Tingyi (Cayman Islands) Holding Corp.

Code of Conduct

Preamble

Tingyi (Cayman Islands) Holding Corp. (hereinafter referred to as “Master Kong”, “the Company” or “We”) is committed to upholding the highest standards of business ethics and professional conduct in all its operations. This Code of Conduct is established to guide the actions of all personnel of Master Kong and its affiliated companies, including all directors, senior executives and employees. It aims to ensure that the Company’s operating activities complies with applicable laws and regulations, social ethics and the concept of sustainable development. We expect everyone at Master Kong to follow these standards and defend the Company’s interests and reputation.

Part 1: Anti-Corruption and Anti-Bribery

Master Kong endeavors to create a workplace environment with integrity, honesty and transparency, and ensures that its behavior adhere to business ethics. The Company strictly complies with the Criminal Law of the People’s Republic of China, the Anti- Unfair Competition Law of the People’s Republic of China, the Anti-Money Laundering Law of the People’s Republic of China and other laws and regulations. It has formulated management systems such as the Management Measures on Employees’ Integrity and Self-discipline Behavior, and the Management Measures on Contract Inspection and Review, and has published the Anti-Corruption Policy on its official website. It 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 behaviors and advocates all our employees to abide by professional ethics and moral principles. We demand our employees, suppliers and distributors to sign the Anti-Commercial Bribery Pledge, which clearly states that they will not offer or accept bribes and maintain a good working environment. The Company constantly enhances its employees’ ability to deal with the relevant issues, improves our employees’ awareness of anti-corruption, and continues to build and promote a culture of corporate integrity.

Master Kong prohibits unauthorized provision of any form of benefits or gifts to individuals or organizations that have direct or indirect relationships with the Company’s internal or external affairs, and strictly avoids donations and sponsorships (including political donations and philanthropic donations) for the purpose of bribery.

Part 2: Avoiding Conflicts of Interest

When a potential or actual conflict arises between an employee’s personal interests and those of Master Kong, it may impair the employee’s ability to make fair and objective decisions. Employees must always place Master Kong’s interests first, avoid any conduct or relationships that could lead to such conflicts, proactively identify situations where a conflict may exist, and promptly report them to their direct supervisor and/or the Company’s Audit Department.

Part 3: Anti-Unfair Competition

Master Kong requires employees to strictly comply with all applicable laws and regulations in business activities and prohibits gaining competitive advantage or impairing competitors through unethical means. The Company focuses on the management of publicity. It requires its partners and other advertising publishers and operators to perform in good faith and compete fairly to avoid exaggerated, false or misleading 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. Master Kong is committed to maintaining order in the marketing environment and prohibits any form of monopolistic marketing activities.

Part 4: Anti-Money Laundering

Master Kong prohibits any form of the legitimization of illegally obtained funds. The Company requires employees not to engage in money laundering and to report suspicious transactions promptly to the Company’s Audit Department. When establishing a business relationship with a customer, precautions against money laundering shall be taken.

Part 5: Anti-Insider Trading

Master Kong prohibits securities trading based on material and non-public information that could affect the price of its securities. All directors, senior executives and employees shall not directly or indirectly exploit insider information for securities trading, or to secure benefits for themselves or any third party.

Part 6: Anti-Discrimination and Anti-Harassment

Master Kong provides fair job opportunities to all individuals and forbids any form of discrimination and harassment in employment. The Company does not discriminate against applicants on grounds of ethnicity, race, gender, religious belief or any other characteristic, and fully respects employees’ cultural backgrounds, political beliefs, religious beliefs and ethnic customs. We firmly oppose and prohibit all forms of discrimination, harassment or improper conduct, as well as the dissemination of any rumors or other defamatory, discriminatory or harassing information. A zero-tolerance approach is adopted toward any such behavior.

We provide training for all employees on the Code of Conduct, anti-discrimination policy and workplace-harassment prevention, together with reporting channels for any breach. Employees may raise concerns by e-mail, telephone or in person to the designated whistle-blowing reception or relevant departments. After investigation, confirmed violations will result in disciplinary action against responsible individuals.

Part 7: Confidentiality of Information

Master Kong is committed to information protection and safeguards our customers’ privacy in every respect. We implement systematic and process-oriented management of the information, set an access limit to customer information and strictly adhere to the principle of confidentiality of customer information. We will sign confidentiality agreements with staff and third-party companies involved in user information and oversee the implantation of such agreements, to ensure the information security of the Company and users. In terms of capturing and recording customer information, each business formulates the Customer Complaint Information Management Operational Approach, records only the basic information about the customer and cleans up the important and sensitive information on a regular basis. In terms of information access, we endeavor to ensure data security in our internal systems and implement account login permission management to restrict the access scenarios and conditions of use of consumer and customer information by our internal staff to ensure information security of our consumers and customers to the greatest extent.

Master Kong requires employees to safeguard the Company’s confidential information both during and after their employment. We strictly prohibit unauthorized disclosure of any information yet to be disclosed or not intended for public disclosure.

Part 8: Environment, Health and Safety Principle

Master Kong understands and pay attention to the impact of its operation on the environment, health and safety. We integrate environmental protection into operating activity and secure the health and safety of all employees. Staff are required to comply with the Company’s regulations on environment, health and safety at every level and to meet the associated performance targets.

Part 9: Reporting and Handling

We have published the Acceptance Principles of Whistleblowing and Reward Regulations and the whistleblower hotline and e-mail address on the Company’s official website. We accept anonymous reports and encourage employees, suppliers, and other stakeholders to raise concerns onymously. We treat every whistleblower’s identity as strictly confidential and operate a zero-tolerance policy against any form of retaliation. 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.

We take into account the compliance of employees’ behaviors when evaluating their performance and have zero tolerance for employees who violate the relevant code of conduct. Depending on the severity of circumstances, we would issue them warnings, demerits, and even dismissals according to our Management Measures of Staff Rewards and Punishments.

Part 10: Review and Revise

Master Kong periodically reviews this Code of Conduct 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 Code.

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