Article 1 Purpose

Livzon Pharmaceutical Group Inc. and its subsidiaries (hereinafter referred to as the “Group” or “we”) are committed to conducting all sales and marketing activities based on responsible, ethical, and patient-centered principles. Therefore, the Responsible Marketing Policy (hereinafter referred to as the “Policy”) is formulated to regulate our sales and marketing activities in global markets.

Article 2 Scope of Application

The Policy applies to the Group and all of its employees (including permanent employees, part-time employees, and temporary employees). All units within the Group shall fully abide by the Policy while making their internal marketing systems.

Article 3 Compliance with Laws, Regulations, and Internal Systems

Any form of sales and marketing activities conducted by the Group must comply with all applicable laws, regulations, and industry guidelines in the location of operations, including but not limited to the Drug Administration Law of the PRC, the Anti-Unfair Competition Law of the PRC, the Advertising Law of the PRC, the Personal Information Protection Law of the PRC, and the General Data Protection Regulation (GDPR). They shall also comply with the Group’s internal systems established for sales, marketing, and advertising.

Article 4 Basic Principles

Any form of sales and marketing activities, including content, methods, and related materials, must be truthful, accurate, and compliant. Specific principles include:

1. Establishing a rigorous review and supervision mechanism that requires external and internal review and approval, as well as continuous supervision.

2. Promoting clinical efficacy based on data from formally published journal articles, ensuring the truthfulness, accuracy, and compliance of the content.

3. Prohibiting the inclusion of exaggerated, misleading, deceptive, or false content.

4. Prohibiting interference with or influence of the rational clinical medication.

5. Prohibiting the concealment of known risks, such as adverse reactions of products, and providing timely, truthful, and accurate feedback.

6. Conducting business with honesty, integrity, and fair competition.

7. Maintaining consistency of information across different channels.

8. Ensuring good business ethics when interacting with customers and healthcare professionals, and strictly prohibiting the use of commercial bribery or any other unlawful means in sales and marketing activities.

9. Strictly protecting customer privacy and refraining from disclosing customer privacy and information without their knowledge and consent.

Article 5 Responsible Marketing Audit

We conduct regular audits of responsible marketing to ensure compliance with our policies and systems in the Group’s sales and marketing activities and by relevant third-party service providers.

Article 6 Responsible Marketing Training

We provide regular responsible marketing training to all employees to continuously improve their expertise, capabilities, and professionalism in responsible marketing.

Article 7 Whistleblowing of Violations

If any behaviors that potentially violate laws, regulations, and relevant policies and systems of the Group are discovered, employees, clients, suppliers, service providers and other relevant personnel have the right to whistleblow them. For whistleblowing channels and procedures, please refer to the Administrative Measures for Whistleblowing and Complaint of Livzon Pharmaceutical Group Inc. (available on the Company’s official website). We will accept, investigate, and handle the whistleblowing based on these measures, keeping the personal information and whistleblowing content of the whistleblower strictly confidential and fully protecting the whistleblower’s legal rights and interests. For whistleblowing proved to be true, we will handle it seriously in accordance with relevant procedures, imposing punishment on the responsible person(s), and will implement necessary corrective measures.

Article 8 Miscellaneous

The Policy has been reviewed and approved by the ESG Committee (the “ESG Committee”) under the board of directors (the “Board”). The ESG Committee regularly reports to the Board on the implementation of the Policy and provides recommendations for the Board’s decision-making and oversight.

The ESG Committee is fully responsible for the implementation, oversight, and periodic review of the Policy. The ESG Committee is responsible for the interpretation and revision of the Policy.

For matters not covered in the Policy, relevant laws, regulations, and normative documents shall apply.

The Policy shall come into effect from the date of issuance.

Livzon Pharmaceutical Group Inc.