Tingyi (Cayman Islands) Holding Corp.

Responsible Marketing Policy

As a leading enterprise in China’s food and beverage industry, Master Kong has always adhered to the principle of integrity in business operations, earning consumer trust through open, transparent, and authentic communication. We will continue to leverage the power of our brand and product to foster a healthy and responsible marketing environment within the industry, making wholesome products the preferred choice for consumers and encouraging healthier lifestyle decisions.

??Scope of Application:??

This Policy applies to all marketing activities of ??Tingyi (Cayman Islands) Holding Corp.?? (hereinafter referred to as “??Master Kong??”, “??the Group??”, or “??we?”), including its subsidiaries and affiliated entities, covering all brands and products under its portfolio. This Policy governs marketing channels including but not limited to ??social media, television, film, print media, websites, and applications??. It also extends to ??contractors under the Group’s supervision and external stakeholders??.

??Basis of Formulation:??

Master Kong strictly adheres to laws and regulations including the Advertising Law of the People’s Republic of China, the Trademark Law of the People’s Republic of China, the Food Safety Law of the People’s Republic of China, and the Regulation on the Implementing of the Food Safety Law of the People’s Republic of China, as well as national standards such as the General standard for the labeling of prepackaged foods (GB 7718) and the General Rules for Nutrition Labeling of Prepackaged Foods (GB 28050-2011). In accordance with these requirements, Master Kong has formulated the Product Promotion and Marketing Manual to strictly control advertising and labeling reviews, standardize product promotion and marketing practices, establish transparent communication channels with consumers, and commit to building a responsible marketing corporate image while enhancing brand value.

Policy Principles:

• Commit to ensuring that all promotional activities of Master Kong comply with ethical standards and eliminate the use of misleading information;
• Guarantee that promotional messages are concise, clear, and easy to understand, avoiding complex language that may cause confusion;
• Ensure that promotional content fully considers and respects all audiences, refraining from any expression that could be perceived as offensive, discriminatory, or harmful;
• Respect intellectual property rights, ensuring that all promotional materials are authentic and have obtained appropriate permissions;
• Engage in responsible and transparent communication with consumers and stakeholders across society, encouraging the adoption of healthier and more nutritious dietary habits.

Policy Contents:

• Responsible Marketing Management
  14. We require our partners and other advertising publishers and operators to perform in good faith and compete fairly to avoid exaggerated, false or misleading publicity. To ensure that the promotional content is true and compliant, we require all external promotional materials and label designs shall be reviewed and approved by various departments such as Legal Affairs Department, Research and Development Department and Quality Assurance Department before release.
  14. It shall not carry out advertising activities in primary and secondary schools and kindergartens, and shall not use the teaching materials and teaching aids for primary and secondary school students and young children, school uniforms, school buses and other channels to publish or disguise advertisements.
  14. In the area of brand promotion, product marketing and content publicity, Master Kong stipulates that it is prohibited to involve competitors’ brands in promotional content, to disparage the goods or services of other producers and operators, or to make one-sided publicity or comparisons of goods.
  14. Master Kong pledges to provide clear, non-misleading ingredient and nutrition labeling on all product packaging, avoiding exaggerated or false health claims.
• Responsible Marketing Training
  14. We organize annual responsible marketing-related training for all marketing employees, and regularly organize special training on the implementation of marketing strategies and other activities, analyze the potential risks and consequences of different marketing approaches, and require all advertising creatives, communication materials and promotional channels to comply with Master Kong’s internal regulations, thereby enhance employees’ awareness of responsible marketing and ensuring the legality and compliance of marketing activities.
• Responsible Marketing Audits
  14. We regularly conduct self-inspection audit on marketing work every year, and identify risk points to continuously improve the risk control and supervision mechanism. Responsible marketing audit includes, but is not limited to, marketing system management, creative media agency management, monitoring agency management, spokesperson management, IP cooperation program management, social media management, whether the advertisement content involves negative publicity and improper publicity, and whether the packaging of the placed products has been audited and reviewed. In addition, we regularly carry out third-party marketing audit, which covers all the media projects placed in the previous year, and the review content includes the authenticity and quality of the implementation and interaction data of Internet key opinion leaders (KOLs), advertisements, IP cooperation and other projects.

Review and Revise:

Master Kong periodically reviews this Policy and revises it in line with the latest laws, regulatory developments and business conditions. Employees should keep themselves informed of any updates and ensure that their conduct remains in full compliance with this Policy.

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