Lepu Medical: Accountability system for major errors in annual report information disclosure (October 2025)

Lepu (Beijing) Medical Devices Co., Ltd. Responsibility system for major errors in information disclosure in the annual report Lepu (Beijing) Medical Devices Co., Ltd. Responsibility system for major errors in information disclosure in the annual report

October 2025

Lepu (Beijing) Medical Devices Co., Ltd. Accountability System for Major Errors in Annual Report Information Disclosure

Article 1 In order to improve the standard operation level of the company, ensure the authenticity, accuracy, completeness and timeliness of information disclosure, increase the accountability of those responsible for annual report information disclosure, and improve the quality and transparency of annual report information disclosure, this system is formulated in accordance with the provisions of relevant laws, regulations and the company's articles of association, and in conjunction with the company's actual situation.

Article 2 The scope of application of this system: Company directors, senior managers, heads of subsidiaries, controlling shareholders and actual controllers, and other personnel related to annual report information disclosure.

Article 3 The accountability referred to in this system refers to the accountability and handling system for relevant personnel in the annual report information disclosure work who fail to perform their duties and obligations as required, resulting in major errors in the company's annual report information disclosure, resulting in the company's economic losses or major adverse social impacts.

Article 4 When implementing the accountability system, the following principles should be followed: seeking truth from facts, being objective and fair, and making mistakes must be held accountable; faults should be commensurate with responsibilities; and the principle of equality of responsibilities and rights.

Article 5 The secretary of the board of directors is responsible for reporting to the board of directors major errors in information disclosure in the annual report and proposing relevant resolution plans, which will be implemented after approval by the board of directors.

Article 6 The person responsible shall be held accountable under any of the following circumstances:

(1) Violating the provisions of national laws and regulations such as the Company Law, the Securities Law, the Accounting Standards for Business Enterprises, and the Accounting System for Business Enterprises, causing major errors or adverse effects in the annual report information disclosure;

(2) Violating the "Measures for the Administration of Information Disclosure by Listed Companies", "Shenzhen Stock Exchange GEM Stock Listing Rules", "Shenzhen Stock Exchange Self-Regulatory Guidelines for Listed Companies No. 2 - Standardized Operation of GEM Listed Companies" and relevant annual report information disclosure guidelines, standards, notices, etc. issued by the China Securities Regulatory Commission, Shenzhen Stock Exchange and Beijing Securities Regulatory Bureau, causing major errors in annual report information disclosure or causing adverse effects;

(3) Violating the "Articles of Association", "Information Disclosure Management System" and other internal control systems of the company, causing major errors or adverse effects in the annual report information disclosure;

(4) Failure to follow the procedures for information disclosure in the annual report and causing major errors or adverse effects in the information disclosure of the annual report;

(5) Failure to communicate and report in a timely manner during the annual report information disclosure work, resulting in major mistakes or adverse effects;

(6) Other personal reasons cause major errors in the disclosure of annual report information or cause adverse effects.

Article 7 Before dealing with the responsible person, the responsible person's statement shall be heard and his right to make a statement and defense shall be protected.

Lepu (Beijing) Medical Devices Co., Ltd. Accountability System for Major Errors in Annual Report Information Disclosure

Article 8 Forms of accountability:

(1) Order corrections and review;

(2) Notify criticism;

(3) Transferred from post, suspended, demoted, or dismissed;

(4) Fines and compensation for losses;

(5) Termination of labor contract.

Article 9 Before dealing with the responsible person, one should fully understand the situation, listen to the responsible person's statement, and clarify the responsibilities.

(1) Anyone under any of the following circumstances shall be given a lighter sentence, mitigated or exempted from treatment.

1. Effectively prevent adverse consequences from occurring;

2. Take the initiative to correct and recover all or most of the losses;

3. It is indeed caused by non-subjective factors such as accidents and force majeure;

4. The board of directors believes that there are other circumstances that should be mitigated, mitigated or exempted from handling.

(2) Any of the following circumstances shall be dealt with severely or aggravated.

1. The circumstances are egregious, the consequences are serious, the impact is large, and the cause of the accident is indeed caused by personal subjective factors;

2. Attack, retaliate, frame investigators, or interfere with or obstruct accountability investigations;

3. Failure to implement the decision made by the board of directors in accordance with the law;

4. The board of directors believes that there are other circumstances that should be dealt with more severely or aggravated.

Article 10 When dealing with the person responsible, the cause of the error, the consequences, the position of the party in the company, and the corresponding responsibilities must be fully considered, and be realistic and treat them differently.

Article 11 Matters not covered by this system or that are contrary to relevant laws and regulations shall be handled in accordance with relevant laws, regulations and rules.

Article 12 This system shall be interpreted and revised by the company's board of directors.

Article 13 This system shall come into effect on the date it is reviewed and approved by the Board of Directors.