Code of Conduct

The group has formulated the Integrity and Compliance Manual with the aim of providing principled compliance guidelines for the business management activities of all units and the job performance behaviors of employees, as well as preventing compliance risks. Internally, it fosters a corporate culture of integrity and compliance, while externally, it establishes a positive image of the group as being honest and compliant. The "Manual" applies to all units within the Group system, as well as all employees, directors, and supervisors, and encourages business partners (including suppliers, contractors, subcontractors, agents, distributors, third-party intermediaries, joint venture partners, and other counterparties or participants in business activities) to maintain integrity and compliance with behavioral standards that are no less rigorous than those outlined in this manual.

We maintain a robust compliance reporting and accountability mechanism, embedding legal and regulatory adherence into institutional frameworks and operational practices. Oversight responsibilities are assigned to departments such as disciplinary inspection, supervision, and audit, which ensure timely rectification of identified issues and rigorously enforce accountability for losses caused by non-compliant operations. The Group continuously collects data, conducts risk analyses, evaluates the effectiveness of implemented practices, and identifies improvement opportunities to refine management systems and strengthen the foundation of ethical operations.

-Violation Handling

The group adopts a "zero-tolerance" policy towards any violations of compliance requirements and will seriously handle such violations in accordance with relevant regulations. For cases that result in asset losses or serious adverse consequences, the matter will be referred to the accountability department. For suspected violations of discipline or laws, the matter will be referred to relevant authorities or agencies such as discipline inspection and supervision in accordance with regulations.

The group has established a violation reporting platform to receive information on violation reports. If any issues or clues are discovered regarding the business management activities of units within the Group system or the job performance behaviors of employees that violate national laws and regulations, regulatory requirements, industry standards, international treaties and rules, as well as the group's articles of association, relevant rules and regulations, etc., any employee, business partner, or other relevant party may report them through the following channels. The Group will strictly keep the identity of the reporter and the reported matters confidential, and no unit or individual is allowed to retaliate against the reporter in any form.

-Anti-Corruption and Anti-Bribery

The group strictly abides by the anti-commercial bribery, anti-corruption laws, regulations, and related international conventions of China and the countries (regions) where it operates. The Group maintains a "zero-tolerance" policy towards commercial bribery and corruption, with supervision carried out by senior management. The Group has formulated the Financial Business Integrity Risk Prevention and Control Manual (2024 Edition), which focuses on key aspects of financial business processes and personnel management. Centered on strengthening checks and balances and supervision of power, and based on position-level risk prevention, the Group has established a mechanism for integrity risk prevention and control that features clear responsibilities, identified risks, strong measures, and timely early warnings, thereby enhancing anti-corruption capabilities. Within this policy, the Group clearly defines multiple key aspects, including: preventing bribery and corruption, guidelines on gifts and hospitality, management of political donations, standards for charitable donations and sponsorships, conducting regular anti-corruption training, as well as procedures and disciplinary measures for handling violations.

In effectively preventing bribery and corruption, the Group has established a sound risk monitoring and early-warning mechanism with corrective measures, and conducts regular monitoring and evaluation of integrity risk control across positions to build a dynamic prevention system. Multi-channel dynamic monitoring is carried out on employee conduct, institutional implementation, and the exercise of authority, enabling the timely identification of institutional loopholes, management weaknesses, and emerging or potential issues. Through measures such as enquiries, admonitory conversations, and accountability actions, the Group promptly corrects deviations, mitigates integrity risks, and ensures early prevention, early detection and early correction, eliminating misconduct at the source.

With regard to the guidance on gifts and hospitality, no employee may, for the purpose of influencing business decisions or obtaining improper benefits, directly or indirectly provide, offer, or accept any form of bribe from any individual or relevant party. This includes but is not limited to the direct or indirect giving or receiving of cash, gift money, securities, goods, travel and entertainment expenses, or other non-financial benefits. Employees are strictly prohibited from accepting any form of kickbacks or soliciting benefits from subordinates or partner companies. Procurement activities must strictly comply with the Tendering and Bidding Law and other relevant laws and regulations, as well as the Group’s policies, with strict prohibition of non-compliant or fraudulent tendering, and a firm rejection of benefit transfers.

The Group regularly conducts training on identifying and reporting bribery and corruption incidents, guiding employees and partners to familiarize themselves with reporting channels and methods, enhancing their ability to identify and report violations, and promoting the implementation of a culture of integrity and compliance. For each report received, the Group strictly investigates and follows up in accordance with established procedures. The investigation process is standardized and transparent, and the investigation results and corrective measures are disclosed in a timely manner as required, effectively safeguarding the sustainable operation of the enterprise and the common interests of stakeholders.

- Whistleblowing and Protection

Universal Medical upholds anti-corruption principles, requiring employees to maintain ethical standards and collectively foster a fair, transparent, and disciplined business environment. We have developed the Whistleblowing and Complaint Work Rules and has set up a dedicated disciplinary inspection and petition reporting platform managed by a designated person. This platform receives information on violations, logs it in an organized manner, classifies it, and ensures that the reported information is processed in a timely and effective manner. The platform also facilitates the resolution and correction of any issues. We commit to keeping whistleblower information confidential and ensuring the protection of their rights.

The whistleblowing mechanism and handling procedures are periodically reviewed to assess effectiveness, with continuous improvements made to reporting channels and internal compliance governance.

-Equality, Inclusivity, and Anti-discrimination

The group adheres to equal recruitment, just treatment, and equal employment opportunities. It values diversity and inclusivity, fosters an equitable work environment, and provides employees with opportunities for fair development. Employees of different nationalities, races, religions, ethnicities, genders, ages, and marital statuses are treated fairly and equitably, with character, performance, and ability serving as the fundamental basis for recruitment and promotion.

In terms of diversity recruitment, we continue to focus on employment opportunities for ethnic minority groups. From FY2021 to FY2024, the number of newly recruited employees from ethnic minorities is as follows:

We strive to cultivate a workplace where employees feel safe, trusted, and respected, with zero tolerance for discrimination, harassment, and violence. The group does not permit any discrimination or differential treatment based on race, color, religion, ethnicity, gender, family status, genetics, or any other factors.

-Information Security and Data Protection

The group places great importance on information security and data protection, and actively addresses information security challenges. We strictly comply with the information security laws and regulations, regulatory requirements, and international treaties and rules of China and other countries or regions where we operate, and take prudent measures to ensure the security of information relating to business partners and stakeholders. Internal management systems such as the Cybersecurity Management Measures and the Cyber and Information Security Emergency Response Plan have been formulated, covering all relevant business lines and subsidiaries. Cybersecurity management provisions are also included in the employee handbook as a basic requirement for staff. To safeguard individuals’ rights to access, rectify and delete their personal data, we have issued the Medical Data Security Management Measures and plan to release the Data Security Management Measures in 2025 to further regulate personal information processing and information security management.

The Group conducts information disclosure in strict accordance with applicable laws, regulations and regulatory requirements, ensuring that disclosures are truthful, accurate, complete and timely. Employees may disclose information externally only within the scope of their duties and in compliance with the law and internal policies. Unauthorised or unapproved disclosure of information is strictly prohibited.

The Group regularly conducts cybersecurity certification, testing, and risk assessments, develops cybersecurity incident response plans, and promptly addresses system vulnerabilities, computer viruses, and cyberattacks to prevent information security risks. The Group regularly conducts internal audits of its information security management system, and Global Tech Services, a subsidiary of the Group, has obtained ISO 27001 information security management system certification. Additionally, the Group has established a clear and efficient incident reporting and handling mechanism. Employees can promptly report information security incidents, vulnerabilities, and suspicious activities through the internal platform. The Group strictly keeps all reported information confidential and responds swiftly to ensure information security is traceable and actionable. In 2024, the Group did not experience any information security violations.

-Avoiding Conflicts of Interest

1. Must not misuse company resources

Employees must use the assets, information, opportunities, and any other resources they access and utilize in the Group solely for work purposes. They must not misappropriate or abuse these resources, nor use them for personal gain, for the benefit of stakeholders, or for any other improper purposes. It is essential to prevent waste, loss, misappropriation, or abuse of company resources due to improper custody or use.

2. Must not abuse authority

Employees should exercise their powers and functions correctly and appropriately for the benefit of the Group, and must not use them for any personal purposes. They should not use their position to seek benefits for themselves, their relatives, or friends. If employees need to conduct business activities such as inspections, negotiations, contract signing, bidding and tendering, providing guarantees, issuing certificates, expressing opinions or releasing news on behalf of the Group in the media, or participating in public activities on behalf of the Group, they should obtain prior approval or authorization from the Group.

3. Must not unauthorized part-time work

Employees should focus on their primary job responsibilities and must not engage in any paid or unpaid part-time work without the Group's consent. They must not engage in unauthorized part-time work for remuneration. Except for the exceptions stipulated by laws and regulations, employees are not allowed to hold concurrent positions in any organization that competes with the Group's business.

-Anti-Monopoly and Fair Competition

The Group has consistently adhered to the conduct of legitimate, compliant, and fair transactions with other market players, strictly observing the anti-monopoly laws and regulations of China and countries (regions) where its business operates, and resolutely prohibiting all forms of unfair competition that violate anti-monopoly laws and regulations.

Both the Group and its employees are prohibited from engaging in any form of competition with other operators that violates laws and regulations, breaches business ethics, disrupts market competition order, or harms the legitimate rights and interests of other operators or consumers. Such behaviors include but are not limited to price manipulation, disrupting bidding procedures, market segmentation, restricting output, and unjustifiably boycotting a particular customer or supplier.

-Anti-Money Laundering/Insider Trading/Terrorist Financing

The Group strictly adheres to the anti-money laundering laws and regulations of China and the countries (regions) where it operates, establishing corresponding systems and procedures to prohibit employees from participating in any such activities and prevent exploitation by criminal elements. We thoroughly vet our business partners, opting to collaborate with those who maintain legitimate funding sources and possess a reputable standing.

Furthermore, the Group expects its employees to strictly adhere to the Group's financial regulations and procedures, refusing any payments that do not comply with regulations and avoiding transactions with non-transactional or abnormal accounts. We actively cooperate with relevant parties to fulfill our anti-money laundering reporting obligations.

The Group conducts rigorous due diligence on customers in the anti-money laundering field, verifying customer identities based on reliable and independent documents and information, and identifying beneficial owners. For non-face-to-face customers, the Group has established dedicated verification and certification processes to ensure the authenticity and completeness of customer information. Additionally, the Group legally retains all anti-money laundering and counter-terrorist financing-related documents, with retention periods compliant with industry regulatory requirements. It also conducts regular independent assessments to ensure the effectiveness and continuous improvement of monitoring procedures. Through these measures, Universal Medical is committed to building an honest and compliant business environment, ensuring the safe and stable development of its operations, and safeguarding the legitimate rights and interests of its customers and the general public.

-Environmental Resources

The Group is committed to enhancing environmental management, promoting green transformation, and advocating low-carbon concepts. We continuously improve the construction of our energy conservation and environmental protection management system, strengthen the fundamental management of energy conservation and ecological environmental protection, and intensify the investigation and remediation of ecological environmental pollution sources and risk points. We integrate the concept of green development into every aspect of our business operations and development. All building materials used in our facilities are eco-friendly, effectively reducing the application of hazardous substances to ensure a health-conscious environment for patients and healthcare professionals.By promoting green construction and clean production, we strictly control energy and resource consumption, focus on controlling dust emissions, preventing noise pollution, and rational utilization of water resources. We properly dispose of all types of production and living waste, reducing the impact of our production and business activities on the environment. We adhere to integrating the concept of green development into our daily operations, starting from the smallest details and establishing an environmentally friendly office model. We strengthen the promotion and education of green concepts, enhance employees' awareness of energy conservation and environmental protection, and create a low-carbon and environmentally friendly office environment.

-Health and Safety

The Group attaches great importance to the safety and health of its employees and is committed to eliminating various risks and hidden dangers in the workplace. We continuously improve our professional management of employee safety and health, striving to enhance our overall safety and health management standards.

Employees have a responsibility to prioritize their own safety and health, as well as to ensure the safety and health of their colleagues and the work environment. Employees should take seriously and actively participate in relevant testing, publicity, training, and other activities organized by the Group. They should firmly establish a safety awareness, strictly abide by relevant laws and regulations on work safety, as well as company rules and regulations, and never violate operational safety rules. It is essential for employees to promptly report any violations of work safety regulations and potential safety hazards.

Public Donation Statement

The group engages in public affairs in a responsible and ethical manner, adhering to the principle of not participating in political activities or electoral processes through direct donations to government teams or political parties. With regards to any donations of a political or charitable nature, Universal Medical will make truthful and public disclosures to ensure that our political participation is lawful and compliant, subject to the scrutiny of all sectors of society.

In addition to the public donations made by Xinyan Foundation and for rural revitalization, Universal Medical has not provided any donations to political campaigns, political organizations, lobbying organizations, industry associations, or other tax-exempt groups (including membership fees for chambers of commerce, trade councils, etc.) in recent years.