Conclusion of Inspection No. 51/KL-TT Regarding Khải Hoàn Land Joint Stock Company

On September 4, 2026, the State Securities Commission issued Conclusion of Inspection No. 51/KL-TT regarding the inspection at Khải Hoàn Land Joint Stock Company (the Company/KHG). The full text of the Inspection Conclusion is as follows:

1. General Overview

Khải Hoàn Land Joint Stock Company was established in 2009 under the name Nguyễn Khải Hoàn Real Estate Joint Stock Company, with an initial charter capital of 6,000,000,000 VND. In 2013, the Company changed its name to Khải Hoàn Land Real Estate Joint Stock Company, and in 2022, it changed its name to its current name, Khải Hoàn Land Group Joint Stock Company.

In 2020, the Company registered as a public company with the State Securities Commission (SSC), with a charter capital of 1,600,000,000,000 VND. On June 30, 2021, the Ho Chi Minh City Stock Exchange (HOSE) issued Decision No. 354/QĐ-SGDHCM approving the listing of the Company's shares (stock code: KHG), with 174,817,547 listed shares; the official trading date was July 19, 2021.

At the time of inspection, the Company operated under Enterprise Registration Certificate No. 0309139261 issued by the Department of Finance of Ho Chi Minh City, first issued on July 24, 2009, and amended for the 28th time on October 21, 2025. The Company's headquarters is located at 5-7-9-11 Hung Gia 4 Internal Street, Phu My Hung Urban Area, Tan Hung Ward, Ho Chi Minh City. The legal representative is Ms. Dinh Thi Nhat Hanh - General Director.

• Main business lines (according to the Enterprise Registration Certificate): Real estate business, land use rights belonging to owners, users, or leased. Details: Real estate business, land use rights belonging to owners, users, or leased, excluding item 7A Appendix I of Decree 31/2021.

• Regarding subsidiaries and affiliated companies: According to the Company's report, at the time of inspection, the Company had 03 subsidiaries and 17 branches/representative offices; there were no affiliated companies. Detailed information on subsidiaries is as follows: An Pha Real Estate Investment and Development Limited Liability Company (100% ownership); An Thinh Phat Real Estate Investment and Business Limited Liability Company (100% ownership); and Hoang Thao My Trading and Service Limited Liability Company (100% ownership).

• Capital increase process from the time of public company registration to the time of the inspection decision announcement: From the time of public company registration (2020) to the time of the inspection decision announcement, the Company conducted 05 rounds of share offers/issuances, increasing its charter capital from 1,600,000,000,000 VND to 4,494,352,050,000 VND.

• Regarding shareholder structure and major shareholders: According to the shareholder list finalized by the Vietnam Securities Depository and Clearing Corporation (VSDC) on March 19, 2026, to organize the 2026 Annual General Meeting of Shareholders (AGM), the Company had 10,312 shareholders, including 02 major individual shareholders owning 40.44% of the Company's charter capital.

• Charter capital: According to the consolidated financial statements (CFS) for 2023, 2024, and 2025 audited by An Viet Audit Joint Stock Company, and the Q1/2026 financial statements prepared by the Company, the Company's charter capital from 2023 to the present has been 4,494,352,050,000 VND.

• Business operation status: According to the audited CFS for 2023, 2024, and 2025, and the Q1/2026 financial statements prepared by the Company, the Company's net profit after tax was 25,361,139,253 VND in 2023, 54,626,254,024 VND in 2024 (adjusted to 55,715,100,588 VND), 68,708,602,345 VND in 2025, and 13,401,654,569 VND in Q1/2026.

2. Inspection and Verification Results

2.1. Implementation of Information Disclosure (ID) Obligations

2.1.1. Regarding the process and organization of ID

• The Company has built and promulgated an ID Regulation in accordance with Clause 1, Article 300 of Government Decree No. 155/2020/NĐ-CP dated December 30, 2020, detailing the implementation of certain articles of the Securities Law (Decree No. 155/2020/NĐ-CP).

• The Company has established an electronic information page at the address https://khaihoanland.vn in accordance with point a, Clause 2, Article 7 of Circular No. 96/2020/TT-BTC dated November 16, 2020, by the Minister of Finance guiding information disclosure on the securities market (Circular No. 96/2020/TT-BTC). The Company's electronic information page has a dedicated section for shareholder relations, where it has published the Company's Charter, ID Regulation, internal regulations on corporate governance, regulations on the operation of the Board of Directors (BOD), regulations on the operation of the Supervisory Board, and periodic and unusual information as required by point c, Clause 2, Article 7 of Circular No. 96/2020/TT-BTC.

• The person performing ID for the Company is Ms. Pham Thi Minh Phu - Deputy General Director, authorized by Ms. Dinh Thi Nhat Hanh - General Director, the Company's Legal Representative.

• Regarding ID methods: The Company has registered and used the SSC's ID system and the HOSE electronic information page in accordance with points b, c, Clause 1, and Clause 9, Article 7 of Circular No. 96/2020/TT-BTC.

2.1.2. Regarding compliance with legal regulations on ID

The inspection results show that the Company violated the implementation of ID obligations, specifically as follows:

• The Company disclosed information late on the SSC's ID system, on the HOSE electronic information page, and on the Company's electronic information page regarding the Explanation of Net Profit Differences in the 2023 Financial Statements before and after auditing.

• The Company did not disclose sufficient content as required by law regarding data and transaction values with related parties in the Corporate Governance Situation Report for the first half of 2023, 2023, the first half of 2025, and 2025, as required by item 2.VII of Appendix V form attached to Circular No. 96/2020/TT-BTC, specifically:

• According to the audited 2023 semi-annual financial statements, the Company had transactions: Transfer of business cooperation funds 100,000,000,000 VND; Disbursement for La Partenza project 32,002,000,000 VND; Collection from La Partenza project 7,785,000,000 VND with Khải Minh Land Real Estate Joint Stock Company (The sister of the Chairman of KHG's Board of Directors is a major shareholder of this company); Repayment of business cooperation 327,500,000,000 VND; Repayment of business cooperation interest 30,000,000,000 VND with Cộng Đồng Môi Giới Limited Liability Company (The brother of KHG's General Director is a contributing member and Chairman of the Member Council of this company); Disbursement for La Partenza project 1,174,000,000 VND with Giao Hưởng Xanh Limited Liability Company (The brother of KHG's General Director is a contributing member and Chairman of the Member Council of this company). However, the Company did not present these transactions in the Corporate Governance Situation Report for the first half of 2023.

• According to the audited 2023 financial statements, the Company had transactions: Investment in business cooperation 500,000,000,000 VND with Khải Hoàn - Vũng Tàu Group Limited Liability Company (The Chairman of KHG's BOD is a major shareholder of this company). However, the Company did not present this transaction in the Corporate Governance Situation Report for 2023.

• According to the audited 2025 semi-annual financial statements, the Company had transactions: Transfer of business cooperation funds 295,000,000,000 VND with Giao Hưởng Xanh Limited Liability Company (The brother of KHG's General Director is a contributing member and Chairman of the Member Council of this company). However, the Company did not present this transaction in the Corporate Governance Situation Report for the first half of 2025.

• According to the audited 2025 financial statements, the Company had transactions: Transfer of deposit 291,420,000,000 VND with Giao Hưởng Xanh Limited Liability Company (The brother of KHG's General Director is a contributing member of this company). However, the Company did not present this transaction in the Corporate Governance Situation Report for 2025.

2.2. Regarding the Offer and Issuance of Private Corporate Bonds

During the inspection period, the Company conducted 05 rounds of private corporate bond (PCB) issuances in the years 2023, 2024, 2025, and 2026; additionally, the Company had conducted 03 rounds of PCB issuances in 2020 and 2021 (before the inspection period) with maturity dates during the inspection period. All 08 rounds of bond issuances by the Company were non-convertible private corporate bonds without warrants. 05 rounds of issuances during the inspection period were guaranteed for payment by a credit institution, and 03 rounds of issuances before the inspection period had collateral assets. These issuance rounds did not require submission of registration dossiers or reports to the SSC when implemented; they were conducted in accordance with Government Decree No. 163/2018/NĐ-CP dated December 4, 2018, on the issuance of corporate bonds (Decree No. 163/2018/NĐ-CP), Government Decree No. 81/2020/NĐ-CP dated July 9, 2020, amending and supplementing certain articles of Decree 163/2020/NĐ-CP (Decree No. 81/2020/NĐ-CP), Government Decree No. 153/2020/NĐ-CP dated December 31, 2020, on the offer and trading of private corporate bonds in the domestic market and the offer of corporate bonds to the international market (Decree No. 153/2020/NĐ-CP), Government Decree No. 65/2022/NĐ-CP dated September 16, 2022, amending and supplementing certain articles of Decree No. 153/2020/NĐ-CP (Decree No. 65/2022/NĐ-CP), Circular No. 122/2020/TT-BTC dated December 31, 2020, by the Minister of Finance guiding the ID and reporting regime of Decree No. 153/2020/NĐ-CP, and Circular No. 76/2024/TT-BTC dated November 6, 2024, by the Minister of Finance guiding the ID and reporting regime for the offer and trading of private corporate bonds in the domestic market and the offer of corporate bonds to the international market.

The Inspection Team reviewed the implementation of reporting and ID obligations related to corporate bond issuance activities and the use of proceeds from PCB issuances based on documents provided by the Company to assess the consistency and appropriateness of the documents with the purpose of capital use, the proceeds from PCB issuances, and the approved capital use plan.

2.2.1. Regarding 03 rounds of PCB issuances in 2020 and 2021 with maturity dates during the inspection period

(1) 2020 PCB issuance round, value 200 billion VND

• Regarding the issuance plan: According to the ID document dated February 10, 2020, regarding the issuance of private corporate bonds, the Company issued bonds according to BOD Resolution No. 01/NQ-HĐQT/2020 dated February 10, 2020, and the accompanying issuance plan (Bond code: BOND.KHL2020.01; total number of bonds issued: 2,000 bonds; par value: 100,000,000 VND; total issuance value: 200,000,000,000 VND divided into 03 rounds (Round 1 expected on February 25, 2020 (max 80,000,000,000 VND), Round 2 expected before March 16, 2020 (max 120,000,000,000 VND); Round 3 depending on the previous 2 rounds); term: 03 years from the issuance date; bond type: Non-convertible bond, without warrants, secured by assets; Interest payment: Every 03 months; fixed interest rate applied for the first year is 11.5%/year, floating interest rate applied for subsequent interest calculation periods (not lower than 11.5%); capital use plan: All proceeds from the bond issuance round will be used by the Issuer (TCPH) to increase operational capital scale, implement projects, and investment programs of the TCPH).

According to the ID document before the issuance of bond code BOND.KHL2020.01, in item 5 "Conditions, terms of the bond" under section III "Information about the bond offer round," information about bond transactions according to Clause 8, Article 6 of Decree No. 163/2018/NĐ-CP was not stated; in Part 2 "Detailed information about the bond issuance round," the Company did not present content about Related Partners (including name, main office address, brief introduction of related partners to the issuance: underwriting organization or issuing agent, representative of bondholders...) according to the model in Appendix I attached to Decree No. 163/2018/NĐ-CP.

• Regarding the offer result and bondholders: According to the ID document dated March 3, 2020, regarding the result of the bond issuance round via private method, Round 01 on February 25, 2020, and documents provided by the Company, it shows: The Company successfully issued 800 bonds to 34 individual investors (NĐT) with a total value of 80,000,000,000 VND; Issuance date: February 25, 2020; Maturity date: 03 years from the issuance date; According to the ID document dated April 16, 2020, regarding the result of the bond issuance round via private method, Round 02 on March 18, 2020, and documents provided by the Company, it shows: The Company successfully issued 1,200 bonds to 51 individual investors with a total value of 120,000,000,000 VND; Issuance date: March 18, 2020; Maturity date: 03 years from the issuance date of Round 01.

• Regarding the use of proceeds from PCB issuance:

According to the bank statement of the Company's account receiving bond purchase funds at Joint Stock Commercial Bank (JSCB) Tieng Phong (TPBank) - Ben Thanh Branch and documents provided by the Company, the Company received 200,000,000,000 VND in bond purchase funds from February 1, 2020, to April 15, 2020. From February 12, 2020, to April 15, 2020, the Company transferred money to other payment accounts of the Company for use in purposes: serving real estate brokerage such as booking deposits, booking, holding apartments for customers, paying employee salaries, paying bond issuance service fees, paying advances for EPC general contractor contracts (general contractor for design, supervision, construction, supply and installation of equipment for the High-rise Apartment Project, commercial name La Partenza, located in Nhon Duc Commune, Nha Be District, Ho Chi Minh City - La Partenza Project),...

(2) 2021 PCB issuance Round 01, value 300 billion VND

• Regarding the issuance plan: According to the ID document dated September 28, 2021, regarding the issuance of bonds via private method, the Company issued bonds according to BOD Resolution No. 31/2021/NQ-HĐQT dated September 28, 2021, and the accompanying issuance plan (Bond code: KHGH2123001; total number of bonds issued: 300,000 bonds; par value: 1,000,000 VND; total issuance value: 300,000,000,000 VND; term: 18 months from the issuance date; bond type: Non-convertible bond, without warrants, secured by assets; Interest payment: Every 03 months; fixed interest rate 12%/year).

The capital use plan according to BOD Resolution No. 31/2021/NQ-HĐQT dated September 28, 2021, was to increase the Company's operational capital scale and/or implement investment programs and projects of the Company; according to the ID document dated September 28, 2021, it was to increase the scale of real estate brokerage activities and Exclusive Development and Distribution Cooperation for Phase 1.1 of the T&T City Millennia Project.

• Regarding the offer result and NĐT owning bonds: According to the ID document dated December 14, 2021, regarding the result of private bond issuance and documents provided by the Company, it shows: The Company successfully issued 300,000 bonds to 68 individual NĐT with a total value of 300,000,000,000 VND; Issuance date: October 5, 2021; Maturity date: April 5, 2023.

The Company provided documents identifying the professional securities investors of the 68 NĐT participating in buying the privately issued shares (confirmed by the securities company as professional securities investors, the time of identifying professional investors from January 12, 2021, to November 22, 2021, or having a securities business certificate according to regulations).

• Regarding bond custody and trading registration: On October 18, 2023, VSDC issued Initial Securities Registration Certificate No. 564/2023/GCNTPRLVSDC. On November 1, 2023, the Hanoi Stock Exchange (HNX) issued Notice No. 4335/TB-SGDHN regarding the trading registration of bond KHGH2123001 and Notice No. 4336/TB-SGDHN regarding the first trading date of bond KHGH2123001 being November 6, 2023.

• Regarding principal and interest payment of bonds: Based on documents provided by the Company, by the time of completing the early repurchase of all bonds with code KHGH2123001 (March 3, 2025), the Company had paid interest in full to NĐT with a total amount of 116,569,571,249 VND.

• Regarding the use of proceeds from PCB issuance:

According to the bank statement of the Company's account receiving bond purchase funds at Bao Viet Joint Stock Commercial Bank (BVB) - Phu My Hung Branch, the Company received 300,000,000,000 VND in bond purchase funds from October 5, 2021, to December 9, 2021.

According to the Report on the Use of Proceeds from Bond Issuance for bonds with remaining debt as of December 31, 2023, audited by An Viet Audit Joint Stock Company, from November 2021 to July 2022, the Company used the 300,000,000,000 VND received from the PCB issuance round with code KHGH2123001 to pay for development cooperation and distribution of the project with T&T Group, and to supplement working capital for business operations.

According to documents provided by the Company and the bank statement of the Company's account receiving bond purchase funds, from October 15, 2021, to December 10, 2021, the Company transferred all proceeds from the issuance to 04 payment accounts of the Company opened at Vietnam Joint Stock Commercial Bank for Industry and Trade (Techcombank), Joint Stock Commercial Bank Tieng Phong (TPBank), and Joint Stock Commercial Bank for Foreign Trade of Vietnam (MSB).

According to the statements of the 04 aforementioned accounts (after receiving funds from the Company's account receiving bond purchase funds at BVB); the result of considering the use of proceeds from the PCB issuance round with code KHGH2123001 shows that, from October 15, 2021, to December 11, 2021, the Company used 24,433,387,502 VND out of the total 300,000,000,000 VND received from the PCB issuance round with code KHGH2123001 to pay bond interest, pay taxes, purchase equipment, air conditioning costs, shipping fees, advertising, buy tables and chairs, pay salaries, and other operational expenses of the Company, which was not consistent with the plan previously disclosed to NĐT in the ID document regarding the issuance of bonds via private method dated September 28, 2021, by the Company, which was to increase the scale of real estate brokerage activities and Exclusive Development and Distribution Cooperation for Phase 1.1 of the T&T City Millennia Project; this did not comply with the regulations at Clause 2, Article 5 of Decree No. 153/2020/NĐ-CP "The use of capital raised from the issuance of bonds by the enterprise must ensure compliance with the purpose according to the issuance plan and the content of information disclosed to NĐT."

(3) 2021 PCB issuance Round 02, value 300 billion VND

• Regarding the issuance plan: According to the ID document dated December 20, 2021, regarding the issuance of bonds via private method, the Company issued bonds according to BOD Resolution No. 44/2021/NQ-HĐQT dated December 7, 2021, and the accompanying issuance plan (Bond code: KHGH2123002; total number of bonds issued: 300,000 bonds; par value: 1,000,000 VND; total issuance value: 300,000,000,000 VND; term: 18 months from the issuance date; bond type: Non-convertible bond, without warrants, secured by assets; Interest payment: Every 03 months; fixed interest rate 12%/year; capital use plan: To perform deposits for projects that the Company's affiliated companies distribute, including: One Verandah Project, The River Thu Thiem Project, The Ocean Villas Quy Nhon Project, The 9 Stellar Project, Lumiere Riverside Project, and Masterise Centre Point Project).

• Regarding the offer result and NĐT owning bonds: According to the ID document dated March 15, 2022, regarding the result of private bond issuance and documents provided by the Company, it shows: The Company successfully issued 300,000 bonds to 71 individual NĐT with a total value of 300,000,000,000 VND; Issuance date: December 22, 2021; Maturity date: June 22, 2023.

The Company provided documents identifying the professional securities investors of the 71 NĐT participating in buying the privately issued shares (confirmed by the securities company as professional securities investors, the time of identifying professional investors from January 5, 2021, to March 10, 2022, or having a securities business certificate according to regulations).

• Regarding bond custody and trading registration: On October 25, 2023, VSDC issued Initial Securities Registration Certificate No. 641/2023/GCNTPRLVSDC. On November 1, 2023, HNX issued Notice No. 4337/TB-SGDHN regarding the trading registration of bond KHGH2123002 and Notice No. 4338/TB-SGDHN regarding the first trading date of bond KHGH2123002 being November 6, 2023.

• Regarding principal and interest payment of bonds: Based on documents provided by the Company, it shows that, by the time of bond maturity for code KHGH2123002 (maturity date June 22, 2024), the Company had paid principal and interest in full to NĐT with a total principal amount of 300,000,000,000 VND and a total interest amount of 89,004,531,439 VND.

• Regarding the use of proceeds from PCB issuance:

According to the bank statement of the Company's account opened at Vietinbank, the Company received 300,000,000,000 VND in bond purchase funds from December 1, 2021, to March 31, 2022.

According to the Report on the Use of Proceeds from Bond Issuance for bonds with remaining debt as of December 31, 2023, audited by An Viet Audit Joint Stock Company, from January 2022 to March 2022, the Company used the 300,000,000,000 VND received from the PCB issuance round with code KHGH2123002 to perform deposits for projects that the Company's affiliated companies distribute.

According to documents provided by the Company and the bank statement of the account receiving bond purchase funds, from January 7, 2022, to February 21, 2022, the Company used 300,000,000,000 VND to deposit for projects Masteri Centre Point, Lumiere Riverside, One Verandah, The River Thu Thiem, The 9 Stellar, and The Ocean Villas Quy Nhon.

2.2.2. Regarding 05 rounds of PCB issuances in 2023, 2024, and 2025

During the inspection period, the Company conducted 01 round of PCB issuance in 2023, 01 round of PCB issuance in 2024, 02 rounds of PCB issuance in 2025, and 01 round of PCB issuance in 2026, specifically:

(1) 2023 PCB issuance round, value 240 billion VND

• Regarding the issuance plan: According to the ID document dated September 28, 2023, regarding the issuance of bonds via private method, the Company conducted issuance according to BOD Resolution No. 06/2023/NQ-HĐQT dated September 28, 2023, with the accompanying issuance plan (Bond code: KHGH2328001; total number of bonds issued: 2,400 bonds; par value: 100,000,000 VND; total issuance value: 240,000,000,000 VND; term: 60 months from the issuance date; bond type: Non-convertible bond, without warrants, secured by payment guarantee of a credit institution; Interest payment: Every 06 months; fixed interest rate: max 13.5%/year for the first 2 interest calculation periods, subsequent interest calculation periods will calculate interest rate equal to the savings deposit rate for individual customers for a 13-month term; capital use plan: To implement the program, project of cooperation investment in the High-rise Apartment Project, at Nhon Duc Commune, Nha Be District, Ho Chi Minh City, where Giao Hưởng Xanh Limited Liability Company is the investor according to the Investment Cooperation Contract No. HD01/2023/HĐHT/GHX-KHG dated August 1, 2023).

• Regarding the offer result and NĐT owning bonds: According to the ID document dated October 23, 2023, regarding the result of bond issuance via private method and documents provided by the Company, it shows: The Company successfully issued 2,400 bonds to 01 organizational NĐT (Ho Chi Minh City Development Joint Stock Commercial Bank - Long An Branch (HDBank)) with a total value of 240,000,000,000 VND; Issuance date: September 29, 2023; Maturity date: September 29, 2028.

• Regarding bond custody and trading registration: On December 13, 2023, VSDC issued Securities Registration Certificate No. 954/2023/GCNTPRL-VSDC. On December 22, 2023, HNX issued Notice No. 5495/TB-SGDHN regarding the trading registration of the bond and Notice No. 5496/TB-SGDHN regarding the first trading date of the bond being December 27, 2023.

• Regarding principal and interest payment of bonds: Based on documents provided by the Company, it shows that, by the time of early repurchase of bond code KHGH2328001 (repurchase date...

before the maturity date of 26/5/2026), the Company has made 06 interest payments to investors with a total amount of 82,529,753,787 VND. The Company has executed the repurchase of all bonds with code KHGH2328001 according to the Board of Directors Resolution No. 07/2026/NQ-HĐQT dated 22/4/2026 on 26/5/2026.

• Regarding the use of proceeds from the issuance of private corporate bonds (TPDNRL):
  According to the statement of account for receiving bond purchase funds opened by the Company at HDBank, the Company received 240,000,000,000 VND in bond purchase funds on 29/9/2023.
  According to the Report on the use of proceeds from the bond issuance regarding bonds with outstanding debt from 01/01/2025 to 31/12/2025, audited by An Viet Accounting Joint Stock Company, the Company has used the entire 240,000,000,000 VND received from the issuance of bond code KHGH2328001 according to the issuance plan approved by the Board of Directors.

According to the documents provided by the Company and the statement of account for receiving bond purchase funds, on 03/10/2025 and 19/10/2023, the Company used 240,000,000,000 VND to pay investment cooperation capital to Green Symphony Joint Stock Company according to Contract No. HD01/2023/HĐHT/GHX-KHG dated 01/8/2023. On 19/10/2023, 04/12/2023, and 20/6/2024, Green Symphony Joint Stock Company used 240,000,000,000 VND received from KHG to pay advances, preparatory work, construction measures, and material collection for the Hochiminh City Nha Be District Nhơn Đức Apartment Building Project.

(2) 2024 Private Corporate Bond (TPDNRL) Issuance Round, Value 250 Billion VND

• Regarding the issuance plan: According to the Information Disclosure Document (CBTT) dated 18/6/2024 of the Company regarding the issuance of bonds by private method, the Company implements issuance according to Board of Directors Resolution No. 06/2023/NQ-HĐQT dated 28/9/2023, attached with the issuance plan, and Decision No. 110/2024/QĐ-KHL dated 18/6/2024 regarding the implementation of private corporate bond issuance (Bond code: KHGH2429001; total number of bonds issued: 2,500 bonds; face value: 100,000,000 VND; total issuance value: 250,000,000,000 VND; term: 60 months from the issuance date; bond type: Non-convertible corporate bonds, not accompanied by warrants, secured by payment guarantee of a credit institution; Interest payment 06 months/time, fixed interest rate: maximum 12.5%/year for the first 2 interest calculation periods, subsequent interest calculation periods will calculate interest based on 13-month personal savings deposit rates; use of funds plan: Implement investment cooperation program/project into the Apartment Building Project, at Nhơn Đức commune, Nhà Bè district, Hochiminh City, managed by Green Symphony Joint Stock Company according to Investment Cooperation Contract No. HD01/2023/HĐHT/GHX-KHG dated 01/8/2023.

• Regarding the sales result and bond-holding investors: According to the Information Disclosure Document (CBTT) dated 26/6/2024 regarding the result of issuing bonds by private method and documents provided by the Company, it shows: The Company successfully issued 2,500 bonds to 01 institutional investor (HDBank) with a total value of 250,000,000,000 VND; Issuance date: 20/6/2024; Maturity date: 20/6/2029.

• Regarding bond custody and transaction registration: On 18/7/2024, VSDC issued Securities Registration Certificate No. 230/2024/GCNTPRL-VSDC. On 15/8/2024, HNX issued Notice No. 3753/TB-SGDHN regarding the registration of bond transactions and Notice No. 3754/TB-SGDHN regarding the first trading date of the bond being 20/8/2024.

• Regarding principal and interest payment of bonds: Based on documents provided by the Company, as of the time of early repurchase of bond code KHGH2429001 (early repurchase date is 26/5/2026), the Company has made 04 interest payments to investors with a total amount of 60,717,123,288 VND. The Company has executed the repurchase of all bonds with code KHGH2429001 according to the Board of Directors Resolution No. 07/2026/NQ-HĐQT dated 22/4/2026 on 26/5/2026.

• Regarding the use of proceeds from the issuance of private corporate bonds (TPDNRL):
  According to the statement of account for receiving bond purchase funds opened by the Company at HDBank, the Company received 250,000,000,000 VND in bond purchase funds on 20/6/2024.
  According to the Report on the use of proceeds from the bond issuance regarding bonds with outstanding debt as of 31/12/2024, audited by An Viet Accounting Joint Stock Company, the Company has used the entire 250,000,000,000 VND received from the issuance of bond code KHGH2429001 according to the issuance plan approved by the Board of Directors.

According to the documents provided by the Company and the statement of account for receiving bond purchase funds, on 20/6/2024, the Company used 250,000,000,000 VND to pay investment cooperation capital to Green Symphony Joint Stock Company according to Contract No. HD01/2023/HĐHT/GHX-KHG dated 01/8/2023. On 20/6/2024, Green Symphony Joint Stock Company used 250,000,000,000 VND received from KHG to make advances for contracts related to the Hochiminh City Nha Be District Nhơn Đức Apartment Building Project.

(3) 2025 Private Corporate Bond (TPDNRL) Issuance Round, Value 80 Billion VND

• Regarding the issuance plan: According to the Information Disclosure Document (CBTT) dated 29/9/2025 of the Company regarding the issuance of bonds by private method, the Company implements issuance according to Board of Directors Resolution No. 06/2025/NQ-HĐQT dated 29/9/2025, attached with the issuance plan (Bond code: KHG12501; total number of bonds issued: 800 bonds; face value: 100,000,000 VND; total issuance value: 80,000,000,000 VND; term: 60 months from the issuance date; bond type: Standard corporate bonds, non-convertible, not accompanied by warrants, secured by payment guarantee of a credit institution; Interest payment 06 months/time, fixed interest rate: maximum 13.5%/year for the first 2 interest calculation periods, subsequent interest calculation periods will calculate interest based on 13-month personal savings deposit rates; use of funds plan: Implement investment cooperation program/project into the Apartment Building Project, at Nhơn Đức commune, Nhà Bè district, Hochiminh City, managed by Green Symphony Joint Stock Company according to Investment Cooperation Contract No. HD01/2023/HĐHT/GHX-KHG dated 01/8/2023.

• Regarding the sales result and bond-holding investors: According to the Information Disclosure Document (CBTT) dated 08/10/2025 regarding the result of issuing bonds by private method and documents provided by the Company, it shows: The Company successfully issued 800 bonds to 01 institutional investor (HDBank) with a total value of 80,000,000,000 VND; Issuance date: 02/10/2025; Maturity date: 02/10/2030.

• Regarding bond custody and transaction registration: On 27/10/2025, VSDC issued Securities Registration Certificate No. 387/2025/GCNTPRL-VSDC. On 05/11/2025, HNX issued Notice No. 4819/TB-SGDHN regarding the registration of bond transactions and No. 4820/TB-SGDHN regarding the first trading date of the bond being 10/11/2025.

• Regarding principal and interest payment of bonds: Based on documents provided by the Company, as of the time of early repurchase of bond code KHG12501 (early repurchase date is 26/5/2026), the Company has made 02 interest payments to investors with a total amount of 6,983,013,698 VND. The Company has executed the repurchase of all bonds with code KHG12501 according to the Board of Directors Resolution No. 07/2026/NQ-HĐQT dated 22/4/2026 on 26/5/2026.

• Regarding the use of proceeds from the issuance of private corporate bonds (TPDNRL):
  According to the statement of account for receiving bond purchase funds opened by the Company at HDBank, the Company received 80,000,000,000 VND in bond purchase funds on 02/10/2025.
  According to the Report on the use of proceeds from the bond issuance regarding bonds with outstanding debt from 01/01/2025 to 31/12/2025, audited by An Viet Accounting Joint Stock Company, the Company has used the entire 80,000,000,000 VND received from the issuance of bond code KHG12501 according to the issuance plan approved by the Board of Directors.

According to the documents provided by the Company and the statement of account for receiving bond purchase funds, on 03/10/2025, the Company used 80,000,000,000 VND to pay investment cooperation capital to Green Symphony Joint Stock Company according to Contract No. HD01/2023/HĐHT/GHX-KHG dated 01/8/2023. On 03/10/2025, Green Symphony Joint Stock Company used 80,000,000,000 VND received from KHG to pay the first installment for initial preparatory work for the Hochiminh City Nha Be District Nhơn Đức Apartment Building Project and to pay for preparation, equipment and material collection at the construction site, and construction measures.

(4) 2025 Private Corporate Bond (TPDNRL) Issuance Round 2, Value 80 Billion VND

• Regarding the issuance plan: According to the Information Disclosure Document (CBTT) dated 01/12/2025 of the Company regarding the issuance of bonds by private method, the Company implements issuance according to Board of Directors Resolution No. 06/2025/NQ-HĐQT dated 29/9/2025, attached with the issuance plan (Bond code: KHG12502; total number of bonds issued: 800 bonds; face value: 100,000,000 VND; total issuance value: 80,000,000,000 VND; term: 60 months from the issuance date; bond type: Standard corporate bonds, non-convertible, not accompanied by warrants, secured by payment guarantee of a credit institution, with fixed interest rate and combined floating interest rate, establishing direct repayment obligation of TCPH; Interest payment 06 months/time, fixed interest rate: maximum 13.5%/year for the first 2 interest calculation periods, subsequent interest calculation periods will calculate interest based on 13-month personal savings deposit rates; use of funds plan: Implement investment cooperation program/project into the Apartment Building Project, at Nhơn Đức commune, Nhà Bè district, Hochiminh City, managed by Green Symphony Joint Stock Company according to Investment Cooperation Contract No. HD01/2023/HĐHT/GHX-KHG dated 01/8/2023.

• Regarding the sales result and bond-holding investors: According to the Information Disclosure Document (CBTT) dated 08/12/2025 regarding the result of issuing bonds by private method and documents provided by the Company, it shows: The Company successfully issued 800 bonds to 01 institutional investor (HDBank) with a total value of 80,000,000,000 VND; Issuance date: 03/12/2025; Maturity date: 03/12/2030.

• Regarding bond custody and transaction registration: On 31/12/2025, VSDC issued Securities Registration Certificate No. 515/2025/GCNTPRL-VSDC. On 07/4/2026, HNX issued Notice No. 1462/TB-SGDHN regarding the registration of bond transactions and Notice No. 1463/TB-SGDHN regarding the first trading date of the bond being 10/4/2026.

• Regarding principal and interest payment of bonds: Based on documents provided by the Company regarding the status of principal and interest payment, interest accrued from the time of bond issuance to the time of early repurchase of bond code KHG12502, the Company paid interest along with the early repurchase amount to the bond-holding organization (HDBank) on 26/5/2026; the interest amount is 5,148,493,150 VND. The Company has executed the repurchase of all bonds with code KHG12502 according to the Board of Directors Resolution No. 07/2026/NQ-HĐQT dated 22/4/2026 on 26/5/2026.

• Regarding the use of proceeds from the issuance of private corporate bonds (TPDNRL):
  According to the statement of account for receiving bond purchase funds opened by the Company at HDBank, the Company received 80,000,000,000 VND in bond purchase funds on 03/12/2025.
  According to the Report on the use of proceeds from the bond issuance regarding bonds with outstanding debt from 01/01/2025 to 31/12/2025, audited by An Viet Accounting Joint Stock Company, the Company has used 90,000,000,000 VND received from the issuance of bond code KHG12502 according to the issuance plan approved by the Board of Directors.

According to the documents provided by the Company and the statement of account for receiving bond purchase funds, on 04/12/2025, the Company used 80,000,000,000 VND to pay investment cooperation capital to Green Symphony Joint Stock Company according to Contract No. HD01/2023/HĐHT/GHX-KHG dated 01/8/2023. According to documents provided by the Company, Green Symphony Joint Stock Company used 80,000,000,000 VND received from KHG to pay land use fees according to Notice No. 13527/TB-TPHCM dated 01/12/2025 of the Hochiminh City Tax Department.

(5) 2026 Private Corporate Bond (TPDNRL) Issuance Round, Value 190 Billion VND

• Regarding the issuance plan: According to the Information Disclosure Document (CBTT) dated 18/12/2025 of the Company regarding the issuance of bonds by private method, the Company implements issuance according to Board of Directors Resolution No. 06/2025/NQ-HĐQT dated 29/9/2025, attached with the issuance plan (Bond code: KHG12503; total number of bonds issued: 1,900 bonds; face value: 100,000,000 VND; total issuance value: 190,000,000,000 VND; term: 60 months from the issuance date; bond type: Standard corporate bonds, non-convertible, not accompanied by warrants, secured by payment guarantee of a credit institution, with fixed interest rate and combined floating interest rate, establishing direct repayment obligation of TCPH; Interest payment 06 months/time, fixed interest rate: maximum 13.5%/year for the first 2 interest calculation periods, subsequent interest calculation periods will calculate interest based on 13-month personal savings deposit rates; use of funds plan: Implement investment cooperation program/project into the Apartment Building Project, at Nhơn Đức commune, Nhà Bè district, Hochiminh City, managed by Green Symphony Joint Stock Company according to Investment Cooperation Contract No. HD01/2023/HĐHT/GHX-KHG dated 01/8/2023.

On 03/02/2026, the Company issued Decision No. 10/2026/QĐ-KHL of the General Director regarding the adjustment of Bond code KHG12503 of KHG, thereby approving the adjustment of bond code KHG12503 to KHG12601.

• Regarding the sales result and bond-holding investors: According to the Information Disclosure Document (CBTT) dated 08/01/2026 regarding the result of issuing bonds by private method and documents provided by the Company, it shows: The Company successfully issued 1,900 bonds to 01 institutional investor (HDBank) with a total value of 190,000,000,000 VND; Issuance date: 06/01/2026; Maturity date: 06/01/2031.

• Regarding bond custody and transaction registration: On 12/01/2026, VSDC issued Securities Registration Certificate No. 42/2026/GCNTPRL-VSDC. On 07/4/2026, HNX issued Notice No. 1460/TB-SGDHN regarding the registration of bond transactions and Notice No. 1461/TB-SGDHN regarding the first trading date of the bond being 10/4/2026.

• Regarding principal and interest payment of bonds: Based on documents provided by the Company regarding the status of principal and interest payment, interest accrued from the time of bond issuance to the time of early repurchase of bond code KHG12601, the Company paid interest along with the early repurchase amount to the bond-holding organization (HDBank) on 26/5/2026; the interest amount is 9,838,356,165 VND. The Company has executed the repurchase of all bonds with code KHG12601 according to the Board of Directors Resolution No. 07/2026/NQ-HĐQT dated 22/4/2026 on 26/5/2026.

• Regarding the use of proceeds from the issuance of private corporate bonds (TPDNRL):
  According to the statement of account for receiving bond purchase funds opened by the Company at HDBank, the Company received 190,000,000,000 VND in bond purchase funds on 07/01/2026.
  According to the documents provided by the Company and the statement of account for receiving bond purchase funds, on 07/01/2026, the Company used 190,000,000,000 VND to pay investment cooperation capital to Green Symphony Joint Stock Company according to Contract No. HD01/2023/HĐHT/GHX-KHG dated 01/8/2023. According to documents provided by the Company, Green Symphony Joint Stock Company used 190,000,000,000 VND received from KHG to pay for equipment and material collection at the construction site and to pay for rough structure construction costs for the Apartment Building Project.

2.3. Regarding the implementation of information disclosure obligations of TCPH for Private Corporate Bonds (TPDNRL)

Based on the monitoring results of HNX at Document No. 1615/SGDHN-TTTP dated 24/6/2026 and the inspection results of the Inspection Team, basically the Company complies with the information disclosure obligations of TCPH for Private Corporate Bonds (TPDNRL). However, the Company has not fully disclosed information regarding the principal payment of bond code KHGH2123001 in the Information Disclosure Documents (CBTT) regarding the status of principal and interest payment for the reporting year 2024 and 06 months of 2025, specifically:

• The Company has executed the early repurchase of 59,999 bonds KHGH2123001 (total value 59,999,000,000 VND) on 05/12/2024; however, the Company did not present the principal payment of 59,999,000,000 VND for bond KHGH2123001 in the Information Disclosure Document (CBTT) regarding the status of principal and interest payment for the reporting year 2024 (reporting period from 01/01/2024 to 31/12/2024);
• The Company has executed the early repurchase of 240,001 bonds KHGH2123001 (total value 240,001,000,000 VND) on 17/01/2025, 14/02/2025, and 03/3/2025; however, the Company did not present the principal payment of 240,001,000,000 VND for bond KHGH2123001 in the Information Disclosure Document (CBTT) regarding the status of principal and interest payment for the reporting 06 months of 2025 (reporting period from 01/01/2025 to 30/6/2025).

3. Conclusion

3.1. Conclusion on inspection contents

During the inspection period, the Company had some violations and shortcomings stated in Section 2 of the Inspection Conclusion, specifically:

• The Company disclosed information late on the information disclosure system of the State Securities Commission, on the electronic information page of HOSE, and on the Company's electronic information page regarding the Explanation of Profit Difference after Tax in the 2023 Financial Statements before and after audit, violating Clause 4, Article 14 of Circular No. 96/2020/TT-BTC;

• Did not ensure that the information in the private bond offering or issuance dossier was accurate, truthful, verifiable, and contained all required contents according to regulations (At Clause 5 "Conditions, terms of bonds" in Section III "Information about the bond offering round" of the Information Disclosure Document (CBTT) before the issuance round of bond code BOND.KHL2020.01 dated 10/02/2020 did not mention information about bond transactions; in Part 2 "Detailed information about the bond issuance round" of the Information Disclosure Document (CBTT), the Company did not present content about Related Partners (including name, registered office address, brief introduction of related partners: underwriting organization or issuance agency, bondholder representative...), violating Clause 8, Article 6 of Decree No. 163/2018/NĐ-CP;

• The Company disclosed information incompletely according to legal regulations (The Company did not present fully the data, transaction values with related parties in the Report on Corporate Governance Status for the first 6 months of 2023, year 2023, first 6 months of 2025, and year 2025 according to Clause 2.VII of Appendix V form issued together with Circular No. 96/2020/TT-BTC and the status of principal and interest payment of bonds in the Information Disclosure Documents (CBTT) regarding the status of principal and interest payment for the reporting year 2024 and 06 months of 2025), violating Clause 1, Article 4 of Circular No. 96/2020/TT-BTC;

• The Company used proceeds from the private securities offering round inconsistently with the content disclosed to investors (From 15/10/2021 to 11/12/2021, the Company used 24,433,387,502 VND out of the total 300,000,000,000 VND received from the private corporate bond issuance round code KHGH2123001 to pay for the Company's operational costs (Bond interest payment, tax payment, equipment purchase, air conditioning costs, postage fees, advertising, table and chair purchase, salary payment, and other operational costs of the Company), not consistent with the plan disclosed to investors in the Information Disclosure Document (CBTT) regarding the issuance of bonds by private method dated 28/9/2021 of the Company, which was to increase the scale of real estate brokerage operations and Cooperation Development, exclusive distribution phase 1.1 of the T&T City Millennia project), violating Clause 2, Article 5 of Decree No. 153/2020/NĐ-CP.

3.2. Responsibilities

The Company, Board of Directors, General Director, leaders, and employees of relevant departments are responsible for the violations regarding the information disclosure obligations of the public company, the organization issuing Private Corporate Bonds (TPDNRL), and the use of proceeds from the securities offering round (disclosing information late according to legal regulations; Not ensuring that the information in the private bond offering or issuance dossier was accurate, truthful, verifiable, and contained all required contents according to regulations; Disclosing information incompletely according to legal regulations; Using proceeds from the private securities offering round inconsistently with the content disclosed to investors).

4. Handling measures within authority already applied

On 22/7/2026, the Inspection Team established Administrative Violation Record No. 302/BB-VPHC regarding the Company's violations. The State Securities Inspectorate has reported and recommended the State Securities Commission to handle administrative penalties against the Company according to regulations on administrative penalties in the securities field.

• Regarding the violation of disclosing information incompletely according to legal regulations: On 30/7/2026, the State Securities Inspectorate issued Administrative Penalty Decision No. 419/QĐ-XPHC against the Company, specifically: Fined 65,000,000 VND (Sixty-five million VND) according to Clause 3, Point a, Article 42 of Decree No. 156/2020/NĐ-CP, amended and supplemented by Clause 16, Article 1 of Decree No. 306/2025/NĐ-CP;

• Regarding the violation of using proceeds from the private securities offering round inconsistently with the content disclosed to investors: On 30/7/2026, the State Securities Inspectorate issued Decision to Implement Remedial Measures No. 420/QĐ-KPHQ against the Company (did not issue an administrative penalty decision due to the expiration of the statute of limitations for handling penalties according to Clause 1, Point a, Article 6 of the Law on Handling Administrative Violations, amended and supplemented by Clause 1, Article 1 of Law No. 88/2025/QH15, belonging to the case of not issuing a penalty decision according to Clause 1, Point c, Article 65 of the Law on Handling Administrative Violations and Clause 2, Article 65 of the Law on Handling Administrative Violations, amended and supplemented by Clause 33, Article 1 of Law No. 67/2020/QH14).

Remedial measure: Mandatory repurchase of offered and issued securities; refund to investors the money for purchasing securities or deposit money (if any) plus interest calculated at the interest rate stated on the bonds or the interest rate for non-term bank deposits that the violating organization or individual opened an account to receive money for purchasing securities or deposit money at the time the decision applying this measure takes effect, within 15 days from the date of receiving the investor's request (for bond code KHGH2123001). The time limit for investors to submit requests is a maximum of 60 days from the date the decision applying this measure takes effect, according to Clause 9, Point a, Article 8 of Decree No. 156/2020/NĐ-CP.

• Regarding the violation of the Company disclosing information late according to legal regulations and Not ensuring that the information in the private bond offering or issuance dossier was accurate, truthful, verifiable, and contained all required contents according to regulations, belonging to the case of not issuing an administrative penalty decision due to the expiration of the statute of limitations for handling penalties according to Clause 1, Point a, Article 6 of the Law on Handling Administrative Violations, amended and supplemented by Clause 1, Article 1 of Law No. 88/2025/QH15 and Clause 1, Point c, Article 65 of the Law on Handling Administrative Violations.

5. Recommendations for handling measures

The State Securities Inspectorate recommends the Company to urgently take measures to rectify and overcome the violations and shortcomings after inspection and ensure full compliance with the obligations of a public company, organization issuing Private Corporate Bonds (TPDNRL), specifically as follows:

• Regarding information disclosure obligations:

• Review and rectify the implementation of information disclosure obligations, ensuring that information is disclosed fully, accurately, and on time according to regulations;
• Overcome and submit information disclosure content to HNX the Information Disclosure Document (CBTT) before the issuance round of bond code BOND.KHL2020.01 dated 10/02/2020 with full content according to regulations.
• Overcome and disclose fully the data, transaction values with related parties in the Report on Corporate Governance Status for the first 6 months of 2023, year 2023, first 6 months of 2025, year 2025, and the status of principal and interest payment of bonds in the Information Disclosure Documents (CBTT) regarding the status of principal and interest payment for the reporting year 2024 and 06 months of 2025

51/KL-TT Report on principal and interest repayment for the reporting year 2024 and the first 6 months of 2025.

• Regarding the offering and issuance of securities: Implement remedial measures for the act of using funds obtained from a private securities offering for purposes other than those disclosed to investors. Ensure that the information in the offering or corporate bond issuance dossier is accurate, truthful, verifiable, and contains all required contents as prescribed. Furthermore, ensure strict compliance with legal regulations in the offering and issuance of securities, and bear legal responsibility for the accuracy, truthfulness, and completeness of all reported contents and documents provided regarding the use of funds raised from the securities offering.

The State Securities Commission requires the Company to immediately implement corrective and remedial measures following the inspection within a period of 30 days from the date of signing the inspection conclusion. The result report must be sent to the State Securities Commission within 05 days from the date the correction and remediation period expires.