HUTCHMED (CHINA) LIMITED

CODE OF ETHICS FOR

BUSINESS PARTNERS

Adopted by the board of directors on 14 March 2017

and amended by the board of directors on 1 January
2023
HUTCHMED CODE OF ETHICS FOR BUSINESS PARTNERS

Code of Ethics – for Business Partners

HUTCHMED (China) Limited (the “Company”) is firmly committed to maintaining high ethical
standards in the conduct of its business. All directors, officers and employees (the “Company
Personnel”) of the Company, its subsidiaries and affiliated businesses (the “Group”) have
individually committed to working in accordance with the Company’s code of ethics applicable
to them to conduct the Group’s business fairly, honestly, in compliance with the applicable law
and in accordance with high ethical standards.

The Group expects its business partners (suppliers, vendors, customers, agents, contractors,
joint venture partners and representatives, etc.) who work with the Group (the “Business
Partners”) to work to the same high standards.

This code of ethics for Business Partners (the “Code”) is not intended to be an exhaustive list
of rules but is intended to set out the key principles which the Group expects its Business
Partners to adhere to and seeks to provide guidance for certain circumstances that may arise
during the conduct of their business with the Group. This Code should be interpreted in the
context of all applicable laws. As this Code cannot and does not cover every applicable
situation or provide answers to all questions that might arise, all Business Partners are
expected to use common sense in determining what is right or wrong, including a sense of
when it is proper to seek guidance from their own professional advisors or a Company
compliance officer on the appropriate course of conduct. If there is anything within this Code
that a Business Partner of the Group feels that it cannot comply with or which will cause it
problems adhering to when carrying out business activities with or for the Group, such
Business Partner should let the Company know immediately.

If a Business Partner becomes aware of any potential problems or incidents that happen during
its conduct of business with or on behalf of the Group that may lead to a conflict or breach of
the guidelines set out in this Code, the Company expects to be notified by such Business
Partner, as soon as possible, to enable the Company and the Business Partner both to promptly
take appropriate corrective action.

This Code may be modified from time to time by the Company. Any changes to this Code will
be made available to the Business Partners.

1. Purpose of the Code

This Code contains general guidelines for the Group’s Business Partners consistent with the
highest standards of business ethics and the law. To the extent that this Code requires a higher
standard than is usually required by commercial practice or applicable laws, rules or
regulations, the Group expects its Business Partners to adhere to these higher standards.
This Code is designed to deter wrongdoing and to promote (i) honest and ethical conduct,
including the ethical handling of actual or apparent conflicts of interest between personal and
professional relationships; (ii) respect of confidentiality and intellectual property; (iii)
compliance with applicable laws, rules, codes and regulations; (iv) prompt internal reporting
of any violations of this Code; and (v) accountability for adherence to this Code.

Contact Details

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If a Business Partner has any questions regarding this Code and would like to discuss how this
Code applies to its conduct of business with the Group, please contact the Group General
Counsel of the Company at Level 18, The Metropolis Tower, 10 Metropolis Drive, Hunghom,
Kowloon, Hong Kong, with a copy to the Company Secretary at 48th Floor, Cheung Kong Center,
2 Queen’s Road Central, Hong Kong. If you would like to report any breach of this Code, please
report either by email to report@hutch-med.com or by post to the General Manager, Group
Management Services, 48th Floor, Cheung Kong Center, 2 Queen’s Road Central, Hong Kong.

2. Conflicts of Interest
A conflict of interest occurs when Business Partners’ commercial interests, or the interests of
one of their other clients, who may be a competitor to the Group, interferes with, or appears
to interfere with, in any way with the commercial interests of the Group. Business Partners
should actively avoid any situation that could impact on their ability to act in the best interests
of the Group or that may make it difficult to carry out the agreed work/services objectively
and effectively.

The Group requires that its Business Partners should fully disclose to the Group any situations
that could reasonably be expected to give rise to a conflict of interest. If a Business Partner
suspects that there may be a conflict of interest, or a situation that others could reasonably
perceive as a conflict of interest, such Business Partner must report it immediately to a
Company compliance officer. The Group expects its Business Partners to put in place
appropriate internal procedures to enable the identification, disclosure and management of
any such conflicts of interest.

3. Gifts, Business Courtesies and Anti-bribery Compliance

The giving and receiving of appropriate gifts may be considered to be common business
practice, but also carry the risk of perceived bribery. The Company understands that
appropriate business gifts and courtesies, such as meals, are designed to build relationships
and understanding among business partners. However, gifts and courtesies should never
compromise, or appear to compromise, the Group’s or its Business Partners’ ability to make
objective and fair business decisions.
It is the responsibility of both Business Partners and Company Personnel to use good judgment
in this area. As a general rule, Company Personnel may not give or receive gifts or
entertainment from Business Partners unless the gift is in compliance with applicable law and
Company policy, is insignificant in value and not given in consideration or expectation of any
action by the recipient.

The Company has an internal policy in respect of the receipt of gifts and courtesies with which
all Company Personnel are required to comply – this includes reporting and prior internal
authorization of the receipt of any gifts and courtesies, with certain exceptions of gifts of de
minimis value. The Company may choose to decline to allow the Company Personnel to receive
such offers or they may be required to return gifts. If in any doubt about how this policy applies
to the Business Partners, please contact a Company compliance officer.

The Group and the Company Personnel are subject to anti-bribery and anti-corruption
legislation including the U.S. Foreign Corrupt Practices Act (“FCPA”) and the United Kingdom

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Bribery Act 2010 (“Bribery Act”). These generally prohibit giving anything of value, directly or
indirectly, to officials of foreign governments or foreign political candidates in order to obtain
or retain business. A violation of FCPA, Bribery Act or similar legislation not only violates the
Company’s policy but also constitutes a civil or criminal offense under such legislation.

A Business Partner may not make any political contributions as a representative of the Group
or create the impression that such Business Partner is acting as a representative of the Group.
In addition, a Business Partner, when acting on behalf of the Group, must not offer bribes,
similar considerations or anything of value to any public employee or any other person or
company with the intent of improperly influencing any governmental entity, or such person or
company, for the purpose of obtaining or retaining business for, directing business to or
otherwise gaining some benefit or advantage for, the Group.

4. Intellectual Property and Confidentiality

The Group respects the confidentiality and intellectual property of its Business Partners and
third parties, and it expects its Business Partners to do the same. Unless otherwise agreed in
writing, the Group expects its Business Partners to comply with the following principles when
working with the Group:

• All inventions or discoveries, research data, processes, specifications, designs, drawings

or other scientific or technical information developed by a Business Partner in the course
of performing its duties or primarily through the use of the Group’s assets or resources
while working at or for the Group shall be the property of the Group, unless explicitly
described in a separate agreement.

• Business Partners should maintain the confidentiality of information entrusted to them

by the Group or its customers, suppliers, other business partners, Company Personnel or
stockholders, except when disclosure is authorized by the Company or is legally mandated.
Confidential information includes all non-public information relating to, among other
things, decisions, operations, procedures, plans, earnings, financial or business forecasts,
databases, names and addresses, competitive bids, formulas, designs, configurations,
technical processes, methods or characteristics of machines, trade secrets, supplies,
products or materials, research, development, strategies and know-how, regarding the
Group, its customers, suppliers, business partners, business relationships, Company
Personnel or shareholders, that might be of use to competitors or harmful to the Group,
its customers, suppliers, business partners, business relationships, Company Personnel or
shareholders, if disclosed.
• A Business Partner shall not, without obtaining prior approval from the Company, use
such confidential information outside the course of conduct of duties for the Group.
If a Business Partner anticipates or identifies problems adhering to any of the principles set
out above during the conduct of business with the Group, it should discuss the matter with a
Company compliance officer prior to commencement of business or immediately in the event
that a problem occurs during the conduct of our business together.

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5. Compliance with Laws and Regulations

Each Business Partner has an obligation to comply with the laws of jurisdiction where they
operate. This includes, without limitation, laws covering commercial bribery and kickbacks,
copyrights, trademarks and trade secrets, information privacy, insider trading, offering or
receiving business courtesies, employment harassment, environmental protection,
occupational health and safety, false or misleading financial information, misuse of corporate
assets and foreign currency exchange activities. Business Partners are expected to understand
and comply with all laws, rules and regulations that apply. If any doubt exists about whether a
course of action required during the conduct of business with the Group is lawful, ethical, or
contrary to Company policy, the Business Partner should seek advice immediately from a
Company compliance officer.

6. Fair Dealing and Integrity

Fair Dealing
A Business Partner, when dealing with the Group or acting on the Group’s behalf, should
endeavor to deal fairly with the customers, suppliers, competitors and employees of the Group,
governmental authorities and the general public. A Business Partner should not take unfair
advantage of or injure anyone through manipulation, concealment, abuse of privileged or
confidential information, misrepresentation of material facts, fraudulent behavior or any other
unfair dealing practice.

Integrity
A Business Partner must perform its duties and responsibilities for the Group with the highest
degree of integrity. Integrity requires such Business Partner to perform its work with honesty,
diligence, responsibility and in accordance with applicable laws. In the performance of its work,
a Business Partner must not knowingly be a party to any illegal activity or engage in acts that
are discreditable to the Group. Integrity requires a Business Partner to observe both the form
and the spirit of the ethical principles contained in this Code.

7. Inside Trading
The securities of the Company are traded on the Nasdaq Stock Market, the Main Board of The
Stock Exchange of Hong Kong Limited and the AIM market of the London Stock Exchange. At
times, during the conduct of business with the Group, Business Partners and their employees
may have access to information about the financial or operating performance of the Group’s
business which is not yet in the public domain. Similarly, from time to time, Business Partners
or their employees may choose to invest or trade in the Company’s securities. In such event,
prior to trading in the Company’s securities, it is the individual’s legal responsibility to ensure
that, in trading or investing in the Company’s securities, they are not in possession of any
material or price-sensitive non-public information regarding the Group or any other entity that
has a business relationship with the Group. Trading in securities whilst in possession of inside
information is strictly prohibited by U.S. Hong Kong and UK securities laws. The Company
operates an insider dealing code for the Company Personnel, whereby each Company
Personnel is required to seek approval from the Company’s management prior to trading. The
Group does not seek to control the securities trading activities of non-employees but expect
its Business Partners to ensure that they and their employees respect the confidentiality of

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any information that they have access to and that they do not trade on non-public information
or otherwise act in breach of any applicable laws.

If you have any questions about buying or selling the Company’s securities, please contact a
Company compliance officer.

8. Debarrment
Business Partners, their Affiliates, Business Partners’ personnel and each of their respective
officers and directors, as applicable: (a) have not been debarred and are not subject to a
pending debarment, and will not use in any capacity in connection with the services provided
to the Group any person who has been debarred or is subject to a pending debarment,
pursuant to Section 306 of the United States Food, Drug and Cosmetic Act, 21 U.S.C. § 335a;
(b) are not ineligible to participate in any federal and/or state healthcare programs or federal
procurement or non-procurement programs (as that term is defined in 42 U.S.C. § 1320a-7b(f));
(c) are not disqualified by any government or regulatory authorities from performing specific
services, and are not subject to a pending disqualification proceeding; and (d) have not been
convicted of a criminal offense related to the provision of healthcare items or services and are
not subject to any such pending action. Business Partners will notify the relevant Group
company immediately if Business Partners, their Affiliates, any Business Partners’ personnel,
or any of their respective officers or directors, as applicable, is subject to the foregoing, or if
any action, suit, claim, investigation, or proceeding relating to the foregoing is pending, or to
the best of Business Partners’ knowledge, is threatened

9. Violations of this Code

Business Partners have a duty to report any known or suspected violation of this Code,
including any violation of laws, rules, regulations or policies that apply to the Group and/or
the business that the Group and the Business Partners carry out together. Reporting in good
faith a known or suspected violation of this Code by others will be considered an action to
safeguard the reputation and integrity of the Group and the Company Personnel.

If a Business Partner knows of or suspects a violation of this Code, it is such Business Partner’s
responsibility to immediately report the violation to a Company compliance officer, who will
work with the Business Partner to investigate the matter. All questions and reports of known
or suspected violations of this Code will be treated with sensitivity and discretion. Failure to
comply with applicable law or with this Code may have serious consequences for both the
Business Partner and the Group. It is the Group’s policy that any Business Partner who violates
this Code will be subject to appropriate action, including possible termination of engagement,
based upon the facts and circumstances of each particular situation.

10. Sustainability
All Business Partners should also be committed to observing the sustainability-related policies,
including but not limited to the Sustainability Policy, Environmental Policy, Health and Safety
Policy, Human Rights Policy, Modern Slavery and Human Trafficking Statement, and other
sustainability practices of the Group.

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11. Conclusion
This Code contains general guidelines for the conduct of business with, or on behalf of, the
Group, consistent with the highest standards of business ethics. Further guidance can be
obtained from a Company compliance officer if required.

We expect all Business Partners to adhere to this Code. Each Business Partner is legally and
ethically responsible for the actions of their employees. If a Business Partner engages in
conduct prohibited by law or this Code, they will be deemed to have acted outside the scope
of their engagement by the Group.

This Code is in addition to and supplements any existing Group or Company policy relating to
a similar or related subject matter.

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