During the period from 2022 to 2025, the Group recorded zero incidents of non-compliance concerning product and service information and labelling, zero incidents of non-compliance concerning marketing communications, and incurred no monetary losses as a result of legal proceedings associated with false marketing claims.

Livzon Pharmaceutical Group Inc.

Responsible Marketing Policy

(Revised 2026)

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 in a responsible, ethical, and patient-centric manner. To this end, this Responsible Marketing Policy (hereinafter referred to as the “Policy”) is hereby formulated to govern our sales and marketing activities in all markets worldwide.

Article 2  Scope of Application

This Policy applies to the Group and all of its employees (including full-time, part-time, and temporary employees). All units within the Group shall fully comply with this Policy when formulating their internal marketing policies and procedures.

Article 3  Compliance with Laws, Regulations, and Internal Policies

All forms of sales and marketing activities conducted by the Group shall comply with all applicable laws, regulations, and industry codes in the jurisdictions where we operate, including but not limited to the Drug Administration Law of the People’s Republic of China, the Anti-Unfair Competition Law of the People’s Republic of China, the Advertising Law of the People’s Republic of China, the Personal Information Protection Law of the People’s Republic of China, and the General Data Protection Regulation (GDPR), as well as the Group’s internal policies and procedures relating to sales, marketing, and advertising.

Article 4  Fundamental Principles

All forms of sales and marketing activities, including their content, methods, and related materials, must be truthful, accurate, and compliant. Specifically:

A rigorous review and supervision mechanism shall be established. Both promotional and non-promotional materials must undergo external and internal review and approval prior to use, and shall be subject to ongoing supervision.

Claims regarding clinical efficacy and product information shall be based on data from formally published peer-reviewed literature, ensuring that the content is truthful, balanced, accurate, and compliant.

Content that is exaggerated, misleading, deceptive, or false is strictly prohibited.

Any interference with or influence over the rational use of medicines in clinical practice is strictly prohibited.

Concealment of known adverse reactions or other risks associated with products is strictly prohibited. Such risks shall be disclosed in a timely, truthful, and accurate manner, and in fair balance with information on product benefits.

Honesty, integrity, and fair competition shall be upheld.

Information communicated through different channels shall remain consistent.

Interactions with customers and healthcare professionals shall uphold high standards of business ethics. The use of commercial bribery or any other unlawful means in sales and marketing activities is strictly prohibited.

Customer privacy shall be strictly protected. Customer privacy and information shall not be disclosed without the customer’s informed consent.

Promotional materials (including advertisements, brochures, display materials, digital content, etc.) must undergo internal compliance review and approval prior to use. Non-promotional materials (such as medical education materials, patient education materials, and materials supporting scientific publications) must also be reviewed and approved in accordance with established procedures before external use.

All product information (including both promotional and non-promotional materials) must be truthful, accurate, and balanced. It shall clearly state the approved indication(s)/health condition(s) for the product and provide a fair and adequate balance between information on product benefits and known risks/adverse reactions. Exaggeration of efficacy or concealment of risks is prohibited.

Interactions with healthcare professionals must be ethical and transparent. Any transfer of value from the Company to healthcare professionals (including but not limited to speaker fees, consulting fees, travel support, and research funding) shall be recorded, disclosed, or reported in accordance with applicable laws, regulations, and industry codes (including but not limited to reference to the U.S. Sunshine Act, the EFPIA Code of Practice, the IFPMA Code of Practice, and similar requirements).

Collaboration and engagement with patient organizations/patient groups must be transparent and ethical, and must fully respect and safeguard the independence of such organizations. The Company shall not improperly influence the decision-making, positions, or activities of patient organizations in any manner. All related support shall be open and traceable.

The Company shall establish mechanisms for the review and ongoing monitoring of product-related content, activities, and materials published on social media, digital channels, and online platforms to ensure compliance with applicable laws, regulations, and this Policy.

Article 5  Responsible Marketing Audits

We regularly conduct responsible marketing audits to ensure that the Group’s sales and marketing activities, as well as those of relevant third-party service providers, comply with our policies and procedures. The scope of such audits includes the implementation of approval processes for promotional and non-promotional materials, the disclosure of transfers of value to healthcare professionals, the compliance of interactions with patient organizations, and the monitoring of social media and digital channels.

Article 6  Responsible Marketing Training

We regularly provide responsible marketing training to all employees to continuously enhance their professional knowledge, capabilities, and ethical standards in responsible marketing. Training content covers the provision of accurate and balanced information, ethical interactions with healthcare professionals and patient organizations, requirements for the approval of promotional and non-promotional materials, and social media compliance, among other topics.

Article 7  Reporting of Violations

Any employee, customer, supplier, service provider, or other relevant party who becomes aware of potential violations of applicable laws, regulations, or the Group’s relevant policies and procedures has the right to report such matters. Reporting channels and procedures are set out in the Livzon Pharmaceutical Group Inc. Whistleblowing and Complaint Management Measures (published on the Company’s official website). We will accept, investigate, and handle reports accordingly, strictly protect the personal information of whistleblowers and the content of reports, and fully safeguard the legitimate rights and interests of whistleblowers. Where a report is verified to be true upon investigation, we will take serious action against the responsible individuals in accordance with relevant procedures, impose penalties, and implement necessary corrective measures.

Article 8  Miscellaneous

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

The ESG Committee has overall responsibility for the implementation, supervision, and periodic review of this Policy. The ESG Committee is responsible for the interpretation and revision of this Policy.

Matters not covered by this Policy shall be handled in accordance with applicable laws, regulations, and normative documents.

This Policy shall come into effect as of the date of its promulgation.

Livzon Pharmaceutical Group Inc.

September 2026