Chapter I General Provisions

Article 1 Joincare Pharmaceutical Group Industry Co., Ltd. (hereinafter referred to as the Company or Joincare) attaches great importance to integrity-based operation. In accordance with relevant provisions of the Company Law of the People’s Republic of China, the Basic Standards for Enterprise Internal Control and other laws, regulations and normative documents and in light of the actual conditions of the Company, this Protection Policy is hereby formulated to strengthen the management of complaints, whistleblowing and whistleblower protection, regulate the management of complaints and whistleblowing, safeguard the legitimate rights and interests of the Company and guarantee the normal exercise of the right of employees (including full-time employees, part-time employees and contractors), customers and suppliers of the Company and other third parties in complaining and reporting illegal and illicit activities.

Article 2 This Policy shall apply to all departments, direct or indirect wholly-owned subsidiaries and direct or indirect majority-owned subsidiaries (collectively referred to as subsidiaries) of the Company. Joincare actively calls on and advocates its suppliers, agents and other partners to jointly abide by these provisions.

Chapter II Range of Complaints and whistleblowing and Management Accountability

Article 3 The range of complaints and whistleblowing is as follows:

1. Activities in violation of the Articles of Association, internal control systems, professional ethics and code of conduct;
2. Seeking improper benefits, accepting or offering commercial briberies and other activities;
3. Transferring the transactions under which the Company can legally benefit under normal circumstances to others;
4. Deliberately concealing or misrepresenting transactions resulting in false records, misleading statements or material omissions in information disclosure;
5. Embezzlement, misappropriation, theft or encroachment of the assets of the Company;
6. Falsifying or altering accounting records or vouchers or providing false financial reports;
7. Disclosing the business or technical secrets of the Company;
8. Abuse of power for personal gains by directors, supervisors, the president and other senior management of the Company;
9. Activities in violation of the Code of Labor Employment and Ethical Conduct of Joincare Pharmaceutical Group Industry Co., Ltd. and other activities infringing upon the rights and interests of laborers;
10. Other activities that jeopardize the normal operation and social reputation of the Company.

Article 4 The Audit Committee of the Company’s Board of Directors of is responsible for supervising and reviewing the implementation and operation of this Policy. The Supervision and Audit Department of the Company is the routine management department on complaints and whistleblower protection, and its specific responsibilities are as follows:

1. Being responsible for the management of telephone and email for complaints and whistleblowing, accepting real-name or anonymous complaints and whistleblowing and publicize the telephone, email and address for complaints and whistleblowing as necessary;
2. Keeping the written records of the contents of whistleblowing and reporting to the management or the chairman;
3. Carrying investigations on the complaints and whistleblowing received and reporting the investigation results to the chairman;
4. Archiving the materials on complaints and whistleblowing and the report after investigation and treatment in a timely manner.

Chapter III Methods of Complaints and Whistleblowing

Article 5 Employees at all levels and social parties that have direct or indirect economic relations with the Company may report information on actual or suspected cases of fraud by the Company and its staff, as well as information involving the infringement of the rights and interests of laborers, including information on complaints and reports of violations of professional ethics by the Company and its staff.

Article 6 Complainants and whistleblowers may conduct complaints and whistleblowing through written forms, email, telephone and other proper means. Complainants and whistleblowers shall explain the basic process of the matter, the name of the subject complained and whistle-blown, the specific person in question, the name, contact method and specific complaint requirements of the complainants and whistleblowers. They shall also provide the evidence on infringing the benefits of the complainants and whistleblowers or the Company as well as other materials related to the matters concerned.

Article 7 The Company encourages complainants and whistleblowers to conduct whistleblowing in real names. For real-name complaints and whistleblowing, the Supervision and Audit Department will strictly keep them confidential and provide feedbacks on the investigation results to the complainants and whistleblowers through appropriate manners.

Chapter IV Handling Procedures of Complaints and Whistleblowing

Article 8 Complainants and whistleblowers shall provide truthful information in complaints and whistleblowing. The Supervision and Audit Department of the Company shall keep records of the contents of the complaints and whistleblowing. It shall carry out analysis and assessment on the matters concerned and whistle-blown and conduct hierarchical handling in the following principles:

(I) Level A: For those involving the Company’s directors, supervisors and senior management or being deemed as serious in nature by the Supervisory Committee, the Supervision and Audit Department will make preliminary investigation and judgment on the matters involved and handle them in the following manners if it deems that the fact concerned is generally true:

1. For the whistleblowing of the violation of disciplines involving the Company’s directors, supervisors and senior management and the violation of disciplines stipulated under relevant rules of the Company, the Supervision and Audit Department of the Company shall determine the method of investigation after receiving the report and propose treatment opinions based on the investigation results;

2. For the whistleblowing of management defects or other significant errors at the management level of the Company, the Supervision and Audit Department shall immediately report to the Board of Directors of the Company and propose the method of investigation based on the internal management systems and requirements of the Company. After investigating the facts, the responsible department on investigation shall propose treatment or rectification opinions or advices and report the treatment to the Board of Directors of the Company;

3. For the whistleblowing of other violations of disciplines, it shall be handled based on relevant procedures of the Company on relevant violations of disciplines.

(II) Level B: For the whistleblowing or complaints with facts or constituting the violation of disciplines but none of the Company’s directors, supervisors and senior management being involved or being not serious in contents or nature, they shall be in the following manners:

1. For the whistleblowing or complaints with facts or constituting the violation of disciplines by individuals, the Supervision and Audit Department shall designate special staff to further investigate and verify the contents whistle-blown, propose advices or treatment advices to the department of the person under the whistleblowing based on the investigation. The department of the person under the whistleblowing shall be responsible for handling the case under the whistleblowing and the handling department shall report the treatment results to the Supervisory Committee in a timely manner;

2. For the whistleblowing or complaints on management defects or other errors of relevant departments of the Company and the incident, the Supervision and Audit Department shall notify relevant departments of the Company to propose remedial measures or opinions or suggestions on rectification measures on the management defects in a timely manner. Relevant departments shall adopt remedial measures or rectify the defects or errors and report the treatment results to the Supervisory Committee in a timely manner.

(III) Level C: For the complaints preliminarily determined to lack of evidence but not malicious false accusations or slanders in nature by the Supervision and Audit Department after preliminary investigations, it shall notify the investigation results to the complainant or whistleblower after further investigations and verifications.

(IV) Level D: For the whistleblowing or complaints being malicious false accusations or slanders after the preliminary judgment of the Supervision and Audit Department after preliminary investigations, the complainant or whistleblower shall be punished correspondingly or transferred to judiciary authorities based on the extent of the influence of his behaviors on the person under question or the Company after further investigation and verification. Where the complainant or whistleblower fabricates information, falsifies evidence and maliciously accuses others through complaints or whistleblowing, he shall assume the corresponding responsibilities.

Article 9 After receiving the complaints or whistleblowing, the Supervision and Audit Department of the Company shall notify the complainant or whistleblower of the investigation or treatment results within a prescribed period. Detailed provisions are as follows:

1. For those within its terms of reference, it shall notify the complainant or whistleblower of the investigation or treatment results within 30 days after receiving the whistleblowing. Where it fails to notify within the time limit, it shall explain the reasons to the complainant or whistleblower;

2. For those out of its terms of reference, it shall notify the complainant or whistleblower of the reasons for not accepting and the authority for acceptance within 5 days after receiving the whistleblowing. Where it is required to transfer or deliver to relevant authorities for handling, it shall notify the complainant or whistleblower of the time of transferring and delivery;

3. If the complainant or whistleblower does not state his/her real name or address and cannot be notified, the above two sub-articles shall not apply.

Article 10 Where the complainant or whistleblower believes that the employees for accepting and handling complaints are relatives or interested parties of the person under whistleblowing or complaints and it may affect the objective and fair treatment of the whistleblowing, it shall have the right to require for abstaining. Relevant employees shall abstain if the conditions prove to be true.

Chapter V Violations in the Process of Complaints and Whistleblowing and Handling

Article 11 Any departments, subsidiaries and individuals shall not interfere with and hinder the employees on handling complaints and whistleblowing to investigate the complaints and whistleblowing.

Article 12 The working staff on accepting and handling complaints and whistleblowing shall follow the following work standards:

1. They shall carry out the face-to-face complaints and whistleblowing in secret places with special staff and other irrelevant persons shall not listen to or enquire about that;

2. They shall strictly follow the confidential principle in the receiving, reading, registration, transfer, safeguarding and face-to-face paraphrasing of letters of complaints and whistleblowing or the reception, answering, recording or taping whistleblowing through telephone and strictly prevent the leaking of contents and the loss of whistleblowing materials;

3. They are prohibited to extract or photocopy the materials of complaints and whistleblowing;

4. For the investigation on the person or the entity under complaints and whistleblowing, it shall be kept confidential without disclosing the identity of the complainant or whistleblower and shall not display the materials of complaints and whistleblowing;

5. They shall not disclose the internal study on the complaints and whistleblowing to the whistle-blower and shall not discuss about the contents of whistleblowing with irrelevant persons;

6. They shall not withhold, conceal or privately destroy the materials of complaints and whistleblowing;

7. They shall not make difficulties or threat the complainant or whistleblower.

Article 13 For the working staff in violation of the above provisions, they shall be held accountable. Where they are suspected of violation of laws and crime, they shall be transferred to judiciary authorities for handling.

Article 14 For those deliberately fabricate false facts or conduct malicious accusation against others in the name of complaints or whistleblowing or make trouble and disturb normal work in the name of complaints or whistleblowing, they shall be treated seriously in accordance with relevant rules. Where it constitutes crimes, they shall be transferred to judiciary authorities for handling. The provisions of this article shall not apply to false complaints or whistleblowing due to the insufficient knowledge of facts.

Chapter VI Measures for Whistleblower Protection

Article 15 The protection of complainants and whistleblower shall follow the principles of confidentiality, incentive and no infringement of their legitimate rights and interests. The Company shall adopt necessary measures to fully safeguard the legitimate rights and interests of complainants and whistleblowers, including the right of the person, the property right, the right to work, the democratic right, the reputation right and other legitimate rights.

Article 16 All departments and subsidiaries of the Company shall correctly treat the whistleblowing reported by complainants and whistleblower according to laws and shall not retaliate against the complainants and whistleblower s under any pretext.

Article 17 It is strictly prohibited to disclose the name, company, address and other information of whistle-blowers and the contents of complaints or whistleblowing to the person under complaints or whistleblowing. Where the person under complaints or whistleblowing is a responsible person of an entity, the materials of complaints or whistleblowing shall not be transferred to the department or subsidiary of the responsible person. Those in violation of the above provisions shall be held accountable. Where they are determined to violate laws by judiciary authorities, they shall be transferred to judiciary authorities for handling.

Article 18 Where the complainant or whistleblower is retaliated, he/she shall have the right to report to the Supervision and Audit Department or his/her superiors.

Article 19 Those who retaliate against the complainant and whistleblower, including conniving, shielding, bribing or instructing others to attack or revenge the complainant and whistleblower, shall be held accountable. Where they are determined to violate laws by judiciary authorities, they shall be transferred to judiciary authorities for handling.

Article 20 Where the departments of the Company conceal complaints or whistleblowing, fail to report in time, refuses to cooperate in investigation, set barriers to disturb investigations or attack and revenge the complainant and whistleblower, the Supervision and Audit Department shall have the right to hold relevant staff accountable. Meanwhile, major leaders of the department shall also be held accountable.

Chapter VII Supplementary Provisions

Article 21 For matters not covered under this Policy, they shall be subject to relevant national laws, regulations, normative documents and relevant provisions of the Articles of Association. Where this Policy is inconsistent with the provisions of relevant laws, regulations and normative documents promulgated in the future, relevant laws, regulations and normative documents shall prevail and this Policy shall be modified immediately.

Article 22 This Policy shall come into effect from the date on which it is considered and approved by the Audit Committee of the Board of Directors. The Audit Committee of the Board of Directors shall be responsible for the interpretation and revision of this Policy.

Joincare Pharmaceutical Group Industry Co., Ltd.

2 April, 2024