Stakeholder Engagement Approach

Materiality Matrix

GCL Technology attaches great importance to communication with stakeholders. By establishing a transparent and efficient communication mechanism, the Group proactively responds to the concerns of all parties, ensures that its actions in environmental, social and governance (ESG) areas are aligned with stakeholders’ expectations, and strives for shared development. Based on research conducted in 2024, 18 material issues were jointly identified by internal and external stakeholders from a total of 29 issues.

Enterprise Risk Management (ERM)

The Company has fully integrated materiality assessment into its Enterprise Risk Management (ERM) system, establishing a closed‑loop management mechanism covering risk identification, assessment, response, and monitoring. During the annual materiality assessment process, the Company systematically identifies and assesses the potential impact of ESG‑related risks and opportunities on the Company's strategy, financial performance, and stakeholders from both the financial materiality and impact materiality dimensions, and uses the results as a key basis for formulating and adjusting the Company's strategic planning, annual operational objectives, and risk response strategies.

1.Risk Identification and Assessment: In the annual comprehensive risk assessment, ESG‑related risks (including but not limited to climate change, energy transition, supply chain resilience, resource utilization efficiency, and social responsibility) are incorporated into the unified risk inventory, and rated by relevant business departments and risk management functions according to likelihood of occurrence and degree of impact.

2.Stakeholder Engagement: The Company collects the level of concern of internal and external stakeholders on ESG issues through questionnaires, interviews, and industry benchmarking, and updates the materiality matrix in conjunction with expert opinions and industry best practices, ensuring the objectivity and forward‑looking nature of risk assessments.

3.Risk Response and Monitoring: For ESG risks assessed as material, the Company develops special risk response plans, clearly defining responsible departments, response measures, and key performance indicators, and incorporates them into the annual risk management report, with regular reports to the Risk Management Committee and the Board of Directors.

4.Dynamic Adjustment Mechanism: The Company conducts annual reviews and necessary updates to materiality assessment results and risk priorities based on changes in the macroeconomic environment, industry policies, technological developments, and the Company's strategic adjustments, ensuring alignment of the ERM system with the Company's long‑term sustainable development goals.