昱能科技(688348):2024年环境、社会及治理（ESG）报告（英文版）
原标题:昱能科技:2024年环境、社会及治理（ESG）报告（英文版） About this Report 01 About APsystems Strengthen Governance of Quality Management01 03 05 Company Overview 09 Corporate Governance 27 R&D Innovation 51Chairman’s Speech 03 Development Milestones 11 Commercial Behaviors 31 Product Quality Management 58ESG Performance Highlights 05 APsystems Global Footprint 13 Risk Control Management 34 Customer Relationship Management 64Awards Received in 2024 15 Strengthening Party Building 36 Data Security and Customer Privacy Protection 68 Supplier Management 71 Cultivating Human Resources and Practicing Responsibility 06 Protecting the Environment and ESG Management Promoting Green Energy 02 04 Employee Employment and Rights 77 ESG Governance 19 39 Employee Training and Development 82 Green Business ESG Data Tables and Notes 89 About this Report Reporting Scope Reporting Principles The scope of this report covers Yuneng Technology Co., Ltd. and its subsidiaries (referred to as "APsystems" or "the Materiality Quantification Company"). Unless otherwise stated, the scope of this report is consistent with the scope of the consolidated financial The Company identifies business-related topics of This report discloses annual key quantitative metrics and statements of APsystems (stock code: 688348) for the same period. materiality to various stakeholders as the focus of historical data to the extent possible. Please refer to the reporting. While reporting material topics in this report, "ESG Data Tables and Notes" section for details. Reporting Period it also focuses on the characteristics of the Company's industry and operating business. The materiality Comparability The reporting period ranges from January 1, 2024 to December 31, 2024. Unless otherwise specified, all data in this report assessment process and results are detailed in the "Topic are from this period. This report is consistent with the statistics and disclosure Materiality Analysis" section of this report. methods of the same quantitative disclosure item in different reporting periods; if the data collection, Reporting Basis Accuracy measurement and calculation methods are changed, the This report ensures that the information is as accurate as This report is prepared in accordance with the Guidelines No. 14 of Shanghai Stock Exchange for Self-Regulation of Listed relevant data is retrospectively adjusted, and the reasons possible. The calculation method, calculation basis and Companies—Sustainability Report (Trial) (April 2024), Guidelines No. 1 of Shanghai Stock Exchange for Self-Regulation of for the adjustment are explained in the annotations to assumptions have been explained in the measurement Listed Companies—Standardized Operations (December 2023 Revision), Rules for the Listing of Stocks on the Sci-Tech the report, so that stakeholders can conduct meaningful of quantitative information to ensure that the calculation Innovation Board of the Shanghai Stock Exchange (Revised in April 2025) and Self-Regulatory Supervision Guidelines for Sci- analysis and evaluate the development trend of the error range will not be misleading to the user of the Tech Innovation Board Listed Companies of the Shanghai Stock Exchange No. 2 - Voluntary Information Disclosure (Revised Company's ESG data level. information. For quantitative information and note in March 2025) information, please refer to the "ESG Data Tables and Completeness Data Sources Notes" section of this report. The Board of Directors The scope of disclosure in this report is consistent guarantees the content of the report, and there are The data and cases in the report are all from the official records of the Company's actual operations. with the scope of the Company's consolidated financial no false records, misleading statements or material statements. The financial data are all denominated in RMB. In case of any discrepancy between the financial data and the omissions. Company's annual financial report, the annual financial report shall prevail. Timeliness Balance This report is an annual report covering the period from The content of this report reflects objective facts, and Report Publication January 1, 2024 to December 31, 2024. The Company discloses both positive and negative information about tries its best to release the report as soon as possible after This report is released in electronic form. The release platforms include the information disclosure platforms the Company impartially. No negative events that should the end of the reporting year, providing timely information designated by the stock exchanges. It can be viewed and downloaded on the Company's website (www. have been disclosed but were not disclosed were found reference for the decision-making of stakeholders. during the reporting period. apsystems.cn) and the website of the Shanghai Stock Exchange (http://www.sse.com.cn). Verifiability Clarity Contact us The cases and data in this report come from the original This report is published in English. This report contains records or financial reports of the Company’s actual If you have any suggestions for the report, you can contact us in the following ways: tables, model diagrams, a list of professional terms and operation. The Company uses the HiESG Performance Strengthening corporate governance, building solid foundation for stable development ’regular evaluations. With the joint efforts of our partners, APsystems products are available in 156 countries and regions around the world, covering multiple different fields such as residential, commercial and industrial, public buildings, and We continuously optimized the corporate governance structure, earnestly fulfilled the information disclosure obligations, BIPV, contributing to the global green energy transition. strengthened communication and interaction with investors, comprehensively strengthened internal control and internal audit, and deeply integrated the concept of legal and compliant operation into the corporate development strategy. We Promoting green practices, protecting the environment for a zero-carbon futurehave adjusted the "Board of Directors' Strategy Committee", a special committee under the original Board of Directors, to We adhere to the path of sustainable development featuring environmental protection and low carbon, and continuously the "Board of Directors' Strategy and Sustainable Development (ESG) Committee", with newly added responsibilities such strengthen our environmental management capabilities. In 2024, the Company, adhered to the concept of "fostering as ESG management. The aim is to integrate the ESG concept into the Company's strategic planning and decision-making environmental awareness and advocating a green lifestyle", integrated green operations into daily office work, and adhered process, and promote the Company's development towards a greener, low-carbon, and sustainable direction. to the common development of the Company and the environment. To reduce the environmental impact of the Company's Leading technological innovation, maintaining the original aspiration and strengthening R&D operations, we adopted a production subcontracting model, and all major subcontracting factories have passed the ISO 14001 Environmental Management System Certification. In addition, we continue to promote the application of advanced We have been deeply engaged in the photovoltaic industry for nearly 15 years, committed to the research, development and green technologies, vigorously develop green businesses, and contribute to the sustainable and high-quality development industrialization of MLPE module-level power electronics technology. We have deeply engraved technological innovation in of the world. the development context of the enterprise and regard it as the primary productive force of the enterprise. We continuously increase investment in research and development and actively carry out industry-university-research cooperation. With Practicing social responsibility, engaging deeply in public welfare to promote harmonygenerations of "pioneering" technologies and products, we empower the high-quality development of the industry. In APsystems actively fulfill our corporate social responsibilities and attach great importance to human capital management 2024, the Company completed the latest enterprise strategic layout plan, identified three photovoltaic and energy storage and social welfare. We adhere to the people-oriented concept, continuously improve the employee rights and welfare industry ecosystems of DIY micro-photovoltaic and energy storage, residential photovoltaic and energy storage, and C&I system, focus on employee training and career development, build a talent development platform for the entire career photovoltaic and energy storage with microinverters as the core, became a full-scenario solution provider for distributed cycle, and achieve the common growth of the value of employees and the enterprise. In addition, we actively engage in photovoltaics + energy storage, and was awarded the title of a national specialized and sophisticated "little giant" public welfare undertakings, closely cooperate with many domestic and foreign public welfare organizations, and support enterprise. We are meeting the green photovoltaic and energy storage needs in different distributed scenarios with a more and promote the implementation of specific projects through donations, volunteer activities, etc., contributing to the healthy comprehensive layout of technologies and products. development of public welfare undertakings. Strengthening industry cooperation, promoting development through efficient collaborationIn the future, APsystems will further solidify the construction of its ESG system and, with a brand - new posture, embark We take "providing customers with the best products and services" as our guiding principles, and closely cooperate with on a new chapter of high - quality development. While developing itself, APsystems, with the vision of becoming "the most stakeholders such as customers and suppliers to promote the development of the industry. In 2024, the Company actively efficient and safe converter of clean energy", will also actively collaborate with various sectors of society, continuously carried out customer service - related training, conducted customer satisfaction surveys, adopted targeted improvement promote the global green energy transformation, and jointly embrace a bright future.measures based on the survey results, improved service quality and satisfaction, and established long - term and good cooperative relationships with many customers. In addition, the Company continuously strengthened the sustainable Corporate Culture Company Overview To provide customers To Be the Safest and Drive a zero-carbon future Yuneng Technology Co., Ltd. was founded in 2010 and registered in the Nanhu High-tech Zone of Jiaxing City. It is a listed company on with state of the art Vision the most Efficient Clean Purpose Mission and make smart energy the Science and Technology Innovation Board (stock code: 688348). The Company focuses on the ?elds of photovoltaic power generation products and the best Energy Converter accessible to everyone and energy storage, mainly engaged in the research and development and industrialization of module-level power electronics technology service quality in distributed photovoltaic power generation systems, as well as residential and commercial and industrial energy storage technologies. It provides full-scenario application solutions for distributed photovoltaics + energy storage with microinverters as the core. The Company's products and businesses include: microinverters and energy communication unit products, residential and commercial and industrial ener- gy storage products, RSD products, AI smart energy business, distributed photovoltaic power station business, etc. As of the end of 2024, Product Family uangzhi, Jingning Renegade, Leader Reserve Yulin, Taizhou Renegade, Zhejiang Renegade Leader, Jiangsu Yunda, Jiangsu DeReserve, U.S. Renegade, European Renegade, Australian Renegade, and Singapore Renegade, among others.DIY Balcony Photovoltaics Residential Distributed Commercial and Industrial Distributed Energy Storage Systems relying on international advanced R & D concepts, focusing on module-level power electronic equipment and residential and industrial and commercial energy storage systems. The team has a solid professional knowledge background and rich industry practice experience. Microinverters Intelligent Operation and Maintenance Systems Rapid shutdown device Launched the new generation of hy- brid microinverters for photovoltaic + 2016 2018 energy storage, EZHI series Established a subsidiary in Lyon, Designated as a “Provincial En-Established a subsidiary in Brazil, fur- 2022 2012 France terprise Research Institute” ther strengthening the expansion of its Cumulative global sales of Established a subsidiary Latin American business “ Designated as a “Zhejiang Prov- Honored as 2016-2017 Honest MLPE module-level power in Seattle, USA ” ince Enterprise Technology Cen- Private Enterprise in Jiaxing CityHonored with the “Top PV Brand” electronic products exceed- ’ ter” Completed the world s award from EUPD Research in multiple Participated in formulating the ed 2 GW largest 6MW microinvert- Latin American countries and the na- Again awarded “National High- national energy industry stan-2010 Honored with the “Top PV er project at that time tional-level "Specialized, Sophisticated, Tech Enterprise” and “50 dard Technical specification of 2014 Brand” award from EUPD Distinctive, and Innovative (SSDI) Little Established the head- Growth-Oriented and Charac- photovoltaic grid-connected mi- Research, France and Neth- Established a subsidiary in Giant Enterprise" designation. quarters in Jiaxing, teristic Enterprises in Zhejiang cro-inverter erlands Rotterdam, Netherlands focusing on research Province’s Electronic Information Completed several hundred MWh-level and operations Industry” Continuously recognized as The world’s first multi-mod- commercial and industrial energy stor-2020 a “National High-Tech Enter- ule single-phase microinvert- age projects, with annual installation Cumulative global ship- prise” er YC500 received multiple exceeding 1 GWh ments of microinverters honors such as “Zhejiang Successfully listed on the exceeded 1 GW Cumulative global sales of MLPE mod- Manufacturing Excellence” STAR Market of A-shares, ule-level power electronic products Received the honor of “Top and “First Set of Equipment entering a new development exceeded 6 GW Photovoltaic Brand” from Manufacturing Products in platform EUPD Research, France Zhejiang Province” “ Recognized as one of the 50 Growth-Oriented and Char- acteristic Enterprises in Zhe- ’ jiang Provinces Electronic ” Information Industry 2019 2017 Established the APsmart 2011 brand and launched the Established a subsidiary 2015 rapid shutdown device Established sub- in Mexico 2021 2013 RSD-S with ASIC special- 2023 sidiaries in Sydney, Awarded “Zhejiang Introduced the world’s Released the world’s first fourth-gen-ized chips developed inde- Australia and Shang- Pioneered multi-module Province Patent Released the EZ1 series microinverter with first third generation eration 20A high-current multi-module pendently hai, China microinverter architec- Demonstration Enter- Wi-Fi + Bluetooth dual communication multi-unit micro-inverter microinverter DS3 and QT2 series ture: Released the world’s prise” and “Zhejiang Continuously recognized modes Entered the Austra- products YC600 and products first dual single-phase Export Brand” as a “National High-Tech lian market as the QS1, compliant with in- Honored with the “Top PV Brand” award microinverter YC500 Launched the world’s ?rst dual mrapid Enterprise” pioneering microin- Again recognized telligent grid scheduling from EUPD Research, France, Latin Ameri- shutdown device RSD-D with input verter brand “ Introduced the world’s as one of the 50 ca, Mexico, Brazil The third-generation dual “ Awarded Key Enterprise current up to 20A ?rst quad three-phase mi- Growth-Oriented and single-phase microinverter Launched the ’ in Zhejiang Provinces Again honored with the “Top PV Brand” croinverter YC1000-3 Characteristic En- YC600 received the honor first-generation sin- Information Economy award from EUPD Research, France terprises in Zhejiang of “Zhejiang Manufacturing gle-phase microin- “ Recognized as a National - Innovative Leading En- ’ Provinces Electronic Excellence” verter ” ” Established the APstorage energy High-Tech Enterprise and terprise ” Information Industry “ storage brand and laid out in the resi- Jiaxing City-Level High- Became the first draft- ” Included in the fifth dential energy storage ?eld Tech R&D Center ing entity for the PV batch of the enter- Awarded “Jiaxing City grid-connected micro- prise list for the Pho- Patent Demonstration En- inverter under the “Zhe- tovoltaic Manufactur- Global Global Global ESG Governance The Company prioritizes effective communication with stakeholders by identifying them, outlining their key concerns and ’ To improve the Companys ESG management, APsystems, in accordance with the relevant laws, regulations, and normative specifying communication channels to ensure accurate and timely information dissemination. Moreover, the Company Company Law of the People’s Republic of China Governance Code for Listed Companies, documents such as the , the the adopts a responsive approach, addressing stakeholders’ concerns promptly and effectively to foster mutual trust and Guidelines No. 1 of the Shanghai Stock Exchange for Self-regulation of Listed Companies — Standard Operation Guide- , and the achieve mutually beneficial outcomes. In 2024, the Company identified its key stakeholders as government and regulatory lines No. 14 of Shanghai Stock Exchange for Self-Regulation of Listed Companies — Sustainability Report (Trial) , as well as agencies, shareholders/investors, customers, employees, suppliers, and the community. Articles of Association relevant provisions in the , has adjusted the original Strategic Committee of the Board of Directors into Work Rules of the Stra- the Strategic and Sustainable Development (ESG) Committee of the Board of Directors. The original tegic Committee of the Board of Directors Work Rules of the Strategic and Sustainable Development has been revised to the (ESG) Committee of the Board of Directors . In addition to the existing functions and powers, ESG management and other ’ responsibilities have been incorporated. This change aims to integrate ESG concepts into the Companys strategic planning APsystems Key Stakeholders and Communication Methods and decision-making processes, driving the Company towards a greener, low-carbon, and more sustainable development. Key Stakeholders Key Topics Communication Methods Information disclosure Government and Green Business, Ecosystem and Biodiversity Protection Materiality Analysis Process In 2024, APsystems, based on its operating conditions and industry characteristics, identified, selected, and analyzed ESG Shareholders’ Meeting topics according to both the impact materiality and financial materiality dimensions, following the requirements of the Corporate Governance, Commercial Behaviors, Risk Control Performance BriefingsGuidelines No. 14 of Shanghai Stock Exchange for Self-Regulation of Listed Companies — Sustainability Report (Trial) (herein- Management, R&D Innovation Regular and temporary reports Shareholders/ after referred to as the “Guidelines”). Investor hotline Investors Analysis Process of Dual Materiality of 2024 Topics for APsystems Medium and long- Public Welfare Community/Public Reputation opportunities Increase in revenueThe Company continuously improves the management process for ESG topics, including the impacts, risks, and term opportunities, and assesses the materiality of these topics. Through daily communication, information collection, and other Legal risk Shareholders/Investors, Medium and long- Commercial Behaviors Increase in operating costs means, the Company conducts due diligence with stakeholders to identify, analyze, and understand how each ESG issue suppliers term Operational risk is expected to significantly impact the Company’s business model, operations, development strategy, financial status, Overseas operation risk Increase in operating costs Medium and long- Corporate Governance performance, cash flow, financing methods, and costs in the short term (0-1 year), medium term (1-5 years), and long term Shareholder rights protection term Decrease in revenue opportunities Increase in operating costs Risk Control Medium and long- society, and environment, and discloses the targeted management measures and practices the Company has adopted. Operational risk Management term Decrease in revenue APsystems Impact, Risk, and Opportunity Management of ESG Topics in 2024Topics Affected Stakeholders Risk/Opportunity Type Time Range Financial Impact
personnel turnover risk Core Increase in operating costs Standardizing Operations to Strengthen Governance Corporate Governance Commercial Behaviors Risk Control Management Strengthening Party Building The Company has established a governance framework comprising Shareholders’ Meeting, the Board of Directors, the Supervisory Corporate Governance Board and the management team. Each entity operates in concert, fulfilling distinct roles while synergistically reinforcing one another. This collaboration has fostered a governance structure characterized by clarity of purpose, evidence-based decision- APsystems places great emphasis on corporate governance and has established a sound governance system. The making, robust oversight and seamless execution, thereby propelling the Company’s sustained progress and development. Company Law of the People’s Republic of China, Company strictly adhered to the relevant laws and regulations such as the APsystems Corporate Governance Framework the Securities Law of the People’s Republic of China Guidelines for Articles of Association of Listed Companies , the , and the Rules Governing the Listing of Stocks on the STAR Market of the Shanghai Stock Exchange. Concurrently, it complied with anagement Department Human Resources Department Finance Department Brand Marketing Department Risk Management Department pply Chain Management Department Operations Department R&D Center Marketing Center Governance structure: Established a "three sessions and one layer" governance framework composed of the " shareholders’ meeting, board of directors, supervisors board, and general manager".Strategy Impacts, Risks, and Opportunities: Impact: The corporate governance framework has been improved to enhance the normativity and transparency of governance and protect the rights and interests of investors. Risk: ’ Introduction to the Duties of Shareholders Meeting, the Board of Directors, and the Supervisory Board and Their Overseas Operation Risk: Several key overseas markets for the Company have implemented policies restricting the import of Meeting Frequency photovoltaic products and increasing tariffs, creating significant trade barriers and intensifying overseas operational risks. Aspect Duties Introduction Meeting Frequency Opportunity: Shareholder Rights Protection Opportunity: A reasonable dividend policy has been developed, and the investor relations management has been conducted, so as to attract investors. As the highest governing body of the Company, the Shareholders’ Meeting Held 1 annual Shareholders’ Meeting is responsible for formulating major strategies, reviewing key policies, Response Strategy: A well-defined and balanced corporate governance structure with effective internal control systems has and 3 extraordinary Shareholders’ and deciding core management issues. It ensures shareholders’ rights to been established. The Company strictly complies with regulations to ensure legal and standardized operations. Meetings, reviewing a total of 27 Shareholders’ information, participation and voting, particularly safeguarding the voting resolutions. Meeting rights of minority shareholders. Impact, Risk, and Opportunities Management Held 10 Board of Directors Meetings, The board of directors has established four special committees: audit, reviewing a total of 59 resolutions. nomination, remuneration and appraisal, and strategy.. All members of these Held 4 Audit Committee Meetings, By establishing and improving internal control systems, the Company continuously promotes standardized and procedural specialized committees are directors. The Board of Directors and each reviewing a total of 13 resolutions. management, enhancing corporate governance. It fulfills information disclosure obligations by law, strengthens investor specialized committee have corresponding rules or work procedures to Board of Held 3 Compensation & Assessment relations management, fully protects the legitimate rights and interests of investors, and promotes the sustainable Directors perform their functions according to company regulations, providing strong Committee Meetings, reviewing a development of the Company. ’ support for the Companys scientific decision-making. total of 4 resolutions. Indicators and Targets The Supervisory Board comprises 3 supervisors, including 1 employee Rules of Procedure for the representative supervisor. In accordance with the Supervisory Board , each supervisor upholds a strong sense of accountability Held 9 meetings of the Supervisory Targets: Improve the corporate governance framework, strengthen the investor rights protection mechanism, enhance the to shareholders and carries out their responsibilities diligently in strict Board, reviewing a total of 23 transparency of information disclosure, ensure the clear and efficient operation of the "three sessions and one layer" with well- Articles of adherence to legal statutes, regulatory frameworks, and the Supervisory resolutions. Board of Directors Composition Diversity Investor Relations Management The Company places high importance on and actively promotes the board composition diversity. It has revised and issued The Company values investor relations management. In accordance with the Guidelines for Investor Relations Management the Independent Director Work System, improving the structure of the Board of Directors and strengthening the constraints of Listed Companies and other relevant laws and regulations, and based on the Company’s actual situation, APsystems and supervision mechanisms for non-independent directors and the management team. This ensures the protection of has formulated the Investor Relations Management System, which further standardizes investor relations work, strengthens minority shareholders and stakeholders’ interests and promotes standardized operations. communication between the Company and investors, and aims to maximize corporate value and shareholder returns. The Board of Directors consists of 7 directors, of which 3 are independent directors. All directors possess extensive Investor Communication academic backgrounds and rich practical experience across various domains including economics, accounting and ’ business administration. They serve as a solid foundation for the Companys stable development. Notably, 2 directors hold The Company continuously strengthens connections and interactions with investors. Through diverse channels including ’ doctoral degrees while 2 others hold masters degrees, providing robust intellectual support and strategic guidance to the investor hotlines, emails, the “Shanghai Stock Exchange e-Interaction” platform and investor forums, the Company ’ Companys decision-making processes. enhances communication and engagement with investors. It earnestly listens to investor feedback and diligently safeguards their legitimate rights and interests. During the reporting period, the Company received and responded to 1,500 investor calls, and provided answers to investor queries 35 times through the Shanghai Stock Exchange e-Interaction Information Disclosure platform, achieving a 100% response rate to investor inquiries. The Company rigorously upholds its obligations for information disclosure, as mandated by the Administrative Measures In 2024, the Company hosted a total of 3 Performance Briefings, utilizing interactive teleconferencing to present for Information Disclosure of Listed Companies, and other relevant laws and regulations. In alignment with these legal the Company’s operational performance and engage in detailed discussions with investors. This event fostered the frameworks, APsystems has formulated the Information Disclosure Management System, which delineates guidelines for establishment of enduring collaborative relationships. Additionally, the Company, in collaboration with the media, organized periodic reporting, temporary reporting, responsibilities in information disclosure management, disclosure procedures, and a “Shareholders’ Day of Listed Companies” to give back to shareholders through multiple channels, contributing to the measures for confidentiality. This ensures the authenticity, accuracy, comprehensiveness, and timeliness of information enhancement of the Company’s brand and influence. disclosure, thereby fully protecting the legitimate rights and interests of investors. Shareholder Returns In 2024, the Company disclosed 6 regular reports and 69 temporary announcements. The Company received the highest rating of "A" in the information disclosure evaluation for 2023 - 2024. The Company adheres to a business philosophy of integrity and mutual benefit, placing significant emphasis on delivering returns to its shareholders. It has formulated the Three-Year Dividend Plan for Shareholders after Initial Public Offering and Listing on the STAR Market, which enhances transparency and operational feasibility in profit distribution decision-making. Furthermore, the Company has clearly defined the procedures for profit distribution decision-making in the Articles of The Company received the highest rating of "A" in the information disclosure evaluation for 2023 - 2024. Association and established dividend schemes in accordance with the dividend policy. The Company emphasizes providing reasonable investment returns to investors, safeguarding the legitimate rights and interests of its shareholders. APsystems Cash Dividend Payout in 2024 APsystems Information Disclosure Methods in 2024 Key Performance Unit 2024To implement anti-commercial bribery and anti-corruption work, the Company has operationalized its anti-corruption Commercial Behaviors efforts, utilizing various forms to promote anti-corruption knowledge and enhance employees’ awareness of anti- corruption, thereby preventing corruption from occurring at the source. Through multi-layered and diversified internal Anti-Monopoly Law of the People’s Republic of Chi- training activities, the Company thoroughly educated all employees, suppliers, and customers on relevant laws, regulations, APsystems strictly adheres to relevant laws and regulations such as the na Anti-Unfair Competition Law of the People’s Republic of China Anti-Money Laundering Law of the People’s Re- and the Company’s systems and requirements regarding anti-commercial bribery and anti-corruption. In addition, the , the , and the public of China Company achieved a compliance rate of 100% for anti-commercial bribery and integrity agreements with suppliers. to ensure that the Company operates in compliance with both domestic and international regulations. The Company places high importance on ethical operations, actively fostering a culture of integrity, and adopts a zero-tolerance Furthermore, the Company plans to outline and establish a preliminary anti-commercial bribery and anti-corruption system policy toward corrupt practices. in 2025. By 2026, APsystems will build and improve a compliance management system for anti-commercial bribery and anti-corruption that is suited to the Company’s business operations, clarifying the responsibilities of various departments APsystems Commercial Behavior Management System and positions, standardizing business processes, and eliminating commercial bribery and corruption behaviors from a system perspective. A dedicated supervision system will also be set up, with responsible departments conducting regular Governance and random checks of business activities to ensure the timely identification and correction of potential commercial bribery and corruption risks. Governance Structure: The Company has established a collaborative governance model between the management and governance teams. The management team integrates the business philosophy of legality and compliance into the Company’s At the same time, the Company provides clear reporting channels, ensuring that suppliers, customers, and others who find development strategy and prioritizes creating a favorable business ecosystem as a core development guideline. The governance corruption within the Company can report it directly to internal audit departments, either anonymously or with real names. team formulates anti-corruption measures and actively promotes anti-commercial bribery policies within the Company. The Company ensures strict confidentiality of the whistleblower’s identity and effectively guarantees the operation of the reporting mechanism. In 2024, the Company did not experience any violations of commercial bribery or anti-corruption laws and regulations. Strategy Risk Control Management The Company regards the principle of fair competition as a core tenet of its business activities, deeply integrating it into all aspects of its strategies and daily operations. It has established and improved an anti-unfair competition management APsystems places great emphasis on risk management and internal controls. It strictly follows relevant laws and system, clearly prohibiting participation in competition through unfair means such as false advertising, monopolistic regulations, such as the Audit Law of the People’s Republic of China and the Basic Norms for Internal Control of Enter- practices, and infringement of trade secrets, in order to create a fair and equal business environment. prises. The Company adheres to a risk prevention-oriented approach and aims to improve management effectiveness, enhancing the enforceability of internal control systems and the effectiveness of internal control management. Over time, In addition, the Company has developed and issued a series of management systems, including the Supplier Evaluation Pro- the Company has established a relatively complete internal control system. Through the operation, analysis, and evaluation cedure, making anti-unfair competition performance an important indicator for evaluating and assessing suppliers. During of this system, risks in business management are effectively mitigated, contributing to the achievement of internal control the process of supplier screening, collaboration, and regular evaluation, the Company comprehensively considered whether goals. suppliers engaged in unfair competition practices such as false advertising, commercial defamation, or infringement of trade secrets, managing risks from the source and promoting the healthy development of the supply chain ecosystem. Risk Management Risk and Opportunity Response Control Procedures To strengthen risk management, the Company has established the , which outline countermeasures for risks and opportunities. This includes operational requirements for risk responses, risk （未完）  |