Policy Statement

Phoenix Interactive has established the Code of Ethical Conduct to ensure that all employees of Phoenix Interactive, as well as directors and managers appointed by the company, strictly adhere to the company’s ethical standards when conducting business activities and performing job duties. This includes, but is not limited to, complying with all national laws related to bribery, corruption, and prohibited commercial activities.

All employees must conduct business activities and job duties with integrity. They are strictly prohibited from directly or indirectly offering, promising, requesting, or accepting any form of improper benefit (including but not limited to bribery, corruption, kickbacks, or extortion).

Specific Measures

To ensure compliance, the company has implemented the Phoenix Interactive Co., Ltd. Code of Ethical Conduct.

This code applies to all directors, supervisors, managers, and employees of Phoenix Interactive. It covers the following areas:

• Integrity and Ethics
• Conflict of Interest Avoidance
• Fair Trade Practices
• Confidentiality Obligations
• Proper Charitable Donations and Sponsorships
• Protection and Proper Use of Company Assets
• Compliance with Legal Regulations
• Handling Violations of the Code of Conduct

Compliance Regulations and Training

Phoenix Interactive is committed to promoting integrity and ethical business practices through education and training.

• In addition to issuing the Code of Ethical Conduct, the company’s reward and disciplinary policies clearly outline the penalties for violations of ethical conduct.
• New employees are required to sign an employment contract that includes integrity and ethical behavior clauses.
• During onboarding, new employees receive training on ethics, insider trading laws, and relevant case studies.
• Each year, all employees are required to participate in an online training course on the Code of Ethical Conduct, with a passing score required to complete the course successfully.

Misconduct Reporting

Integrity and ethics are core values at Phoenix Interactive. Regardless of the business activities or job duties being performed, employees must adhere to the company’s ethical standards, which strictly prohibit bribery, corruption, or any form of fraudulent behavior.

If you identify any suspicious, inappropriate, or illegal conduct by Phoenix Interactive employees or representatives, or if you notice a violation of the Code of Ethical Conduct, please notify us immediately.

Reports will be handled by the company’s designated investigation unit. During the investigation, we will ensure that all provided information — including your personal data — is kept confidential and securely protected to safeguard your privacy.

Before Reporting, Please Read the Following Statement:

• Phoenix Interactive does not encourage or support anonymous reporting or anonymous accusations. As a general principle, anonymous reports will not be processed.
• When filing a report, you must provide your real name, contact number, and email address. During the investigation process, Phoenix Interactive may process your information for investigation purposes and related uses. If necessary, Phoenix Interactive may share your personal data with individuals involved in the investigation.
• According to the law, you must not intentionally fabricate false statements or defame specific individuals. If the reported case is proven to be malicious or intentionally fabricated, you will bear full legal responsibility.
• Any contact information provided by Phoenix Interactive, whether in whole or in part, must not be disclosed to any third party. Failure to comply may result in legal responsibility.

To facilitate the investigation process, please provide detailed and specific evidence. If insufficient information is provided, Phoenix Interactive may classify the report as invalid.