Exhibit 97.1

SUNRISE COMMUNICATIONS AG

DODD-FRANK CLAWBACK POLICY

The Board of Directors (the “Board”) of Sunrise Communications AG (the “Company”) has

adopted this Dodd-Frank Clawback Policy (this “Policy”) in accordance with the applicable

provisions of The Nasdaq Stock Market LLC Listing Rules (the “Clawback Rules”), promulgated

pursuant to the final rules adopted by the Securities and Exchange Commission enacting the

clawback standards under Section 954 of the Dodd-Frank Wall Street Reform and Consumer

Protection Act. The Compensation Committee of the Board (the “Committee”) is designated to

administer this Policy. Capitalized terms not otherwise defined in this Policy have the meanings

given to them under the Clawback Rules, which are attached to this Policy as Appendix A.

Recovery of Erroneously Awarded Incentive Compensation. The Company shall comply

with the Clawback Rules and reasonably promptly recover Erroneously Awarded Compensation

Received by current or former members of the Company's Executive Committee appointed by

the Board from time to time, as well as any other individual who is or was an Executive Officer

as determined by the Committee (“Covered Individuals”) in the event the Company is required to

prepare an accounting restatement due to the Company’s material noncompliance with any

financial reporting requirement under applicable securities laws, including any required

accounting restatement to correct an error in previously issued financial statements that is

material to the previously issued financial statements, or that would result in a material

misstatement if the error were corrected in the current period or left uncorrected in the current

period. The Committee may determine not to recover Erroneously Awarded Compensation

pursuant to this Policy in circumstances where non-enforcement is expressly permitted by the

Clawback Rules, including where recovery would violate applicable home country laws in effect

before November 28, 2022.

Covered Compensation. This Policy applies to the Incentive-based Compensation Received

by a Covered Individual: (1) after such Covered Individual began service as a member of the

Executive Committee; (2) who served as a member of the Executive Committee at any time

during the performance period for that Incentive-based Compensation; (3) while the Company

has a class of securities listed on a United States national securities exchange or a United

States national securities association; and (4) during the three completed fiscal years

immediately preceding the date that the Company is required to prepare an accounting

restatement as described above (or during any transition period, that results from a change in

the Company’s fiscal year, within or immediately following those three completed fiscal years, as

determined in accordance with the Clawback Rules).

The amount of Incentive-based Compensation subject to this Policy is the Erroneously Awarded

Compensation, which is the amount of Incentive-based Compensation Received by a Covered

Individual that exceeds the amount of Incentive-based Compensation that otherwise would have

been Received by the Covered Individual had it been determined based on the restated amount

(or otherwise determined in accordance with the Clawback Rules), and will be computed without

regard to any taxes paid by the Covered Individual (or withheld from the Incentive-based

Compensation). The Committee shall make all determinations regarding the amount of

Erroneously Awarded Compensation.

Method of Recovery. The Committee shall determine, in its sole discretion, the manner in which

any Erroneously Awarded Compensation shall be recovered. Methods of recovery may include,

but are not limited to: (1) seeking direct repayment from the Covered Individual; (2) reducing

(subject to applicable law and the terms and conditions of the applicable plan, program or

arrangement pursuant to which the incentive-based compensation was paid) the amount that

would otherwise be payable to the Covered Individual under any compensation, bonus, incentive,

equity and other benefit plan, agreement, policy or arrangement maintained by the Company or

any of its affiliates; (3) cancelling any award (whether cash- or equity-based) or portion thereof

previously granted to the Covered Individual; or (4) any combination of the foregoing.

No-Fault Basis. This Policy applies on a no-fault basis, and Covered Individuals will be subject

to recovery under this Policy without regard to their personal culpability.

Other Company Arrangements. This Policy shall be in addition to, and not in lieu of, any other

clawback, recovery or recoupment policy maintained by the Company from time to time, as well

as any clawback, recovery or recoupment provision in any of the Company’s plans, awards or

individual agreements (including the clawback, recovery and recoupment provisions in the

Company’s equity award agreements) (collectively, “Other Company Arrangement”) and any

other rights or remedies available to the Company, including termination of employment;

provided, however, that there is no intention to, nor shall there be, any duplicative recoupment of

the same compensation under more than one policy, plan, award or agreement. In addition, no

Other Company Arrangement shall serve to restrict the scope or the recoverability of

Erroneously Awarded Compensation under this Policy or in any way limit recovery in compliance

with the Clawback Rules.

No Indemnification. Notwithstanding anything to the contrary set forth in any policy,

arrangement, articles of incorporation or other constitutional document or plan of the Company

or any individual agreement between a Covered Individual and the Company or any of its

affiliates, no Covered Individual shall be entitled to indemnification from the Company or any of

its affiliates for the amount that is or may be recovered by the Company pursuant to this Policy;

provided, however, that to the extent expense advancement or reimbursement is available to a

Covered Individual, this Policy shall not serve to prohibit such advancement or reimbursement.

Administration; Interpretation. The Committee shall interpret and construe this Policy

consistent with the Clawback Rules and applicable laws and regulations and shall make all

determinations necessary, appropriate or advisable for the administration of this Policy. Any

determinations made by the Committee shall be final, binding and conclusive on all affected

individuals. As required by the Clawback Rules, the Company shall provide public disclosures

related to this Policy and any applicable recoveries of Erroneously Awarded Compensation. To

the extent this Policy conflicts, or is inconsistent, with the Clawback Rules, the Clawback Rules

shall govern. In no event is this Policy intended to be broader than, or require recoupment in

addition to, that required pursuant to the Clawback Rules.

Amendment or Termination of this Policy. The Board reserves the right to amend this Policy

at any time and for any reason, subject to applicable law and the Clawback Rules. To the extent

that the Clawback Rules cease to be in force or cease to apply to the Company, this Policy shall

also cease to be in force.

Approved and Adopted: November 8, 2024

COVERED INDIVIDUAL ACKNOWLEDGMENT

I, [INSERT NAME], acknowledge that I have received a copy of the Sunrise Communications AG

Dodd-Frank Clawback Policy (the “Policy”) and the applicable provisions of The Nasdaq Stock

Market LLC Listing Rules (the “Clawback Rules”), and that I have read and understood the

Policy and the Clawback Rules. I further understand that the Policy applies to my Incentive-

Based Compensation, as defined in the Clawback Rules, and that I agree to take all actions

necessary to assist the Company in complying with the Policy and the Clawback Rules.

COVERED INDIVIDUAL

Name:

Date:

Appendix A

Clawback Rules

5608. Recovery of Erroneously Awarded Compensation

(a)Preamble. As required by SEC Rule 10D-1, this Rule 5608 requires Companies to

adopt a compensation recovery policy, comply with that policy, and provide the compensation

recovery policy disclosures required by this rule and in the applicable Commission filings.

(b)Recovery of Erroneously Awarded Compensation. Each Company must:

(1) Adopt and comply with a written policy providing that the Company will recover reasonably

promptly the amount of erroneously awarded incentive-based compensation in the event that

the Company is required to prepare an accounting restatement due to the material

noncompliance of the Company with any financial reporting requirement under the securities

laws, including any required accounting restatement to correct an error in previously issued

financial statements that is material to the previously issued financial statements, or that

would result in a material misstatement if the error were corrected in the current period or left

uncorrected in the current period.

(i) The Company’s recovery policy must apply to all incentive-based compensation

received by a person:

(A)After beginning service as an executive officer;

(B)Who served as an executive officer at any time during the performance period

for that incentive-based compensation;

(C)While the Company has a class of securities listed on a national securities

exchange or a national securities association; and

(D)During the three completed fiscal years immediately preceding the date that the

Company is required to prepare an accounting restatement as described in paragraph

(b)(1) of this Rule. In addition to these last three completed fiscal years, the recovery

policy must apply to any transition period (that results from a change in the Company’s

fiscal year) within or immediately following those three completed fiscal years. 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 would be

deemed a completed fiscal year. A Company’s obligation to recover erroneously

awarded compensation is not dependent on if or when the restated financial statements

are filed.

(ii) For purposes of determining the relevant recovery period, the date that a Company is

required to prepare an accounting restatement as described in paragraph (b)(1) of this

Rule is the earlier to occur of:

(A) The date the Company’s board of directors, a committee of the board of directors, 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 an accounting restatement as described in paragraph (b)(1) of this Rule; or

(B) The date a court, regulator, or other legally authorized body directs the Company to

prepare an accounting restatement as described in paragraph (b)(1) of this Rule.

(iii) The amount of incentive-based compensation that must be subject to the Company’s

recovery policy (“erroneously awarded compensation”) is the amount of incentive-based

compensation received that exceeds the amount of incentive-based compensation that

otherwise would have been received had it been determined based on the restated

amounts, and must be computed without regard to any taxes paid. For incentive-based

compensation based on stock price or total shareholder return, where the amount of

erroneously awarded compensation is not subject to mathematical recalculation directly

from the information in an accounting restatement:

(A)The amount must be based on a reasonable estimate of the effect of the

accounting restatement on the stock price or total shareholder return upon which the

incentive-based compensation was received; and

(B)The Company must maintain documentation of the determination of that

reasonable estimate and provide such documentation to Nasdaq.

(iv) The Company must recover erroneously awarded compensation in compliance with its

recovery policy except to the extent that the conditions of paragraphs (b)(1)(iv)(A), (B), or

(C) of this Rule are met, and the Company’s Compensation Committee, or in the absence

of such a committee, a majority of the independent directors serving on the board, has

made a determination that recovery would be impracticable.

(A)The direct expense paid to a third party to assist in enforcing the policy would

exceed the amount to be recovered. Before concluding that it would be impracticable to

recover any amount of erroneously awarded compensation based on expense of

enforcement, the Company must make a reasonable attempt to recover such

erroneously awarded compensation, document such reasonable attempt(s) to recover,

and provide that documentation to Nasdaq.

(B)Recovery would violate home country law where that law was adopted prior to

November 28, 2022. Before concluding that it would be impracticable to recover any

amount of erroneously awarded compensation based on violation of home country law,

the Company must obtain an opinion of home country counsel, acceptable to Nasdaq,

that recovery would result in such a violation, and must provide such opinion to Nasdaq.

(C)Recovery would likely cause an otherwise tax-qualified retirement plan, under

which benefits are broadly available to employees of the registrant, to fail to meet the

requirements of 26 U.S.C. 401(a)(13) or 26 U.S.C. 411(a) and regulations thereunder.

(v) The Company is prohibited from indemnifying any executive officer or former executive

officer against the loss of erroneously awarded compensation.

(2) File all disclosures with respect to such recovery policy in accordance with the

requirements of the Federal securities laws, including the disclosure required by

the applicable Commission filings.

(c) General Exemptions. The requirements of this Rule 5608 do not apply to the listing of:

(1)Any security issued by a unit investment trust, as defined in 15 U.S.C. 80a-4(2); and

(2)Any security issued by a management company, as defined in 15 U.S.C. 80a-4(3), that

is registered under section 8 of the Investment Company Act of 1940 (15 U.S.C. 80a-8), if such

management company has not awarded incentive-based compensation to any executive officer

of the company in any of the last three fiscal years, or in the case of a company that has been

listed for less than three fiscal years, since the listing of the company.

(d) Definitions. Unless the context otherwise requires, the following definitions apply for

purposes of this Rule 5608 (and only for purposes of this Rule 5608):

Executive Officer. An executive officer is the Company’s president, principal financial officer,

principal accounting officer (or if there is no such accounting officer, the controller), any vice-

president of the Company in charge of a principal business unit, division, or function (such as

sales, administration, or finance), any other officer who performs a policy-making function, or

any other person who performs similar policy-making functions for the Company. Executive

officers of the Company’s parent(s) or subsidiaries are deemed executive officers of the

Company if they perform such policy making functions for the Company. In addition, when the

Company is a limited partnership, officers or employees of the general partner(s) who perform

policy-making functions for the limited partnership are deemed officers of the limited

partnership. When the Company is a trust, officers, or employees of the trustee(s) who perform

policy-making functions for the trust are deemed officers of the trust. Policy-making function is

not intended to include policy-making functions that are not significant. Identification of an

executive officer for purposes of this Rule would include at a minimum executive officers

identified pursuant to 17 CFR 229.401(b).

Financial Reporting Measures. Financial reporting measures are measures that are determined

and presented in accordance with the accounting principles used in preparing the Company’s

financial statements, and any measures that are derived wholly or in part from such measures.

Stock price and total shareholder return are also financial reporting measures. A financial

reporting measure need not be presented within the financial statements or included in a filing

with the Commission.

Incentive-Based Compensation. Incentive-based compensation is any compensation that is

granted, earned, or vested based wholly or in part upon the attainment of a financial reporting

measure.

Received. Incentive-based compensation is deemed received in the Company’s fiscal period

during which the financial reporting measure specified in the incentive-based compensation

award is attained, even if the payment or grant of the incentive-based compensation occurs

after the end of that period.

(e) Effective Date. Each Company is required to (i) adopt a policy governing the recovery of

erroneously awarded compensation as required by this rule no later than 60 days following

October 2, 2023, (ii) comply with its recovery policy for all incentive-based compensation

received (as such term is defined in Rule 5608(d)) by executive officers on or after October 2,

2023, and (iii) provide the disclosures required by this rule and in the applicable Commission

filings on or after October 2, 2023. Notwithstanding the look-back requirement in Rule

5608(b)(1)(i)(D), a Company is only required to apply the recovery policy to incentive-based

compensation received on or after October 2, 2023.

Amended Oct. 2, 2023 (SR-NASDAQ-2023-00