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Regulatory Compliance in Business Practices

COOEC attaches importance to corporate compliance management, by incorporating it into the Company's "14th Five-Year Plan". It has established a sound compliance management system with COOEC characteristics while adaptive to industrial characteristics and the Company’s operation scale and business scope. The Company revised the Compliance Management System and the Sanctions and Export Control Compliance Management Measures to normalize compliance management when striving to achieve "compliance of all employees on all matters".

Improving Organizational Construction of Compliance Management. Clarify the compliance management responsibilities of the Party Committee, the Board of Directors, and the Management Team. Under the Management Team, establish the Legal and Compliance Committee for Legal Construction and Internal Control Compliance and Risk Management to coordinate and promote compliance management work. Appoint the Chief Compliance Officer, who also serves as the Company's Chief Financial Officer and General Counsel. And ??“three lines of defense” for compliance management were constructed, namely, a special compliance management division, leading compliance management divisions, and compliance supervision and evaluation division. The Chief Compliance Officer leads the leading compliance management division to carry out the Company's compliance management work. Special compliance management divisions are responsible for daily compliance management in their respective fields, with business backbone personnel serving as compliance managers. Subordinate units shall establish Business Contract Divisions or Legal Contract Divisions and set up compliance management positions or clarify relevant functions to carry out compliance management in such units. The Company's Discipline Inspection Commission, Audit Department and the Leading Group Office for Party Committee Inspection Work are the third line of defense for compliance risk prevention and control, which supervises the implementation of compliance requirements, investigates violations and holds individuals accountable.

Clarifying Compliance Management Content. The company thoroughly reviewed the laws and regulations relevant to its business ?operations, collecting and identifying 1,596 domestic laws and regulations related to corporate governance, engineering, bidding, ?labor, and anti-corruption, as well as 1,517 foreign laws and regulations. Compliance obligations?identified in Laws and regulations ?were enacted in job responsibilities. The compliance management approval process was clarified with the Compliance Management Checklist formulated and a total of 335 coping measures developed to ensure the implementation of compliance obligations.

Consolidating Compliance Culture Construction. In order to further internalize the compliance concept of ?“keeping in mind and ?putting into practice” and make it the guiding principle for every employee, COOEC strengthened compliance knowledge dissemination through training in 2023. Specialized compliance training sessions were organized, covering areas such as data compliance, ?sanctions and export controls, blacklist screening, anti-corruption, and corporate compliance officers. A total of 367 individuals ?participated in these training sessions. The Company is embedding compliance concepts into its corporate culture, strengthening ?the promotion of compliance concepts, and continuously enhancing employees' compliance awareness to cultivate a corporate ?culture ?of compliance. Through ?public ?legal ?education ?activities such ?as ?collecting ?employee signatures, ?distributing ?legal ?education materials and conducting legal training sessions, the Company has promoted the concept of legal compliance, popularized knowledge of legal compliance among employees, and enhanced the overall compliance awareness throughout the Company.