China Hi-Tech Group Co.Ltd(600730) : internal control evaluation report in 2021

Company code: China Hi-Tech Group Co.Ltd(600730) company abbreviation: China Hi-Tech Group Co.Ltd(600730)

China Hi-Tech Group Co.Ltd(600730)

Internal control evaluation report in 2021

China Hi-Tech Group Co.Ltd(600730) 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. Internal control report conclusion

√ 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: the headquarters of the company and its 15 subsidiaries, namely China Hi-Tech Group Co.Ltd(600730) , Wuhan Guoxin Real Estate Development Co., Ltd., Shenzhen hi tech Industrial Co., Ltd., Beijing Wanshunda Real Estate Development Co., Ltd., Shenzhen hi tech Guorong Education Information Technology Co., Ltd., Beijing hi tech Guorong Asset Management Co., Ltd., Shanghai Guanzhen Equity Investment Fund Management Co., Ltd Shanghai Guanzhen equity investment fund partnership (limited partnership), high tech Education Holdings (Beijing) Co., Ltd., Hong Kong High Tech International Group Co., Ltd., Beijing high tech cloud Education Technology Co., Ltd., high tech Jiangsu Education Development Co., Ltd., Liuzhou yingteng vocational training school Co., Ltd. (formerly known as “Liuzhou yingteng Education Technology Co., Ltd.), Guangxi yingteng Education Technology Co., Ltd Yingteng think tank Education Technology (Beijing) Co., Ltd. and Gaoke Muke (Beijing) Education Technology Co., Ltd. As it has not invested in Centennial Zhongke (Beijing) Education Technology Co., Ltd. and has not started operation at the end of the year, it is not included in the scope of evaluation. 2. 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:

Organizational structure, development strategy, human resources, corporate culture, legal affairs, risk assessment, information and communication, internal supervision, fund management, procurement and payment management, inventory management, fixed assets management, intangible assets management, engineering management, research and development management, production management, salary management, sales and collection management, financial report management, comprehensive budget management Information system management and control of holding subsidiaries. 4. High risk areas of focus mainly include:

Capital activities, procurement business, asset management, engineering management, sales and collection management, financial report, comprehensive budget, contract management, related party transactions, information and communication, etc. 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 (II) Basis of internal control evaluation and identification standard of internal control defects

The company organizes and carries out internal control evaluation in accordance with the requirements of relevant laws and regulations such as the enterprise internal control standard system and the provisions of the company’s internal control management manual and internal control evaluation management system. 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 total assets ≥ 5% of total assets ≤ 1% of total assets amount of misstatement 1% of total assets 5% of total assets

The amount of misstatement of operating revenue ≥ 1% of total operating revenue ≤ amount of misstatement 5% of total operating revenue 1% of total operating revenue

Net profit misstatement amount ≥ 5% of net profit, 1% of net profit ≤ misstatement amount net profit misstatement amount 1% of net profit, 5% of profit

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

A defect in internal control, alone or in combination with other defects, has a reasonable possibility to prevent, detect and correct material misstatement in the financial report in a timely manner.

Signs of significant deficiencies in financial reporting include:

① Invalid control environment. ② The directors, supervisors and senior managers of the company commit fraud and cause heavy losses and major defects to the enterprise

And adverse effects. ③ The certified public accountant found that there was a material misstatement in the current financial report, but the internal control failed to find the misstatement in the operation process. ④ The supervision of the enterprise audit committee and internal audit institutions on internal control is invalid. ⑤ Major deficiencies that have been identified and reported to management have not been corrected within a reasonable time.

Defects in internal control, alone or in combination with other defects, have a reasonable possibility to prevent, detect and correct the misstatement in the financial report that does not reach or exceed the importance level, but should still attract the attention of the board of directors and management. Signs of significant deficiencies in financial reporting include:

Significant defect ① failure to select and apply accounting policies in accordance with GAAP. ② No anti fraud procedures and control measures have been established. ③ For the accounting treatment of unconventional or special transactions, no corresponding control mechanism is established or not implemented and there is no corresponding compensatory control. ④ 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 true and complete goal.

General defects are internal control defects that do not constitute major defects and important defects.

Note: 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 direct property of 1 million yuan to 10 million yuan (including 1 million yuan) is more than 10 million yuan

Loss amount (RMB 10 million)

Or subject to provincial (including provincial) punishment, or cause great negative impact on the company, or be punished by national government departments

The company was punished by the government department, but did not have a significant negative impact, and punished in the form of announcement, but did not report regularly to the company

The disclosure of the company’s periodic report has a negative impact

negative effect

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

① Violation of national laws, regulations or normative documents; ② Unscientific decision-making procedure leads to major decision-making mistakes; ③ Institutional deficiency or systematic failure of important business; ④ Major or important defects cannot be effectively rectified; ⑤ Major safety defects

All environmental accidents that have a significant negative impact on the company; ⑥ Other situations that have a significant negative impact on the company.

① Defects in important business systems or systems; ② Important internal control defects not found in time

Change; ③ Other situations that have a great negative impact on the company.

① Defects in general business system or system; ② General defects found in internal control and internal supervision are not rectified in time

Change.

Note: none (III) 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

According to the above identification standards of internal control defects in financial reports, the company had general defects in internal control of individual financial reports during the reporting period. The company found that there were individual general defects in its daily operation, that is, it carried out corresponding rectification and continued improvement, so as to control the risk and improve the internal control system of the company

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