Chinalin Securities Co.Ltd(002945)
About Fullink Technology Co.Ltd(301067)
Verification opinions on self-evaluation report of internal control in 2021
Chinalin Securities Co.Ltd(002945) (hereinafter referred to as ” Chinalin Securities Co.Ltd(002945) ” and “sponsor”) as a sponsor of Fullink Technology Co.Ltd(301067) (hereinafter referred to as ” Fullink Technology Co.Ltd(301067) ” or “company”) for initial public offering of shares and listing on GEM, In accordance with the requirements of laws and regulations such as the measures for the administration of securities issuance and listing recommendation business, the Listing Rules of Shenzhen Stock Exchange on the gem, the self regulatory guidelines for listed companies on the Shenzhen Stock Exchange No. 2 – standardized operation of companies listed on the gem, and the basic norms of enterprise internal control, the self-evaluation report on internal control in Fullink Technology Co.Ltd(301067) 2021 was verified. The details are as follows:
1、 Fullink Technology Co.Ltd(301067) self evaluation of internal control
Fullink Technology Co.Ltd(301067) evaluated the effectiveness of the company’s internal control on December 31, 2021 (benchmark date of internal control evaluation report).
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. 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.
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.
2、 Fullink Technology Co.Ltd(301067) internal control self-evaluation
(I) evaluation scope of internal control
According to the risk oriented principle, the company determines the main units, businesses and matters included in the evaluation scope and high-risk areas. The scope included in the evaluation includes the company and all subsidiaries within the scope of consolidated statements, including Fullink Technology Co.Ltd(301067) , Huizhou Yaoying Precision Technology Co., Ltd., Guangdong Fullink Technology Co.Ltd(301067) Co., Ltd. and Guangdong Zhiying Technology 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 revenue accounts for 100% of the total operating revenue in the company’s financial statements.
The main operations and matters included in the scope of evaluation include:
1. Internal control environment
(1) Communication and implementation of integrity and moral values
Integrity and moral values are an important part of the control environment and affect the design and operation of important business processes of the company. The company has always attached importance to the creation and maintenance of this atmosphere. Through the formulation of internal normative documents such as employee manual and integrity commitment, the company defines the standards and relevant penalties that should be observed by various behaviors, and implements the socialist core values in multiple channels and all directions through the practice of senior managers. (2) Emphasis on Competence
The management of the company attaches great importance to the setting of the use ability level required for specific jobs, as well as the requirements for the knowledge and ability necessary to achieve this level. The company also carries out various forms of post training and education for different posts according to the needs of actual work, so that employees can be competent for their current jobs.
(3) Participation procedures of governance
The responsibilities of the management have been clearly stipulated in the articles of association and policies of the company. Through its own activities and with the support of the audit committee, the governance layer supervises the company’s accounting policies and internal and external audit work and results. The responsibilities of the governance layer also include supervising whether the policies and procedures designed to review the effectiveness of internal control are reasonable and effective.
(4) Management philosophy and business style
The management of the company is responsible for the operation of the enterprise and the formulation, implementation and supervision of business strategies and procedures. The board of directors and the audit committee effectively supervise it. The management attached great importance to internal control, including information technology control, information management personnel and accounting personnel, and timely and properly handled the reports on internal control weaknesses and violations received. Adhering to the business theory of “based on innovation, focusing on quality, honest service and common development”, the company operates honestly and legally.
(5) Organizational structure
In order to effectively plan, coordinate and control business activities, the company has reasonably determined the form and nature of organizational units, implemented the principle of separation of incompatible positions, scientifically divided the responsibilities and authorities within each organizational unit, and formed a mutual check and balance mechanism. At the same time, we will earnestly achieve “five independence” from the controlling shareholder of the company. The company has designated special personnel to be specifically responsible for internal audit and ensure the implementation of relevant accounting control systems. (6) Distribution of authority and responsibility
The company adopts the method of assigning control responsibilities to individuals, establishes a set of authorization mechanism for performing specific functions (including transaction authorization), and ensures that everyone clearly understands the reporting relationship and responsibilities. In order to effectively control the authorized use and supervise the company’s activities, the company has gradually established a budget control system, which can modify the control policies of the accounting system in a timely manner according to the changes of the situation. The financial department reasonably ensures that business activities are carried out in accordance with appropriate authorization through various measures; Reasonably ensure that transactions and events can be recorded in appropriate accounts in a timely manner with the correct amount in the appropriate accounting period, so that the preparation of financial statements meets the relevant requirements of accounting standards.
(7) Human resources policy and Practice
The company has established and implemented more scientific personnel management systems such as employment, training, job rotation, assessment, reward and punishment, promotion and elimination, and hired enough personnel to complete the assigned tasks.
(8) Asset management
The company has formulated the inventory management system, fixed assets management system and other systems, defined the post responsibilities of relevant departments, standardized the management process of the company’s inventory, fixed assets, intangible assets and other assets, defined the relevant responsibilities of the asset management department, fund management department and use department, controlled the key links such as acceptance and warehousing, receiving, issuance, storage and disposal of physical assets, and took asset records Take measures such as physical storage, regular inventory and account verification to ensure the safety of assets.
(9) Sales business
The company has formulated the sales receivable management system, customer rating and order management system and other systems, defined the post responsibilities of relevant departments, and defined their respective rights and responsibilities and mutual restriction requirements and measures in the links of sales plan management, customer credit management, sales quotation, sales contract signing, product delivery management, collection, return management and accounts receivable management; Strictly standardize the control processes of sales contract, delivery, acceptance and return; Pay attention to the credit status of customers, regularly check current accounts, and take effective measures to prevent credit risks.
2. Risk assessment process
The company has formulated the long-term overall goal of adhering to product R & D innovation and solid and reliable quality assurance system as the core driving force of development, always adhering to integrity, steady operation and focusing on development, supplemented by specific strategies and business process plans, so as to clearly convey the business objectives of the enterprise to every employee.
The company has established an effective risk assessment process to identify and respond to major and generally influential changes that the company may encounter, including business risks, environmental risks, financial risks and so on.
3. Information system and communication
The company has established a powerful information system to provide timely and effective performance reports to the management. The information system personnel (including financial personnel) are scrupulous and diligent, and can effectively perform their assigned responsibilities. The management of the company also provides appropriate human and financial resources to ensure the normal and effective operation of the whole information system.
The company has established effective communication channels and mechanisms for suspicious inappropriate matters and behaviors, so that the management can effectively communicate with employees’ responsibilities and control responsibilities. The adequacy of internal communication enables employees to effectively perform their duties, communicate effectively with customers, suppliers, regulators and other outsiders, and enable the management to take appropriate further actions in time in the face of various changes.
4. Control activities
The company has necessary control policies and procedures for its main business activities. The management has clear objectives for budget, profit, other financial and operating performance. The company has clear records and communication on these objectives, and actively monitors them. The financial department has established appropriate protection measures to reasonably ensure that the contact and handling of assets and records are properly authorized; Reasonably ensure that the book assets are consistent with the actual assets on a regular basis.
In order to reasonably ensure the realization of various objectives, the company has established relevant control procedures, mainly including transaction authorization control, responsibility division control, voucher and record control, asset contact and record use control, independent inspection control, electronic information system control, etc.
(1) Transaction authorization control: it defines the scope, authority, procedures, responsibilities and other relevant contents of authorization and approval. The management at all levels within the unit must exercise corresponding functions and powers within the scope of authorization, and the handling personnel must also handle economic business within the scope of authorization.
(2) Control of responsibility division: reasonably set the division of labor, scientifically divide the responsibilities and authorities, implement the principle of separation of incompatible positions and each person’s work can automatically check the work of another person or more people, and form a mutual check and balance mechanism. Incompatible positions mainly include: authorization approval and business handling, business handling and accounting records, accounting records and property custody, business handling and business audit, authorization approval and supervision and inspection.
(3) Voucher and record control: the voucher circulation procedure has been reasonably formulated, so that the operators can prepare relevant vouchers in time when executing transactions, and the prepared vouchers shall be sent to the accounting department as soon as possible for recording, and the registered vouchers shall be filed in order. Relevant records must be made for various transactions (such as employee salary records, perpetual inventory records, sales invoices, etc.), and the records must be independently compared with the corresponding entries.
(4) Control of asset contact and use of records: strictly restrict the direct contact of unauthorized personnel with property, and take measures such as regular inventory, property records, account verification and property insurance to ensure the safety and integrity of all kinds of property.
(5) Independent inspection and control: the company has set up a special internal audit organization to audit and assess the authenticity, accuracy and completeness of procedures of monetary funds, securities, vouchers and account books, material procurement, consumption quota, payment, salary management, entrusted processing materials and account reality.
(6) The company has formulated a relatively strict electronic information system control system, and has done more work in the development and maintenance of electronic information system, data input and output, document storage and custody, etc.
5. Supervision of control
The company regularly evaluates various internal controls, and on the one hand, establishes various mechanisms to enable relevant personnel to obtain evidence of the effective operation of internal control to a considerable extent when performing their normal post responsibilities; On the other hand, confirm the internal information or point out the existing problems through external communication. The management of the company attaches great importance to the reports and suggestions of various functional departments and regulatory bodies of internal control, and takes various measures to correct the deviations in the control operation in time.
(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 the enterprise’s internal control standard system and in combination with the company’s internal control related systems. According to the identification requirements of the enterprise internal control standard system for major defects, important defects and general defects, and in combination with the factors such as the company’s scale, industry characteristics, risk preference and risk tolerance, the board of directors of the company distinguished the internal control of financial reports from the internal control of non-financial reports, and studied and determined the specific identification standards of internal control defects applicable to the company. The identification standards of internal control defects determined by the company are as follows:
1. Identification standard of internal control defects in financial reporting
(1) Qualitative criteria
① Major defect: refers to the combination of one or more control defects, which may cause the enterprise to seriously deviate from the control objectives. It is identified as a major defect if it has the following characteristics:
a. Fraud of directors, supervisors or senior managers of the company;
b. The company corrects the published financial report;
c. The company’s internal control system does not find any major misstatement in the current financial report;
d. The major defects reported to the management and the board of directors have not been corrected after a reasonable time; e. The supervision of internal control by the audit committee and the internal audit department is invalid.
② Important defect: refers to the combination of one or more control defects, whose severity and economic consequences are lower than those of major defects, but it may still cause the enterprise to deviate from the control objectives. Defects or situations with the following characteristics shall generally be recognized as important defects:
a. Failure to select and apply accounting policies in accordance with GAAP;
b. Failure to establish anti fraud procedures and control measures;
c. No corresponding control mechanism has been established or implemented for the accounting treatment of unconventional or special transactions, and there is no corresponding compensatory control;
d. 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. The general defects of internal control over financial reporting refer to other control defects other than the above major defects and important defects.
(2) Quantitative standard
Defect type potential misstatement amount in financial report
The amount of material defect misstatement ≥ 5% of the total profit
3% of the total profit of major defects ＜ the amount of misstatement ＜ 5% of the total profit
General defect misstatement amount ≤ 3% of total profit
2. Identification standard of internal control defects in non-financial reporting
(1) Qualitative criteria
① The following situations shall be generally recognized as major defects:
a. Losses suffered by the company due to important decision-making mistakes of the company;
b. The loss of management personnel or core personnel in important positions seriously affects the production and operation of the company;
c. Lack of system control or system failure of important business;
d. The result of internal control evaluation is a major defect, but it has not been rectified;
e. The company is punished by the CSRC or publicly condemned by the Shenzhen Stock Exchange;
f. The company’s business activities violate national laws and regulations, resulting in the investigation of relevant departments, revocation of business license or major punishment.
② Non financial reporting internal control defects that do not constitute major defects are recognized as non major defects or general defects.
(2) Quantitative standard
Defect type potential misstatement amount in financial report
Direct property loss due to major defects ≥ 2% of total assets
1% of total assets with major defects ≤ direct property loss ＜ 2% of total assets
General defect and direct property loss
