Kaiyuan Education Technology Group Co.Ltd(300338)
Self evaluation report on internal control in 2021
Kaiyuan Education Technology Group Co.Ltd(300338) all shareholders:
According to 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 internal control system and evaluation methods of Kaiyuan Education Technology Group Co.Ltd(300338) (hereinafter referred to as “the company” or “the company”), on the basis of daily and special supervision of internal control, We evaluated the effectiveness of the company’s internal control as of December 31, 2021 (benchmark date of internal control evaluation report).
1、 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 company’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 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.
2、 Internal control evaluation conclusion
According to the identification of major defects in the company’s internal control over financial reporting, the company has 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.
3、 Internal control 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 main units included in the scope of evaluation include the company and its subsidiaries included in the scope of consolidated statements. The total assets of the units included in the evaluation scope account for 90% of the total assets in the company’s consolidated financial statements, and the total operating revenue accounts for 90% of the total operating revenue in the company’s consolidated financial statements.
The main businesses and matters included in the evaluation scope include: corporate governance, corporate culture, organizational structure, major investment, capital activities, procurement business, R & D business, sales business, asset management, guarantee business, inventory management, investment management, human resource management, financial report management, related party transactions, information transmission, etc; The high-risk areas of focus mainly include: procurement business, sales business, R & D business, capital activities, asset management, external guarantee, related party transactions, raised funds, etc. 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, and there are no major omissions.
(II) basis of internal control evaluation and identification standard of internal control defects
The company organizes and carries out internal evaluation in accordance with the basic norms of enterprise internal control and its supporting guidelines and other relevant provisions, in combination with the provisions of relevant systems, processes and other documents of the company.
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 company’s scale, industry characteristics, risk preference, risk tolerance and other factors, the board of directors of the company distinguished the internal control of financial reports from the internal control of non-financial reports, studied and determined the specific identification standards of internal control defects applicable to the company, which were consistent with that of the previous year. The identification standards of internal control defects determined by the company are as follows:
1. Identification criteria for defects in internal control over 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
2% of operating income misstatement
The amount of misstatement of operating revenue is more than 5% of operating revenue, and the amount of misstatement is less than 2% of operating revenue and less than 5% of operating revenue
0.5% of total assets misstatement
The amount of misstatement of total assets 1.5% of total assets ≤ 1.5% of total assets ≤ 0.5% of total assets. 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
Fraud of directors, supervisors and senior managers of the company; The company corrects the published financial report and the material misstatement in the current financial report found by the certified public accountant but not identified by the company’s internal control; The supervision of the audit committee and the audit and supervision department on the company’s external financial report and internal control over financial report is invalid.
Failure to select and apply accounting policies in accordance with GAAP; Failure to establish anti fraud procedures and control measures; For the accounting treatment of unconventional or special transactions, no corresponding control mechanism has been established or implemented, and there are no corresponding compensatory control important defects
System; 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 refer to other control defects other than the above major defects and important defects. 2. Identification criteria for internal control defects in non-financial reports the quantitative criteria for the evaluation of internal control defects in non-financial reports determined by the company are as follows:
Defect type direct property loss amount potential negative impact
It has been officially disclosed to the public and has caused negative and major defects of more than 20 million yuan (including) to the disclosure of the company’s periodic reports; Serious loss of personnel in key positions; Negative news frequently exposed by the media
More than RMB 5 million (inclusive) was punished by the national government department, but did not disclose important defects in the company’s regular reports
And less than 20 million yuan; Be exposed by the media and have a negative impact
Punished by the government departments below the provincial level (including the provincial level), but failed to punish the general defects of the company less than 5 million yuan
Negative impact of periodic report disclosure
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
Violation of national laws and regulations or normative documents; Major decision-making procedures are unscientific; Lack of system may lead to system failure
Systematic failure of major defects, and major or important defects cannot be rectified; Internal control audit institutions failed to play an effective role
Supervision function; Other situations that have a significant negative impact on the company.
Violation of national laws and regulations or normative documents; Unscientific important decision-making procedures; The lack of system may lead to the failure of important defects of the system and the failure of rectification of important defects; The internal control audit institution fails to effectively perform its supervision function; Other situations that have a great negative impact on the company.
General defects refer to other control defects other than the above major defects and important defects.
(III) identification and rectification of internal control defects
1. Identification and rectification of internal control defects in financial reporting
According to the above identification standards of internal control defects in financial reporting, the company has no major defects and important defects in internal control of financial reporting during the reporting period.
2. Identification and rectification of internal control defects in non-financial reports
According to the above identification standards of internal control defects in non-financial reports, the company has no major defects and important defects in internal control of non-financial reports during the reporting period.
(IV) description of other major matters related to internal control
nothing
Kaiyuan Education Technology Group Co.Ltd(300338) April 27, 2022
