- Ningbo Xingyuan Zhuomei Technology Co., Ltd. Internal Control Self-Assessment Report
According to the provisions of the "Basic Norms for Enterprise Internal Control" and its supporting guidelines, as well as other internal control regulatory requirements (hereinafter referred to as the "Enterprise Internal Control Normative System"), combined with the internal control system and evaluation methods of Ningbo Xingyuan Zhuomei Technology Co., Ltd. (hereinafter referred to as the "Company" or "this Company"), we evaluated the effectiveness of the Company's internal controls as of December 31, 2025 (the benchmark date for the internal control evaluation report) based on daily supervision and special supervision of internal controls.
1. Important Statement
According to the provisions of the Enterprise Internal Control Normative System, it is the responsibility of the Company's board of directors to establish, improve, and effectively implement internal controls, evaluate their effectiveness, and truthfully disclose the internal control evaluation report. The audit committee supervises the establishment and implementation of internal controls by the board of directors. The management is responsible for organizing and leading the daily operation of internal controls. The Company's board of directors, directors, and senior management ensure that the content of this report does not contain any false records, misleading statements, or significant omissions, and bear individual and joint legal responsibility for the truthfulness, accuracy, and completeness of the report's content. The objective of the Company's internal controls is to reasonably ensure that business management is legal and compliant, assets are secure, financial reports and related information are true and complete, operational efficiency and effectiveness are improved, and the achievement of development strategies is promoted. Due to the inherent limitations of internal controls, they can only provide reasonable assurance for achieving the above objectives. Furthermore, changes in circumstances may render internal controls inappropriate or reduce compliance with control policies and procedures, making it risky to infer the future effectiveness of internal controls based on evaluation results.
2. Internal Control Evaluation Conclusion
As of December 31, 2025, based on the identification of significant deficiencies in internal controls over financial reporting, there are no significant deficiencies in financial reporting internal controls. The board of directors believes that the Company has maintained effective financial reporting internal controls in all material respects in accordance with the requirements of the Enterprise Internal Control Normative System and related regulations. As of December 31, 2025, based on the identification of significant deficiencies in non-financial reporting internal controls, the Company has not identified any significant deficiencies in non-financial reporting internal controls.
From December 31, 2025, to the date of issuance of the internal control evaluation report, no factors affecting the evaluation conclusion of internal control effectiveness have occurred.
3. Internal Control Evaluation Work Situation
(1) Scope of Internal Control Evaluation
The Company determined the main units, businesses, and high-risk areas included in the evaluation scope based on a risk-oriented principle. The main units included in the evaluation scope are: Ningbo Xingyuan Zhuomei Technology Co., Ltd., Xingyuan Zhuomei (Ningbo Fenghua) Technology Co., Ltd., SINYUAN ZM (SINGAPORE) PTE.LTD., SINYUAN ZM INTERNATIONAL (SINGAPORE) PTE.LTD., SINYUANZM (THAILAND) CO.,LTD., and Ningbo Yuanxing Magnesium Trading Co., Ltd. The total assets of the units included in the evaluation scope account for 100% of the total assets in the Company's financial statements, and the total operating income accounts for 100% of the total operating income in the Company's financial statements. The main businesses and matters included in the evaluation scope are: development strategy, governance structure, organizational structure, human resources, corporate culture, internal audit, fund management, procurement and payment, sales and collection, inventory management, contract management, financial control, and fundraising management. The specifics are as follows: