Verification Opinion of CITIC Securities Co., Ltd. on the Internal Control Evaluation Report of Zhonglun New Materials Co., Ltd. for 2025
CITIC Securities Co., Ltd. (hereinafter referred to as "CITIC Securities" or "Sponsor") serves as the continuous supervision sponsor for Zhonglun New Materials Co., Ltd. (hereinafter referred to as "Zhonglun New Materials" or "Company") during its initial public offering and listing on the Growth Enterprise Market. In accordance with the "Shenzhen Stock Exchange Growth Enterprise Market Listing Rules" and the "Shenzhen Stock Exchange Self-Regulatory Guidelines No. 2 - Standardized Operations of Growth Enterprise Market Listed Companies," CITIC Securities has conducted a prudent review of the "Internal Control Evaluation Report of Zhonglun New Materials Co., Ltd. for 2025." The specific circumstances are as follows:
I. Conclusion of Internal Control Evaluation
Based on the identification of significant deficiencies in the internal control of financial reporting, there are no significant deficiencies in financial reporting internal controls as of the evaluation report reference date. The board believes that the company has maintained effective internal controls over financial reporting in all material aspects in accordance with the requirements of the enterprise internal control normative system and relevant regulations. 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 as of the evaluation report reference date. No factors affecting the effectiveness of internal control evaluation conclusions have occurred between the evaluation report reference date and the issuance date of the evaluation report.
II. Internal Control Evaluation Work Situation
The company has determined the main businesses and matters to be included in the evaluation scope and high-risk areas based on a risk-oriented principle. The main businesses and matters included in the evaluation scope are as follows:
(1) Control Environment
- Governance Structure
In accordance with the "Company Law," "Securities Law," and other relevant legal provisions, the company has established a relatively complete organizational structure. The shareholders' meeting is the highest authority of the company, the board of directors is the decision-making body, the audit committee is the supervisory body, and the management team is the decision-making execution body managing the company's daily affairs. The board of directors is accountable to the shareholders' meeting and has established four specialized committees: audit, strategy and ESG, nomination, and remuneration and assessment, with effective division of labor and mutual coordination among various departments.