Primeton Information Technologies Inc(688118) : annual internal control evaluation report

Primeton Information Technologies Inc(688118)

Internal control evaluation report in 2021

Primeton Information Technologies Inc(688118) 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 Primeton Information Technologies Inc(688118) and its wholly-owned subsidiaries 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:

Governance structure, development strategy, human resources, corporate culture, sales business, procurement business, capital activities, asset management, investment management, related party transactions, external guarantee, R & D management, financial report, contract management, internal information transmission, information management, internal supervision and other main business processes. 4. High risk areas of focus mainly include:

Capital activities, procurement business, sales business, R & D management, financial reporting, 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. (2) Basis of internal control evaluation and identification standard of internal control defects

The company organizes and carries out internal control evaluation according to the enterprise internal control standard system and other internal control supervision requirements. 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 income ≥ 2% 1% ≤ the amount of misstatement 2% and the amount of misstatement 1%

Total profit misstatement ≥ 10% 5% ≤ misstatement < 10% misstatement < 5%

Total assets misstated amount ≥ 1%, 0.5% ≤ misstated amount 1%, misstated amount 0.5%

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. Ineffective control environment;

2. Fraud of directors, supervisors and senior managers;

3. The external audit found that there were significant misstatements in the current financial report, and the company failed to find such misstatements in the process of operation; 4. Major defects that have been found and reported to the management have not been corrected within a reasonable time;

5. The supervision of the company’s audit committee and audit department on internal control is invalid;

6. Other defects that may affect the correct judgment of report users.

Important defects are those that cannot be prevented, found and corrected in time due to individual defects or together with other defects. Although the level of importance is not reached or exceeded, the misstatement that should be paid attention to by the management in the financial report.

General defects are other control defects other than the above major defects and important defects.

Description: none. 3. Identification standard of internal control defects in non-financial reporting

The quantitative criteria for 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

Direct loss direct loss ≥ 5% of total profit ≤ direct loss direct loss 10% of total profit 10% of total profit

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. Violation of national laws, regulations or normative documents;

2. Major decision-making procedures are unscientific;

3. Lack of system may lead to systematic failure;

4. Major or important defects cannot be rectified;

5. Other circumstances that have a significant impact on the company.

A defect or a combination of multiple control defects that exist in internal control and are less serious than major defects but should attract the attention of the audit committee and the board of directors.

General defects are other control defects other than the above major defects and important 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 major defects in internal control over financial reporting during the reporting period □ yes √ no 1.2 Important defects

Whether the company has significant defects in internal control over financial reporting during the reporting period □ yes √ no 1.3 General defect

For the general defects of internal control found, the company adopts the strategy of “discovery and rectification”, and has instructed relevant departments and principals to rectify them in time. 1.4. The company’s internal control report has not been rectified on the benchmark date of √ 1.5 √ yes After the above rectification, on the benchmark date of the internal control evaluation report, whether the company has 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

For the general defects of internal control found, the company adopts the strategy of “discovery and rectification”, and has instructed relevant departments and principals to rectify them in time. 2.4. After the above rectification, on the benchmark date of the internal control evaluation report, does the company find any major defects in the 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 non-financial reporting internal control 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

The company’s internal control system operated well in 2021, and no major or important control defects were found in the company’s internal control system. The company maintained effective internal control in all major aspects in accordance with the requirements of the enterprise’s internal control standard system and relevant regulations. In 2022, the company will continue to deepen the construction of internal control system, improve internal control system, standardize the implementation of internal control system, strengthen internal control supervision and inspection, improve internal control management level, effectively prevent various risks and promote the healthy and sustainable development of the company. 3. Description of other major events

□ applicable √ not applicable

Chairman (authorized by the board of directors): Liu Yadong Primeton Information Technologies Inc(688118) April 20, 2022

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