Dear colleagues,

As we continue to evolve as an organization, it’s crucial that we continue to uphold our reputation of being a well-respected and ethical company. Part of what makes working at Cook special is how we approach each other, our communities, our customers, and those we partner with to deliver products and services. It’s not just what we do, it’s how we do it. Cook has conducted business with the highest integrity and ethical standards for over 60 years, and we are accountable for acting in alignment with our values.

The Code of Conduct lays the foundation for how we expect all employees to behave, regardless of where we are in the organization. The Code of Conduct is our compliance check: Are our actions allowed? Are we permitted to conduct business in this way? The Cook values are our ethics check: Are our actions ethical? Are we acting with integrity? Can we be proud of what we are doing?

As a reminder, if you are ever uncertain whether an action is ethical or if you have a question about embodying ethical conduct, you should talk to your manager or an Ethics & Compliance representative. Possible violations can also be anonymously reported through the E&C Helpline at CookHelpline.EthicsPoint.com.

Now, more than ever, building a great company requires an unwavering commitment to the highest ethical standards. Each of us plays a role in achieving our vision for the future, and all of us are accountable to reflect our values in our business activities and interactions.

Pete Yonkman President Cook Group and Cook Medical	Drew Northern Chief Ethics & Compliance Officer, Cook Group and Cook Medical

Cook is built upon a foundation of strong values and ethical business practices. Our standards of business conduct serve as an important resource for us in support of our day-to-day decision-making. Our values form the basis of the trust and success that we see in our relationships with customers, suppliers, and each other. Our reputation comes from the sum of our individual actions. Misconduct by just one of us can overshadow hard work by thousands of us.

The Code of Conduct is designed to prevent wrongdoing and to promote:

• Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships
• An inclusive culture, where we value our differences, treat one another with respect, and welcome all ideas and opinions
• Full, fair, accurate, timely, and understandable disclosure in reports and documents we file with regulatory agencies and in our other public communications
• Compliance with External Applicable Standards (EAS)
• The prompt internal reporting of violations of this Code
• Accountability for adherence to this Code, EAS, and our values

This Code should help guide our conduct in the course of our business. Many of the principles described here are general in nature, and not every possible situation is covered. Use common sense and good judgment in applying this Code. Of course, none of us has all the answers, and that’s fine—provided we reach out to find the best answers available. This Code is not the exclusive source of guidance and information regarding the conduct of our business. We should consult applicable policies and procedures in specific areas as they apply.

This Code applies to everyone at Cook Medical, including the board of directors and all officers and employees of the company and its subsidiaries, professional services partners, and third-party contractors, when doing work for Cook Medical. The same high ethical standards apply to all, regardless of job or level in the company. It is the responsibility of each of us to be familiar with the Cook Written Standards CWS relevant to our job functions. CWS include documentation released within the Cook Group Business Policy Management System (BPMS), the Cook Medical Management System (CMMS), Cook Medical employee manuals, or any other formal method of establishing requirements for Cook employees.

We are responsible for recognizing ethical issues and reflecting Cook values in all Cook business activities, but not all circumstances we encounter are straightforward.

As a part of Cook Medical, you are expected to comply with both the letter and the spirit of the Code. This means you must understand and adhere to the standards that apply to your job, even if you feel pressure to do otherwise. The best way to help ensure we are upholding our values and following the Code of Conduct is for each of us to take this as a personal responsibility.

The Code also requires you to seek guidance if you have questions or concerns, and to cooperate fully in any investigation of suspected violations of the Code that may arise in the course of your employment.

Periodically, you may be asked to certify that you will review and understand the Cook Medical Code of Conduct, comply with its standards, and report any violations of the Code by others. This certification is your pledge to uphold the Codeand its expectations and to promptly raise concerns about any situation that you think may violate the Code.

Employees who violate the Code put themselves, fellow employees, and Cook at risk and are subject to disciplinary action up to and including termination of employment.

Cook’s operations and employees are subject to the laws of the countries and jurisdictions in which we operate. It is important that you are aware of—and never intentionally violate—relevant laws and regulations. You should understand that violations of laws or regulations may also result in legal proceedings and penalties including, in some circumstances, civil and criminal penalties that could affect you personally, in addition to a risk of adverse consequences to Cook. You should also be alert to changes in the law or new requirements that may affect your business unit.

An investigation is a good-faith, reasonable, and systematic inquiry aimed at reaching a rational conclusion about the underlying facts and ultimate truth of an allegation.

Cook has established processes and procedures to help ensure that all internal investigations are conducted promptly, fairly, objectively, thoroughly, professionally, and by trained and qualified personnel.

As a manager, you have the special responsibility for building a culture of trust and ethics within your teams. The way you act reinforces your commitment to company values and principles and sets the standards for ethical behavior and trust for your team to follow. Cook’s success depends upon promoting a team environment where compliance is expected and ethical behavior is the norm. Under no circumstances can you ask your team to break the law or violate Cook’s values, policies, and procedures.

Cook believes business decisions should be made with integrity and not influenced by a conflict of interest. A conflict arises when personal, social, political, or financial interests, duties, obligations, or activities, or those of a family member, are or may be in conflict or incompatible with the interests of Cook. Conflicts of interest are a natural part of having relationships and interests outside of Cook, and having a conflict is not necessarily a problem, provided you make prompt and full disclosure of any situation that may involve an actual or potential conflict of interest. Questions regarding conflicts of interest can be submitted to COIDisclosures@CookGroup.com

Conflicts of interest may occur in a variety of forms. Some of the more common types are described in the following sections. For more details, please refer to the conflict of interest policy.*

Cook employees are exposed to a great deal of information while doing their jobs. At times, we may receive information related to another company before the information is made publicly available to ordinary investors. Some of that information may be considered significant, or “material,” and could be important to an investor deciding whether to buy, sell, or hold securities in publicly traded companies with which Cook does business or may be exploring a business opportunity.

Examples of information that could be material are:

• Information about possible business deals, such as a merger, purchase, sale, or joint venture
• Pricing information
• Financial results or changes in dividends
• Important management changes
• Major raw-materials shortages or discoveries
• Significant product or manufacturing process developments
• Gain or loss of a significant customer or supplier
• Major lawsuit or regulatory investigation

We must not use or share confidential information for personal benefit, trade securities based on material inside information, or provide such confidential or inside information to others.

We actively oppose fraud, bribery, and corruption. Anti-bribery, anti-corruption, and “anti-kickback” laws require a commitment from each of us to prevent improper influence in all of our business activities. Become familiar with these laws, including the US Foreign Corrupt Practices Act, the UK Bribery Act, the US Anti-Kickback Statute, and other relevant laws that potentially apply to Cook’s business activities around the world, both for Cook employees and third parties working on behalf of Cook. For more details, please refer to the anti-bribery anti-corruption policy.*

We expect the highest ethical standards in all of our business activities. In addition to observing External Applicable Standards (EAS), you must uphold Cook’s ethical standards and follow Cook Written Standards (CWS), even when they are stricter than local customs or practices.

Everyone at Cook must ensure that services performed by third parties on Cook’s behalf are carried out in a way that meets our expectations and comply with EAS and CWS. We must take reasonable steps to know third parties before engaging them, pay fair market value for the services they provide, and accurately document all payments.

Bribery is illegal everywhere. Furthermore, bribery and corruption restrict economic and social development; contribute to poverty, hunger, disease, and crime; create unfair business environments; and harm customers.

You must not offer, promise, make, approve, provide, request, agree to receive, or accept any payments, gifts, or anything of value for the purpose of gaining or keeping an unlawful business advantage.

Gifts and entertainment can create goodwill in our business relationships but can also make it hard to be objective about the person or company providing them. Although Cook understands that some cultural traditions embrace modest gift giving, anti-corruption and transparency laws and various healthcare industry standards around the world prohibit giving any gifts to healthcare professionals (HCPs), healthcare organizations (HCOs), or government officials. Our choice of suppliers, vendors, and partners must be based on objective factors like cost, quality, value, service, and ability to deliver. We must avoid even the appearance of making business decisions based on gifts received through these relationships. When working with public officials, we must be aware that even simple offers such as purchasing a meal or refreshments may be unacceptable or even against the law. For more details, please refer to the anti-bribery anti-corruption policy.*

It is Cook’s policy that all directors, officers, and employees must comply with international and US federal and state antitrust and competition laws.  These laws prohibit efforts and actions to restrain or limit competition between companies that otherwise would be competing for business in the marketplace. Violations of applicable antitrust and competition laws can result in both criminal and civil penalties. We must be particularly careful when we interact with any employees or representatives of Cook’s competitors. We should use extreme care to avoid any improper discussions with our competitors, especially at trade association meetings or other industry or trade events where competitors may interact. Under no circumstances should we discuss customers, prospects, pricing, market intelligence, or other business terms with any employees or representatives of our competitors.

If we are not careful, we could find that we have violated antitrust and competition laws if we discuss or make an agreement with a competitor regarding:

• Prices or pricing strategy
• Discounts
• Terms of our customer relationships
• Sales policies
• Marketing plans
• Market information (including competitive intelligence)
• Customer selection
• Allocation of customers or market areas
• Contract terms and contracting strategies

Agreements with competitors do not necessarily need to be written agreements in order to violate applicable antitrust and competition laws. Informal, verbal, or implicit understandings—e.g., knowing winks—are also violations. In the US, antitrust violations may be prosecuted criminally as felonies and can result in severe penalties for Cook and any associate or other person who participates in a violation.

Gathering information about our competitors for Cook’s own internal business use, often called competitive intelligence, is a legitimate business practice. Doing so helps us stay competitive in the marketplace; however, we must never use any illegal or unethical means to acquire such competitive information about other companies. Legitimate sources of competitive information include news accounts, industry surveys, competitors’ displays at conferences and trade shows, and publicly available information, including that found on the Internet. We may also gain competitive information appropriately from customers and suppliers (unless they are prohibited from sharing the information) and by obtaining, in appropriate cases, a license to use the information or actually purchasing the ownership of such information. When working with consultants, vendors, and other partners, we must ensure that they understand and follow Cook’s policy on the gathering and use of competitive information.

Our assets are the resources we use to conduct our business. We must use them for legitimate Cook business and appropriately safeguard them, including against cyber-related attack, theft, loss, waste, or abuse. By protecting our assets, we protect our competitive advantage in the marketplace. We also have a responsibility to extend the same degree of care to assets entrusted to Cook by others.

Our assets include but are not limited to:

• Physical assets, such as office furnishings, equipment, and supplies
• Technology assets, such as computer hardware, software, and information systems
• Financial assets, such as cash, securities, and credit cards
• Cook’s name, our brand, and our customer relationships
• Information assets, such as IP, including information about products, services, systems, and other data

Company assets should be used only for the conduct of Cook business, except where otherwise provided by the Code or other Cook policies. Cook business includes, for these purposes, services related to an outside activity that are performed at the request of Cook.

All physical and technology assets provided by Cook, whether used inside or outside of the workplace, are Cook’s property and are provided for your business use. You must never sell them, lend them, or give them away, regardless of their condition or value, unless you are authorized to do so. Please remember that company assets, including email, can be accessed by the company at any time, without notice.

Cook Medical records are our corporate memory, providing evidence of decisions and actions in support of business continuity.

Records consist of physical and electronic forms of information received by Cook or created by or on behalf of Cook in the course of its business activities, regardless of media. Examples of media include but are not limited to papers, photographs, external/thumb drives, CDs/DVDs, video tapes, audio files, backup tapes, computer hard drives, servers, Internet cloud storage, laptops, tablets, printers, phones, and voicemail systems.

Keeping reliable records is crucial to maintaining trust in our business, making good business decisions, and meeting External Applicable Standards (EAS). Reliable records are accurate, legible, complete, and managed. There is never a reason to falsify, backdate, or obscure records—with the exception of de‑identifying personal data when required. Cook is committed to properly labeling, carefully handling, and securing personal, confidential, and proprietary information. We are responsible for having reliable records that are readily available for those who need access.

Records are the property of Cook and must be retained in accordance with applicable policy, procedures, and Records Retention Schedules (RRS). RRS catalogs our record types and retention periods determined by EAS and business requirements. We retain company official records before retention periods expire, and we destroy records after retention periods expire. Exceptions to expired retention periods include the preservation of Cook artifacts and records under legal hold. Failure to abide by these instructions could subject Cook and employees to serious legal and regulatory risks. We have the responsibility to promptly report records that may be deemed unreliable, as well as any pressures to prepare, alter, conceal, or destroy records in violation of company policy.

For more details, please refer to the records management policy.* Visit the Records Management SharePoint* for procedures, additional resources, and RRS applicable to your area of focus and region. Refer to your local management system for additional records instructions. Records-management questions and concerns can be sent to Records.Management@CookGroup.com.

The Global Data Privacy team strives to maintain the integrity of the data entrusted to Cook, including the personal data of Cook’s employees, customers, guests, and business partners as well as that of patients. The team offers guidance on the compliant use, disclosure, transfer, and maintenance of protected data according to current data privacy laws and requirements. Global data privacy and security requirements are quickly evolving and must be taken into consideration when seeking to control or process data. Employees are responsible for understanding and following the data privacy policies and guidance that apply to their job, and they share in the responsibility to protect the data Cook is entrusted with.

While we perform our necessary job functions, we handle regulated personal data that requires us to follow data privacy and security measures. Employees are required to familiarize themselves with the Cook Data Classification Chart* to understand the data being handled in their job and the protection measures that may apply.

Personal data, classified as Cook Class 1 and Class 2 data, is information that can directly or indirectly identify an individual. Examples of Cook Class 1 or Class 2 data include an individual’s name, date of birth, national identification number, or health-related information. As employees who handle the personal data of others, we must do the following:

• Be familiar with company policies regarding handling Cook Class 1 and Class 2 data.
• Complete all required company Data Privacy trainings.
• Act in accordance with all applicable Cook policies and procedures.
• Act in accordance with applicable laws, requirements, and contractual obligations.
• Minimize collection of  Cook Class 1 and Class 2 data to only that which is necessary.
• Collect, use, and process such information only for legitimate and lawful business purposes.
• Provide clear and accurate privacy notices and obtain consent where necessary when collecting or processing personal data.
• Limit data access to those who have a legitimate and lawful business purpose for access.
• Securely store, transmit, and destroy personal information, using Cook IT-approved technology tools (e.g., encryption) and in accordance with the Cook Records Retention program.
• Take care to prevent unauthorized disclosure. In the event of known or suspected loss of data, employees are required to notify their local IT Manager immediately (same day as discovery).

For additional guidance on the handling of personal data and a description of protected information, refer to Cook Medical’s Data Privacy program and policies* and the Cook Group Security Standards (CGSS).* For questions or concerns about the handling of Cook Class 1 or Class 2 data, reach out to your manager or supervisor, Ethics & Compliance representative, or Cook Group Security Standards operations team, or the Global Data Privacy team.

Cook is committed to the ethical, transparent, and accountable development and use of artificial intelligence (AI) in alignment with our mission to improve patient lives. We recognize that AI has the power to enhance innovation, quality, and efficiency, but also carries responsibilities to safeguard individuals, uphold human rights, and maintain trust with our business partners. All employees, contractors, and business partners who develop, procure, or use AI tools must ensure that such technologies are used in ways consistent with our values of integrity, quality, transparency, and respect, and that they comply with all applicable laws to which Cook is subject, in particular privacy, data protection, and medical device regulations.

Our approach to Responsible AI is guided by the following principles:

• Safetyfirst
• Transparency andexplainability
• Fairness and biasmitigation
• Accountability andoversight
• Privacy anddata security
• Sustainability andcontinuous improvement
• Innovation-forward Responsible AI
• Datagovernance

We expect everyone at Cook to understand and apply these principles and related Cook policies in their daily work. This includes using company-approved AI tools responsibly, protecting confidential, privileged information and personal data (Class 1 and Class 2 at Cook), identifying and promptly reporting potential AI-related risks or concerns, and seeking guidance when in doubt. Through shared accountability, we uphold Cook’s reputation as a company that supports innovation in ways that are lawful, ethical, and worthy of the trust our employees, customers, and business partners place in us.

For more details, please refer to the responsible artificial intelligence policy.*

At Cook, having a culture that prioritizes wellbeing, connection, and opportunity (WCO) for all is not simply a goal; it is a fundamental value that guides our decisions. We believe that we perform at our best when our work environment welcomes individuals with different perspectives, personalities, values, and backgrounds. Such an environment also helps us attract and retain the best talents and reach even higher levels of inventiveness, connection to our employees and customers, and, ultimately, better patient outcomes.

Each of us is responsible for creating a culture of trust and respect that promotes a positive, inclusive, and equitable work environment. This means treating each other with respect and courtesy in all of our interactions in the on-site and virtual workplace.

Cook encourages personal participation in the political process in a manner consistent with all relevant laws and the policy on political interactions with covered officials.* We may support candidates or organizations of our choice through personal contributions or by volunteering so long as we separate our personal political activities from our work.

This helps to ensure that we maintain transparency, honesty, and integrity with our stakeholders and each other.  Participation in politics must adhere to the following principles:

• We respect the political opinions of all our colleagues even if those opinions are different from ours, and we do not force our views on them.
• We do not conduct political activities on company time or use company resources such as telephones, computers, or other supplies.
• We do not use Cook letterhead or company email or reference our business address or title when we express a personal view in a public forum (such as a letter to the newspaper or social media post).
• Cook does not reimburse any personal political activity expenses.
• We obtain prior approval through the conflict-of-interest disclosure process before we run for office or get appointed or elected to office.
• We never contact lawmakers on behalf of Cook or lobby with lawmakers for Cook’s interests without getting explicit approval from the Government Affairs team.

Cook is committed to responsible and sustainable business practices and strives to improve our performance to benefit our employees, customers, communities, and the environment.

• We have done a lot to reduce our footprint on the environment and are seeking more ways to prevent pollution, reduce waste, and promote the sustainable use of natural resources.
• We are employing strategies to continually improve our sustainability efforts in our facilities, products, packaging, operations, and supply chain.
• We use energy wisely and efficiently and employ technology to minimize environmental impact.
• We comply with applicable environmental laws and regulations.
• We educate employees whose work affects environmental compliance.
• We educate our employees and inform external stakeholders about our sustainability efforts.
• We promote environmentally sustainable practices and communities.
• We engage our supply chain in supporting our sustainability efforts.

Our future is dependent on the sustainable development of healthcare for our customers and patients and the environment. For more details, please refer to the Social Impact & Sustainability SharePoint.*

Cook Medical strives to be a good neighbor in the communities where we live and work. We recognize the opportunity and obligation to help communities develop and thrive. From the very beginning, the Cook family instilled the company with a strong community-involvement core. Being a good corporate neighbor through philanthropy, volunteerism, and engagement with social enterprises is central to who we are.

Cook’s impact goes beyond the products and patients we serve. Our efforts to be a good and responsible corporate neighbor have a positive social impact on the lives of individuals and help build better communities.

Cook Medical strives to provide a safe and healthy workplace for employees, customers, and visitors to its premises. All managers have the responsibility of ensuring proper safety and health conditions for their employees. Management is committed to maintaining industry standards in all areas of employee safety and health, including industrial hygiene, ergonomics, and safety. To support this commitment, we are responsible for observing all safety and health rules, practices, and laws that apply to our jobs, and for taking precautions necessary to protect ourselves, our coworkers, and visitors. We are also responsible for immediately reporting accidents, injuries, occupational illnesses, and unsafe practices or conditions to our supervisors. As is the case with any violation of the Code, we have a responsibility to report any unsafe behavior or condition regardless of whether we are directly involved or are a witness.

Cook Medical is responsible for complying with national and global regulations, including import and export laws, that relate to international trade involving materials, products, services, and technology. These regulations are complex and may change quickly as governments respond to their political and security environments. When engaging in international trade, it is our responsibility to know, understand, and follow the laws that apply to our work and the transfer of goods and services across national borders. We also expect our suppliers to know, understand, and follow the laws that apply to their products and services in their relationships with Cook Medical and others.

When engaged in international trade, we (and our vendors) must provide accurate product descriptions, tariff classifications, valuation, and country-of-origin statements for all commodities involved in import and export transactions, as required. These rules apply in all contexts, including but not limited to sales, provision of evaluation and demonstration products, raw materials, research and development projects, and donations. If you have a question or concern, you must report it immediately to your supervisor, Human Resources, Trade Compliance, or the E&C Helpline.

Business with certain countries or persons may be restricted or prohibited through economic and other sanctions. Appropriate due diligence should be completed before any transaction that has an international element to determine whether any parties to the transaction are restricted or prohibited by any national government sanctions program.

Social media is changing the way employees work and engage with clients, partners, and each other. Cook Medical has made a strategic decision to embrace social media. We continue to advocate, however, for the use of social media in a responsible, lawful, and professional manner which includes, among other things, following relevant data-protection laws. To assist employees in avoiding the negative aspects of social media, Cook has a social media policy. Below are some guidelines to be followed from that policy:

• Employees are personally responsible for the content they publish on any social media platform.
• Employees are not to post about Cook products or brand names or to post images of products on any social platform, including private/closed groups.
• Employees are to respect the privacy and confidentiality of others, including patients, customers, and Cook employees.

For more information, please refer to the social media policy.*

Third parties who work with us, including suppliers, vendors, distributors, consultants, temporary contract workers, and agencies, are contractually obligated to follow External Applicable Standards (EAS), ethical business practices, and the Supplier Code of Conduct for labor, health and safety, environmental protection, and management systems. Third parties working with Cook should have the appropriate contracts in place before beginning work. When identifying potential third parties to work with, we take steps to mitigate risk by conducting due diligence and background checks to better know our business partners and gain a better understanding of the medical devices and healthcare market in which they operate.

It is our responsibility to accurately represent Cook and our products in our marketing, advertising, and promotional activities.

The marketing and sale of medical products must follow the regulations of each country where the products are sold. All Cook companies that market and sell medical devices, all Cook employees, and all Cook distributors must commit to market and sell our medical products only for the product’s approved intended uses, sometimes referred to as “on-label,” as determined by the regulators in the countries where the medical product is registered and available for sale. We are also prohibited from promoting products prior to receiving the proper regulatory authorization.

Sometimes it is necessary to make comparisons between our products and our competitors’ products. When we do so, we make factual and accurate statements that can be substantiated with the appropriate level of documented evidence.

When doing business with federal, state, or local governments, we must ensure that all statements and representations, including costs and other financial data, to government procurement officials are accurate and truthful. If our assignment directly involves the government or if we are responsible for someone working with the government on behalf of Cook, we must be alert to the special rules and regulations applicable to our government customers. We must take additional steps to understand and comply with these requirements and must avoid any conduct that could appear improper when dealing with government officials and employees. Payments, gifts, or other favors given to government officials or employees are strictly prohibited, as they may appear to be a means of influence or a bribe. Failure to avoid these activities may expose Cook to substantial fines and penalties. For these reasons, any sale of our products or services to any federal, state, or local government entity must be in accordance with Cook policy.

In accordance with the Cook value of “Be Transparent”, our goal is to appropriately share information with those who need it. If you have a concern about a possible violation of any federal, state, or local law, rule, or regulation, the best practice is to bring that concern to your Ethics & Compliance representative. You are permitted to raise those concerns to the appropriate governmental or regulatory agency if you choose, however, and you are not required to notify Cook that you have done so. For more details, please refer to the whistleblowing policy.*

If you are contacted by law enforcement or other government officials with respect to your Cook duties, you should immediately contact the Legal Function. The Legal representative will advise you on how to best respond and may issue a document hold to ensure that all relevant information is retained and available as needed.

It is never acceptable to take any part, no matter how small your role, in any activity that involves theft, fraud, embezzlement, extortion, or misappropriation of property. A fraud occurs any time someone helps conceal, alter, falsify, or omit information in records, either for Cook’s benefit or at the direction of any others. You must refuse to engage in any questionable activities and must follow up on any suspicions.

Cook strongly advocates for fundamental human rights and believes that everyone around the world should be treated with dignity, fairness, and respect. We expect our suppliers and direct contractors to promote the health and safety of their workers and to operate in compliance with human rights laws. We are also committed to the responsible sourcing of minerals throughout our supply chain. Cook does not use or condone the use of slave labor or human trafficking and denounces any unsafe working conditions or degrading treatment of individuals.

We are committed to following all applicable labor, wage, and hour laws and regulations.  Any Cook employee or third-party contractor paid based on hours worked must report and record all time worked accurately in accordance with established local procedure.

Cook will permit exceptions to the policies set forth in this Code only where circumstances warrant granting an exception based on the best interests of Cook. Any exception pertaining to an employee must be approved by the Chief Ethics & Compliance Officer and by the President. Exceptions to the Code for directors and executive officers may be made only by those members of the board of directors not involved in the possible exception and must be promptly disclosed as required by law or regulation.