Anhui Zhongyuan New Materials Co.Ltd(603527)
Internal control evaluation report in 2021
Anhui Zhongyuan New Materials Co.Ltd(603527) all shareholders:
In accordance with the provisions of the basic norms of enterprise internal control and its supporting guidelines and other internal control regulatory requirements (hereinafter referred to as the enterprise internal control normative system), combined with the company’s (hereinafter referred to as the company’s) internal control system and evaluation methods, and on the basis of daily and special supervision of internal control, we evaluated the effectiveness of the company’s internal control on December 31, 2021 (the benchmark date of internal control evaluation report). I Important statement
It is the responsibility of the board of directors of the company to establish, improve and effectively implement internal control, evaluate its effectiveness and truthfully disclose the internal control evaluation report in accordance with the provisions of the enterprise’s internal control standard system. The board of supervisors shall supervise the establishment and implementation of internal control by the board of directors. The management is responsible for organizing and leading the daily operation of the enterprise’s internal control. The board of directors, the board of supervisors and the directors, supervisors and senior managers of the company guarantee that there are no false records, misleading statements or major omissions in the contents of this report, and bear individual and joint legal liabilities for the authenticity, accuracy and completeness of the contents of the report.
The objective of the company’s internal control is to reasonably ensure the legal compliance of operation and management, asset safety, authenticity and integrity of financial reports and relevant information, improve operation efficiency and effect, and promote the realization of development strategy. Due to the inherent limitations of internal control, it can only provide reasonable assurance for the realization of the above objectives. In addition, as changes in circumstances may lead to inappropriate internal control or reduced compliance with control policies and procedures, there is a certain risk to speculate the effectiveness of internal control in the future according to the internal control evaluation results. II Internal control evaluation conclusion 1 On the benchmark date of the internal control evaluation report, does the company have any major defects in the internal control of financial reporting
□ yes √ no
2. Evaluation conclusion of internal control over financial reporting
√ valid □ invalid
According to the identification of major defects in the company’s internal control over financial reporting, there are no major defects in the internal control over financial reporting on the benchmark date of the internal control evaluation report. The board of Directors believes that the company has maintained effective internal control over financial reporting in all major aspects in accordance with the requirements of the enterprise’s internal control standard system and relevant regulations. 3. Whether major defects in internal control over non-financial reporting are found
□ yes √ no
According to the identification of major defects in the company’s internal control over non-financial reports, the company found no major defects in the company’s internal control over non-financial reports on the benchmark date of the internal control evaluation report.
4. Factors affecting the evaluation conclusion of internal control effectiveness from the benchmark date of internal control evaluation report to the date of issuance of internal control evaluation report □ applicable √ not applicable
There are no factors affecting the evaluation conclusion of the effectiveness of internal control from the base date of the internal control evaluation report to the date of issuance of the internal control evaluation report. 5. Whether the internal control audit opinion is consistent with the company’s evaluation conclusion on the effectiveness of internal control over financial reporting
√ yes □ No 6 Whether the disclosure of major defects in internal control of non-financial reports in the internal control audit report is consistent with the disclosure of the company’s internal control evaluation report √ yes □ no III Internal control evaluation (I) Scope of internal control evaluation
According to the risk oriented principle, the company determines the main units, businesses and matters included in the evaluation scope and high-risk areas. 1. The main units included in the evaluation scope include: Anhui Zhongyuan New Materials Co.Ltd(603527) , Anhui Yongjie Copper Industry Co., Ltd., Wuhu Zhongyuan import and Export Co., Ltd., Anhui Jieguan Trading Co., Ltd., Wuhu Zhongyuan Trading Co., Ltd., Anhui Anhui Zhongyuan New Materials Co.Ltd(603527) Investment Co., Ltd., Dongguan ZhongLuo Electronic Technology Co., Ltd., Harbin Hechang New Material Technology Co., Ltd., Anhui Hechang New Material Technology Co., Ltd Anhui Zhongyong Materials Co., Ltd., Anhui Zhongyuan new energy technology Co., Ltd Proportion of units included in the scope of evaluation:
Proportion of indicators (%)
The ratio of the total assets of the units included in the evaluation scope to the total assets of the company’s consolidated financial statements 100
The total operating income of the units included in the evaluation scope accounts for 100% of the total operating income in the company’s consolidated financial statements
3. The main operations and matters included in the scope of evaluation include:
Corporate governance structure, corporate culture, human resources, authorization and approval, internal audit, financial management, budget management, management of holding subsidiaries, fixed assets management, financial report, contract management, internal control of foreign investment, internal control of external guarantee, internal control of related transactions and internal control of information disclosure. 4. High risk areas of focus mainly include:
Management of holding subsidiaries, internal control of foreign investment, internal control of external guarantee, internal control of related party transactions, internal control of raised funds and internal control of information disclosure. 5. The above units, businesses and matters included in the evaluation scope and high-risk areas cover the main aspects of the company’s operation and management. Is there any major omission
□ yes √ No 6 Is there a statutory exemption
□ yes √ no
7. Other explanatory matters
None. （2） Basis of internal control evaluation and identification standard of internal control defects
In accordance with the provisions of the enterprise internal control standard system and its supporting guidelines and other internal control supervision requirements, combined with the company’s internal control system and evaluation methods, the company organizes and carries out internal control evaluation on the basis of daily and special supervision of internal control. 1. Whether the specific identification standard of internal control defects is adjusted with that of previous years
□ yes √ no
The board of directors of the company distinguished the internal control of financial report from the internal control of non-financial report according to the identification requirements for major defects, important defects and general defects of the enterprise internal control standard system, combined with the factors such as the company’s size, industry characteristics, risk preference and risk tolerance, and studied and determined the specific identification standards of internal control defects applicable to the company, which are consistent with the previous years. 2. Identification standard of internal control defects in financial reporting
The quantitative criteria for the evaluation of internal control defects in financial reporting determined by the company are as follows:
Index name major defect quantitative standard important defect quantitative standard general defect quantitative standard
The amount of misstatement of operating revenue ＞ 2% of operating revenue, and the amount of misstatement accounts for 1% of the amount of misstatement of operating revenue ≤ 1% – 2% of operating revenue
The amount of misstatement of total assets ＞ 3% of total assets, and the amount of misstatement accounts for 2% of the amount of misstatement ≤ 2% – 3% of total assets
Description: none.
The qualitative criteria for the evaluation of internal control defects in financial reporting determined by the company are as follows:
Qualitative standard of defect nature
Major defects (1) fraud by the company’s directors, supervisors and senior managers and causing heavy losses and adverse effects to the enterprise; (2) The external audit found that there were significant misstatements in the current financial report, and the company failed to find them first;
(3) Major defects that have been found and reported to the management have not been corrected within a reasonable time;
(4) The supervision of the company’s audit committee and the company’s internal audit department on internal control is invalid.
Significant defects (1) failure to select and apply accounting policies in accordance with generally accepted accounting standards;
(2) Failure to establish anti fraud procedures and control measures;
(3) There are one or more defects in the control of the financial reporting process at the end of the period, and it can not reasonably ensure that the prepared financial statements achieve the goal of authenticity and accuracy;
General defects and other internal control defects that do not constitute major defects and important defect standards are recognized as general defects.
Description: none. 3. Identification standard of internal control defects in non-financial reporting
The quantitative criteria for the evaluation of internal control defects in non-financial reporting determined by the company are as follows:
Index name major defect quantitative standard important defect quantitative standard general defect quantitative standard
The amount of misstatement of operating revenue ＞ 2% of operating revenue, and the amount of misstatement accounts for 1% – 2% of operating revenue ≤ 1% of operating revenue
The amount of misstatement of total assets ＞ 3% of total assets. The amount of misstatement accounts for 2% – 3% of total assets ≤ 2% of total assets
Description: none.
The qualitative criteria for the evaluation of internal control defects in non-financial reporting determined by the company are as follows:
Qualitative standard of defect nature
Major defects (1) safety liability accidents caused by the company’s failure to manage safety production, resulting in heavy casualties;
(2) Violation of national laws and regulations and punishment;
(3) Negative news frequently appears in the media, involving a wide range;
(4) Lack of system control or failure of control system for important business;
(5) Middle and senior managers leave one after another, or the loss of personnel in key positions is serious.
Important defects: (1) general mistakes caused by decision-making procedures;
(2) Losses caused by violation of internal rules and regulations of the enterprise;
(3) Negative news in the media involves local areas;
(4) Defects in important business systems or systems;
(5) Important or general defects in internal control have not been rectified;
General defects other internal control defects of non-financial reporting other than major defects and important defects shall be recognized as general defects.
Description: none. （3） Identification and rectification of internal control defects 1 Identification and rectification of internal control defects in financial reporting 1.1 Major defects
Whether the company has any major defects in internal control over financial reporting during the reporting period
□ yes √ no 1.2 Important defects
Whether the company has any significant defects in internal control over financial reporting during the reporting period
□ yes √ no 1.3 General defect
None. 1.4. After the above rectification, on the benchmark date of the internal control evaluation report, does the company have any major defects in the internal control of financial reporting that have not been rectified
□ yes √ no 1.5 After the above rectification, on the benchmark date of the internal control evaluation report, does the company have any important defects in the internal control of financial reporting that have not been rectified
□ yes √ no
2. Identification and rectification of internal control defects in non-financial reporting 2.1 Major defects
Whether the company found any major defects in internal control over non-financial reporting during the reporting period
□ yes √ no
2.2. Important defects
Whether the company found any significant defects in internal control over non-financial reporting during the reporting period
□ yes √ no 2.3 General defect
None. 2.4. After the above rectification, on the benchmark date of the internal control evaluation report, does the company find any major defects in non-financial reporting internal control that have not been rectified
□ yes √ no 2.5 After the above rectification, on the benchmark date of the internal control evaluation report, does the company find any important defects in the internal control of non-financial reporting that have not been rectified
□ yes √ no IV Description of other major matters related to internal control 1 Rectification of internal control defects in the previous year
□ applicable √ not applicable 2 Operation of internal control in this year and improvement direction in the next year
□ applicable √ not applicable 3 Description of other major events
□ applicable √ not applicable
Chairman (authorized by the board of directors): Feng Quanhu Anhui Zhongyuan New Materials Co.Ltd(603527) March 25, 2022
