Scienjoy Holding Corp

ITEM 16.B. CODE OF ETHICS

On May 12, 2020, our Board adopted (a) an Amended and Restated Code of Conduct and Ethics (the “Ethics Code”), which amended and restated our then existing code of conduct and ethics (the “Previous Code”) in its entirety and applies to all officers, directors, and employees of us and our subsidiaries, and (b) an Insider Trading Policy (the “Policy”).

The Previous Code was refreshed and updated in connection with the Business Combination to conform the Ethics Code to reflect current best practices and enhance the personnel’s understanding of our standards of ethical business practices, promote awareness of ethical issues that may be encountered in carrying out an employee’s or director’s responsibilities, and improve its clarity as to how to address ethical issues that may arise. The updates include clarifications and enhancements to the purposes of the Ethics Code, compliance with law matters, policies regarding maintenance of our corporate records, and compliance standards and procedures of the Ethics Code. The adoption of the Ethics Code did not relate to or result in any waiver, whether explicit or implicit, of any provision of the Previous Code.

The Policy provides guidelines to employees, officers and directors of us and our subsidiaries with respect to transactions in our securities and the procedures set forth therein is intended to help prevent insider trading and to assist the employees, officers and directors of us and our subsidiaries in complying with their obligations under the federal securities laws.