China Mengniu Dairy : 2023Code of Conduct for Business Partners

Code of Conduct for Business Partners

1. Compliance with Laws and Regulations

Mengniu Group is committed to complying with all laws and regulations applicable to Mengniu Group. Business partners also abide by this commitment and establish effective measures to ensure their compliance with relevant laws and regulations.

2. Anti-bribery and Corruption

Mengniu Group does not tolerate any form of bribery and corruption. Business partners are committed to abide by anti-bribery and corruption laws and regulations and prohibit any form of bribery and corruption in the course of business, including but not limited to giving and receiving, directly or through third parties, cash, gifts, securities, tangible properties, rebates, travel and entertainment expenses, and non-property benefits such as employment opportunities.

3. Fair Competition

Mengniu Group strives to ensure fair and equitable transactions and consciously maintains market order. Business partners shall conduct business in a fair competition manner and comply with relevant competition laws. Specifically, when conducting business, business partners shall comply with the following requirements.

1. Avoid using the same or similar logos, business names, names of social organizations, individual names, domain names of the main part, website names, and web pages, as others, as well as avoiding other confusing behaviors that are sufficient to lead people to believe that they are other people's goods or have a specific connection with others.
2. Truthful propaganda on product performance, functionality, quality, sales status,

1

user reviews, and honors received, and no false or misleading propaganda.

1. Avoid fabricating or disseminating false or misleading information to damage the business reputation and merchandise reputation of competitors.
2. If a company wants to organize prize sales activities, the types of prizes, prize redemption conditions, prize amounts, and prizes will be clearly stated, and the company should not take the deceptive way of falsely claiming that there is a prize or deliberately let the internal personnel to win the prize. If there is a sweepstakes-style prize sale, the maximum prize amount does not exceed the legal limit.

4. Anti-monopoly

Mengniu Group opposes monopolistic behavior. Business partners should insist on competing with competitors through fair trade and in a lawful manner, refrain from entering into agreements or engage concerted behavior with competitors for the purpose of restricting or excluding competition in the market as well as entering into other vertical and horizontal monopoly agreements, refrain from abusing a dominant market position, and declare the concentration of operators in accordance with the laws and regulations..

5. Conflicts of Interest

Business partners should act in the interest of their companies and private interests and personal considerations should not influence any business decisions. Mengniu Group and its business partners must avoid any activity or situation that could lead to a conflict between the private interests of Mengniu Group's employees or business partners, and the business interests of Mengniu Group. Business partners should disclose existing and potential conflicts of interest to Mengniu Group in a timely manner.

2

6. Bidding

Mengniu Group is committed to creating a fair and just bidding environment. Business partners shall participate in the bidding in accordance with the relevant laws and regulations and the bidding management system of Mengniu Group, shall not collude in bidding, shall not bribe the bid inviter or the members of the bid evaluation committee to win the bid, and shall not adopt fraudulent means such as bidding at a below-cost bid price or bidding under the name of others to win the bid. Business partners shall perform the contract with Mengniu Group and other bidders in good faith and strictly abide by the contractual obligations.

7. Intellectual Property

Mengniu Group respects and protects the intellectual property rights of others. Business partners should strictly comply with the intellectual property laws and regulations of China and the countries and regions where they operate, focus on creating, using, and protecting their own intellectual property rights, respect the intellectual property rights of others, and obtain appropriate authorization and licenses if they need to use the intellectual property rights of others in their business activities; when researching and developing new products and technologies, they shall conduct timely intellectual property rights inquiries to avoid infringing on the intellectual property rights of others, and at the same time shall timely stop the infringement of others' intellectual property rights.

8. Privacy and Data Protection

Business partners shall comply with relevant personal privacy and data protection laws and regulations. Business partners shall safeguard the right to personal privacy and data protection, and shall always use the information of the persons concerned

3

correctly for the necessary business purposes and prevent misuse, in order to avoid personal or property damage such as discrimination, defamation, deception, identity theft, etc.

9. Keeping trade secrets

Business partners shall be responsible for ensuring that confidential business information and trade secrets disclosed in the course of their business activities with Mengniu Group are kept strictly confidential and shall not use such information in any prohibited way or disclose it to third parties.

10. Environmental Protection

Business partners shall comply with all relevant laws and regulations related to environmental protection. Mengniu Group encourages business partners to formulate and implement environmental policies and to strive to conserve resources and protect the environment.

11. Product Quality

Mengniu Group is committed to providing customers with high-quality products and services. Business partners shall comply with laws and regulations related to the quality of products and services, and continuously monitor and improve the quality of products and services.

12. Trade Compliance

Mengniu Group is committed to establishing a good international image. Business partners should:

1. strictly comply with laws and regulations of China and the countries and regions where the business is operated and relevant international conventions, strengthen risk management in the fields of import and export trade, project contracting, international

4

transportation, customs declaration and clearance, and international settlement, and ensure that international engineering and trade business is carried out legally and orderly;

1. strictly comply with laws and regulations of economic sanctions and export control of China and the countries and regions where the business is operated and relevant international conventions. The counterparty, items traded, end-use,end-user, and final destination should be fully reviewed at the time of the transaction to obtain a license. By including export control and economic sanctions compliance clauses in transaction contracts, we can effectively fulfill export control and economic sanctions obligations, establish a good international image of the company, and prevent compliance risks;
2. Strictly comply with laws and regulations of multilateral financial institutions such as the World Bank, Asian Development Bank, African Development Bank, European Bank for Reconstruction and Development, and Inter-American Development Bank. In the course of financing provided by multilateral financial institutions, it is forbidden to engage in any acts of corruption, fraud, collusion, coercion, obstruction, and other misconduct, directly or through business partners, in order to ensure that the business operates in accordance with the law.

13. Anti-money Laundering

Mengniu Group conducts its business with high integrity. Business partners should strictly comply with the anti-money laundering laws and regulations of China and the countries and regions where they operate, and attach importance to the management of compliance risks such as financial sanctions, anti-money laundering, and counter- terrorism financing, in order to prevent the company from being exposed to money

5