Governance Information

Sonova is committed to conducting business ethically and responsibly in all interactions with stakeholders and across the organization. This commitment is grounded in compliance with applicable laws and regulations in all countries where we operate, as well as adherence to our Code of Conduct, internal policies, and company standards. Business ethics at Sonova is supported by a culture that does not tolerate fraud, corruption, bribery, and anti-competitive practices, and encourages and protects speaking up through established reporting and whistleblowing mechanisms.

The Sonova Code of Conduct defines general principles for ethical behavior and applies to all employees of the Sonova Group, its subsidiaries, and any third parties such as distributors, agents, or suppliers while they are performing work for Sonova. An acknowledgment of the Code of Conduct is part of new employment and third-party contracts. The Code of Conduct is approved by the Board of Directors, reviewed regularly, revised when necessary, and governs all relevant aspects of Sonovaʼs business operations. It covers compliance with laws and regulations, conflicts of interest, and anti-competition, along with Sonovaʼs commitment to social and environmental responsibility such as human rights, equal employment opportunities, non-discrimination, and workplace safety. Sonovaʼs Code of Conduct training is mandatory for all employees worldwide and is delivered through our eLearning platform or periodically via classroom training for employees who do not have access to a computer in performing their role. It provides guidance on how to act with integrity and how to identify and report potential violations such as conflict of interest, harassment, fraud, discrimination, corruption, or breach of secrecy. Third parties are regularly instructed to ensure adequate understanding and compliance with the Code of Conduct.

The principles of the Code of Conduct are further refined in various internal guidelines and policies, including – but not limited to – antibribery, interactions with hearing care professionals, anti-competitive practices, infringement of intellectual property, human rights, data protection and information security, securities trading, public disclosure and reporting, product quality, trade compliance, and AI governance. Non-compliance with Sonovaʼs Code of Conduct, internal policies, or guidelines leads to disciplinary action, up to and including termination of the employment contract. Sonovaʼs distributors, suppliers, and vendors go through an onboarding due diligence process before being contracted for their services. This helps to ensure that our upstream and downstream partners conduct their business in accordance with Sonovaʼs Code of Conduct and in compliance with the relevant individual policies. In addition, the Sonova Supplier Code of Conduct also serves as a binding principle for its suppliers. Suppliers are required to provide written certification that they will adhere to these requirements in all business transactions, operations, goods, and services pertaining to Sonova.

The Sonova Anti-Bribery Policy prohibits all forms of corruption and provides the framework for ethical interaction with customers, consumers, and third parties – with a particular focus on Sonovaʼs interactions with hearing care professionals (HCPs) and health care organizations. The Anti‑Bribery Policy has been communicated to all Sonova employees and to third parties acting on Sonovaʼs behalf, both of whom must commit to complying with its principles. This policy is supported by detailed procedures governing high-risk activities (e.g., HCP & Government Official engagements, sponsorships, grants, donations, and distributor relationships). Awareness of the Anti-Bribery Policy is integrated into the annual mandatory Code of Conduct training; mandatory periodic trainings have been rolled out to employees in defined high-risk functions (such as sales, marketing, finance, Sonovaʼs senior and middle management, and Group company-level management roles including Managing Directors and controllers). The training provides in-depth guidance on healthcare-specific risk scenarios, third-party risk management, fair-market value principles, and real-world case studies.

Sonovaʼs Global Competition Law Policy describes the basic principles of fair competition while conducting business. All Sonova employees worldwide have access to the policy and must comply with the principles it sets out. The Competition Law Policy is supported by guidance on exchanging commercially sensitive information, participation in trade associations, pricing practices, and interactions with competitors. Mandatory periodic trainings on the Competition Law Policy have been rolled out to employees in defined high-risk functions (similar to those addressed by the Anti-Bribery Policy).

Sonova is committed to providing reporting channels that encourage employees, contractors, and other stakeholders to speak up and report potential wrongdoing (i.e., violation of applicable laws, regulations, the Code of Conduct, or related internal policies and procedures). To further support a culture of speaking up, Sonova has implemented a SpeakUp Policy which outlines the escalation process to handle and report compliance concerns. Concerns are classified according to their impact (global/local) and/or the implicated person. The escalation process includes the handling of certain matters by local management under the guidance and oversight of the Global Compliance team. All matters with global impact (both in severity and/or where senior members of management are implicated) are investigated by a dedicated Investigations team within Global Compliance. Sonovaʼs SpeakUp platform and investigation process are compliant with the EU Whistleblower directive and have been audited and verified by external auditors. Employees may report a concern to their line manager, their local HR function, a compliance manager, or directly via the SpeakUp platform, which is available online and via phone. The SpeakUp platform is operated by an independent third-party provider and ensures the anonymity of the reporter. We include awareness of the SpeakUp Policy in our annual Code of Conduct training for all employees.

In the 2025/26 financial year, one confirmed case of private bribery was identified (prior year: none). The case did not involve government officials and related to transactions between a Sonova entity and one of its vendors. It did not result in regulatory consequences. Disciplinary action was taken, and the individuals involved were terminated both at Sonova and at the vendor.

No fines or non-monetary sanctions for non-compliance, including violation of anti-corruption and anti-bribery laws, were levied against Sonova in the 2025/26 financial year.

In the 2025/26 financial year, we sourced materials and services from around 3,000 direct and indirect suppliers across our businesses. Sonova suppliers are based in Europe, Americas, and Asia, and some operate in geographies and industries with high inherent risk of environmental and social impacts. To mitigate the risk, Sonovaʼs sustainability commitments and expectations are embedded in policies and processes and communicated transparently throughout the supplier journey. Sustainability requirements are increasingly included in supplier agreements, requests for proposals, and bidding processes. Sustainability criteria (such as ESG risk rating, decarbonization maturity, and responsible sourcing) represented up to 10% of total evaluation weighting in selected tenders, influencing our supplier selection decisions.

Sonovaʼs relations with suppliers are guided by the Sonova Supplier Code of Conduct, the Sonova Code of Conduct and the General Conditions of Purchase, which together form the foundation of all supplier agreements. The Sonova Supplier Code of Conduct aligns with OECD Due Diligence Guidance, UN Guiding Principles on Business and Human Rights, and ILO core standards. Suppliers must certify in writing that they will comply with these standards and principles in all their Sonova-related dealings, activities, and delivered products and services (certification is included in all supply agreements). Compliance with these requirements is further reinforced through contractual sustainability clauses, audit rights, and corrective action obligations. Sonova emphasizes sustainability expectations of suppliers through the selection Due Diligence program and, for significant suppliers, the Supplier Relationship Management process.

One supplier with an insufficient EcoVadis score at the beginning of the fiscal year was supported in developing a corrective action plan. Sonovaʼs engagement helped the supplier to significantly improve their score. Key actions addressed environmental policies, decarbonization targets, and reporting on environmental and human rights. Besides the high-risk suppliers, 30 suppliers were selected based on high spend, carbon emissions, and strategic relevance and requested to complete EcoVadis self-assessments.

All direct material suppliers and risk relevant indirect suppliers are evaluated on the Dun & Bradstreet Risk Analytics platform during onboarding. This process identifies human rights risks through screenings of sanctions and watchlists, political exposure, and adverse media, along with a dedicated human rights risk tool.

Besides EcoVadis, the Consumer Hearing business conducted four onsite sustainability audits. The Hearing Instruments business carried out more than 75 supplier visits to ensure that their practices are reliable and robust, and to conduct risk-based evaluation of components and processes that could affect product performance, safety, or broader supply chain stability.

Sonova maintains and continuously assesses a critical supplier list, which included 36 suppliers at the end of the 2025/26 financial year. Critical suppliers include those whose materials come into direct contact with usersʼ skin, single-source suppliers, or those with high business impact. The classification of critical suppliers is conducted at the beginning of each new supplier relationship and is reviewed regularly. In the 2025/26 financial year, 76% of relevant critical suppliers were covered by EcoVadis assessments, an increase from 70% in the previous fiscal year. Critical supplier sustainability performance also improved, with the average EcoVadis scores increasing from 53 to 58.

Purchased goods and services represent a significant share of our Scope 3 emissions, and we actively engage with our suppliers to align them with our near-term decarbonization trajectory. Sonova contracts include expectations for suppliers to measure greenhouse gas (GHG) emissions, set reduction targets, and provide carbon data. We encourage suppliers to develop credible transition plans and disclose their corporate emissions on an annual basis. Sonova collects supplier carbon data via the EcoVadis platform and through direct engagement with priority suppliers. Based on recognized industry standards, we have developed guidance to support suppliers in calculating Product Carbon Footprint (PCF). We observed improvements among the top 20 emitting suppliers. We worked with seven of these suppliers, representing 75% of reported direct material emissions, to develop supplier-specific PCF calculation capabilities.

Sonova operates in a highly regulated environment, and our public affairs efforts focus on active engagement in public discussions and providing insights on evolving policy changes. These changes include regulations affecting the market placement of hearing instruments and consumer products, as well as public access to medical technology. We work to raise awareness about the societal impact of hearing loss and the benefits of hearing care, all while upholding high standards of business ethics and integrity in compliance with applicable laws. In line with our Global Anti-Bribery Policy, Sonova does not permit donations to political parties.

We recognize the importance of animal welfare in advancing medical research and are committed to ethical practices and the responsible treatment of animals in compliance with international standards. Sonova does not conduct any animal testing in-house and works with only a small number of third-party organizations. We adhere to ISO 10993–1, which requires animal testing in certain cases to demonstrate the biological safety of medical devices that come into contact with the human body. As part of our research contributions, we provide components of cochlear implants to a few selected research centers and universities. We are dedicated to the Three Rs principle – replacement, reduction, and refinement – to minimize the need for animal testing.