ICU Medical connects patients and caregivers through safe, life-saving, life enhancing IV therapy products, systems, and services. We strive to create long-term value for shareholders while being a responsible corporate citizen and a good employer.

Our business activities generate various type of taxes. We pay corporate income taxes, employment and other taxes as well as collect and pay employee and indirect taxes such as VAT.

ICU Medical is committed to complying with laws in a responsible manner and to building and maintaining constructive working relationships with tax authorities based on principles of mutual transparency and trust. We support public efforts to increase trust in tax systems and initiatives for improvement of tax regimes to encourage investment and economic growth.

The above principles align with our code of conduct that everyone at ICU Medical is expected to adhere to. Our commitment, applicable to all countries and all employees, is as follows:

1. Tax Planning
ICU Medical engages in efficient tax planning that supports our business operations and reflects commercial and economic activity. This includes taking advantage of available tax incentives and exemptions. We adhere to relevant tax laws and seek to minimize risk of uncertainty or disputes.

We operate in a manner in which our commercial objectives are aligned to meet our legal obligations in an ethical manner. We do not engage in artificial tax arrangements. We do not operate in a manner that we believe is contrary to the clear intentions of legislation concerned.

2. Relationships with tax authorities
We are committed to building constructive working relationships with tax authorities based on full disclosure and mutual respect. We work collaboratively with tax authorities to resolve disputes in order to remove uncertainty in our business operations and transactions.

Where appropriate, we engage with tax authorities to help shape proposed legislation or help in development of future tax policy either directly or through trade associations and other similar organizations.

3. Transfer Pricing
We seek to price transactions between ICU Medical companies as if they were between unrelated parties in compliance with the OECD Transfer Pricing Guidelines and the laws of the relevant jurisdictions.

4. Tax Risk Management
We identify, assess and manage risk as part of our internal control processes. We have implemented risk management measures including controls over compliance processes to monitor their effectiveness. We ensure that staff with tax responsibilities as well as staff whose business operations have a direct tax impact have a clear understanding of how tax risk is identified, assessed and managed.

5. Governance

ICU Medical’s VP of Taxes owns and implements our tax approach which is approved by the Board. We manage tax risks and uncertainties in line with our Governance framework.

Our VP of Taxes is responsible for ensuring that appropriate tax policies, processes and systems are in place and used consistently worldwide and that the global tax team has the required skills to support and implement the adopted tax approach.

We regard the above to comply with our duty under Schedule 19 of UK Finance Act 2016 for the period ended 31 December 2021.