ADAMALtd.Information Disclosure Management

Policy

(October 2025)

1Chapter I General Provisions

Article 1 The Information Disclosure Management Policy (hereinafter referred to as

“this Management Policy”) are enacted in accordance with the Company Law the

Securities Law the Administrative Measures for the Disclosure of Information of

Listed Companies Stock Listing Rules of Shenzhen Stock Exchange the

Self-regulatory Supervision Guidelines for Listed Companies of Shenzhen Stock

Exchange No.5 – Management of Information Disclosure and other laws and

administrative regulations as well as the provisions of the Articles of Associations of

the Company for the purpose of regulating the information disclosure made by

ADAMA Ltd. (hereinafter referred to as “the Company”) and other information

disclosure obligors strengthening the management of information disclosure matters

and protecting the legitimate rights and interests of investors.Article 2 The "information disclosure obligors" relevant to this Management Policy

refers to the Company its directors of the board senior executives shareholders

ultimate controllers acquirers as well as natural persons entities and their related

persons involved in major asset restructuring refinancing and material transactions

bankruptcy administrators and their members as well as other subjects who have

information disclosure obligations as stipulated by laws administrative regulations

and China Securities Regulatory Committee (hereinafter abbreviated as “CSRC”).Article 3 An information disclosure obligor shall comply with the provisions of this

Management Policy when performing the information disclosure obligation. Where

the CSRC provides otherwise on the information disclosure of initial public offerings

and listing of stocks and the issuance of securities by listed companies such

provisions shall prevail.Article 4 An information disclosure obligor shall perform its information disclosure

obligation in a timely manner in accordance with the law. The information disclosed

shall be authentic accurate complete concise clear and easy to understand and shall

not contain any false record misleading statement or material omission.Any information disclosed by an information disclosure obligor shall be disclosed to

all investors at the same time and shall not be disclosed to any entity or individual in

advance. However if it is otherwise provided for in any law or administrative

regulation such provisions shall prevail.

2Prior to the disclosure of insider information in accordance with the law any insider

who has access to any insider information or any person who has illegally obtained

any insider information may not publicize or divulge such information or conduct any

insider trading by taking advantage of such information. No entity or individual may

illegally require an information disclosure obligor to provide any undisclosed

information which shall be disclosed in accordance with the law.Article 5 The directors of the board and senior executives of the Company shall

perform their duties faithfully and diligently and ensure that the information will be

disclosed truthfully accurately completely fairly and in time.Article 6 In addition to the information that shall be disclosed in accordance with the

law an information disclosure obligor may voluntarily disclose information related to

the value judgment and investment decision made by the investors which shall not

conflict with the information disclosed in accordance with the law and may not

mislead the investors.The information voluntarily disclosed by the information disclosure obligor shall be

authentic accurate and complete. The voluntary information disclosure shall be

subject to the principle of fairness and the continuity and consistency of the

information disclosure shall be kept. No selective disclosure shall be made.An information disclosure obligor shall not improperly affect the trading prices of the

Company's securities as well as the derivatives thereof by taking advantage of the

information voluntarily disclosed or engage in any illegal or non-compliant actions

such as market manipulation by taking advantage of the voluntary information

disclosure.Article 7 If the Company and its actual controller shareholders related parties board

directors senior executives acquirers asset transaction counterparties bankruptcy

restructuring investors and other relevant parties make any public commitments such

commitments shall be timely disclosed and fully implemented.Article 8 The information disclosure documents include periodic and interim reports

IPO prospectuses fundraising prospectuses listing announcements acquisition

reports etc.Article 9 The information disclosed in accordance with the law shall be published on

the website of the stock exchange and the media that meets the conditions prescribed

3by the CSRC and shall also be simultaneously made available for public reference at

both the Company’s domicile and the stock exchange.The full text of the information disclosure documents shall be presented on the

websites of the stock exchange and of the newspaper and magazines that meet the

conditions prescribed by CSRC in accordance with the law. The abstract of periodic

reports and acquisition reports etc. shall also be disclosed on the website of the stock

exchange and on the newspaper and magazines that meet the conditions prescribed by

CSRC.No information disclosure obligor may replace the due reporting or announcement

obligations with any forms such as press conference or Q&A with journalists or

replace the due ad hoc reporting obligations with the form of periodic reports.Article 10 The information disclosure obligor shall submit the manuscript of the

information disclosure announcements and relevant documents for future reference to

the Provincial Bureau of CSRC in Hubei Province.Article 11 The information disclosure documents shall be in Chinese. In case of a

version in a foreign language at the same time the information disclosure obligor

shall ensure that the content of the two texts is consistent. In case of any discrepancy

between the two versions the Chinese version shall prevail.Chapter II Disclosure of Periodic Reports

Article 12 The periodic reports that the Company shall disclose include annual

semi-annual reports and based on the requirement of the Shenzhen Stock Exchange

quarterly reports. Any information that may significantly affect investors in making

value judgments and investment decisions shall be disclosed.The financial statements in the annual report shall be audited by an accounting firm

that complies with the provisions of the Securities Law.Article 13 The annual report shall be completed and disclosed within four (4) months

from the end of each fiscal year the semi-annual report within two (2) months from

the end of the first half of each fiscal year and quarterly reports within one month

from the end of the first three months and the first nine months of each fiscal year.

4Article 14 The annual report shall contain the following information:

(I) Basic information of the Company

(II) Main accounting data and financial indicators

(III) Information on issuance of Company's shares and bonds and changes thereto; the

total amount of shares and bonds and the total number of shareholders at the end of

the reporting period; as well as information on the shareholding of the Company's top

ten (10) shareholders.(IV) Information on shareholders holding five percent (5%) or more of the shares the

controlling shareholders and the ultimate controllers

(V) Appointment of directors and senior executives their changes and annual

remuneration

(VI) Reports of the board of directors

(VII) Management discussion and analysis

(VIII) Material events occurring within the reporting period and their impact on the

Company

(IX) Full text of financial reports and audit reports; and

(X) Other matters as stipulated by the CSRC.Article 15 The semi-annual report shall contain the following information:

(I) Basic information of the Company

(II) Main accounting data and financial indicators

(III) Information on issuance of the Company's shares and bonds and changes thereto;

the total number of shareholders as well as information on the shareholding of the

Company's top ten (10) shareholders; changes of controlling shareholder and ultimate

controller

(IV) Management discussion and analysis

(V) Material events occurring within the reporting period such as material lawsuits

and arbitrations and their impact on the Company

(VI) Financial reports; and

5(VII) Other matters as stipulated by the CSRC.

Article 16 The quarterly report shall contain the information required by the Shenzhen

Stock Exchange.Article 17 All periodic reports shall be deliberated and approved by the board of

directors of the Company. Any periodic report that has not been deliberated and

adopted by the board of directors shall not be disclosed. The financial information

presented in periodic reports shall be reviewed by the Audit Committee and submitted

to the board of directors for consideration upon approval by a majority of all members

of the Audit Committee.In case any of the directors are unable to ensure the truthfulness accuracy or

completeness of any periodic report or have any objections they shall vote against or

abstain from voting during the deliberation of the board of directors. If any member of

the Audit Committee is unable to ensure the truthfulness accuracy or completeness of

the financial information in any periodic report or has any objection he or she shall

vote against or abstain during the review of the periodic report.The board of directors and senior executives shall sign written confirmation opinions

on periodic reports and state whether the preparation and deliberation procedures of

the board of directors are in compliance with the laws administrative regulations and

provisions of the CSRC and whether the contents of the report can truthfully

accurately and completely reflect the actual situation of the Company.If any of the directors and senior executives is unable to ensure the authenticity

accuracy or completeness of the content of any periodic report or has any objection

against the content they shall express their opinions and state their reasons in writing

and the Company shall disclose such opinions. If the Company refuses to do so the

directors and senior executives may apply for disclosure directly.The directors and senior executives shall follow the principle of prudence in

expressing their opinions in accordance with the preceding paragraph and their

responsibility to ensure the authenticity accuracy and completeness of the contents of

any periodic report shall not be exempted by that very act.Article 18 If the Company foresees a loss or any substantial alteration of its

performances it shall make a timely pre-announcement.

6Article 19 If there is a leak or any hearsay about the financial performance or any

abnormal fluctuation in the trading of securities and derivatives of the Company

before the disclosure of its periodic reports the Company shall disclose the

preliminary financial results in a timely manner.Article 20 If a non-standard audit opinion is issued on the financial reports in the

periodic report the board of directors of the Company shall make a special report on

the related items.Chapter 3 Disclosure of Interim Reports

Article 21 Where the occurrence of any material event is likely to have a significant

impact on the trading price of the Company's securities and its derivatives and the

investors have yet to be informed the Company shall promptly disclose its occurrence

and explain the cause the current status and the likely effect.A material event referred to in the preceding paragraph shall include:

(I) Material event as stipulated in Paragraph 2 of Article 80 of the Securities

Law;

(II) Occurrence of liability for any significant sum of compensation;

(III) Provision for any significant amount of asset impairment;

(IV) Occurrence of negative value of shareholders’ equity;

(V) The Company's main debtor becomes insolvent or enters bankruptcy and

the Company has not made full provision for bad debts for the

corresponding credits;

(VI) Any newly promulgated law regulation rules or industrial policy that

may materially affect the Company;

(VII) The Company carries out any equity incentive program repurchase of its

shares major asset restructuring spin-off or listing;

(VIII) The controlling shareholder is prohibited by the rule of any court from

transferring its shares;

Shares of any shareholder accounting for five percent (5%) or more of the

7Company's total equity being pledged frozen judicially auctioned held in

custody placed in trust or restricted in voting rights in accordance with

the law or forced transfer of ownership;

(IX) The Company's main assets are seized impounded or frozen; or the main

bank accounts are frozen;

(X) The Company anticipates a loss or substantial change in its business

performance;

(XI) The main or all of its business comes to a halt;

(XII) The Company receives extraneous income that has a material impact on

the current profit or loss which may have a material effect on its assets

liabilities equity or its business performance;

(XIII) The appointment or dismissal of the accounting firm as an auditor of the

Company;

(XIV) Significant autonomous changes in accounting policies and accounting

estimation;

(XV) The Company is ordered by the relevant authorities or the board of

directors decides to make corrections to previous disclosed information

due to errors failure to disclose information as required or false

statements;

(XVI) The Company or its controlling shareholder the ultimate controller any

director or senior executive is subject to criminal penalties under

investigation or administrative penalties by the CSRC due to suspicion of

violating the law or subject to significant administrative penalties by other

authorities entitled to do so;

(XVII) The controlling shareholder the ultimate controller directors and senior

executives of the Company are suspected of serious disciplinary offences

or duty-related crimes or are detained by the disciplinary inspection and

supervision authorities which consequentially affects their performance of

duties;

(XVIII) Any of the directors senior executives other than the chairman of the

8board or the CEO of the Company are unable to normally perform their

duties for more than three (3) months due to health issues work

arrangements and other reasons or are subject to mandatory measures

adopted by the competent authorities for alleged violation of the law

which consequentially affect the performance of their duties;

(XIX) Other matters as prescribed by the CSRC

If the controlling shareholder or the ultimate controller of the Company has a

significant influence on the occurrence or progress of any major event he or she shall

promptly inform the Company in writing of the relevant circumstances to which he or

she is aware and cooperate with the Company in fulfilling the information disclosure

obligations.Article 22 Any change to the Company's name stock abbreviation Articles of

Associations registered capital registered address main office address and contact

number shall be disclosed immediately.Article 23 The Company shall perform the information disclosure obligation of a

material event in a timely manner at any of the following points of time when it first

occurs:

(I) the board of directors forms a resolution on the material event;

(II) the parties concerned sign a letter of intent or agreement in respect of the event;

(III) the directors or senior executives become or should become aware of the

occurrence of the material event.If any of the following circumstances occurs prior to the events mentioned in the

preceding paragraph the Company shall timely disclose the status of all relevant

matters and the risk factors that may affect the development of the significant event:

(I) The material event is difficult to keep confidential

(II) The material event has been divulged or rumors emerge in the market;

(III) The securities of the Company and the derivatives thereof are abnormally traded

Article 24 If the disclosure of any material event by the Company leads to any

development or change that may significantly affect the trading price of its securities

and derivatives it shall disclose the development or change and the likely impact in a

9timely manner.

Article 25 In case a material event as stipulated in Article 21 of this Management

Policy occurs in any of the Company's controlled subsidiaries which may

significantly affect the trading price of its securities and derivatives it shall fulfill its

obligation of information disclosure.If an event occurs in a subsidiary in which the Company holds equity and may result

in a significant impact on the trading price of the Company’s securities and

derivatives it shall fulfill its information disclosure obligations.Article 26 Where any acquisition merger division issuance of shares repurchase of

shares etc. in which the Company is involved results in significant changes to its total

equity shareholders or the ultimate controller the information disclosure obligor shall

perform the obligation to report and announce the equity changes in accordance with

the law.Article 27 The Company shall keep track on any abnormal trading of its securities and

derivatives as well as relevant media coverage.If any abnormal trading or media report may materially affect the trading of the

Company's securities and derivatives it shall promptly ascertain the facts from

relevant parties inquire in writing and clarify in public if necessary.The Company's controlling shareholder ultimate controller and parties acting in

concert shall timely and accurately notify the Company whether there is any proposed

share transfer asset restructuring or other significant event and cooperate with the

Company in the disclosure of information.Article 28 If the trading of the Company's securities and derivatives is identified as

abnormal trading by the CSRC or the Shenzhen stock exchange it shall timely assess

the actors triggering the abnormal fluctuations in trading and disclose them in a timely

manner.Chapter 4 Management over Information Disclosure Affairs

Section 1 Procedures for Information Disclosure

Article 29 Procedures for the preparation deliberation and disclosure of periodic

10reports are as follows:

(I) The divisions of the headquarter of the Company and each subsidiary shall

provide basic information diligently. The CEO the CFO and the secretary

of the board of directors shall organize and lead the relevant teams to draft

periodic reports in a timely manner and submit the financial information

contained in the periodic reports to the Audit Committee for review and to

the Board of Directors for deliberation.(II) The chairman of the board shall be responsible for convening and chairing

the meeting of the board of directors to review and deliberate the periodic

reports.(III) The directors and senior executives of the Company shall sign a written

confirmation regarding the periodic reports.(IV) After the board meeting approves the periodic reports the secretary of the

board shall be responsible for arranging the relevant departments to

disclose the periodic reports.Article 30 Procedures for the preparation deliberation and disclosure of interim

reports are as follows:

(I) When the directors and senior executives become aware of a material

event they shall immediately report to the chairman of the board and

inform the secretary of the board. Heads of all departments and

subsidiaries of the Company shall immediately notify the board secretary

upon becoming aware of or preparing any material matter so as to help to

promptly assess if the disclosure obligation should be fulfilled. The

secretary of the board will arrange and coordinate the relevant parties of

the Company to draft the disclosure of the interim reports.(II) For events that require resolution of the board of directors and the general

meeting of shareholders the secretary of the board shall arrange and

coordinate the relevant parties of the Company prepare an interim report

based on the instructions and resolutions of the board of directors and the

general meeting of shareholders.For information disclosure of any material event prescribed in Article 21

11of this Management Policy and not subject to the approval of the board of

directors and the general meeting of shareholders the secretary of the

board shall arrange and coordinate the relevant parties of the Company

prepare the corresponding interim reports.(III) The draft interim report shall be reviewed by the secretary of the board and

shall be approved for release by the chairman of the board (or the CEO

authorized by the chairman of the board).(IV) The secretary of the board shall submit the approved interim reports to the

Shenzhen Stock Exchange in a timely manner.Article 31 The information disclosed by the Company shall be published in the form

of the announcement of the board of directors. Directors and other senior executives

other than the secretary of the board shall not release undisclosed information to the

public without authorization in writing by the board of directors.Article 32 The Company formulates and implements the Investor Relations

Management Policy which constitutes the framework for information communication

between the Company and investors securities service providers medias and other

relevant parties. The Company shall not provide insider information when it

communicates with any entity or individual regarding its operation financial status

and other issues through performance presentation analysts’ meeting road shows or

investors’ inquiries.Section 2 Responsibilities of Information Disclosure

Article 33 The board of directors shall lead the information disclosure of the

Company and implement the rules stipulated in this Management Policy.(I) The chairman of the board shall be the primary person responsible for the

management over information disclosure affairs of the Company.(II) The secretary of the board shall be responsible for the arrangement and

coordination of information disclosure affairs.(III) As the standing institution for information disclosure the department of

securities and legal affairs led by the secretary of the board shall

12specifically handle relevant affairs contacts with investors and

shareholders receiving visitors answering inquiries providing investors

with information publicly disclosed by the Company and other daily

functioning affairs. Other relevant functional departments of the Company

and its subsidiaries shall closely cooperate with the department of

securities and legal affairs and the secretary of the board of directors to

ensure that the disclosure of information in all the periodic and interim

reports can be carried out in a timely manner.Article 34 The information disclosure obligor holds the responsibility to provide the

material and information required for the relevant information disclosure to the

secretary of the board in a timely manner.Article 35 The directors and senior executives of the Company shall diligently fulfill

their duties pay careful attention to the preparation and drafting of information

disclosure documents and ensure that periodic and interim reports are disclosed within

the prescribed period.Article 36 Directors of the board shall be aware of and pay continuous attention to the

business operation and financial status of the Company and any significant event of

the Company that has occurred or may occur as well as the impacts and take the

initiative to investigate and obtain the information required for decision-making.Article 37 The Audit Committee shall monitor the Company's directors and senior

executives in the performance of their information disclosure duties; pay attention to

the information disclosure and if identifying any violation of information disclosure

investigate and suggest proper handling.Article 38 Senior executives shall report to the board of directors in a timely manner

on significant issues related to the business operation or financial status of the

Company any development of or changes in a disclosed event and other relevant

information.Article 39 The secretary of the board shall be responsible for collecting the

information to be disclosed by the Company analyzing and judging information

significance.If it is necessary to fulfill the obligation of information disclosure in accordance with

relevant laws and regulations as well as provisions of this Management Policy the

13secretary of the board shall report to the board of directors in a timely manner and

request to go through the corresponding procedures and disclose to the public.The secretary of the board shall also continuously pay attention to the media coverage

on the Company and take the initiative to seek verification.The secretary of the board has the right to attend the general meeting of shareholders

the meeting of the board the meeting of the Audit Committee and relevant meetings

of the senior executives to understand the financial and operational situation of the

Company and consult all documents related to information disclosure matters.The secretary of the board is responsible for handling matters related to the

announcement of the Company's information to the public.The Company shall facilitate the secretary of the board to perform one’s duties and

the CFO shall cooperate with the secretary of the board in the work related to

financial information disclosure.Article 40 When the following events occur the shareholders or the ultimate

controller of the Company shall take the initiative to inform the board of directors and

cooperate with the Company in fulfilling its information disclosure obligations:

(I) A substantial change in the shareholding of a shareholder who holds five

percent (5%) or more of the total equity or to the shareholding proportion

or control over the Company of the person in effective control or a

substantial change to the ultimate controller and other enterprises under

one’s control which are engaged in the same or similar business as the

Company.(II) A court rules to prohibit the transfer of shares held by the controlling

shareholder; or five percent (5%) or more of the total shares of the

Company held by any shareholder are pledged frozen judicially auctioned

entrusted set up in trust or restricted in voting rights in accordance with

the law; or there is a risk of forced transfer of ownership.(III) Proposed major asset or business restructuring of the Company.(IV) Other circumstances as prescribed by the CSRC.Where prior to the information disclosure in accordance with the law relevant

14information has been circulating in the media or if there are abnormal trade

fluctuations in the securities and derivatives of the Company the shareholder or the

ultimate controllers shall submit a timely and accurate written report to the Company

and cooperate to make timely and accurate announcement accordingly.The shareholders or ultimate controllers of the Company shall neither abuse their

rights or dominant position nor request to provide them with insider information.Article 41 When the Company issues shares to qualified investors its controlling

shareholders ultimate controllers and the recipient shall provide relevant information

to the Company in a timely manner and cooperate in fulfilling its information

disclosure obligations.Article 42 The directors senior executives shareholders holding five percent (5%) or

more of the shares parties acting in concert and the ultimate controller shall submit to

the board of directors a list of related parties and indicate the associated relationships

concerned in a timely manner.The Company shall fulfill the deliberation procedures for related-party transactions

and strictly implement the voting abstention rules in related party transactions. The

parties to the transaction shall not circumvent the Company's procedures to review the

related-party transactions and information disclosure obligations by concealing the

connected relationship or adopting other means.Article 43 A shareholder who holds five percent (5%) or more of the total equity of

the Company or a person in effective control by accepting a commission or trust shall

promptly inform the Company of information about the principal and cooperate with

the Company in fulfilling the information disclosure obligations.Section 3 Suspension and Exemption of Information Disclosure

Article 44 If the Company or other information disclosure obligor possesses

conclusive and sufficient evidence demonstrating that the information proposed for

disclosure involves national secrets or other matters whose disclosure may result in

breaches of national confidentiality regulations or management requirements such

disclosure shall be exempted in accordance with the law.Where information proposed for disclosure by the Company or other information

disclosure obligor involves commercial secrets or confidential commercial

15information (hereinafter collectively referred to as “commercial secrets”) and meets

any of the following circumstances while remaining undisclosed or uncompromised

disclosure may be suspended or exempted in accordance with relevant CSRC

regulations

(I) Where the information constitutes core technological information etc. and

disclosure may lead to unfair competition.(II) Where the information pertains to the Company's own business details or the

business details of clients suppliers or other parties and disclosure may infringe

upon the Company's or such parties' commercial secrets or cause substantial detriment

to their interests.(III) Where disclosure may otherwise cause substantial detriment to the interests of

the Company or other parties.Article 45 In case of the occurrence of the any of the following circumstances after an

information disclosure obligor has suspended or been exempted from disclosing

commercial secrets disclosure shall be made promptly.(I) The causes for suspension or exemption have ceased to exist;

(II) The relevant information has become difficult to keep confidential;

(III) The relevant information has been disclosed or spread out in the market.Article 46 Where the Company suspends or exempts disclosure of relevant

information the secretary of the board shall promptly record such matters which shall

be duly signed off by the chairman of the board before being properly archived for

safekeeping.Article 47 The Company shall establish policies for the suspension and exemption of

information disclosure.Section 4 Management on Information Disclosure Filing

Article 48 The documents and information related to the disclosure according to

provisions of this Management Policy shall be filed by the department of securities

and legal affairs and managed in accordance with the Company's file management

policy.Article 49 The performance of duties by directors of the Company shall be recorded

16by the department of securities and legal affairs. The performance of duties by senior

executives shall be recorded by the general office of the headquarter. Records

pertaining to the performance of duties by board directors and senior executives shall

be managed in accordance with the Company's archive management system.Section 5 Confidentiality Measures for Undisclosed Information

Article 50 A person who gets to know any undisclosed and material information of the

Company before it is disclosed shall be responsible for keeping it confidential.Article 51 The board of directors shall take necessary measures to minimize the

number of insiders before the disclosure of any material information.Article 52 The Company shall implement a registration management system for those

who hold insider information. Before the disclosure of any insider information in

accordance with the law the Company shall prepare files about relevant insiders and

report to the Shenzhen Stock Exchange within five (5) trading days after the first

public announcement of the insider information in accordance with the law as may be

changed from time to time.Article 53 In carrying out business activities if various departments of the Company

are in actual need to provide non-public material information to counterparties agents

other institutions and relevant personnel who are under confidentiality obligations to

the Company due to special circumstances while promoting business activities they

shall require the relevant institutions and personnel to sign confidentiality agreements

otherwise they shall not provide the relevant information.Article 54 The relevant departments of the Company shall carefully review the

contents of reports at large and important internal meetings as well as speeches and

written materials prepared for meetings held by the controlling shareholders.Regarding any relevant undisclosed and material information the scope of

communication shall be limited and confidentiality requirements shall be made to the

report drafters and participants of those meetings. The participants of normal working

meetings of the Company have the responsibility of confidentiality of the relevant

important information stipulated in this Management Policy.Section 6 Management and Reporting on Information Disclosure Affairs of

Departments and Subsidiaries

17Article 55 The heads of departments and subsidiaries of the Company shall be the

primary person responsible for the management and reporting of information

disclosure relating to its affairs. The heads of departments and subsidiaries shall

appoint a designated person responsible for the management of relevant information

disclosure documents and materials and reporting to the secretary of the board of the

Company in a timely manner any material information related to the department (or

the subsidiary).Article 56 The Company's controlled subsidiaries shall refer to material events

prescribed by this Management Policy and report in writing to the secretary of the

board of the Company in a timely manner the corresponding events occurring in their

companies and the secretary shall be responsible for the disclosure of information in

accordance with the provisions of this Management Policy.Section 7 Standing Institution and Contacts for Information Disclosure

Article 57 The department of securities and legal affairs of the Company is its

standing institution for information disclosure and investor reception with the

following contact details.Tel：010-56718110

E-mail：IRChina@adama.com

Chapter 5 Internal Control and Supervision of Financial Management and

Accounting

Article 58 The Company establishes and implements an internal control system for

financial management and accounting. The internal audit department should conduct

regular or ad hoc oversights and report periodically to the Audit Committee of the

board of directors as required.Chapter 6 Legal Liabilities

Article 59 The directors and senior executives of the Company shall be responsible

for the truthfulness accuracy completeness timeliness and fairness of information

disclosure except cases with sufficient evidence for their diligence to have performed

18their duties.

The chairman the CEO and secretary of the board shall be primarily responsible for

the truthfulness accuracy completeness timeliness and fairness of the information

disclosed in any interim report of the Company.The chairman the CEO and the CFO of the Company shall be primarily responsible

for the truthfulness accuracy completeness timeliness and fairness of the disclosed

financial statements of the Company.Article 60 If any negligence of the parties related to the information disclosure

covered by this Management Policy causes violation of laws of information disclosure

and consequentially triggers serious impact or loss to the Company the person

responsible shall be criticized warned or even dismissed from his or her position.Article 61 The Company reserves the right to pursue the responsibility of consultants

staff of agents and associates hired by the Company if any of these discloses the

Company's information without authorization and cause losses.Chapter 7 Supplementary Provisions

Article 62 This Management Policy shall be interpreted and amended by the board of

directors of the Company.Article 63 In case of any matters not covered by this Management Policy or any

conflict between this Management Policy and relevant laws administrative

regulations regulatory documents and other relevant provisions the latter shall

prevail.Article 64 This Management Policy shall take effect from the date of approval by the

board of directors of the Company replacing the "Information Disclosure Affairs

Management Policy" (revised in March 2022) adopted at the Ninth Meeting of the

Ninth Session of the Board of Directors.Board of Directors of ADAMALtd.October 28 2025

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