I. General

1. To strengthen internal monitoring within Livzon Pharmaceutical Group Inc. (hereinafter referred to as the “Company”) and its subsidiaries (hereinafter collectively referred to as the “Group”), prevent the occurrence of misconduct, violations, and fraudulent acts in various forms, and ensure the standardization of supervision and integrity management work, these measures (the “Measures”) are formulated in accordance with laws, regulations, and relevant provisions of the Group.

2. The Measures applies to all whistleblowing and complaints that involve violation of discipline and law, fraudulent actsor misconduct within the Group.

3. All employees of the Group and all clients, suppliers, service providers, contractors and other relevant personnel that have business relationship with the Group shall be entitled to report and complain about any violation of discipline and law and violation of the Group’s rules and regulations by any person within the Group. No entity or individual shall retaliate against whistleblowers and complainants in any form.

II. Scope of Responsibilities

4. The Audit Committee under the Company’s Board of Directors (hereinafter referred to as the “Audit Committee”) acts as the Group’s acceptance center for whistleblowing and complaints, and is responsible for the acceptance of whistleblowing and complaints, recording, reporting, investigating, and follow-up of reported violations of discipline and regulations. Appointed by the Audit Committee as its executive body, the risk management head office of the Company (hereinafter referred to as the “Whistleblowing Management Department”) is responsible for the day-to-day implementation and execution of the Measures and for reporting to the Audit Committee.

5. The risk management head office of the Company regularly submits work reports to the Audit Committee.

6. Main Scope of Responsibilities:

1) Promoting and informing the Group about whistleblowing and complaints regarding violations of discipline and law and fraudulent acts in various forms.

2) Accepting, managing, and handling whistleblowing and complaint materials and information.

3) Investigating, assigning and supervising whistleblowing and complaint cases.

4) Reporting and communicating the progress of investigations on whistleblowing matters.

5) Regularly statistically analyzing and summarizing the management of whistleblowing.

6) Undertaking the protection and reward of whistleblowers and complainants.

III. Whistleblowing Methods

7. Whistleblowing and complaintscan be made by letters, telephone, WeChat message, intranet mailbox, email, visits, and other means. Real-name whistleblowing is encouraged. However, anonymous whistleblowing is also allowed if specific clues of suspected violations of laws and regulations are provided and the truthfulness of the whistleblowing content is guaranteed. The legitimate rights and interests of the whistleblower will be fully protected in either case.

Contact persons for whistleblowing and complaint: Wang Wei, Xu Dan

Telephone No. for whistleblowing and complaint: 0756-8135383, 0756-8135948

Mobile No. for whistleblowing and complaint: 18666123020

Email for whistleblowing and complaint: wangwei@livzon.cn, xudan01@livzon.cn

Address for whistleblowing and complaint: Risk Management Head Office of Livzon Pharmaceutical Group Inc., Chuangye North Road No.38, Zhuhai City, Guangdong Province

8. The Whistleblowing Management Department should keep the information of whistleblowers confidential without disclosure of the personal information of whistleblowers and the handling of whistleblowing to the person being reported or personnel not relevant to the whistleblowing work.

9. For the issues raised in the whistleblowing or complaint, the whistleblower should be responsible for the authenticity of the materials provided, and shall not fabricate or distort facts, make false accusations or frame others, or harm the interests of the Group and the legitimate rights of other employees. The whistleblower shall conscientiously maintain the order of the Company and whistleblowing.

10. Regardless of the form of whistleblowing, whistleblowers shall allow the specific personnel responsible for accepting the whistleblowing and complaint to contact them. Otherwise, the Whistleblowing Management Department has the right to reject acceptance.

IV. Whistleblowing Acceptance Process

11. The Whistleblowing Management Department must carefully record the complaints and whistleblowing and fill in the Whistleblowing and Complaint Registration Form. It shall be submitted for approval by the responsible leaders of the Company according to the approval process. Based on the whistleblowing content, personnel will be organized to investigatein accordance with the law. The investigation shall be completed within 30 working days, and a written investigation report shall be provided. If an extension of the investigation is needed, the whistleblower shall be informed of the situation, but the duration for the overall investigationshall not exceed 90 working days. 

12. Handling of investigation results:

1)     If the investigation verifies that the whistleblowingor complaintcontent is unfounded, the investigators shall truthfully explain and clarify the facts.

2)     If the investigation verifies that the whistleblowing or complaint content is true but of a minor nature, the investigators shall report to the Audit Committee and require the person being reported or complained against to correct mistakes, and impose appropriate punishment according to regulations.

3)     If the investigation verifies that the whistleblowing or complaint content is true and of a serious nature, the investigators shall report to the Audit Committee and impose punishment on the responsible person after completing the relevant procedures and approval. If a violation of the law is involved, it shall be transferred to judicial organs for handling.

13. The investigators shall inform the whistleblower of the handling results in written form in 5 working days after it is handled, ensuring the whistleblower’s right to know. For any disagreement with the handling opinions, the whistleblower can request a review by the supervisory body of the original investigation department.

14. The investigators must be familiar with how to manage whistleblowing and maintain compliance with discipline and laws, integrity, and secrets. They must adhere to the principles of objectivity, emphasizing evidence, facts, and investigations and research.

V. Authority of the Whistleblowing Management Department

15. When accepting and investigating whistleblowing cases, the Whistleblowing Management Department has the authority to:

1)     request the associated departments and personnel under investigation to provide documents, materials, financial accounts, and other relevant information related to the matters under investigation.

2)     request the associated departments and personnel under investigation to provide explanations and clarifications on the issues related to the matters under investigation.

3)     request the associated departments and personnel under investigation to stop their disciplinary violations.

4)     work with the human resource department ontermination oflabor contracts or dismissalif serious disciplinary violations are determined in accordance with the law, and immediately transfer any violations that constitute a crime to the judicial organs for handling.

5)     investigate the responsibilities of the relevant persons and hold the main leaders of theirdepartmentsaccountable if thosedepartmentsconceal or delay reporting on the complaint or whistleblowing circumstances, do not cooperate with investigations, set obstacles to obstruct investigations or retaliate against the complainant or whistleblower.

VI. Protection of Whistleblowing and Complaints

16. The legitimate rights and interests of whistleblowers (including those who reportin real name or anonymously) shall be fully protected, including personal rights, property rights, rights at work, democratic rights, reputation rights, and other legitimate rights thatare protected by law.

17. For any whistleblowing or complaint case verified that meets the relevant conditions, whistleblowers shall be rewarded accordingly based on the nature of the case. The reward conditions are as follows:

1)     There is a clear and specific party being reported or complained against.

2)     The clues provided by the whistleblower or complainant were not previously known to the relevant department.

3)     The situation being reported or complained against has been proved to be true.

4)     If an anonymous whistleblower requests a reward, it will be handled according to the provisions for real-name whistleblowing.

VII. Confidentiality System for Whistleblowing and Complaint

18. The personal information and details of whistleblowers and complainants and their whistleblowing content must be strictly kept confidential. Whistleblowing materials and records should be kept as confidential documents, and any whistleblowing cases concludedshould be archived.

19. When the Whistleblowing Management Department accepts whistleblowing from a whistleblower or verifies information with the whistleblower and individuals involved, it should ensure confidentiality without revealing the identity of the whistleblower or complainant.

20. The publicity of rewards for whistleblowers must obtain their consent. Otherwise, their personal information shall not be publicly disclosed.

VIII. Related Responsibilities

21. Those who violate the relevant provisions of the Measures and disclose the information of the whistleblower or complainant shall be seriously dealt with in accordance with relevant regulations. If the circumstances are minor, they will be transferred out of their jobs or have their salaries reduced or have themselves demoted; if the circumstances constitute a crime, they will be transferred to judicial organs for investigation of criminal responsibility.

22. If whistleblowers or complainants deliberately fabricate facts, make false charges or frame-ups, create trouble or disrupt the normal operation of the whistleblowing department under the pretext of whistleblowing or complaint, they shall be seriously dealt with in accordance with relevant provisions. If it constitutes a crime, they shall be transferred to judicial organs for investigation of criminal responsibility in accordance with the law.

23. Any retaliation against whistleblowers or complainants, once verified, shall be seriously dealt with in accordance with relevant provisions, and shall be transferred to judicial organs for investigation of criminal responsibility in accordance with the law if it constitutes a crime.

24. If whistleblowers or complainants suffer personal injuries and reputational or economic losses due to retaliation, the Whistleblowing Management Department should handle it in accordance with the law. The whistleblowers may also sue in court for damages.

25. If it is confirmed that the whistleblower or complainant intentionally fabricates lies or fictional situations that interfere with the Whistleblowing Management Department or cause waste of human, financial, or material resources, the whistleblower may be held legally or financially liable.

26. The Audit Committee is fully responsible for the implementation, oversight, and periodic review of the Measures. The Audit Committee is responsible for the interpretation and revision of the Measures. For any questions regarding the content of the Measures, please contact the Whistleblowing Management Department.

27. The Measures shall come into effect from the date of issuance.

Livzon Pharmaceutical Group Inc.

Appendix

Whistleblowing and Complaint Registration Form

Whistleblowing/complaint No.: [     ]

Note: The form is to be completed and signed by the investigator