Chapter 1 General Provisions

Article 1   This system is formulated to prevent corruption in production and operation management, effectively carry out anti-commercial bribery and anti-corruption work, strengthen internal control within the group, strengthen institutional supervision and anti-corruption efforts, strengthen supervision of personnel in key positions, ensure the long-term effectiveness of anti-corruption and anti-commercial bribery efforts, and prevent various illegal and disciplinary violations and other improper behaviors.

Article 2 This system applies to the group headquarters and all its wholly-owned enterprises, holding companies, and branches (hereinafter collectively referred to as the "Group").

Article 3   All production and operation management activities or external liaison activities of the Group shall strictly abide by this system. The activities in this regulation include, but are not limited to, contact with government departments, order negotiations with customer representatives, procurement of raw materials, engineering construction, product sales, equipment procurement and maintenance, and other economic activities.

Article 4 All customers, suppliers, service providers, and contractors who have business dealings with the Group are within the scope of this system.

Chapter 2 Responsibilities

Article 5   The Group's Risk Management Department is the supervisory and management department for anti-corruption and anti-commercial bribery within the Group.

Article 6   The main responsibilities of the supervisory and management department are:

(1) In accordance with relevant national policies, laws, regulations, and group rules and regulations, carry out the Group's anti-corruption and anti-commercial bribery work;

(2) Strengthen the management and supervision of the integrity of employees in important positions and key links, prevent and manage corruption at the source, achieve both symptomatic and root-cause treatment, improve the system, and make true records of the integrity of employees in important positions and key links;

(3) Have employees in important positions and key links fully sign the "Anti-Corruption and Anti-Commercial Bribery Commitment Letter," have third-party partners such as customers, suppliers, service providers, and contractors who have business dealings with the Group sign the "Anti-Commercial Bribery Agreement," and track and supervise the implementation of the commitment letter.

Chapter 3 Regulations

Article 7 Interpretation of corruption and commercial bribery in this system:

(1) In violation of legal provisions, for the purpose of obtaining business opportunities or improper benefits, providing rebates, promotional fees, publicity fees, service fees, or reimbursement of various expenses outside of normal transactions, or directly or indirectly paying or receiving cash, goods, and other benefits under various names such as domestic and foreign tourism;

(2) Taking advantage of one's position to embezzle the Group's assets or misappropriate the Group's assets for personal or others' use.

Article 8 Specific measures for anti-corruption and anti-commercial bribery:

(1) Organize company executives to solemnly swear the "Company Executive Integrity Oath"; implement a commitment system for preventing corruption and commercial bribery for employees in important positions and key links; employees in important positions and key links must sign the "Anti-Corruption and Anti-Commercial Bribery Commitment Letter" with the Group;

(2) In contracts or bid documents submitted by customers, suppliers, service providers, and contractors who have business dealings with the Group, it is necessary to require the contract signatories and bidders to abide by this system and sign the "Anti-Commercial Bribery Agreement";

(3) Establish a leading body for the governance of corruption and commercial bribery, and carry out long-term anti-corruption and anti-commercial bribery work;

(4) The Group Risk Management Department should regularly conduct investigations and research, grasp the characteristics and laws of corrupt acts and commercial bribery, conduct research on prevention in terms of systems, education, and supervision, put forward specific countermeasures and measures, and promptly resolve issues with tendencies and signs;

(5) Disciplinary and regulatory issues discovered by various departments of the Group in the prevention of corruption and commercial bribery should be promptly stopped, promptly handled, and reported to the supervisory and management department; those suspected of crimes should be transferred to judicial organs for handling;

(6) Various departments of the Group should strengthen the management of employees in important positions and key links, and the implementation of the "Anti-Corruption and Anti-Commercial Bribery Commitment Letter" should be used as an important content for the Group's assessment and appraisal, as well as an important basis for appointments and removals;

(7) For verified cases of corruption and commercial bribery, penalties shall be imposed in accordance with the provisions of the Group's various rules and regulations according to the severity of the circumstances; in serious cases, the labor relationship shall be terminated; for losses caused to the Group, legal recourse shall be taken; and those suspected of constituting crimes shall be transferred to judicial organs for handling;

(8) For units and their employees who have business activities with the Group and violate the commitments stipulated in this system, their supplier, service provider, agent, distributor, and various bidding qualifications shall be cancelled; those suspected of constituting crimes shall be transferred to judicial organs for handling;

(9) For verified reports and complaints, certain material rewards shall be given to the reporters and complainants in accordance with the provisions of the Group's various rules and regulations, and they can also be used as a basis for promotion and salary increases.

Article 9 The following acts are prohibited in all production and operation management of the Group:

(1) Giving or receiving cash, goods, or other gifts to relevant units and their personnel in violation of Group regulations;

(2) Giving property or other economic benefits under the guise of donations to obtain transaction opportunities, services, or preferential conditions;

(3) Giving or receiving commercial sponsorships, tourism, etc., that violate the principles of fair competition;

(4) Giving or receiving membership cards (coupons), consumption cards (coupons), shopping cards (coupons), and other types of securities;

(5) Providing valuable items such as houses and cars to relevant parties for use, or accepting houses, cars, and other valuable items provided by relevant parties;

(6) Giving or receiving improper shares or dividends;

(7) Giving or receiving property under the guise of publicity fees, promotional fees, advertising fees, training fees, consulting fees, consulting fees, technical service fees, research fees, clinical fees, etc., to transfer or obtain benefits;

(8) Giving or receiving property through gambling to transfer or obtain benefits;

(9) Taking advantage of one's position to embezzle the Group's assets;

(X) Misappropriating funds for personal use or lending to others by taking advantage of one's position;

(XI) Acts that violate national laws, regulations, and the Group's various rules and regulations.

Article 10 Reporting and Complaint Methods

(I) The Group encourages employees at all levels and units with business dealings to report various acts of corruption;

(II) During the acceptance and investigation of various reports, the Group strictly protects the confidentiality of the reporter's name, department, and company name, and strictly prohibits disclosure to the reported person or unit; those who illegally disclose the reporter's information or retaliate against the reporter will be removed from office, their employment contracts terminated, and if they violate the law, they will be transferred to judicial organs for legal processing;

(III) After receiving a report or complaint, the Group's Risk Management Department shall immediately register and file it, and conduct an investigation according to the management authority of this system. If the reported person is a senior manager of the Group, it will be transferred to the Chairman for handling, and if necessary, submitted to the Board of Directors and the Supervisory Board; for all reports with real names, regardless of whether an investigation is launched, the Group's Risk Management Department shall provide feedback to the reporter;

(IV) Reporting and Complaint Telephone and Email:

  Reporting and Complaint Telephone: 0755-86252316 ； 0755-26980226

  Reporting and Complaint Email: SAMD@joincare.com

  Reporting and Complaint Address: Langshan Road, Nanshan District, Shenzhen, Guangdong Province 17-2 Joincare Pharmaceutical Group Building, Risk Management Department

Chapter 4 Supplementary Provisions

Article 11   This system shall come into effect and be implemented from the date of its approval by the company's board of directors.

Article 12   Matters not covered in this system shall be governed by relevant laws, administrative regulations, normative documents, and the company's articles of association.

Article 13 The right to interpret this system belongs to the company's board of directors.

Joincare Pharmaceutical Group Industry Co., Ltd.

202 4 Year 8 Month 27 Day