Alibaba Group

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ALIBABA GROUP HOLDING LIMITED
ALIBABA GROUP CODE OF ETHICS

(Adopted on September 2, 2014 and as amended on
November 17, 2021 by the Board of Directors)

Introduction

This Alibaba Group Code of Ethics (the “Code”) applies to all directors, officers and employees of Alibaba
Group Holding Limited and its consolidated subsidiaries, including variable interest entities that are
consolidated pursuant to United States generally accepted accounting principles (collectively, “Alibaba...