ByteDance
Code of Conduct

PREFACE

The Code of Conduct (the “Code”) is a cornerstone of our business. The Codesets out the high ethical standards and culture of integrity which are goals of
the ByteDance Group entities, its affiliates and subsidiaries (collectively, the“Company” or “ByteDance”).

ByteDance Code of Conduct

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Table of Contents
Message from CEO
1. Overview

3. Treat Others with Respect

2. Acting with Integrity

4. Doing Business Responsibly

1.1 Application of the Code
1.2 Following the Code
1.3 Speak Up

2.1 Confidentiality
2.2 User and Business Partner Privacy and Information
2.3 Proper Use and Protection of Company Assets
2.4 External Communications
2.5 Conflicts of Interest
2.6 Preventing Fraud

ByteDance Code of Conduct

3.1 Mutual Respect
3.2 Safety and Security
3.3 Drugs and Alcohol

4.1 Anti-Corruption and Anti-Bribery
4.2 Receiving Gifts or Entertainment
4.3 Anti-Money Laundering
4.4 International Trade Compliance
4.5 Fair Competition
4.6 Financial Integrity and Record Keeping
4.7 Insider Trading
4.8 Corporate Social Responsibility & Sustainability

2Message from CEO
With ByteDance’s rapid international expansion and growth, we
continue to enrich the lives of people around the world. In this pursuitof excellence, we stand firm on the values of ethics and integrity
to nurture and strengthen our organizational culture. Our Code of
Conduct sets the standard for our professional conduct, and forms
the basis of how we interact with each other, our customers, and third
parties. The Code consists of three overarching principles:
1. Integrity - we hold ourselves and each other accountable, and upholdhigh ethical standards to protect our company and users;
2. Respect - we create an inclusive environment where we treat eachother with mutual respect and build lasting relationships; and3. Responsibility - we comply with laws and regulations, and conduct
our business in good faith with transparency.

These principles serve as the foundation for us to continue to build
a strong ethical and compliant work culture. By following theseprinciples and holding each other accountable, we will ensure that we
continue to conduct our business ethically to fulfill our obligations to
the Company, colleagues, clients, vendors, and business partners. For
situations where you observe others are not following the principles,
speak up to help safeguard our workplace. We will not retaliate, andwill not tolerate retaliation, against any individual for reporting a
concern in good faith or participating in an investigation of a concern.
By working together, we will be able to achieve our mission to inspire
creativity, enrich life, and ensure the sustained and robust growth of
our company.

Rubo Liang

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1.Overview
1.1 Application of the Code
The Code applies to all ByteDance employees, interns, members of the boards of directors,
supervisors, and senior officers (collectively, “ByteDancers”). The Code also applies to those
assigned to perform work or services for or on behalf of ByteDance, such as independent
contractors, third-party associates, and outsourcing staff (collectively, “Extended Workforce”).
“We” and “You” in the Code will refer to both ByteDancers and the Extended Workforce. Please
note that nothing in the Code creates an employment relationship with the Extended Workforce.
A separate set of guidelines known as the Business Partner Code of Conduct applies to all
Business Partners. The term “Business Partner(s)” refers to all third parties including suppliers,
service providers, agents, vendors, and consultants who provide any kind of products, services,or undertake any activity for or on behalf of ByteDance.
Different countries have different legal systems, and as such, conflicts may arise between aprovision of the Code and local laws or regulations. We follow the stricter guidance when there
are differences with the Code, laws, or regulations. Additionally, no one should follow any portionof the Code if it is illegal under local laws or regulations. The Company will conduct periodic
reviews to determine whether the Code requires revisions based on changes in laws, regulations,or developments of the Company.
1.2 Following the CodeOur Responsibility
We have a responsibility as employees and representatives of ByteDance to model the Code andcreate a “Speak Up” culture.

ByteDance Code of Conduct

Model the Code: We model the Code by understanding and complying with
the Code and the Company’s policies. We promote a culture of integrity,and encourage adherence to our principles by using good judgment andethical decision-making. We hold ourselves and others accountable for our
respective decisions and behaviors.

Create a “Speak Up” Culture: We foster an environment of trust and open
communications where colleagues feel comfortable coming forward if theywant to talk or ask questions. We escalate concerns regarding potential
violations or misconduct immediately once known or reported. We support
and cooperate with investigations, and we never excuse or condone
inappropriate behaviors.

We expect leaders to firmly uphold the Code, communicate its importance to their teams, andensure that the listed expectations are met.

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1.Overview
Violations of the CodeIn no circumstance will failure to read the Code or Company policies exempt your obligation tocomply with these requirements. Violations, depending on the nature and severity, may resultin disciplinary action, up to and including, termination of employment or termination of anengagement service contract, where necessary. Where there is a potential violation of law and/or policy, the Company will cooperate with the appropriate authorities.
1.3 Speak Up
We value everyone’s voice and well-being. Furthermore, we take pride in holding ourselves andeach other accountable. Please speak up if someone asks you to do something that makes you
feel uncomfortable, or if you see or suspect activity that goes against our Code. By reporting
misconduct, you will help contribute to the ethical culture at ByteDance.

Reporting Channels
You can speak up in any of the following ways:· Contact your leader or HRBP
· Speak Up Hotline· Ethics Office (ethics@bytedance.com)

Investigations
For all concerns raised, the Company has the responsibility to take appropriate actions. This
includes conducting a fair, objective, and thorough investigation. Based on the nature of theviolation, the appropriate investigation team will perform an impartial review of all the facts
available, maintain confidentiality to the greatest extent possible, and comply with applicablelaws and regulations. The Company requires employees to cooperate fully with any inquiry or
investigation by providing truthful and complete responses and information to investigators.
The Company will take appropriate action when it determines that a violation has occurredor someone was untruthful during an investigation. This includes disciplinary action whereappropriate, and corrective actions to improve our policies and internal controls to prevent futureissues.
No Retaliation
The Company strictly prohibits retaliation of any kind against anyone who shares a concern ingood faith or participates in an investigation. An individual would have reported in good faith if
the individual reasonably believes, perceives, or suspects the information reported to be true.
The Company encourages honest reporting, but does not tolerate anyone knowingly submitting
a false report. Making false accusations can lead to disciplinary action as it diverts investigatory
resources away from credible good faith concerns and damages the morale of those impacted.

However you choose to speak up, the Company will seriously treat and promptly address yourconcerns and questions. The Company will take appropriate steps to maintain confidentiality to
the fullest extent possible.

ByteDance Code of Conduct5

2. Acting with Integrity
As employees, we hold ourselves and each other accountable to high ethical standards, andhelp the Company succeed by complying with the Code and the Company’s policies. We
are also proud representatives of the Company, and take pride in preserving the Company’s
image through our actions.
2.1 Confidentiality
The Company attributes its success in part based on innovations, intellectual property
and technology. To ensure the Company’s success, we recognize the importance of our
responsibility to preserve and uphold data confidentiality.
To ensure that we handle confidential information appropriately, each of us needs tounderstand the types of confidential information and the ways to protect it. We consider
all non-public information about the Company, its customers and Business Partners asconfidential unless the Company clarifies that the information is public. Non-public information
includes business plans, proprietary data, financial information, internal communications,organizational structure, operational information, personnel information, and information
related to third parties with which the Company has non-disclosure agreements. We should
not disclose confidential information to third parties, nor should we discuss it in public places.
For confidential information limited to a specific range of people, you should only disclose it
to those who need to use it to perform their duties and are authorized to know.
2.2 User and Business Partner Privacy and Information
Protecting and ensuring the privacy and safety of our users’ and Business Partners’ information
is of the utmost importance. We arrange to take all lawful steps possible to protect user privacy
and Business Partners’ information during the obtaining, processing, and transferring of data.
This includes personal data, customer lists, trade secrets, and patented technologies.

ByteDance Code of Conduct

We abide by our policies as well as local laws and regulations regarding personal privacy anddata disclosure for each country in which we do business.
2.3 Proper Use and Protection of Company Assets
The Company provides us with a variety of assets to allow us to complete our work tasks
effectively. These assets include physical (tangible) assets such as IT hardware and equipment,
and non-physical (intangible) assets such as access to internal systems, apps, and emails.
Our policies provide guidelines on proper use of assets including password use, lost/stolen
items, and misuse of company assets (including improper use or over-indulgence). We must:- use Company assets for legitimate work purposes only;- ensure the safe and correct operation of Company assets; and- take appropriate care to protect and secure Company assets, both in the workplace and at
home.
The Company reserves the right to seek remedies should you wilfully damage assets, use
assets for an unlawful purpose, fail to take good care of the assets, or fail to stop losses fromincreasing.
2.4 External Communications
With ByteDance being a high-profile global company, the media, organized events,
competitors or interested external parties may contact or ask you to provide commentary.
Such commentary has the potential to cause serious damage, specifically when there isa perception that the communication is on behalf of the Company, discloses non-public
information, is misinterpreted, or is inaccurate.

62. Acting with Integrity
Any situation in which it may appear that you are representing the Company requires formal
pre-approval prior to partaking in these engagements or activities. This is to ensure that theCompany provides you with proper guidance and support prior to such engagements oractivities.

You are responsible for understanding what are conflicts of interest, and proactively declaring
all potential and actual conflicts via the Conflict of Interest Declaration system. Furthermore,
you must cooperate with the Company and work towards remediating identified conflicts. If
there are no conflicts, you are required to confirm the same on the system.

2.5 Conflicts of Interest
The Company embraces and supports our private lives and endeavors. However, we havea responsibility to ensure that our personal interests do not conflict with the Company. A
conflict of interest occurs when we, or someone with whom we have a significant personal
relationship, has a private interest or associated business that interferes or appears to interferewith the interest of the Company.

2.6 Preventing Fraud
We are a company that is transparent and honest as we take pride in our product and what we
represent. We have the responsibility to represent the Company in a transparent and honest
manner and avoid any fraudulent activity. The Company prohibits fraudulent activity, which
includes any use of deception to obtain monetary or personal gain, to avoid an obligation, or tocause loss to another party. Examples of fraud include: knowingly providing false, misleading
or incomplete information to the Company or Business Partners; manipulation, falsification,
forgery or unauthorized alteration of any company records; and knowingly or negligently
supporting or assisting any fraudulent or deceptive behavior.

Common situations where a conflict of interest might exist that requires disclosure include
the following:
1. investments;
2. outside activities & personal intellectual property;
3. commercial cooperation & business opportunities;
4. personal relationships; and5. personal account monetization.

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3. Treat Others with Respect
Respect is a fundamental behavior and requirement that we exhibit to promote a positive andinclusive work culture and environment. We are a company that promotes collaboration, teamwork
and the inclusion of all thoughts and ideas. We act responsibly by demonstrating respect andkindness to all team members and Business Partners.
3.1 Mutual Respect
We believe in providing every ByteDancer with the opportunity to reach their full potential andcontribute to the Company’s success. We respect and embrace diversity and believe that ourcollective differences make us stronger.
We commit to providing a workplace free from discrimination or harassment based on an
individual’s protected status. Protected status refers to an individual’s personal characteristics
including: race, color, age, sex, language, religion, national or ethnic origin, citizenship, marital/
civil status, sexual orientation, gender identity or expression, disability, pregnancy, or any othercharacteristics protected by applicable laws.
We oppose any form of discrimination, workplace bullying, harassment or sexual harassment.
This applies to all ByteDancers, and covers actions occurring at the workplace, and any othersettings involving work. To the extent permitted by law, this also applies to dealings with external
parties in the settings involving work.
The Company also provides equal employment opportunities and commits to ensuring that hiring,
continued employment and performance reviews are only evaluated and based on Company
policies, an individual’s work performance, and not influenced by any irrelevant factors.
3.2 Safety and Security
Whether working remotely or in our office we prioritize the safety and security of our colleagues.

ByteDance Code of Conduct

The Company has implemented robust physical security controls including the deployment ofpeople, technology and procedures, to ensure global workplace security. These controls areconstantly assessed to ensure their continued effectiveness. We have a shared responsibility tohelp protect our workplaces by reporting anything that could endanger or detrimentally impact
personnel, property, or the Company’s reputation. In the event of an emergency, please contact
your local emergency authorities.
The Company has also established an Environment, Health and Safety Management System, tocomply with applicable environmental, health and safety laws and regulations in the countries
in which we operate. We take appropriate measures to provide a safe and healthy workplace for
employees, promote employee health management, and protect environmental sustainability.
3.3 Drugs and Alcohol
We take great pride in being able to represent the Company through our work and the products
we deliver. The Company expects us to perform our job duties without being under the influenceof drugs, alcohol, or any substance that could impair job performance. Being under the influence ofsuch substances can also pose a safety risk to yourself or others.
The Company prohibits substance abuse, including:- working under the influence of alcohol or drugs while on Company premises or conducting workfor the Company; and- possessing, selling, distributing, or consuming illegal drugs or controlled substances while on
Company premises, or conducting work for the Company.
There are occasions where the Company permits alcohol consumption (e.g., at approved Company
events). In such case, when consuming alcohol in an approved setting, we should always exercise
sound judgment and ensure our conduct remains professional at all times.

84. Doing Business Responsibly
We are a company that believes in conducting ourselves virtuously and adhering to applicablelaws and regulations. We stand behind the quality of our products and services and demonstrate
our responsible business practices by consistently abiding by our standards in both our dailytasks and interactions with others.
4.1 Anti-Corruption and Anti-Bribery
We seek to preserve our culture of integrity and ethical behavior, as well as comply with allapplicable anti-corruption laws and regulations in the countries in which we operate. We prohibit
bribery in all forms. You may not, whether directly or indirectly, offer, give, receive, or solicit,
anything of value to improperly influence any decision or any other act or omission related to theCompany’s business or to obtain an improper advantage.
We do not maintain business relationships based on offering, or providing, gifts or entertainment.
We understand that local business customs or etiquette may require the giving of a gift orentertainment on certain occasions. Nonetheless, the following conditions must be met whengiving such gifts or entertainment:- The gift or entertainment given should not violate applicable laws or Company policies, musthave legitimate business purposes, be appropriate, and conform to local business etiquette.
- The Company prohibits offering, making any payment, or giving any lavish gift or entertainment,that could be considered a bribe, kickback, commission or advantage.
- Obtain the requisite pre-approvals for giving gifts or entertainment and maintain proper records.
4.2 Receiving Gifts or Entertainment
Take caution when receiving gifts or entertainment as it may bring about actual influence, or theappearance of undue influence.

ByteDance Code of Conduct

Our general policy is to politely decline or return any gift or cash regardless of the value. If
declining the gift or cash is culturally inappropriate or not possible, you must promptly disclose
it in accordance with the policy.
Entertainment should be for business purposes only. It should not interfere or influence any
business judgment. Accepting such an invitation should be done mindfully, infrequently, andshould never be considered lavish or extravagant. Pre-approval from a direct leader must be
obtained when the entertainment exceeds the policy threshold limit.
4.3 Anti-Money Laundering
We commit to complying with all applicable laws and regulations in the countries in which we
operate to prevent the use of our platforms, products and services for money laundering or
terrorism financing purposes, and to combat any sort of criminal activity.
- Money laundering refers to concealing the origins of money generated by a criminal activity, sothat it appears to have come from a legitimate source.
- Terrorist financing refers to carrying out transactions that are linked to, or likely to be used by,terrorists or terrorist organizations.
4.4 International Trade Compliance
We commit to complying with applicable trade laws and regulations, trade sanctions, export
controls, and other trade-related laws and regulations that apply in the countries in which we
do business. We also prohibit business activities, or other dealings, with sanctioned regions andparties that may lead to any violation.

94. Doing Business Responsibly
4.5 Fair Competition
We believe in free, fair and honest competition and should avoid any conduct that unfairly
restricts trade. Antitrust or competition laws protect consumers and markets against unfair
business practices, and promote and protect healthy competition. We commit to outperforming
our competitors legally and ethically, and observing applicable antitrust and competition laws in
the countries in which we operate.
Additionally, the Company does not seek to obtain confidential information from our competitors,
either directly, through third parties, or from current ByteDance employees who may have worked
at other companies.
4.6 Financial Integrity and Record Keeping
Financial integrity and record keeping are essential to the healthy operations of the Company.
We make business decisions based on accurate, clear and complete records. We also maintaincompliance with financial reporting regulations to uphold credibility with our customers andstakeholders, and demonstrate success as a company. We strive to:- ensure that our financial statements are always complete and accurate;- follow relevant accounting and reporting standards and policies; and- comply with applicable laws, regulations and policies regarding record keeping and record
retention.
It is important that we manage and keep records in accordance with applicable record retention
policies and legal holds as failures to do so could expose both the Company and you to civil andcriminal liability.
4.7 Insider Trading
In each of our roles, we may have access to material non-public information about the Company,
ByteDance Code of Conduct

as well as our clients or Business Partners. “Insider information” is non-public information that areasonable investor would consider important in conducting a trade.
The Company considers transactions of stock in a company while in possession of insider
information about that company obtained in connection with your employment at ByteDance as
insider trading and this is strictly prohibited. Additionally, insider trading includes passing along
insider information to another person who then utilizes that information, and would be strictly
prohibited. Insider trading is not only against policy, but is also illegal and may lead to legal
consequences.
4.8 Corporate Social Responsibility & Sustainability
We understand that as members of a global company we have a positive role to play in thecommunity, and to consider the social and environmental impact of business decisions. The
Company prohibits child labor, forced or involuntary labor, illegal employment, or trafficking of
persons within our organization or supply chain.
We encourage active participation in public welfare activities, promoting social causes andbecoming part of the solution. We believe that a strong corporate culture is one where we not
only focus on our development needs, but also how we can grow with and help build up ourcommunities.
We seek to improve the sustainability of our operations and look to find ways to lessen our
carbon footprint and support environmental initiatives. We do this by complying with applicable
environmental laws and recognize our responsibility and commitment to minimize our direct andindirect impact on natural resources through our business practices. We believe that each of us
has the opportunity and responsibility to address climate change and biodiversity protection.

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If you have any questions concerning the Code, please contact Ethics Oncall.
If you see something that does not seem right, please report it through the Speak Up Hotline,
or mail the Ethics Office (ethics@bytedance.com) to speak up.

ByteDance Code of Conduct