Exhibit 97.1

ICU MEDICAL, INC. POLICY FOR RECOVERY OF ERRONEOUSLY AWARDED

COMPENSATION

ICU Medical, Inc. (the “Company”) has adopted this Policy for Recovery of Erroneously

Awarded Compensation (the “Policy”), effective as of October 2, 2023 (the “Effective Date”).

Capitalized terms used in this Policy but not otherwise defined herein are defined in Section 11.

1.    Persons Subject to Policy

This Policy shall apply to current and former Officers of the Company. Each Officer shall

be required to sign an Acknowledgment Agreement pursuant to which such Officer will agree to

be bound by the terms of, and comply with, this Policy; however, any Officer’s failure to sign any

such Acknowledgment Agreement shall not negate the application of this Policy to the Officer.

2.     Compensation Subject to Policy

This Policy shall apply to Incentive-Based Compensation received on or after the Effective

Date. For purposes of this Policy, the date on which Incentive-Based Compensation is “received”

shall be determined under the Applicable Rules, which generally provide that Incentive-Based

Compensation is “received” in the Company’s fiscal period during which the relevant Financial

Reporting Measure is attained or satisfied, without regard to whether the grant, vesting or payment

of the Incentive-Based Compensation occurs after the end of that period.

3.     Recovery of Compensation

In the event that the Company is required to prepare a Restatement, the Company shall

recover, reasonably promptly, the portion of any Incentive-Based Compensation that is

Erroneously Awarded Compensation, unless the Committee has determined that recovery would

be Impracticable. Recovery shall be required in accordance with the preceding sentence regardless

of whether the applicable Officer engaged in misconduct or otherwise caused or contributed to the

requirement for the Restatement and regardless of whether or when restated financial statements

are filed by the Company. For clarity, the recovery of Erroneously Awarded Compensation under

this Policy will not give rise to any person’s right to voluntarily terminate employment for “good

reason,” or due to a “constructive termination” (or any similar term of like effect) under any plan,

program or policy of or agreement with the Company or any of its affiliates.

4.     Manner of Recovery; Limitation on Duplicative Recovery

The Committee shall, in its sole discretion, determine the manner of recovery of any

Erroneously Awarded Compensation, which may include, without limitation, reduction or

cancellation by the Company or an affiliate of the Company of Incentive-Based Compensation,

Erroneously Awarded Compensation or time-vesting equity awards, reimbursement or repayment

by any person subject to this Policy of the Erroneously Awarded Compensation, and, to the extent

permitted by law, an offset of the Erroneously Awarded Compensation against other compensation

payable by the Company or an affiliate of the Company to such person. Notwithstanding the

foregoing, unless otherwise prohibited by the Applicable Rules, to the extent this Policy provides

for recovery of Erroneously Awarded Compensation already recovered by the Company pursuant

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to Section 304 of the Sarbanes-Oxley Act of 2002 or Other Recovery Arrangements, the amount of

Erroneously Awarded Compensation already recovered by the Company from the recipient of such

Erroneously Awarded Compensation may be credited to the amount of Erroneously Awarded

Compensation required to be recovered pursuant to this Policy from such person.

5.     Administration

This Policy shall be administered, interpreted and construed by the Committee, which is

authorized to make all determinations necessary, appropriate or advisable for such purpose. The

Board of Directors of the Company (the “Board”) may re-vest in itself the authority to administer,

interpret and construe this Policy in accordance with applicable law, and in such event references

herein to the “Committee” shall be deemed to be references to the Board. Subject to any permitted

review by the applicable national securities exchange or association pursuant to the Applicable

Rules, all determinations and decisions made by the Committee pursuant to the provisions of this

Policy shall be final, conclusive and binding on all persons, including the Company and its

affiliates, equityholders and employees. The Committee may delegate administrative duties with

respect to this Policy to one or more directors or employees of the Company, as permitted under

applicable law, including any Applicable Rules.

6.     Interpretation

This Policy will be interpreted and applied in a manner that is consistent with the

requirements of the Applicable Rules, and to the extent this Policy is inconsistent with such

Applicable Rules, it shall be deemed amended to the minimum extent necessary to ensure

compliance therewith.

7.     No Indemnification; No Liability

The Company shall not indemnify or insure any person against the loss of any Erroneously

Awarded Compensation pursuant to this Policy, nor shall the Company directly or indirectly pay

or reimburse any person for any premiums for third-party insurance policies that such person may

elect to purchase to fund such person’s potential obligations under this Policy. None of the

Company, an affiliate of the Company or any member of the Committee or the Board shall have

any liability to any person as a result of actions taken under this Policy.

8.     Application; Enforceability

Except as otherwise determined by the Committee or the Board, the adoption of this Policy

does not limit, and is intended to apply in addition to, any other clawback, recoupment, forfeiture

or similar policies or provisions of the Company or its affiliates, including any such policies or

provisions of such effect contained in any employment agreement, bonus plan, incentive plan,

equity-based plan or award agreement thereunder or similar plan, program or agreement of the

Company or an affiliate or required under applicable law (the “Other Recovery Arrangements”).

The remedy specified in this Policy shall not be exclusive and shall be in addition to every other

right or remedy at law or in equity that may be available to the Company or an affiliate of the

Company.

9.     Severability

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The provisions in this Policy are intended to be applied to the fullest extent of the law;

provided, however, to the extent that any provision of this Policy is found to be unenforceable or

invalid under any applicable law, such provision will be applied to the maximum extent permitted,

and shall automatically be deemed amended in a manner consistent with its objectives to the extent

necessary to conform to any limitations required under applicable law.

10.     Amendment and Termination

The Board or the Committee may amend, modify or terminate this Policy in whole or in

part at any time and from time to time in its sole discretion. This Policy will terminate

automatically when the Company does not have a class of securities listed on a national securities

exchange or association.

11.     Definitions

“Applicable Rules” means Section 10D of the Exchange Act, Rule 10D-1 promulgated

thereunder, the listing rules of the national securities exchange or association on which the

Company’s securities are listed, and any applicable rules, standards or other guidance adopted by

the Securities and Exchange Commission or any national securities exchange or association on

which the Company’s securities are listed.

“Committee” means the committee of the Board responsible for executive compensation

decisions comprised solely of independent directors (as determined under the Applicable Rules),

or in the absence of such a committee, a majority of the independent directors serving on the Board.

“Erroneously Awarded Compensation” means the amount of Incentive-Based

Compensation received by a current or former Officer that exceeds the amount of Incentive-Based

Compensation that would have been received by such current or former Officer based on a restated

Financial Reporting Measure, as determined on a pre-tax basis in accordance with the Applicable

Rules.

“Exchange Act” means the Securities Exchange Act of 1934, as amended.

“Financial Reporting Measure” means any measure determined and presented in

accordance with the accounting principles used in preparing the Company’s financial statements,

and any measures derived wholly or in part from such measures, including GAAP, IFRS and non-GAAP/IFRS financial measures, as well as stock or share price and total equityholder return.

“GAAP” means United States generally accepted accounting principles.

“IFRS” means international financial reporting standards as adopted by the International

Accounting Standards Board.

“Impracticable” means (a) the direct costs paid to third parties to assist in enforcing

recovery would exceed the Erroneously Awarded Compensation; provided that the Company has

(i) made reasonable attempts to recover the Erroneously Awarded Compensation, (ii) documented

such attempt(s), and (iii) provided such documentation to the relevant listing exchange or

association, (b) to the extent permitted by the Applicable Rules, the recovery would violate the

Company’s home country laws pursuant to an opinion of home country counsel; provided that the

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Company has (i) obtained an opinion of home country counsel, acceptable to the relevant listing

exchange or association, that recovery would result in such violation, and (ii) provided such

opinion to the relevant listing exchange or association, or (c) recovery would likely cause an

otherwise tax-qualified retirement plan, under which benefits are broadly available to employees

of the Company, to fail to meet the requirements of 26 U.S.C. 401(a)(13) or 26 U.S.C. 411(a) and

the regulations thereunder.

“Incentive-Based Compensation” means, with respect to a Restatement, any

compensation that is granted, earned, or vested based wholly or in part upon the attainment of one

or more Financial Reporting Measures and received by a person: (a) after beginning service as an

Officer; (b) who served as an Officer at any time during the performance period for that

compensation; (c) while the Company has a class of securities listed on a national securities

exchange or association; and (d) during the applicable Three-Year Period.

“Officer” means each person who serves as an executive officer of the Company, as defined

in Rule 10D-1(d) under the Exchange Act.

“Restatement” means an accounting restatement to correct the Company’s material

noncompliance with any financial reporting requirement under securities laws, including

restatements that correct an error in previously issued financial statements (a) that is material to

the previously issued financial statements or (b) that would result in a material misstatement if the

error were corrected in the current period or left uncorrected in the current period.

“Three-Year Period” means, with respect to a Restatement, the three completed fiscal years

immediately preceding the date that the Board, a committee of the Board, or the officer or officers

of the Company authorized to take such action if Board action is not required, concludes, or

reasonably should have concluded, that the Company is required to prepare such Restatement, or,

if earlier, the date on which a court, regulator or other legally authorized body directs the Company

to prepare such Restatement. The “Three-Year Period” also includes any transition period (that

results from a change in the Company’s fiscal year) within or immediately following the three

completed fiscal years identified in the preceding sentence. However, a transition period between

the last day of the Company’s previous fiscal year end and the first day of its new fiscal year that

comprises a period of nine to 12 months shall be deemed a completed fiscal year.

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