Supplier Code

PHOENIX CARS LLC, PHOENIX MOTOR INC. AND AFFILIATIES SUPPLIER CODE OF CONDUCT POLICY Effective Date: January 1, 2026

  1. INTRODUCTION AND SCOPE

Phoenix Motor Inc. (“Phoenix Motor” or “Company”) is committed to conducting business with integrity, respect for human rights, and environmental responsibility. As a leading manufacturer of zero-emission electric vehicles serving transit agencies, airports, municipalities, universities, and corporate fleets, we hold our suppliers to the highest standards of ethical business conduct.

This Supplier Code of Conduct (“Code”) applies to all suppliers, vendors, contractors, and subcontractors who provide goods or services to Phoenix Motor Inc., including their subsidiaries, affiliates, and sub-tier suppliers (“Suppliers”). Suppliers must ensure compliance with this Code throughout their supply chains.

Publication and Updates: This Code is published on Phoenix Motor’s website at www.phoenixmotorcars.com/supplier-code and may be updated periodically to reflect changes in laws, regulations, and business practices. Suppliers are responsible for regularly reviewing the current version of this Code as published on our website. The most current version supersedes all previous versions.

Compliance Requirement: Suppliers must comply with all applicable laws and this Supplier Code. Where there is a gap between applicable law and this Code, the stricter requirement offering the greatest protection shall apply. Where there is direct contradiction between applicable law and this Code, the law shall apply, but Suppliers shall honor the spirit of this Code.

  1. ETHICS AND INTEGRITY

2.1 Legal Compliance

Suppliers shall comply with all applicable federal, state, and local laws and regulations in all jurisdictions where they operate, including but not limited to:

  1. Federal Transit Administration (FTA) requirements
  2. Buy America Act provisions
  3. California Transparency in Supply Chains Act
  4. Uyghur Forced Labor Prevention Act (UFLPA)
  5. Export control and economic sanctions laws

PHOENIX CARS LLC, PHOENIX MOTOR INC. AND AFFILIATIES SUPPLIER CODE OF CONDUCT POLICY Effective Date: January 1, 2026

2.2 Anti-Bribery and Anti-Corruption

Suppliers shall have a zero-tolerance policy for corruption in all forms, including bribery and extortion. Suppliers shall not engage in any form of bribery or corruption and will not offer, promise, give, authorize or receive payment of anything of value to anyone for the purpose of influencing, obtaining, retaining, or giving an improper business advantage.

2.3 Conflicts of Interest

Suppliers shall conduct business transparently and avoid any appearance of impropriety. Suppliers must disclose any known situation where a Phoenix Motor employee has a personal interest or economic tie with the Supplier’s business.

2.4 Accurate Records and Financial Responsibility

Suppliers shall maintain accurate records related to all business dealings, financial reports, and filings. All information provided to Phoenix Motor must be complete, accurate, and truthful.

2.5 Intellectual Property Protection

Suppliers shall respect Phoenix Motor’s and third parties’ intellectual property rights by safeguarding all confidential information and work products from misuse, mishandling, theft, or improper disclosure.

  1. HUMAN RIGHTS AND LABOR STANDARDS

3.1 Prohibition of Forced Labor

The use of forced, bonded, or compulsory labor, including human trafficking, in any form, at any place in the supply chain will not be tolerated. Suppliers shall not engage in restrictions of movement, involuntary transfer, excessive recruitment fees, confiscation of identity documents or passports, withholding of wages, unsafe or abusive working conditions, debt bondage, violence or any kind of exploitation.

UFLPA Compliance: Suppliers must ensure that goods are not mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region (XUAR) of China or by entities on the UFLPA Entity List.

PHOENIX CARS LLC, PHOENIX MOTOR INC. AND AFFILIATIES SUPPLIER CODE OF CONDUCT POLICY Effective Date: January 1, 2026

3.2 Child Labor Prohibition

The use of child labor at any place in the supply chain will not be tolerated. Suppliers shall prevent all forms of child labor and support children’s right to education, following OECD Guidelines for Multinational Enterprises.

3.3 Fair Wages and Benefits

Suppliers shall provide wages and benefits that, at minimum, comply with applicable laws and collective bargaining agreements. Suppliers shall provide employees with information about their employment terms via written contract or handbook and provide regular wage statements.

3.4 Working Hours

Suppliers shall comply with applicable laws regarding working hours, resting periods, overtime, and leaves of absence. Overtime work shall be voluntary and minimize strains on employees’ physical and mental health.

3.5 Non-Discrimination and Equal Opportunity

Suppliers shall treat everyone with dignity and respect and shall not tolerate discrimination in any form. Suppliers will provide equal employment opportunities regardless of race, color, age, gender, sexual orientation, gender identity, ethnicity, national origin, disability, pregnancy, religion, political affiliation, union association, covered veteran status, genetic information, or marital status.

3.6 Freedom of Association

Suppliers shall allow workers to communicate openly with management regarding working conditions without fear of reprisal. Employees should have rights to associate freely, join or not join unions, bargain collectively, seek representation, and join workers’ councils in accordance with local law.

3.7 Health and Safety

Suppliers shall ensure employee exposure to physical safety hazards is identified and controlled through proper safety procedures. Safety information shall be made available to educate and protect employees, and employees shall have access to safe working conditions including free drinking water, hygienic facilities, and proper lighting, ventilation, and protective equipment.

PHOENIX CARS LLC, PHOENIX MOTOR INC. AND AFFILIATIES SUPPLIER CODE OF CONDUCT POLICY Effective Date: January 1, 2026

  1. ENVIRONMENTAL SUSTAINABILITY

4.1 Environmental Management

Suppliers are expected to support Phoenix Motor’s commitment to environmental protection and shall implement comprehensive environmental management systems to minimize the impact of their operations, products, and services throughout the entire lifecycle.

4.2 Energy and Greenhouse Gas Emissions

Suppliers shall implement comprehensive energy reduction strategies including increasing use of renewable energy to support Phoenix Motor’s objective to reduce greenhouse gas emissions through its entire supply chain. Suppliers should:

Commit to achieving renewable energy goals in their operations

4.3 Water and Air Quality Management

Suppliers shall monitor, track and document water consumption to identify opportunities to minimize usage. All wastewater discharges shall be treated to levels that meet or exceed regulatory standards and protect the environment.

4.4 Waste Reduction and Circular Economy

Suppliers shall make efforts to move toward circular business models, seeking opportunities for improvement and minimized waste. Suppliers shall optimize packaging materials, utilizing recyclable materials as appropriate.

4.5 Chemical Management

Suppliers shall disclose all materials, minerals and substances contained in products delivered to Phoenix Motor and ensure compliance with applicable chemical legislation and automotive industry standards including the Global Automotive Declarable Substance List (GADSL).

  1. RESPONSIBLE SOURCING

5.1 Conflict Minerals and Responsible Sourcing

Suppliers shall exercise due diligence following OECD Due Diligence Guidelines for Responsible Supply Chains from Conflict-Affected and High-Risk Areas. Specialized attention shall be focused on required due diligence and reporting for Tin, Tantalum, Tungsten, Gold,

PHOENIX CARS LLC, PHOENIX MOTOR INC. AND AFFILIATIES SUPPLIER CODE OF CONDUCT POLICY Effective Date: January 1, 2026

Cobalt and Mica. Suppliers are prohibited from procuring minerals that contribute to or finance armed conflict, human rights abuses or violations.

5.2 Supply Chain Transparency

California Transparency in Supply Chains Act Compliance: Suppliers must disclose the extent of their efforts in five areas: verification, audits, certification, internal accountability, and training regarding human trafficking and slavery in supply chains.

Suppliers shall:

  1. Conduct verification of product supply chains to evaluate risks of human trafficking and slavery
  2. Conduct audits of suppliers to evaluate compliance with trafficking and slavery standards
  3. Require direct suppliers to certify compliance with applicable laws regarding slavery and human trafficking
  4. Maintain internal accountability standards for employees failing to meet company standards
  5. Provide training on human trafficking and slavery to supply chain management personnel

5.3 Sub-Tier Supply Chain Management

Suppliers shall implement this Code throughout their organization, cascade to their direct suppliers, and require their direct suppliers to implement the requirements set forth in this Code and ensure cooperation from their supply chain.

  1. DATA PRIVACY AND CYBERSECURITY

6.1 Information Security

Suppliers entrusted with personal data shall safeguard it from misuse in compliance with applicable data privacy laws. Suppliers shall implement best practices of information security management systems such as NIST, ISO 27001, SOC2, TISAX, or equivalent standards.

6.2 Incident Response

Suppliers shall implement security controls and monitoring systems to protect against security incidents and have processes to manage emerging cybersecurity risks. Suppliers shall notify Phoenix Motor within 24 hours of any incident suspected of impacting Phoenix Motor.

PHOENIX CARS LLC, PHOENIX MOTOR INC. AND AFFILIATIES SUPPLIER CODE OF CONDUCT POLICY Effective Date: January 1, 2026

  1. QUALITY AND SAFETY

7.1 Product Quality and Safety

Suppliers shall maintain quality management systems appropriate for their products and services. Any quality problems with parts supplied to Phoenix Motor shall be reported immediately to Phoenix Motor’s buyer or quality engineer.

7.2 Counterfeit Parts Prevention

Suppliers shall have appropriate controls in place to prevent introduction of counterfeit and/or diverted parts and materials into products sold to Phoenix Motor. If suppliers suspect counterfeit parts have been included in products sold to Phoenix Motor, they shall notify Phoenix Motor immediately.

7.3 Quality Management System Certification

Suppliers shall maintain a documented quality management system appropriate to their products and services. Suppliers should be certified to IATF 16949 or ISO 9001, depending on the nature and scope of the supplied goods or services, and shall maintain such certification throughout the course of business with Phoenix Motor. Suppliers shall provide certification documentation upon request.

  1. MANAGEMENT SYSTEMS AND CONTINUOUS IMPROVEMENT

8.1 Management System Requirements

Suppliers shall have formal and appropriate management systems to oversee full compliance with this Code, including written policy commitment from management.

8.2 Due Diligence and Risk Assessment

Suppliers shall have due diligence processes to identify and mitigate risks for all areas of this Code. Due diligence processes shall align with internationally recognized standards and be prepared to report information in industry formats or Phoenix Motor-directed formats as needed.

8.3 Continuous Improvement

Suppliers shall support Phoenix Motor’s goals for continuous improvement in all areas of this Code and actively work to enhance their performance over time.

PHOENIX CARS LLC, PHOENIX MOTOR INC. AND AFFILIATIES SUPPLIER CODE OF CONDUCT POLICY Effective Date: January 1, 2026

  1. GRIEVANCE MECHANISM AND NON-RETALIATION

9.1 Grievance Mechanism

Suppliers shall implement and make available for all employees and third parties an anonymous grievance mechanism to raise concerns related to their code of conduct, operations, or supply chain, as well as ideas for improvement.

9.2 Non-Retaliation Policy

Suppliers shall adopt a non-retaliation policy in connection with their grievance mechanism and ensure protection of individuals who report concerns in good faith.

  1. MONITORING, AUDITING, AND COMPLIANCE

10.1 Self-Assessment and Certification

Suppliers shall conduct regular self-assessments of their compliance with this Code and provide annual certification of compliance when requested by Phoenix Motor.

10.2 Auditing Rights

Phoenix Motor reserves the right to audit Suppliers’ declarations, data, or premises to confirm compliance with this Code. Audits may be announced or unannounced and may be conducted by Phoenix Motor personnel or authorized third parties.

10.3 Corrective Action

When non-compliance issues are identified, Suppliers must take prompt corrective action to address deficiencies and prevent recurrence. Phoenix Motor may require immediate action to achieve compliance or may terminate the business relationship for serious violations.

  1. REPORTING AND COMMUNICATION

11.1 Reporting Violations

Violations or suspected violations of this Code can be reported through Phoenix Motor’s ethics hotline or directly to Phoenix Motor management. All reports will be investigated promptly and confidentially.

PHOENIX CARS LLC, PHOENIX MOTOR INC. AND AFFILIATIES SUPPLIER CODE OF CONDUCT POLICY Effective Date: January 1, 2026

11.2 Training and Communication

Suppliers shall ensure their employees receive appropriate training on this Code and maintain awareness of their responsibilities under applicable laws and regulations.

  1. IMPLEMENTATION AND ENFORCEMENT

12.1 Contractual Requirements

Compliance with this Code is a contractual requirement for all Suppliers. Violation of this Code may result in termination of the business relationship and other legal remedies.

12.2 Supplier Acknowledgment and Ongoing Compliance

By conducting business with Phoenix Motor, Suppliers acknowledge that they have reviewed the current version of this Code as published on Phoenix Motor’s website and agree to comply with all requirements. Suppliers are responsible for:

  1. Regularly checking Phoenix Motor’s website for updates to this Code
  2. Ensuring ongoing compliance with the most current version
  3. Implementing necessary standards, policies, and governance to meet these requirements
  4. Notifying Phoenix Motor of any material changes in their operations that may affect compliance

12.3 Supplier Change Notification

Suppliers shall notify Phoenix Motor in advance of any proposed changes to product design, material composition, manufacturing processes, sub-tier suppliers, or production locations that may affect quality, safety, performance, or compliance. Such changes must not be implemented without prior written approval from Phoenix Motor.

12.4 Website Publication and Updates

Current Version: The most current version of this Code is always available at: www.phoenixmotorcars.com/supplier-code Phoenix Motor will update the version number and effective date when material changes are made.

Notification of Updates: While Phoenix Motor may provide notice of significant updates through various communication channels, Suppliers are ultimately responsible for staying

PHOENIX CARS LLC, PHOENIX MOTOR INC. AND AFFILIATIES SUPPLIER CODE OF CONDUCT POLICY Effective Date: January 1, 2026

informed of the current requirements by regularly reviewing the Code as published on our website.

Transition Periods: When material changes are made to this Code, Phoenix Motor may provide reasonable transition periods for compliance, which will be specified in the updated version or through separate communication.

Contact Information: For questions regarding this Supplier Code of Conduct, please contact the Phoenix Motor Inc. Purchasing Department at: sying@phoenixev.ai

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