Xunlei(XNET) - 2022 Q4 - Annual Report

Supplemental Submission Regarding HFCAA This submission addresses the company's HFCAA identification and asserts it is not controlled by a Chinese governmental entity Background and Purpose of Submission The company explains its HFCAA identification and the purpose of this submission to prove non-government control - On May 26, 2022, the SEC conclusively identified Xunlei Limited as a Commission-Identified Issuer pursuant to the HFCAA[4] - The identification resulted from the company's 2021 annual report being audited by PricewaterhouseCoopers Zhong Tian LLP, a firm in a jurisdiction the PCAOB could not fully inspect until December 2022[4] - The company asserts that the information provided in this report establishes that it is not owned or controlled by a governmental entity in China[4] Analysis of Ownership and Control The company details its ownership structure to demonstrate a lack of Chinese government control or influence Major Shareholders (as of March 31, 2023) | Shareholder | Beneficial Ownership & Voting Power | Key Details | | :--- | :--- | :--- | | Itui International Inc. | 41.1% | Beneficially owned by Mr. Jinbo Li (Chairman & CEO) and Best Ventures Limited (wholly owned by Xiaomi Corporation) | | Sean Shenglong Zou | 7.1% | Co-founder and director, holding shares through various entities | - Mr. Jinbo Li (Chairman and CEO) and Best Ventures Limited (a Xiaomi subsidiary) are deemed beneficial owners of the 41.1% stake held by Itui International Inc[6] - The company states that to its knowledge, Xiaomi Corporation is not owned or controlled by a governmental entity of mainland China[6] - The company affirms it is not aware of any Chinese governmental entity that has the power to direct or cause the direction of its management and policies[8] Signatures This section provides the official authorization and signature for the submitted report Authorization The report was duly authorized and signed on behalf of Xunlei Limited on April 26, 2023 - The report was signed by Naijiang (Eric) Zhou, Chief Financial Officer of Xunlei Limited[9] - The date of the signature is April 26, 2023[9]