1. Summary

The Policy is to improve and consolidate the sustainable operation and development of Joincare Pharmaceutical Group Industry Co., Ltd. (hereinafter referred to as “the Company” or “we”, “our”) and ensure the compliance with relevant laws and regulations as well as the requirements of business ethics with our stakeholders in promoting and marketing the services of the Company. We undertake to provide accurate and balanced information about our products and services based on their actual conditions and display the social responsibility and values of the Company.

2. Scope of Application

The Policy is applicable to all employees (including full-time employees, part-time employees and temporary employees) of the Company and our subsidiaries.

3. Compliance with Laws and Regulations on the Industry

Any forms of marketing activities carried out by the Company, including our marketing contents and methods, shall comply with the requirements of applicable laws and industry standards of the places where we conduct business operation, including but not limited to the Advertising Law of the People’s Republic of China, the Drug Administration Law of the People’s Republic of China, the Law of the People’s Republic of China Against Unfair Competition and the Personal Information Protection Law of the People’s Republic of China.

4. Compliance with Relevant Marketing, Advertising and Sales Systems of the Company

The Company has established relevant systems on marketing, advertising and sales, including the Code of Conduct for Sales Personnel of Joincare, specified that relevant contents and methods of marketing activities shall meet relevant policies of the Company and shall be reviewed and approved by personnel authorized by the Company. We strictly prohibit exaggeration, deception or false contents in marketing activities.

5. Accurate Information Disclosure

The Company shall accurately disclose information in accordance with applicable laws and regulations of the places where we operate as well as standards and guidelines on the industry. Meanwhile, the Company shall not make false reports on our products, services or prices; and shall not make false or misleading representations on the products, services, performance or results records of the Company. The Company shall maintain all marketing materials for evaluation or review when necessary.

6. Privacy Protection

The Company shall ensure that no privacy of customers will be disclosed without the informed consent of customers.

7. Audit on Responsible Marketing

The Company has established an audit and supervision mechanism on responsible marketing materials and all marketing materials shall be approved by the management authorized by the Company. The Company conducts regular audits on marketing activities and materials. The audit shall include but not be limited to the planning, implementation and effects of marketing activities, advertising, publicity materials and sales documents and shall ensure their truthfulness, accuracy and legality without false publicity and misleading information and in compliance with the requirements of the responsible marketing policy of the Company.

The supervision and internal audit department of the Company conducts regular audits on the implementation of the responsible marketing policy to ensure all marketing activities of the Company in compliance with the requirements of the responsible marketing policy of the Company.

8. Environmental Protection and Social Responsibilities

While carrying out businesses, the Company actively performs environmental protection and social responsibilities of enterprises and initiatively integrates the environmental, social and sustainable development concepts into the business processes of R&D, testing and production, which is consistent with the approaches of the Company in environmental protection.

9. Staff Trainings

The Company will regularly provide trainings on responsible marketing for all employees and organize additional trainings for all marketing staff. The contents of trainings cover marketing rules and systems, products sales techniques and knowledge, negotiations and communications, laws and regulations and sales techniques.

10. Channels for Reporting Violations

The Company encourages employees to report the violation of the Policy through relevant channels in accordance with the requirements of the Code of Conduct on Business Ethics. Any employees, customers or suppliers of the Company or other third-party institutions may report the possible violations of marketing laws and regulations, industry standards or policies of the Company. All improper activities reported will be seriously handled and investigated in accordance with our Code of Conduct on Business Ethics and rectification measures will be adopted when necessary. Employees in violation of the Policy will be demoted or dismissed in principle and will assume relevant legal responsibilities in case of serious circumstances.

- Contact for reporting and complaints: Supervision and internal audit department of the Group

- Telephone for reporting and complaints: 0755-86252316, 0755-26980226

- Email for reporting and complaints: SAMD@joincare.com, joincaresamd@163.com

11. Circulation and Revision

All employees of the Company should read the Policy. We reserve the right to revise, modify or abolish the Policy at any time for any reasons. We will regularly review the Policy and make revisions when necessary. The latest version of the Policy will be disclosed on the website of the Company (https://www.joincare.com). In case of any changes to the Policy, we will notify employees of the latest version of the responsible marketing policy through various channels.

Joincare Pharmaceutical Group Industry Co., Ltd.

7 April 2023