Shanghai Geoharbour Construction Group Co.Ltd(605598) : Shanghai Geoharbour Construction Group Co.Ltd(605598) explanation on undisclosed internal control evaluation report in 2021

Company code: Shanghai Geoharbour Construction Group Co.Ltd(605598) company abbreviation: Shanghai Geoharbour Construction Group Co.Ltd(605598)

Shanghai Geoharbour Construction Group Co.Ltd(605598) infrastructure (Group) Co., Ltd

Notes on undisclosed internal control evaluation report in 2021

I Construction of internal control system

During the reporting period, the company improved various systems of internal control in strict accordance with relevant laws and regulations, as well as the relevant provisions of the guidelines for the governance of listed companies, the rules for the listing of shares on the Shanghai Stock Exchange and the articles of association, followed the basic principles of internal control, combined with the characteristics of the industry and the actual operation, strengthened the supervision and inspection of internal control, and improved the management level of internal control, Prevent and resolve various risks in business operation and management.

The company has formulated the rules of procedure of the general meeting of shareholders, the rules of procedure of the board of directors, the rules of procedure of the board of supervisors, the working system of independent directors, the management system of external guarantee, the management measures of related party transactions, the management system on regulating capital exchanges with related parties, the management system of raised funds and other internal governance systems of the company. Through institutionalized provisions, the general meeting of shareholders, the board of directors The scope of rights and responsibilities and work norms of the board of supervisors and senior managers. During the reporting period, the company’s internal control system can operate effectively to ensure the normal operation and steady development of the company. II Description of non disclosure of annual internal control evaluation report 1. Is there any special situation of non mandatory disclosure

√ yes □ no

Special circumstances of non mandatory disclosure are: New Listing 2. Description of specific circumstances

The company’s shares were listed and traded on the Shanghai Stock Exchange on September 17, 2021. According to the relevant provisions of the notice on the implementation of enterprise internal control standard system by main board listed companies in 2012 by classification and batches issued by the China Securities Regulatory Commission, “newly listed main board listed companies shall start to build the internal control system in the year of listing, and disclose the internal control self-evaluation report and audit report at the same time as the annual report of the next year of listing”, The company is a newly listed company on the main board, so the internal control evaluation report of 2021 is not disclosed.

Authorized by the board of directors of Xu Shilong Group Co., Ltd. (August 30, 2024)

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