I. General

1. To regulate the employment management and ethical conduct of Livzon Pharmaceutical Group Inc. (hereinafter referred as the “Company”) and its units (hereinafter referred to as “Livzon Group” or “we”), the Code of Labor Employment and Ethical Conduct (hereinafter referred to as the “Code”) is formulated in accordance with the United Nations Global Compact, the ILO core conventions, and relevant laws, regulations, and policies of the People’s Republic of China.

2. The scope of application of the Code is Livzon Group and all of its employees (including permanent employees, part-time employees and temporary employees),as well as clients, suppliers, service provider, contractors and other partners that have business relationship with Livzon Group (hereinafter collectively referred to as "relevant personnel"). Each unit shall fully abide by the Code while making its own human resources and related policies.

II. Recruitment and Employment

1. Livzon Group’s recruitment and employment follows the principle of fairness, impartiality and openness. The recruitment is based on job qualifications and the ability of the candidate, regardless of age, ethnicity, race, family status, ethnic background, skin color, gender, sexual orientation, religious belief, social origin, nationality, disability, pregnancy, etc. Each unit shall ensure equal opportunities during the employment process and reject all acts of discrimination and prejudice.

2. Livzon Group believes that diversity is one of the important elements to maintain the Company’s competitive advantage and promote the Company’s sustainable development. We endeavor to create an inclusive working environment and respect the diversity and differences of our employees. We incorporate the principle of diversity into the recruitment and employment policies of each unit of Livzon Group, which apply to all employees and units of Livzon Group.

3. Livzon Group prohibits the use of child labor, and all of our units are forbidden to recruit and employ minors under the age of sixteen.

III. Employment and Ethical Conduct

1. We are against forced labor. No unit shall force employees to labor by means of violence, threats or illegal restrictions on personal freedom.

2. We respect employees’ freedom of association. Employees have the right to freely choose to form or join a trade union. The trade union has the right to bargain with Livzon Group on an equal footing on behalf of the employees and sign collective agreements according to law.

3. We strive to create a physically and mentally healthy working environment for employees. We guarantee the labor safety and health protection of employees in the workplace in accordance with the requirements of national regulations, and support the continuous improvement of the working environment. All employees are responsible for reporting potential unsafe factors in the workplace.

4. In case of sick leave or non-work-related injuries, all units shall adhere strictly to the national Regulations on Medical Treatment Periods for Enterprise Employees with Illnesses or Non-work-related Injuries (《企业职工患病或非因工负伤医疗期规定》). After employees have recovered from their illness or injury and returned to work, their positions shall be arranged based on their physical condition and practical requirements, without any form of discrimination.

5. We highly regard the development and advancement of employees’ talents. In matters concerning employment, such as remuneration, benefits, training opportunities, promotion, demotion, assignment, transfer, development, tuition assistance, or retirement, we will base our decisions on employees’ competencies, work performance, and work requirements, regardless of age, ethnicity, race, family status, ethnic background, skin color, gender, sexual orientation, religious belief, social origin, nationality, disability, pregnancy, or other factors. We strive to eradicate all forms of bias and discrimination.

6. We strictly prohibit any form of harassment in the workplace, including sexual harassment and other non-sexual harassments against the will of others by means of oral language, written texts, images, physical behavior, etc. Subjecting employees to unreasonable interference with their work performance or creating a working environment that is intimidating, hostile, humiliating, or otherwise unpleasant through conduct that has sexual connotations is also considered sexual harassment. We encourage employees who are victims of harassment to immediately report the situation to their supervisors or the human resource department for the Company to investigate. We will investigate such reports confidentially as promptly as possible. Once the investigation is sufficient to substantiate relevant allegations, we will take appropriate corrective actions.

7. We are against corruption and bribery. All employees and units of Livzon Group must abide by the Anti-Corruption and Anti-Commercial Bribery Regulations of the Company, and all clients, suppliers, service providers and contractors who have business relationship with Livzon Group are within the scope of these regulations.

8. We incorporate the principles and concepts such as diversity, anti-discrimination, impartiality, and anti-harassment into employee training, and require all employees of the Group to participate in the training to gain a deep understanding of the above principles and relevant regulations.

9. Avoidance of conflicts of interest. Employees shall avoid actual or potential conflicts of interest while performing their job duties. They shall comply with relevant laws, regulations, and industry guidelines, and allow no relationships to interfere with their job duties and business judgments. They shall not undertake or participate in any activities that conflict with the interests of Livzon Group, nor shall they use their authority to obtain benefits, privileges, or interests for themselves or their relatives in their work and business. If a potential conflict of interest is identified, employees shall immediately report it to their supervisors or the human resource department.

10. We uphold the EHS (Environment, Health and Safety) values of “Put life first, prioritize safety, follow regulations and laws, protect the environment”, and continuously promote green and sustainable development. We actively fulfill our responsibilities for health, safety, and environmental protection, and continuously cultivate and enhance the awareness and skills of safety and environmental protection among employees and relevant personnel. Employees and relevant personnel shall have a clear understanding of and comply with our EHS policies and regulations, and implement measures to improve EHS performance, such as energy conservation and emission reduction, occupational health and safety, in their work to integrate continuous improvement of EHS performance into daily work and operations.

11. Information confidentiality. Employees and relevant personnel shall strictly protect confidential information and take appropriate protective actions to ensure the security of confidential information. They shall not use, exploit, or disclose confidential information in any way without our prior written consent or unless it is within the scope of legitimate performance of their job duties. Even within Livzon Group, the circulation of confidential information shall be limited to “what is necessary for fulfilling one’s duties”. Such obligation of confidentiality does not terminate upon an employee’s departure or the termination of cooperation with relevant personnel.

12. Anti-money laundering. We strictly prohibit money laundering and comply with all applicable anti-money laundering laws and regulations.

13. Insider trading. Insider information refers to information related to Livzon Group’s operations and finances or information that has a significant impact on the market prices of the Company’s securities and has not been officially disclosed through designated channels by regulatory agencies. We strictly prohibit insiders (those who have direct or indirect access to insider information before its public disclosure) from trading the Company’s stocks and derivatives based on insider information, disclosing insider information to external parties, or advising others to trade based on insider information. Insiders shall take necessary measures to keep the number of people privy to insider information to a minimum.

14. Whistleblowing. We encourage employees and relevant personnel to report any violations of the Code or any suspected violations of laws and regulations. We accept both anonymous and real-name whistleblowing and strictly keep the whistleblower’s information confidential. We are committed to protecting whistleblowers’ legal rights and interests and strictly prohibit any retaliation against them. Any violations will be dealt with in accordance with relevant regulations so as to achieve the maximum protection for whistleblowers. For details on whistleblowing channels and procedures, please refer to the Company’s Administrative Measures for Whistleblowing and Complaint.

15. Fair competition. We advocate for fair competition and comply with all applicable laws and regulations on fair competition and anti-monopoly. We strictly prohibit any conduct that hinders or restricts fair competition, including entering into illegal agreements with competitors to eliminate or reduce competition.

IV. Remuneration Management

1. The approval and calculation of employees’ remuneration and related benefits shall follow the principle of fairness. Employees’ remuneration shall not be lower than the minimum wage standard stipulated in national and local regulations. Social insurance and housing provident fund contributions shall be made legally for all employees who have signed labor contracts.

2. Wage distribution shall be made according to individual performance, following the principle of equal remuneration for work of equal value.

3. Employees who work overtime should be able to take working days off or be offered overtime pay in accordance with national laws and the Company’s regulations.

V. Handling of Violations

1. We will give our best effort to identify acts that do not comply with the provisions of the Code, and commits to make every effort to prevent such acts from occurring. To this end, we encourage relevant personnel to report violations of the Code to their supervisors or the human resource department as promptly as possible so that the Company can investigate and tackle them to reduce the occurrence of such violations in the future.

2. We will investigate the violations of the Code as promptly as possible and take necessary measures to protect the legitimate rights and interests of relevant personnel who report and complain in good faith. Those who deliberately fabricate facts and make false charges or frame-ups under the pretext of reporting or complaining will be seriously dealt with in accordance with relevant regulations, and shall be transferred to judicial organs for handling if the action constitutes a crime.

3. Once the investigation is sufficient to prove that there is a violation of the Code, we will impose appropriate penalties and take appropriate corrective actions, including but not limited to negatively impacting the employee’s performance appraisal results and terminating labor contracts or commercial contracts. Those whose actions are suspected of constituting a crime shall be transferred to judicial organs for handling.

VI. Miscellaneous

1. The Code 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 Code and provides recommendations for the Board’s decision-making and oversight.

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

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

4. The Code shall come into effect from the date of issuance.

Livzon Pharmaceutical Group Inc.