OneConstruction Group Ltd

Item 16B. CODE OF ETHICS

As a foreign private issuer, we are permitted to follow home country practice in lieu of certain Nasdaq corporate governance requirements, subject to applicable disclosure requirements. We have not adopted a code of conduct applicable to all directors, officers and employees as contemplated by Nasdaq Listing Rule 5610, and we follow Cayman Islands practice, which does not require the adoption of such a code. We have also not adopted a code of ethics within the meaning of Item 16B of Form 20-F applicable to our principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions. We believe that our existing governance policies and procedures, including oversight by our board of directors and audit committee, are appropriate for our current stage of development.