Anti-corruption Management and Ethics

Master Kong focuses on enhancing its compliance management, endeavoring to create a workplace environment with integrity, honesty and transparency. The Company strictly complies with the Anti-Unfair Competition Law of the People’s Republic of China and the Anti-Money Laundering Law of the People’s Republic of China and other laws and regulations, and has formulated anti-corruption-related management systems such as the Management Measures on Employees’ Integrity and Self-discipline Behaviour, and the Management Measures on Contract Inspection and Review, and continuously improves the anti-corruption management system, avoiding any direct or indirect illegal commercial acts including corruption, bribery, extortion, fraud and money laundering, etc.

Master Kong prohibits directors and all employees from engaging in or profiting from any illegal or unethical economic behaviours and advocates all of our employees to abide by professional ethics and moral principles. We demand our employees and suppliers to sign the Anti-Commercial Bribery Commitment Letter, which clearly states that they will not offer or accept bribes and maintain a good working environment. We enhance our ability to deal with the relevant issues, constantly improve our employees’ awareness of anti-corruption, and continue to build and promote a culture of corporate integrity. In 2022, we trained all employees on the online learning platform based on the Measures for the Management Measures on Employees’ Integrity and Self-discipline Behaviour which was included in the training for new employees, with more than 58,000 participants. In addition, we conducted on-site integrity training for employees, and all the employees who participated in the training signed the Honesty, Integrity and Self-discipline Assurance Statement after the training. We also published articles and shared anti-fraud cases on the enterprise WeChat platform and online learning platform, and sent the Audit Fraud Investigation Report to the senior management, constantly strengthening the directors’ and employees’ awareness of integrity and compliance to enhance their awareness of business ethics.

In response to commercial bribery, fraud and other illegal acts, Master Kong has established a special reporting channel to encourage internal and external personnel to monitor each other, and participate in the construction of the Company’s business ethics and compliance culture to resist malpractices. We have announced the Whistleblower Acceptance Principles and Reward Provisions on the Company's official website, as well as the whistleblower hotline and email address. We encourage our employees, suppliers and other relevant parties to participate in real-name whistleblowing. In response to external extortion, fraud and other incidents, the Company has formulated a special emergency plan and handling mechanism to improve its ability to deal with related problems. We set up a Corporate Security Team under the Audit Department, which is fully responsible for the analysis, investigation and handling of whistleblowing cases. We have formulated the Whistleblowing Operation Procedures to regulate the process of handling reports, the principles of reward and the relevant requirements for the protection of whistleblowers, we strictly keep the whistleblowers’ information confidential. If there is any information leakage, we will dispose of it in accordance with

the Management Measures on Employees’ Rewards and Punishments after verification. The personnel of the Audit Department are also required to sign the commitment letter of the Code of Professional Ethics and Disciplinary Guidelines for Audit Office Personnel every year, promising to abide by the code of professional ethics and disciplinary code, and strictly follow the principle of confidentiality when performing their duties. In 2022, no whistleblower information was exposed. As an important component of risk management, the Audit Department reviews the effectiveness of the Company-wide major risk management and internal control systems every year. The Audit Department makes suggestions for improvements to address the deficiencies

of the existing systems, which prevents corrupt behaviours such as employees taking advantage of system loopholes to violate laws and regulations. During this year, the Corporate Security Team completed the investigation of 44 fraud reporting cases, and conducted the evaluation and inspection of business ethics and professional ethics for special audit operations such as internal control and risk management, supplier and quality management, and procurement management. Comprehensively strengthen the anti-corruption and anti-fraud management of the Company.

Master Kong Whistleblowing Official Website: https://www.masterkong.com.cn/contactus/index.shtml

Master Kong Whistleblower Acceptance Pinciples and Reward Provisions: https://www.masterkong.com.cn/contactus/20150527/32285.shtml

Hotline: 021-31753602 Email: jianju@masterkong.com.cn

Mailing address: Building A, No.1688, Wuzhong Road, Minhang District, Shanghai, China, 201103 Whistleblowing supervisor.

Source: