Supplemental Submission Pursuant to Item 16I(a) of Form
20-F
NaaS Technology Inc. (the Company) is submitting to the U.S. Securities and
Exchange Commission (the SEC) the following information as required under Item 16I(a) of Form 20-F in relation to the Holding Foreign Companies Accountable Act (the HFCAA).
On June 14, 2022, Education Cayman Ltd, our predecessor, was conclusively identified by the SEC as a Commission-Identified Issuer
pursuant to the HFCAA because it filed an annual report on Form 20-F for the year ended December 31, 2021 with the SEC on May 13, 2022 with an audit report issued by BDO China Shu Lun Pan Certified
Public Accountants LLP, a registered public accounting firm retained by the Company for the preparation of the audit report on the Companys financial statements included therein. BDO China Shu Lun Pan Certified Public Accountants LLP is a
registered public accounting firm headquartered in mainland China, a jurisdiction where the Public Company Accounting Oversight Board (the PCAOB) determined that it was unable to inspect or investigate completely registered public
accounting firms headquartered there, including BDO China Shu Lun Pan Certified Public Accountants LLP, until December 2022 when the PCAOB vacated its previous determination.
In response to Item 16I(a) of Form 20-F, the Company believes that the following information
establishes that it is not owned or controlled by a government entity in mainland China.
The Company is controlled by Newlinks Technology
Limited, which beneficially owned 248,888,073 Class B ordinary shares and 1,398,659,699 Class C ordinary shares of the Company, representing 75.0% of the total issued and outstanding ordinary shares and 90.6% of the total voting power of
the Company as of March 31, 2023. To the Companys knowledge, Newlinks Technology Limited is not owned or controlled by a government entity in mainland China.
Mr. Zhen Dai, founder and chairman of the Company, beneficially owned 13.5% of the total issued and outstanding ordinary shares of the
Company, representing 43.2% of the total voting power of the Company, as of March 31, 2023. The directors and senior management of the Company, including Mr. Zhen Dai, beneficially owned 17.9% of the total issued and outstanding ordinary
share of the Company, representing 46.0% of the total voting power of the Company.