IM Cannabis Corp.

. CODE OF ETHICS

On November 26, 2020, we have adopted a Code of Business Conduct and Code of Ethics that applies to directors, officers and employees of, and consultants to, the Company. The Code of Business Conduct and Code of Ethics is posted on our website at https://investors.imcannabis.com/corporate-governance/governance-documents. Information contained on, or that can be accessed through, our website does not constitute a part of this annual report on Form 20-F and is not incorporated by reference herein. If we make any amendment to the Code of Business Conduct and Ethics or grant any waivers, including any implicit waiver, from a provision of the code, we will disclose the nature of such amendment or waiver on our website to the extent required by the rules and regulations of the SEC including the instructions to Item 16B of Form 20-F. The Code of Business Conduct and Code of Ethics meets the requirements for a “code of ethics” within the meaning of that term in General Instruction 16B(b) of Form 20-F.

All waivers of the Code of Business Conduct and Code of Ethics with respect to any of the employees, officers or directors covered by it will be promptly disclosed as required by applicable securities rules and regulations. During the fiscal year ended December 31, 2025, we did not waive or implicitly waive any provision of the Code of Business Conduct and Code of Ethics with respect to any of our principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions.

ITEM 16C