Zhejiang Jiuli Special Materials Technology Co., Ltd.
2025 Internal Control Self-Evaluation Report
To all shareholders of Zhejiang Jiuli Special Materials Technology Co., Ltd.:
In accordance with the requirements of the "Basic Norms for Enterprise Internal Control" and its supporting guidelines, and combined with Zhejiang Jiuli Special Materials Technology Co., Ltd.'s (hereinafter referred to as the Company) internal control system and evaluation methods, based on daily and special supervision of internal controls, we have conducted a self-evaluation of the effectiveness of the Company's internal controls as of December 31, 2025.
I. Important Statement
In accordance with the requirements of the enterprise internal control norm system, establishing and effectively implementing internal controls, evaluating their effectiveness, and truthfully disclosing the internal control evaluation report are the responsibilities of the Company's Board of Directors. The Board of Directors and the management team guarantee that the content of this report does not contain any false records, misleading statements, or major omissions, and they bear individual and joint responsibility for the authenticity, accuracy, and completeness of the report.
The objectives of the Company's internal control are to reasonably guarantee that business management is legal and compliant, assets are safe, financial reports and related information are true and complete, operating efficiency and effectiveness are improved, and development strategies are promoted. Due to the internal environment and the continuous changes in the macro environment, policies, and regulations, existing control activities may become inapplicable or deviate. The Company will promptly supplement and improve its internal control system. Due to the inherent limitations of internal control, it can only provide reasonable assurance for achieving these objectives. Furthermore, changes in circumstances may cause internal controls to become inappropriate, or the degree of compliance with control policies and procedures may decrease. Inferring the future effectiveness of internal controls based on the results of the internal control evaluation carries certain risks.
II. Conclusion of Internal Control Evaluation
Based on the identification of material defects in financial reporting internal controls, as of the reporting date of the internal control evaluation, no material defects in financial reporting internal controls were found. The Board of Directors believes that the Company has maintained effective financial reporting internal controls in all material aspects in accordance with the requirements of the enterprise internal control norm system and relevant regulations.
Based on the identification of material defects in non-financial reporting internal controls, as of the reporting date of the internal control evaluation, no material defects in non-financial reporting internal controls were found. No factors have occurred between the reporting date of the internal control evaluation and the issuance date of the internal control evaluation report that affect the conclusion of the internal control effectiveness evaluation.
III. Internal Control Evaluation Work
(I) Scope of Company Internal Control Evaluation
The Company, based on the requirements of the basic norms and relevant supporting guidelines, and guided by risk, has further strengthened the hierarchical self-evaluation system for the headquarters, business units, and various business departments to determine the main businesses, matters, and high-risk areas included in the scope of evaluation.
The matters included in the Company's evaluation scope include the internal environment, risk assessment, control activities, information and communication, and internal supervision. The main businesses included in the evaluation scope include sales and collections, procurement and payments, fixed asset management, inventory management, fund management, investment management, subsidiary management, related-party transactions, and external guarantees, and the use of raised funds. Key high-risk areas of focus mainly include: financial management, asset management, procurement and payment management, sales management, engineering projects, and contract management.
(II) Overall Situation of Company Internal Control
- Internal Environment
(1) Governance Structure and Allocation of Powers and Responsibilities