XCHG Ltd

Our board of directors has adopted a code of business conduct and ethics that applies to all of our directors, officers, employees, including certain provisions that specifically apply to our principal executive officer, principal financial officer, principal accounting officer or controller and any other persons who perform similar functions for us. A copy of our code of business conduct and ethics is filed as Exhibit 11.1 to this annual report on Form 20-F. Additionally, we have posted a copy of our code of business conduct and ethics on our website at https://investors.xcharge.com/. The information contained on our website is not incorporated by reference in this annual report on Form 20-F. We hereby undertake to provide to any person without charge, a copy of our code of business conduct and ethics within ten working days after we receive such person’s written request. Any waiver (including any implicit waiver) from the provisions of our code of business conduct and ethics may only be granted to our executive officers or directors by the board of directors or a committee thereof and will be promptly disclosed on our website at the same address.