ACM Research Inc

Evaluation of Disclosure Controls and Procedures

Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, evaluated the effectiveness of our disclosure controls and procedures pursuant to Rule 13a-15 under the Securities Exchange Act of 1934, or the Exchange Act, as of June 30, 2024. In designing and evaluating the disclosure controls and procedures, our management recognizes that any controls and procedures, no matter how well designed and operated, can provide only reasonable assurance of achieving the desired control objectives. In addition, the design of disclosure controls and procedures must reflect the fact that there are resource constraints and that our management is required to apply its judgment in evaluating the benefits of possible controls and procedures relative to their costs.

Based on such evaluation, our Chief Executive Officer and Chief Financial Officer concluded that, as of June 30, 2024, our disclosure controls and procedures were effectiveto provide reasonable assurance that information we are required to disclose in reports that we file or submit under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in the Securities and Exchange Commission rules and forms, and that such information is accumulated and communicated to our management, including our Chief Executive Officer and Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosure.

Changes in Internal Control Over Financial Reporting

There were no changes in our internal control over financial reporting that occurred during the quarter ended June 30, 2024, that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting, except the remediation efforts as described below.

Remediation Efforts

As previously reported, during the quarter ended March 31, 2024, management ident ified a deficiency constituting a material weakness in our internal control over financial reporting related to the design and implementation of information technology general controls ("ITGCs") related to the implementation of our new enterprise resource planning ("ERP") system in mainland China utilized in the preparation of our consolidated financial statements. Specifically, we did not (1) establish and maintain adequate pre-approval policy and process for the system changes; and (2) maintain a complete system change log.

Our management, under the oversight of our Audit Committee, has implemented the following remediation measures designed to improve our internal control over financial reporting and to remediate the material weakness noted above:

•Corp orate Governance and Oversight: We have implemented a plan to stabilize the ERP system and correct the identified control deficiency. Additionally, we have engaged an outside professional firm to assist management overseeing the efforts to design, implement and ensure the ongoing execution of our ITGCs of the ERP system.

•Change Management: We have designed and implemented an improved process for requesting, testing, authorizing, and reviewing system changes. This implementation includes enabling a complete activity log of accessing and/or making changes to the system and the addition of detection controls which include the review of such activity logs. We have also established policies and processes surrounding the testing, approval, and implementation of system changes to ERP system.

•End User Training: We have enhanced the training of our personnel regarding their roles and responsibilities within the ITGCs objectives and activities.

During the quarter ended June 30, 2024, we completed our testing of the operating effectiveness of internal controls impacted by these remediation efforts and concluded that as a result of the measures described above, the material weakness has been remediated and our internal control over financial reporting was effective as of June 30, 2024.