deliberately falsified records contradict our values and are prohibited. Transparent accounting is an essential component of responsible corporate governance.We do not tolerate any form of money laundering or involvement in non-transparent financial structures. We only enter into business relationships with partners whose integrity and reliability we can verify.

Responsibility in International Business Relationships

We comply with all applicable regulations regarding export controls, embargoes, and international sanctions. We do not engage in business activities that could violate such regulations.

Collaboration with Business Partners

Our responsibility does not end at our own corporate boundaries. We expect our business partners to adhere to comparable standards regarding integrity, legal compliance, and responsible conduct. Before entering into business relationships, we vet our partners both prior to and during the course of our collaboration, paying particular attention to potential conflicts of interest, legal risks, or reputational risks.

Political Activities and Advocacy

Onpoint maintains political neutrality. Political activities conducted on behalf of the company are carried out exclusively in accordance with applicable law and require appropriate coordination and approval. Corporate donations or other contributions to political parties, public officials, or similar institutions are made only in strict compliance with legal requirements and internal approvals. 

Information Protection and IT Security

The protection of our data and systems is a shared responsibility. We ensure the secure use of IT systems and protect them from unauthorized access, misuse, or loss. Security incidents, vulnerabilities, or suspicious activity must be reported immediately. Compliance with internal IT and security policies is mandatory for all employees.

Responsible Use of Company Resources

Company resources are generally used for business purposes. Personal use is permitted only within the scope of applicable regulations and must not interfere with business operations or undermine trust in our integrity.

Implementation, Training, and Continuous Improvement

The Code of Conduct and the supplementary principles are addressed through training and continuously improved as needed. Employees receive appropriate training on relevant topics.

ESG (Environmental, Social, and Governance), Human Rights, and the Supply Chain

We respect human rights and fair working conditions and strictly reject child labor, forced labor, and exploitation. This responsibility also applies to our partners, whom we select based on integrity, compliance with the law, and sustainability. We do not tolerate corruption or unethical practices. In the event of violations, we take action, up to and including the termination of business relationships. We understand sustainability as a responsibility toward the environment, society, and future generations.  The protection of our employees is our top priority: we are committed to safe working conditions, the prevention of physical and psychological hazards, and the responsibility of each individual in their daily work.

Mag. Alexander Höfinger CEO

2026-06-03