Entity List customers and export controls

Therefore, as advised by U.S. Legal Advisor, the Act has not had any direct or indirect impact on the Group’s business operations during the Track Record Period and up to the Latest Practicable Date.

Business · p. 162

Accordingly, we believe our transactions with these customers did not give rise to a violation of the Entity List restrictions under the EAR.

Risk Factors · p. 43

To the best of our knowledge and based on the consultation with our legal advisor to international sanctions laws and regulations, we have not identified any circumstances indicating that our business operations violated applicable U.S. export control regulations during the Track Record Period.

Risk Factors · p. 43

While we do not qualify as a "covered foreign person" under the current regulations, as we do not engage in any kinds of the "covered activities," there remains uncertainty regarding potential expansions of regulatory restrictions.

Risk Factors · p. 44

During the Track Record Period, one of our suppliers and one of our customers were included in the Entity List.

Risk Factors · p. 46

To the extent U.S. export control considerations may be implicated, our relevant business activities remain in compliance with applicable laws and have not been materially affected by such restrictions.

Risk Factors · p. 46

As advised by our International Sanctions Advisor, no member of our Group was included on the applicable sanctions lists, and no violation of applicable international sanctions laws was identified in connection with such activities.

Risk Factors · p. 37

In light of the foregoing, we are advised by our International Sanctions Advisor that, during the Track Record Period, we did not engage in any unauthorized transactions or commit any violations of the EAR from the perspective of U.S. export control.

Business · p. 150

The amount of Relevant Transactions in 2023, 2024, 2025, and for the six months ended June 30, 2026 was RMB25.1 million, RMB15.8 million, RMB10.9 million, and RMB11.1 million, respectively, representing 2.6%, 1.5%, 1.1%, and 1.7% of our revenue for the corresponding periods.

Business · p. 148

As advised by our legal adviser in connection with the foregoing matters, we may be deemed a "covered foreign person" defined under the Outbound Investment Rule due to our business activities which falls within the "covered activities" targeted by the Outbound Investment Rule, and the acquisition of our equity interests may be deemed as a "notifiable transaction" and U.S. person who acquires our equity interests may need to notify the U.S. Treasury pursuant to the Outbound Investment Rule.

Risk Factors · p. 46

In light of the FAQs’ guidance, we are of the view, as advised by our legal advisor and taking into account its view, at the time U.S. persons acquire our H shares (which may be interpreted as the date of acquisition, i.e., the date of Listing) in this Global Offering, such shares would be publicly listed and tradable and a U.S. person’s acquisition of our H shares in this Global Offering may constitute an "excepted transaction" assuming the U.S. person would not also be afforded rights beyond "standard minority shareholder protections."

Risk Factors · p. 46

as advised by our Legal Advisor as to U.S. export control and sanctions law, during the Track Record Period, (i) our direct customers are not designated on BIS Entity List, Denied Persons List or Unverified List or headquartered in or ordinarily resident in, or owned or controlled by a government of, any countries or regions subject to Comprehensive Trade Embargos (collectively, the “Sanctioned Targets”); and (ii) our activities do not involve operations or transactions that have violated or would violate (a) the restrictions on Sanctioned Targets; and (b) the restrictions set forth in the EAR.

Business · p. 171

In addition, our solutions and products are manufactured outside the United States, do not incorporate controlled U.S.-origin content and do not fall within the scope of any applicable foreign direct product rules, and therefore are not subject to the EAR.

Business · p. 171

Given the above, our International Sanctions Legal Advisor is of the view that during the Track Record Period and up to the Latest Practicable Date, our sales to Russia did not constitute a Primary Sanctioned Activity or a violation of the U.S. primary sanctions.

Business · p. 178

Based on the foregoing factors, as advised by our International Sanctions Legal Advisor, we are not aware of any material violations of U.S. sanctions laws and regulations during the Track Record Period and up until the Latest Practicable Date.

Business · p. 178

Accordingly, our International Sanctions Legal Advisor is of the view that our activities do not constitute “covered activities” under the Final Rule, that we are not a “covered foreign person”, and the Final Rule is inapplicable to our Company and its business operations.

Business · p. 179

Our International Sanctions Legal Advisor has advised that, because the Company did not utilize U.S.-origin software or technology in its product design and manufacturing processes, nor did it procure any U.S.-origin components or technology during the Track Record Period, the Company’s products are not subject to export control restrictions under the U.S. Export Administration Regulations and has not been subject to any sanctions imposed by the U.S. government.

Risk Factors · p. 48

As advised by our International Sanctions Legal Advisor, we are a “covered foreign person,” and U.S. person investments in our equity interests are “notifiable transactions.”

Risk Factors · p. 48

Our Company does not “develop,” “fabricate,” “design,” or “package” any product that meets any parameter described in the definition of “prohibited transactions” concerning semiconductors and microelectronics under the Outbound Investment Rule.

Business · p. 199

our Directors are of the view that we were not designated as a sanctioned person or entity under the sanctions regimes of the United States, the European Union, the United Kingdom, Australia or the United Nations, and we did not conduct transactions with persons designated on the SDN List.

Business · p. 145

After the consultation with our legal advisor as to the OISP Final Rule, our Directors are of the view that we do not engage in Covered Activities for purposes of the OISP Final Rule, principally because we do not develop, produce or enable technologies or products in the specific sectors targeted by the OISP Final Rule, including semiconductors and microelectronics, quantum information technologies and artificial intelligence.

Business · p. 145

As we design and develop robotics technology to support reinforced motion control and decision making for robots, with the aim of expanding their overall mobility and operational versatility, enabling the broad adoption of robots across diverse industries, based on the legal advice of our legal advisor as to U.S. foreign investment law, our Directors are of the view that we are a “Covered Foreign Person” in the context of “notifiable transactions” within the artificial intelligence sector.

Risk Factors · p. 41

Our Directors are of the view, based on the legal advice of our legal adviser as to U.S. export control laws and taking into account its view, that our exposure under U.S. export control laws arising from transactions with these entities is limited and manageable, considering that (i) in terms of our sales to Relevant BIS Customers, as our products are not subject to the EAR, our supply of such products does not require BIS export licenses; and (ii) in terms of purchase from Relevant BIS Supplier, (a) the transaction amount was lower than RMB500 during the Track Record Period, and (b) the purchased raw material did not involve any items subject to the EAR.

Business · p. 179

Our Directors are of the view, based on the legal advice of our legal advisor as to U.S. foreign investment law, that the Final Rule will not have a material adverse impact on our Company’s business operations, financial performance, the Offering or our investment prospects.

Business · p. 180

As advised by our International Sanctions and U.S. Tariffs Legal Advisor, our sales to these Relevant Customers did not represent a violation of applicable U.S. export controls, and no export licenses were required for our sales to the Relevant Customers.

Business · p. 173

Based on the advice from our U.S. counsel, Cleary Gottlieb Steen & Hamilton (Hong Kong), we concluded that we are not a covered foreign person within the meaning of the Outbound Investment Rule, because (a) our Company is not engaged in covered activities within the meaning of that rule, including covered activities concerning semiconductors and microelectronics, quantum information technologies, and artificial intelligence systems, and (b) our Company does not hold relevant interests in persons engaged in covered activities meeting the financial metrics described in limb (ii) of the definition of “covered foreign person” above.

Risk Factors · p. 44

Our products manufactured in Thailand are exempt from U.S. Section 301 Tariffs, because they experienced substantial transformation in Thailand and thus were Thai-origin as advised by our International Sanctions and U.S. Tariffs Legal Advisor.

Risk Factors · p. 42

As advised by our International Trade Legal Advisor, our Company is not a Sanctioned Target, or located, incorporated, organized or resident in a Sanctioned Country; and our business activities during the Track Record Period do not qualify us as a Sanctioned Trader for the purposes of Chapter 4.4 of the Guide.

Business · p. 150

For the purpose of Chapter 4.4 of the Guide, our International Trade Legal Advisor has further advised that our business activities did not constitute Primary Sanctioned Activity or Secondary Sanctionable Activity.

Business · p. 150

As advised by our International Trade Legal Advisor, a transaction with an entity on the U.S. Entity List does not, by itself, violate U.S. export control laws.

Business · p. 149

As advised by our International Sanctions Legal Advisor, given that we are non-restricted entities in China and we are not Anti-terrorism Restrictions Sanctioned Targets, we do not require a license to procure the Procured Items; therefore, our procurement of these Procured Items (including those U.S.-origin products) during the Track Record Period and up to the Latest Practicable Date did not represent a violation of the applicable U.S. export controls.

Business · p. 221

As advised by our International Sanctions Legal Advisor, during the Track Record Period and up to the Latest Practicable Date, given that we did not have business activities in Comprehensively Sanctioned Countries or with any SDNs, our business activities (including our sales and purchase) did not represent a violation of the applicable primary sanctions administered by Sanctions Relevant Jurisdictions or represent Primary Sanctioned Activities as defined in Chapter 4.4 of the Guide for New Listing Applications issued by the Stock Exchange (“Chapter 4.4 of the Guide”).

Business · p. 223

As advised by our International Sanctions Legal Advisor, given that our exports to the United States are relatively low compared to our total revenue and we do not plan to expand our U.S. exports, U.S. tariffs are unlikely to have a material adverse impact on our business operations, and our Directors are of the view that U.S. tariffs did not have, and are unlikely to have, any material adverse impact on our business operations, financial condition or results of operations.

Business · p. 224

After advice and consultation with our International Sanctions Legal Adviser, our Company is of the view that our transactions with customers and suppliers named on or affiliated with entities on U.S. restricted party lists did not involve items subject to U.S. export controls requiring a license, nor do they constitute Primary or Secondary Sanctionable Activity, based on the following facts and legal analyses:

Business · p. 201

As advised by our International Sanctions Legal Adviser, we should not be viewed as a Covered Foreign Person under the Final Rule, because we do not engage in a "Covered Activity" (as defined in the Final Rule) or otherwise meet the definition of Covered Foreign Persons provided in the Final Rule based on the following parameters:

Business · p. 201

Accordingly, even though the Footnote 5 Entity List Foundries are within the end-user scope of the rule, the product scope is not satisfied, and based on information provided by us, our legal adviser as to U.S. outbound investment rules, sanctions and export control laws is of the view that the transfer of the chip design files to the Footnote 5 Entity List Foundries does not require a license from the BIS under the Footnote 5 FDP Rule.

Business · p. 174

Because the Entity List Foundries act as our suppliers, our legal adviser as to U.S. outbound investment rules, sanctions and export control laws has informed us that our procurement of the services from the Entity List Foundries does not, in itself, trigger a license requirement under §744.11.

Business · p. 175

Based on the foregoing and the factual matters described above, and subject to our ongoing implementation of the sanctions compliance measures, our legal adviser as to U.S. outbound investment rules, sanctions and export control laws advised us that our business activities during the Track Record Period did not implicate material risks of U.S. primary or secondary sanctions.

Business · p. 175

As advised by the International Sanctions Legal Advisors, we would not be viewed as a Covered Foreign Person under the Final Rule.

Risk Factors · p. 47

our procurements (and subsequent use in our products) of such Procured Items during the Track Record Period did not represent a violation of the applicable U.S. export controls.

Business · p. 205

As advised by our International Sanctions Legal Advisors, given the aforementioned nature of our transactions with these Entity List Customers, these transactions did not involve any exports or transactions of any items subject to the EAR, and hence did not represent a violation of the applicable U.S. export controls.

Business · p. 205