Tingyi (Cayman Islands) Holding Corp.

Anti-Corruption Policy

Purpose

Tingyi (Cayman Islands) Holding Corp. (hereinafter referred to as “Master Kong”, “the Company” or “We”) understands that integrity and legal compliance are the key to long-term business success, and endeavors to create a workplace environment with integrity, honesty and transparency. The policy requires compliance with all applicable laws and regulations on bribery and corruption, including, but not limited to, 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 applicable national anti-bribery statutes and implementing rules and regulations.

Scope and Applicability

The Anti-corruption Policy is applicable to all individuals working at all levels and grades, including directors, senior executives, senior officers, other employees (whether permanent, fixed-term or temporary), consultants, contractors, interns, etc.

Policy Statement

1. Anti-Corruption and Anti-Bribery

• Master Kong prohibits directors and all employees from engaging in or profiting from any illegal or unethical economic behaviors and advocates all of our employees to abide by professional ethics and moral principles.
• We demand our employees, suppliers, distributors and to sign the Anti-Commercial Bribery Pledge, which clearly states that they will not offer or accept bribes and maintain a good working environment.

2. Gifts

Master Kong encourages employees to maintain professionalism and courtesy in business dealings, but any gift offering and acceptance must strictly comply with the following rules:

• Cash or cash equivalents (including gift cards, vouchers, etc.) must not be accepted or offered.
• In general, the offer or acceptance of gifts should be explicitly declined. Should exceptional circumstances arise, written approval must be obtained and the gift surrendered for official handling.
• All gifts offered or accepted must comply with applicable laws and regulations. Accepting or offering any prohibited items is forbidden. No gift that may influence—or reasonably be perceived as influencing—objective judgment or the proper performance of duties shall be accepted or offered.
• The value of any gift offered or accepted must be reasonable and must not exceed the limits set by industry norms and Company rules.
• All gifts offered or accepted must be fully documented.

3. Charitable Donations and Sponsorships

Master Kong actively participates in social and community development to enhance public well-being. All charitable donations and sponsorships must comply with the following requirements:

• All charitable donations and sponsorships must comply with applicable laws, be approved through the Company’s internal authorization process and be fully documented.
• No donation or sponsorship may involve any potential or actual act of corruption, bribery, conflict of interest or unfair competition that violates business ethics.
• It is prohibited to provide any form of benefit or advantage to any individual or organization that has an actual or potential business relationship or interest with the Company, where the purpose is to bribe or obtain an improper benefit. Donation, sponsorship (including political or charitable contributions) or any other form of contribution made with the purpose of bribery shall not occur.

4. Whistleblower Protection

• All employees in the Company shall abide by the Whistleblowing Operation Management Measures and keep whistleblowers’ information strictly confidential. If there is any leakage of the whistleblowers’ information, it will be dealt with in accordance with the Management Measures of Staff Rewards and Punishments after verification.
• The personnel of the Audit Department signed a commitment letter of Code of Professional Ethics and Disciplinary Guidelines for Audit Office Personnel every year, promising to strictly follow the principle of confidentiality in the performance of their duties.

5. Communication and Training

• All new employees of the Company are required to receive training on anti-corruption and anti-bribery, including the Management Measures on Employees’ Integrity and Self-discipline Behavior.
• The Company regularly provides training and awareness programs on this Policy, its integrity culture and related norms, as well as on corporate procedures and measures. All employees are required to complete the relevant training and courses actively and on schedule.

6. Penalties

• Any employee found to be in violation of this policy will be subject to disciplinary action, up to and including termination of employment, in accordance with applicable laws and company policies.

7. Reporting Breaches or Concerns

• Any employee who witnesses a breach of this policy is obliged to promptly report through Master Kong’s reporting channels.
• Any employee who is in doubt, suspects that this policy has been breached or has concerns about past or proposed actions by anyone in Master Kong, or any third party working with the Company in any capacity, is encouraged to contact Master Kong through the following channels:

Master Kong WeChat Corporate Account: 13764166520 Whistleblowing supervisor

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

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

Hotline: 021-31753602

Email: jianju@masterkong.com.cn

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

Policy Review and Revise

The content of this Policy is supervised by the Sustainable Development Committee of Master Kong. All material impacts and implementation progress are reported to the Board of Directors. Master Kong periodically reviews this Policy and revises it in line with the latest laws, regulatory developments and business conditions. Employees must keep themselves informed of any updates and ensure that their conduct remains in full compliance with this Policy.

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