BUSINESS ETHICS POLICYINFICON Group
Business Ethics Policy
Message from the CEO ......................................................................1
Ethics and Business Conduct .............................................................2
Conflict of Interest and other Misconduct ........................................4International Business ......................................................................5
Corporate Information and Confidentiality .......................................6
Employment Practices .......................................................................7
Health and Safety ..............................................................................8
Environment .....................................................................................8
Compliance .......................................................................................9March-2024[- 0 -]

Ethics Policy

BUSINESS ETHICS POLICY

Message from the CEO
INFICON is an international company with a strong reputation for providing market leading vacuum
instrumentation products and smart manufacturing software which help customers increase theirperformance. Our objective is to develop and manufacture products that cater to vital needs of today
and tomorrow in Semiconductor and other high-tech industries.
Ethical conduct is defined as that which is morally correct and honorable. This Business Ethics Policy
provides the legal and ethical framework for our company and establishes INFICON's commitment tofollowing ethical business practices. It details the fundamental principles of ethical businessbehaviour and defines the responsibilities of all employees and Company representatives.
Familiarize yourself with this Ethics Policy and with the other corporate Policies that relate to it. I
expect managers and supervisors to promote compliance by example and by providing guidance toother employees.
In the course of conducting your business for INFICON you will occasionally find yourself faced withdifficult choices. A circumstance will present itself that gives you reason to pause and consider
whether you are about to violate the principles contained in this Ethics Policy. At such times always
pause and defer your decision until you have had the opportunity to discuss the matter with amember of the Group Management (Chief Executive Officer & Chief Financial Officer), or the Audit
Committee or your immediate manager.

Oliver Wyrsch
President and Chief Executive Officer
INFICON Holding AG

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Ethics Policy

BUSINESS ETHICS POLICY
Ethics and Business Conduct
This Code of Business Conduct and Ethics is intended to articulate INFICON´s expectations aboutbusiness conduct of the Company´s directors, officers and employees. This Code is not exclusive: TheCompany personnel shall also be subject to other applicable policies of the Company as thosepolicies may from time to time be implemented. This Code applies to the Company and all of its
subsidiaries and other business entities controlled by it worldwide.
All employees contribute to INFICON's reputation; therefore, it is important that all employees
adhere to ethical guidelines. Always follow these principles:Compliance with Laws
INFICON business, whether domestic or international, must be conducted in compliance with allapplicable laws and regulations. Be aware of the legal requirements that apply to your job, andfollow those laws strictly. INFICON will not tolerate illegal activity conducted for personal gain or on
the Company's behalf.
Lack of knowledge of the law will not excuse your non-compliance with this Ethics Policy. lf you havequestions or if you require assistance with legal matters contact your immediate manager or theGroup Management (Chief Executive Officer & Chief Financial Officer) of INFICON.
Honesty and Integrity
Consider INFICON's reputation and credibility in all your business relationships. Integrity is one of ourcore values. Be honest and honorable in all dealings with other employees, the public, the business
community, shareholders, customers, suppliers, competitors, and government authorities.
Entertainment and Gifts
Never accept a gift, entertainment, or any other benefit from an individual or organization doing
business with INFICON if that gift, entertainment or benefit could influence your decisions or, if itwere made public, might appear to have influenced your business decision.
Any gift, entertainment, or benefit you provide to a business associate must be modest in scope andvalue. Never provide a gift, entertainment or benefit that contravenes any applicable law or contract
term or that is large enough to influence, or appear to influence, the recipient's business decisions.
Ensure that you record (in INFICON's accounts) all expenditures on gifts, entertainment, and otherbenefits.
Consultant Fees, Commissions and other Payments
Never give or receive any payment that falls outside the normal conduct of business. Ensure that allconsulting or agency fees, commissions, retainers or other payments are reasonable in the context ofacceptable commercial practice and that they comply with applicable corporate policies. Properly
record all payments given or received in the Company’s accounts. If you engage in giving or accepting
kickbacks, bribes, payoffs or other illegal or similar transactions you will be subject to immediate
discipline, up to and including dismissal in accordance with INFICON's policies.

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Ethics Policy

BUSINESS ETHICS POLICY

Political Contributions
INFICON does not wish to discourage the participation of employees in political and related activities.
However, you may not make political contributions on INFICON's behalf, either directly or indirectly,
without the prior written approval of INFICON's Group Management (Chief Executive Officer & Chief
Financial Officer).
Compliance with Accounting Controls and Procedures
Always comply with the Company's accounting procedures and controls, and all applicable laws.
Properly record all financial data and transactions. INFICON does not permit the use of “slush funds",
or other unrecorded funds or assets. All disclosure contained in reports and documents filed withsecurities regulators and other governmental authorities by or on behalf of INFICON shall be full, fair,accurate, timely and understandable.
Prevention of Child or Forced Labor
INFICON is committed to conducting business in an ethical and responsible manner and is opposed toslavery or trafficking of persons. INFICON prohibits the use of child labor and use of forced, bonded,or indentured labor practices and prison labor in our operations. INFICON expects its suppliers tocomply with these same business and ethical standards.
Importing or processing of Minerals and Metals from Conflict-Affected Areas
INFICON is committed to avoiding importing or processing of minerals and metals (tin, tantalum, andtungsten, their ores, and gold) originating from conflict-affected and high-risk areas. INFICON expects
its suppliers to comply with the same business and ethical standards.

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BUSINESS ETHICS POLICY
Conflict of Interest and Other Misconduct
INFICON expects all employees to act only in the best interests of the Company. Avoid situations oractivities where your personal interests are, or may appear to be, in competition with or inopposition to INFICON's interests. This includes situations that might prevent you from devoting
proper time or attention to your duties, or situations that might affect your judgment or ability to act
in INFICON's best interest. Should you be faced with a situation or a transaction that might give rise
to such a conflict of interest, you must disclose this information to a member of the GroupManagement (Chief Executive Officer & Chief Financial Officer).
It is not possible to give a comprehensive list of all potential conflict of interest situations. However,the following are examples of such conflicts:a) Competing business interests.
• If you or someone close to you owns or participates in a business that competes with, isserved by or provides services to INFICON, it may conflict or interfere with your ability towork for INFICON. To clarify such cases, you must inform the Group Management (Chief
Executive Officer & Chief Financial Officer) and seek guidance.
• If you are going to participate in any business venture that may compete with INFICON,
whether directly or indirectly, you must obtain prior written approval from the GroupManagement (Chief Executive Officer & Chief Financial Officer) or, if you are a director of theCompany or member of the Group Management (Chief Executive Officer & Chief FinancialOfficer), the Audit Committee of the Board.
• You may not engage, on INFICON's behalf, in any transaction with a business in which you ora family member has an interest unless you have prior written approval from the GroupManagement (Chief Executive Officer & Chief Financial Officer) or, if you are a director of theCompany or member of the Group Management (Chief Executive Officer & Chief FinancialOfficer), the Audit Committee of the Board.
• If you want to serve on the Board of Directors or a similar body of any company, you mustobtain prior written approval from the Chief Executive Officer (respectively Chairman of theBoard in case of Group Management (Chief Executive Officer & Chief Financial Officer)b) Insider trading.
• You must adhere strictly to the Company's Confidentiality of Information, Insider trading andreporting and applicable laws on insider trading. If you have questions regarding the law orthe Company's policy in this area, seek advice from the Chief Financial Officer.
c) Use of employment activities for personal gain.
• Never abuse your position at INFICON by seeking personal gain, e.g., by obtaining personal
benefits from those doing or seeking to do business with INFICON.
d) Misuse of Company property or resources.
• As an employee, you are entrusted with Company property and resources including vehicles,computer equipment and software, corporate information and tools. Use these resources forCompany business, not for personal gain.
e) Personal transactions with INFICON business associates.
• Never accept a loan from an individual or organization that does business with INFICON,
unless the individual or organization is in the business of making loans.

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Ethics Policy

BUSINESS ETHICS POLICYInternational BusinessIn the course of your employment with INFICON, you may be faced with legal and ethical issues thatarise as a result of the Company's international business activities. In addition to applicable local
laws, INFICON must comply to U.S. law relating with international business transactions.
International Bribery Legislation
The United States have laws that prohibit domestic companies from engaging in corrupt practices
when dealing with foreign governments. In the United States the law is called the Foreign Corrupt
Practices Act. These laws make it an offence to corruptly make or offer any payment, gift, or otherbenefit to a foreign government official in order to gain some business advantage. Engagement inthese activities can result in penalties including personal and corporate fines and imprisonment ofindividuals. Therefore, it is imperative that all INFICON directors, officers, employees, agents andother representatives adhere to all applicable corrupt practices legislation.
In some countries “facilitating" payments or tips are used to expedite routine government services(e.g. obtaining permits, processing visas or obtaining telephone service). Even when these payments
would be legal, INFICONs policy disfavors such payments and requires the written permission of theChief Executive Officer or the Chief Financial Officer prior to making any facilitating payment.
More detailed information on these laws is available from the Human Resources department or theINFICON Intranet.
International Sanctions and Trade Restrictions
INFICON is subject to a variety of laws relating to international trade and the export of equipment
and technology. In addition to local laws, INFICON is subject to U.S. trade laws and economic
sanctions, both directly and as a result of dealing with U.S. suppliers of goods or services.
To ensure we comply with all applicable laws, INFICON has established procedures for evaluating andprocessing international contracts. For more information or assistance with international tradeissues, contact INFICON’s Group Management (Chief Executive Officer & Chief Financial Officer).

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Ethics Policy

BUSINESS ETHICS POLICY
Corporate Information and Confidentiality
Every Company employee has access to some type of confidential information. For example, thefollowing information is considered confidential: technical information about INFICON instruments,
sensors, tools or equipment; financial data; information about how certain processes work; pricelists; methods of conducting operations; information about INFICON´s customers and suppliers;
business plans and intentions; legal matters; applications for patents and trademarks; and softwaredevelopments. Commercial and technical information received on a confidential basis from thirdparties such as suppliers, customers, and partners are also confidential information.
All INFICON employees will receive the Business Ethics Policy when starting their employment withINFICON and must confirm receipt. Except as required in the normal course of performing your job,
do not reveal confidential information to anyone, either while employed by INFICON or after you
leave the Company, unless you have written authorization from the CEO of INFICON.
Corporate Communications
All public communications made by or on behalf of INFICON shall be full, fair, true and clear, timelyand understandable.
The Company's Group Management (Chief Executive Officer & Chief Financial Officer) has designatedindividuals to speak to the public on behalf of the Company. Do not speak publicly on behalf of theCompany unless you are specifically authorized to do so. Investor relations are handled by the Chief
Executive Officer and the Chief Financial Officer.

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Ethics Policy

BUSINESS ETHICS POLICY
Employment Practices
INFICON strives to provide a positive work environment that supports productivity, dignity and selfesteem, and the pursuit of personal goals.
Our employment policies and procedures provide for equal opportunity and fairness in employment
decisions. We do not discriminate on the basis of race, color, ancestry, place of origin, religious
belief, physical or mental disability, age, gender, sexual orientation, marital status, family status orsource of income, and we take steps to comply with all applicable affirmative action legislation. We
also endeavor to ensure that all employees are treated fairly in all aspects of the employment
relationship, including performance appraisals, compensation, opportunities for advancement, anddisciplinary matters.
We believe that employees are entitled to privacy and we recognize our obligations as set out inapplicable privacy legislation. INFICON collects only necessary personal information, and we protect
confidential information using well-defined procedures.
Finally, we do our best to ensure that employees are treated with dignity and respect by theCompany and by fellow employees. INFICON makes every effort to protect employees fromharassment and takes action to address any concerns that arise in this regard. INFICON deals withharassment or other improper conduct in accordance with the Company's policies on harassmentand on employee discipline.
If you have employment-related questions or issues, you may speak with your immediate supervisor
or with a member of the Human Resources team.

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BUSINESS ETHICS POLICY
Health and Safety
INFICON's foremost concern is protection of the health and safety of all employees.
We have adopted policies and procedures that are aimed at ensuring that INFICON meets or exceeds
all applicable health and safety laws and regulations as well as prevailing industry standards. We
strive to fully implement all safety policies and procedures.
Complete compliance with safety policies and procedures requires the cooperation of everyemployee. Be aware of how the company's health and safety policies apply to you, and conduct yourduties and responsibilities in compliance with these policies.

Environment
INFICON is committed to minimizing the effects of our operations on the natural environment. We
endeavor to meet all regulatory and industry standards by implementing appropriate measures for theassessment of potential environmental effects, for the prevention of these potential effects and forappropriate response to any incidents that might occur.
As a INFICON employee you are expected to be familiar with the required environmental standards that
apply to your work at INFICON, and to comply with these standards at all times.

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Ethics Policy

BUSINESS ETHICS POLICY
Compliance
INFICON has adopted this Ethics Policy, and we trust that all employees will use their best judgment
to ensure they comply with its principles.
INFICON cannot control all aspects of employee conduct. However, to ensure the Ethics Policy isupheld we have implemented a compliance framework that includes the following:
Compliance
The Group Management (Chief Executive Officer & Chief Financial Officer) is responsible foroverseeing compliance with this Ethics Policy. Group Management (Chief Executive Officer & Chief
Financial Officer) will receive and investigate complaints and reports of non-compliance and may
delegate such investigation to the Compliance officer or external audit specialist for report back tothe Group Management (Chief Executive Officer & Chief Financial Officer).
Employee Communication/Training
The Company will provide employees with an opportunity to become familiar with the Ethics Policy
and related policies and procedures. We will train and communicate the contents of the Ethics Policy
to all new employees within the orientation programs right after joining INFICON, furthermore wewill provide regular updates and refreshers on a bi-annual basis and ongoing opportunity for
employees to ask questions and seek additional information.
You will find this policy and some reference materials on the INFICON Intranet.
If you wish to obtain additional materials, or discuss any aspect of the Ethics Policy, speak with yourimmediate supervisor, a senior member of the Human Resources team or the Group Management(Chief Executive Officer & Chief Financial Officer).
Reporting
To implement the Ethics Policy, INFICON needs the full cooperation of all employees. We expect
employees to comply with all aspects of this Ethics Policy, and encourage employees to report anyviolations they observe to any member of the Group Management (Chief Executive Officer & ChiefFinancial Officer) or a senior member of the Human Resources department or, if appropriate, to theAudit Committee of the INFICON Board of Directors, attention to Dr. Reto Suter, In der Deisten 11,8125 Zollikerberg, Switzerland, email: INFICON@whistleblowercontact.com . As an alternative andadditional option, you can also use the international phone number +49 221 2888375 to report any
violation or issues. All information will be dealt with confidentiality no matter which reporting
channel you choose.
It is a violation of this Policy to intimidate or retaliate against any person who has reported aviolation of this Ethics Policy.
Compliance Documentation
In order to be able to document the trainings and that you comply with this Policy you may be asked
to complete/sign a document stating you have complied with this Ethics Policy.

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Ethics Policy

BUSINESS ETHICS POLICY

Enforcement
INFICON must make sure prompt and consistent action against violations of this Policy.
The Group Management (Chief Executive Officer & Chief Financial Officer) will investigate all reports
or other information received regarding alleged violations of this Ethics Policy, and will report to theBoard of Directors on the results of investigations of material violations.
Any person, who is found to have violated this Ethics Policy, or any related corporate policy, will be
subject to appropriate disciplinary action as deemed appropriate, including, but not limited to,reassignment, demotion, dismissal and, in the event of criminal conduct or other serious violations ofthe law, notifications of appropriate governmental authorities.
Waivers of Compliance
Only the Board of Directors has the authority to grant a waiver of compliance with this Policy formembers of the board of directors or INFICON´s group management (Chief Executive Officer & Chief
Financial Officer).

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Ethics Policy