SenseTime Group strictly complies with various domestic and foreign trade-related laws and regulations, including but not limited to laws and regulations related to export control, customs, and tax. The Group has set up a rationally structured, well-functioning, and effective compliance system to ensure that SenseTime Group accurately and completely implements applicable international trade laws and regulations.

SenseTime Group’s management has established a well-developed Trade Compliance Program. The TCP continuously improves SenseTime Group’s capability and ensures the Group to meet current trade compliance standards while also maintaining smooth operations of the Group’s businesses. In June 2022, Dr. Xu Li (Executive Chairman of the Board and CEO of SenseTime Group) emailed SenseTime Group’s employees to re-affirm that SenseTime Group’s management supports the Group in building a mature trade compliance program, especially in establishing policies and procedures for human and financial resources.

SenseTime Group has formulated a series of standard operating procedures and rules for trade compliance regarding export/import item review, transaction risk review, sanctioned-party list screening, record keeping, auditing, as well as procedures if a rule is violated.  These procedures and rules have been published and disseminated to all employees. SenseTime Group implements strict compliance management measures in accordance with the standard operating procedures and rules that take into consideration changes in domestic and foreign applicable laws and regulations, the actual conditions of SenseTime Group’s business operations, and new issues arising from the development of SenseTime Group’s business. SenseTime Group continuously updates its various standard operating procedures/systems for trade compliance. In 2022, The Group released its latest edition of the “Compliance Management Manual” and “Operating Procedures for Export Control Compliance Audits”.

SenseTime Group places great importance on trade compliance training.  Along with providing trade compliance training for all employees, the Group provides targeted trade compliance training for individual business units from time to time based on the requirements and actual business operation conditions of each business unit.

Adhering to international trade compliance rules and regulations is one of SenseTime Group’s fundamental principles. Accordingly, SenseTime Group continuously optimizes and improves its Trade Compliance Program to effectively manage trade compliance risks.