White Paper

Luminova Green Compute Limited White Paper

Luminova Green Compute Limited

Let every ray of sunlight lift humanity into a shared intelligent civilization

Full White Paper

Luminova Green Compute Limited White Paper

Online reading edition of the full white paper, formatted by chapter hierarchy.

Foreword

Foreword: A Letter to Future Co-Builders

Dear global partners, investors, and future fellow travelers:

Standing in 2026 and looking back, human civilization has undergone three profound energy paradigm shifts—from biomass to coal, from coal to oil and gas, and from oil and gas to renewables. Each shift changed not only how we obtain energy, but fundamentally reshaped the structure of production, patterns of life, and the boundaries of civilization.

Today, a fourth energy paradigm shift is underway. Its name is power-compute integration—energy is no longer merely the force that drives industrial machinery, but is directly converted into the digital productivity that powers artificial intelligence and an intelligent civilization. The significance of this transformation is no less than that of the steam engine to the Industrial Revolution or electricity to the Electrical Age.

Yet this transformation faces unprecedented resource constraints. The latest research from the International Energy Agency shows that global data center electricity consumption is projected to rise from approximately 485 terawatt-hours in 2025 to about 950 terawatt-hours in 2030—nearly doubling and accounting for roughly 3% of global electricity use by then—with AI-dedicated data centers growing even faster. The competition for compute is shifting from a single-chip contest to a systems competition spanning power, networking, cooling, capital, and operational capability.

This is the era in which Luminova was born.

A mission capable of uniting global participants cannot answer only how to make money—it must answer why we deserve shared belief. As the AI era reshapes the world order, the greatest challenge is not whether technology is powerful enough, but whether that power still belongs to all of humanity: to developed nations as well as emerging ones; to technology giants as well as ordinary households; to capital centers as well as those who change their fate through diligence, education, and long-term effort.

Luminova believes that the combination of clean energy, AI compute, and trusted digital infrastructure should not merely form new equipment and asset portfolios, but a sustainable value-creation system: sunlight converted into dispatchable clean power, power supporting real compute services, and operational data helping customers, partners, and regulators understand how value is created, how costs arise, and how responsibility is fulfilled.

Therefore, Luminova's mission is to make clean energy the foundation for humanity's shared entry into an intelligent civilization, so that every country, every community, and every ordinary household is not excluded from the future because of birthplace, wealth, or resource disparity.

This is a belief oriented toward all humanity: energy should not be a privilege of the few, compute should not become a new wall, and intelligent civilization should not create new divides. Sunlight belongs to Earth, and the future should belong to everyone willing to build it. Luminova seeks to unite long-term thinkers who believe development need not come at the environment's expense, that technology can serve the dignity of ordinary people, and that a cleaner, fairer, more participatory future is worth building together.

Verifiable product and service value can establish the first connection, but what truly inspires long-term companionship is a more stable consensus: technological progress should not leave ordinary people behind, energy transition should not serve only a few capital centers, and intelligent civilization should be built together by more people who are diligent, trustworthy, and believe in the future.

Luminova was founded on a simple yet firm belief: energy is not only a commodity, but a foundational condition for civilizational development. Around 2016, a founding team from energy, finance, and technology began asking how to combine the long-term asset capability of renewables, the growing demand for AI compute, and more transparent digital operations. The company thus established a long-term path—first validating the operating loop through real projects and real customers, then expanding value accessibility through trusted data, tiered services, and compliance tools.

Luminova began with strategic investment and operation of global new energy projects. Over ten years, it gradually formed three mutually reinforcing capabilities: renewable energy assets, modular AI compute centers, and enterprise compute services. In 2026, Luminova established its global headquarters in Hong Kong, marking its transition from a regional energy investment company to a global green compute infrastructure and enterprise services operator.

This is a white paper, and also an invitation—we invite you to join Luminova in building the most indispensable energy infrastructure of the digital civilization era.

Summary

Executive Summary: From Green Compute to Local Shared Value

Luminova is a green compute infrastructure operator built on renewable energy assets, with modular AI compute as its core operating capability and trusted data and compliant value management connecting global resources. The company focuses not on a single link in energy, compute, or digital technology, but on building a replicable synergistic system among real assets, real customers, and real operating data.

This system forms its operating foundation through enterprise-grade compute services: the energy layer provides dispatchable power and storage capability, compute centers execute training, inference, rendering, simulation, and other compliant computing tasks, and the enterprise service system handles demand assessment, resource allocation, delivery acceptance, metering and settlement, and ongoing service. Technical value must ultimately be validated through real customers, real tasks, and real collections.

For ordinary users, Luminova's goal is to lower the threshold for understanding and using green compute services—not to replace infrastructure financing with personal funds. The company plans to build long-term user relationships through standardized services, transparent information, appropriate limits, and local support; any arrangement linked to operating results must be implemented as an independent mechanism after completing local legal characterization, licensing, and risk disclosure.

Vietnam is Luminova's first demonstration market for parallel deployment of long-term user services, local capacity building, and community benefit. The Luminova "Million Green Power Plan" serves the commercial user ecosystem; the five-year community benefit plan serves verified beneficiaries. The two paths share local teams, education resources, and partner networks, but remain independent in eligibility, fund accounts, personal data, and performance evaluation; public benefit support is not conditional on purchasing, registering, referring, or promoting any commercial product.

Globally, Luminova will form a tiered structure of Hong Kong headquarters and professional platforms, regional companies, and project entities. Headquarters consolidates standards and resources; regional companies bear local operations and accountability; project entities isolate specific assets, contracts, and risks. Local financing, strategic investment, or public listing are optional outcomes after regional operations meet operating, audit, and governance thresholds—not prerequisites for expansion or value commitments to users.

This white paper thus answers five interconnected questions: why the AI era needs green compute; how Luminova forms a real operating loop; how ordinary users gain services and participation opportunities; how global capability translates into local value; and how enterprise growth stays aligned with community development without conflation.

Information Methodology Notes

Unless otherwise stated, company asset and project data in this white paper are based on company records as of Q1 2026, with status distinguished as operating, under construction, in early development, or under partnership exploration; data not independently audited or third-party verified should not be understood as audit conclusions. Roadmaps, user scale, community service scale, and capital arrangements are forward-looking targets subject to operating, licensing, funding, partnership, and market conditions.

Chapter

Chapter 1: Era Background: A Civilizational Turning Point

1.1 The Historical Logic of Energy Paradigm Shifts

Throughout human history, the way energy is obtained has defined the boundaries of civilization.

In pre-industrial times, biomass, hydropower, and wind were humanity's dominant energy sources; the scale and form of agrarian civilization remained constrained by the natural endowments of land and climate. In the First Industrial Revolution, coal powered the steam engine, factory systems were established, and humanity first broke through the limits of physical labor and natural motive force. The Second Industrial Revolution brought oil and electricity; internal combustion engines and power grids gave rise to mass urbanization and modern transport networks, fundamentally reshaping human perception of space and time. The Third Industrial Revolution, marked by nuclear energy and renewables, made informatization and globalization the themes of the age, yet energy supply remained centered on centralized systems.

Today, we stand at a critical juncture of the fourth paradigm shift. Its core characteristic is that the end point of energy is no longer end-use appliances, but computation itself—energy becomes AI's "food," and compute becomes energy's "value-added carrier."

The force of this transformation extends far beyond technology. Regions with abundant clean power will gain new opportunities to host AI infrastructure; companies that can organize energy, equipment, and enterprise services will form new industrial capabilities; and models that enable more users and communities to understand, use, and benefit from these opportunities may broaden the social foundation of the digital economy.

1.2 The Paris Agreement: A Global Framework for Energy Transition

In December 2015, the UN Climate Change Conference adopted the Paris Agreement, establishing the global climate goal of holding the increase in global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit it to 1.5°C. This milestone international agreement united the political consensus of more than 190 parties, marking the irreversible launch of the global energy system's transition toward low-carbon and clean development.

The Paris Agreement's core mechanism—Nationally Determined Contributions—requires each party to formulate and progressively raise its national climate action targets. Achieving temperature control goals requires expanding renewables while improving grid, storage, and end-use energy efficiency. The International Renewable Energy Agency proposes that global renewable energy installed capacity must reach approximately 11 terawatts by 2030—nearly triple the 2022 level.

This transition requires sustained investment in power sources, grids, storage, digital infrastructure, and energy efficiency upgrades. Global clean energy investment remains highly concentrated in developed economies and a few major markets; many emerging economies with favorable resource conditions simultaneously face insufficient capital, engineering capability, and long-term operational capacity.

Luminova responds to global energy transition through project practice in markets including China, Brazil, South Africa, and Malaysia. The company believes that only by combining long-term capital, engineering capability, enterprise demand, and local operations can clean energy move from installed capacity targets to stable power, digital services, employment, and industrial capability.

1.3 The Energy Dilemma of the AI Era: When Compute Hits Physical Limits

Global data centers are becoming one of the fastest-growing sectors of electricity demand. The International Energy Agency, in Key Questions on Energy and AI, projects that global data center electricity consumption will rise from approximately 485 terawatt-hours in 2025 to about 950 terawatt-hours in 2030; AI-dedicated data center electricity is growing significantly faster than data centers overall.

The impact of data centers varies significantly by region. Grid capacity, grid-connection timelines, equipment supply, cooling conditions, and renewable energy matching capability are jointly determining the siting of a new wave of compute infrastructure. For markets with energy resources but still-building digital infrastructure, this is both a development opportunity and a test of engineering and governance capability.

In multiple major markets, data center projects already face practical constraints such as grid-connection queues and extended delivery cycles for transformers and power generation equipment. Power is no longer merely a data center operating cost, but a core condition determining when projects come online, how large a deployment is possible, and whether services can be delivered stably.

Power now stands alongside chips, networks, and data as a key resource determining the pace of AI infrastructure development.

This shift is driving AI companies, cloud service providers, and large energy consumers to reassess power procurement, compute siting, and energy efficiency management. Renewables, storage, flexible loads, and long-term power purchase arrangements are moving from corporate sustainability topics to components of compute delivery capability.

1.4 The Global South: Strategic Anchor of the Green Compute Network

In the grand narrative of global energy transition and AI infrastructure, Global South countries are becoming irreplaceable strategic anchors. These regions possess exceptional renewable energy endowments—southwest China averages more than 2,200 hours of sunshine annually; Brazil's northeastern semi-arid region ranks among the world's highest in annual solar radiation; and the southern African plateau likewise holds world-class solar resources. At the same time, these countries are in a dual window of industrialization and digital transformation, with electricity demand closely synchronized with economic growth, providing broad market space for distributed energy infrastructure.

Hong Kong brings together international capital, professional services, cross-border trade networks, and technology innovation resources, supporting Luminova's global strategy, project financing, enterprise customer cooperation, risk governance, and regional resource allocation. The role of the Hong Kong headquarters is to connect global standards with regional execution—not to financialize the company's core business.

International capital and technology are accelerating into these emerging markets. In December 2025, Japan's Natural Energy and Google signed Malaysia's first Corporate Green Power Programme power purchase agreement. Japanese company MinebeaMitsumi and Thailand's Super Energy jointly built a tens-of-megawatt photovoltaic and storage project. Such international cooperation demonstrates that the Global South is becoming fertile ground for global green compute infrastructure investment.

Chapter

Chapter 2: Challenges of Our Era: Three Bottlenecks to Civilizational Progress

Luminova believes that global digital civilization development currently faces three systemic bottlenecks. These are not only industry issues, but civilizational questions determining whether humanity can enter the AI era sustainably.

2.1 Bottleneck One: Centralization of Compute Supply and Energy Constraints

Global AI compute infrastructure is highly concentrated—a few technology giants control the vast majority of high-end GPU resources and hyperscale data centers. This structure not only creates enormous energy pressure, but also causes uneven regional distribution of compute resources and excessively high access barriers.

According to industry research, capital expenditure by leading global technology companies is growing at double-digit annual rates; hyperscale centralized construction is pushing power supply tensions toward a breaking point. Gas turbine manufacturers have orders booked years ahead, and supply chains for transformers and other critical equipment remain tight.

However, compute should not be concentrated only in a few hyperscale centers. Luminova believes that modular deployment, regionalized services, and more flexible energy configuration can bring compute facilities closer to energy resources and enterprise demand, forming a more resilient supply network while ensuring security, networking, and delivery quality.

2.2 Bottleneck Two: One-Way Loss of Green Energy Value

Globally, renewable energy installed capacity continues to grow, yet some projects remain constrained by single sales channels, grid-connection limits, and load absorption capacity. Only by better connecting generation, storage, flexible loads, and long-term enterprise demand can green energy form more stable operating value.

Green certificates, carbon credits, and other environmental attributes can form supplementary value when ownership is clear, methods are applicable, and certification is complete, but they should not replace the operating foundation of power and compute services themselves. For small and medium projects, securing long-term customers, transparent contracts, and sustainable operations capability matters more.

Green energy value should be realized through multiple real business paths, maintaining clear boundaries in contracts, accounting, and environmental attributes to avoid double counting.

2.3 Bottleneck Three: Dual Gaps in Participation and Digital Capability

Every technological revolution redefines the gateway to opportunity. Gaps brought by AI and energy transition appear not only in who owns assets, but in who can access services, understand tools, acquire skills, and enter new employment systems.

Today, ordinary users struggle to understand how compute works and lack low-threshold, verifiable service entry points; disadvantaged households and resource-poor communities may simultaneously face insufficient devices, connectivity, education, and employment connections. The former need trusted products and local services; the latter need long-term capacity building independent of commercial sales.

Luminova therefore treats service accessibility and capability accessibility as two distinct yet mutually reinforcing responsibilities: expanding product and service reach based on genuinely operating green compute; and helping more people build long-term development capability through education, skills, employment, and community cooperation. The two types of action maintain boundaries in objects, rules, and governance, jointly pointing toward more inclusive digital infrastructure.

Chapter

Chapter 3: Luminova's Solution: An Enterprise-Grade Compute Network Powered by Green Energy

3.1 Core Loop: From Green Power to Paid Compute Services

Luminova's core solution organizes renewable energy assets, storage, GPU compute centers, and enterprise customer services into a verifiable operating chain. Green power provides cost and low-carbon foundations; GPU equipment converts power into computing capability; enterprise customers pay for actually used compute and supporting services; and operating revenue supports equipment maintenance, renewal, and network expansion.

Across projects, power may be used for grid sales, direct supply, or supporting compute loads according to contracts and operating conditions. Compute centers serve AI enterprises and other companies with computing needs, providing model training, inference, graphics rendering, industrial simulation, data processing, and customized computing services. Revenue comes from enterprise contracts, actual usage, and completed delivery—not from growth in ordinary user numbers.

Power-compute integration can improve power absorption and asset utilization efficiency, but does not mean the same kilowatt-hour can be sold twice. Luminova will distinguish ownership and revenue for power sales, compute services, and environmental attributes by project, fully accounting for equipment depreciation, power, cooling, networking, operations, taxes, and renewal reserves, validating the business model through actual cash flow.

3.2 Operating Architecture: Energy, Compute Centers, and Enterprise Services

Layer One: Energy and Infrastructure

Luminova deploys photovoltaic, storage, and supporting power facilities in markets with suitable resources and project conditions, configuring grid supplementation, dispatch, and backup capability for continuous compute operation. Site selection comprehensively evaluates irradiance, electricity prices, grid connection, land, networking, climate, cooling, maintenance, and local licensing—not investment decisions based on low electricity prices alone.

Layer Two: GPU Compute Centers

The company deploys a combination of centralized data halls and modular compute facilities, equipped with GPU servers, cooling, networking, security monitoring, and task scheduling systems. Compute centers allocate resources according to customer task performance, latency, data security, duration, and delivery requirements, and ensure service availability through equipment monitoring, failover, and maintenance plans.

Layer Three: Enterprise Services and Operations Management

Luminova's enterprise customer teams engage directly with AI companies, software and digital content firms, industrial and engineering customers, and other institutions with compliant computing needs. Service processes cover demand assessment, solution design, quotation and contracting, resource provisioning, task execution, usage metering, acceptance and settlement, and customer support; for data-sensitive tasks, the company implements access control, data isolation, and security responsibilities under contract.

The three-layer system forms a clear loop: energy and infrastructure determine supply capability; compute centers complete technical delivery; enterprise services convert technical capability into contracts and collections; and operating data in turn guides equipment utilization, customer structure, and expansion decisions.

3.3 Three Core Capabilities

Capability One: Coordinated Energy and Compute Planning

Luminova incorporates power sources, storage configuration, equipment loads, network conditions, and customer tasks into a single planning process, improving energy and equipment utilization while ensuring service quality.

Capability Two: Sustained Delivery for Enterprises

The company's competitiveness comes not only from owning GPUs, but from translating customer needs into executable solutions and delivering continuously. Customer structure, contract quality, equipment utilization, collection cycles, and renewal rates jointly determine compute center operating quality.

Capability Three: From Enterprise Revenue to Broader User and Community Value

Enterprise compute services form the revenue foundation; the Luminova "Million Green Power Plan" lowers the threshold for ordinary users to learn about the company and access digital services; regional teams build long-term user relationships; and community benefit plans bring education, skills, and employment opportunities to families in need. Together they form a value cycle of enterprise services creating an operating foundation, user services expanding social connection, and local capability strengthening long-term development.

Chapter

Chapter 4: Global Practice: Asset Foundation and Service Capability

4.1 Luminova's Founding Purpose

Luminova was born from the founding team's deep insight into global energy transition and digital economy trends, and their firsthand reflection on the limitations of traditional energy investment models.

Around 2016, founding team members accumulated experience across energy, finance, and technology, observing three converging trends: continuously falling photovoltaic costs and improving economics of distributed energy; AI moving from R&D to industrial application with rapidly growing enterprise compute demand; and modular data centers, remote operations, and digital management making cross-regional deployment of energy and computing facilities possible.

Luminova's founding purpose is to make value creation from renewables and AI infrastructure more transparent and accessible. The company understands "Luminova" as illuminating a new beginning with light: continuously building real assets in regions where clean energy and digital infrastructure demand is growing, then enabling enterprise customers, ordinary users, and local communities to participate in ways suited to themselves through standardized services, trusted data, and compliant cooperation.

4.2 Company History: From a Ray of Light to a Green Compute Network

Luminova's development is not a commercial curve chasing installed capacity alone, but a long-term path from clean energy assets to green compute centers to enterprise services and local value. Every step revolves around the same question: how to transform real energy assets into digital infrastructure that customers can procure, that can be delivered sustainably, and that creates long-term social value.

2016: Mission Emergence and Company Formation

Around 2016, Chen Wei and several partners from energy, finance, and technology formed a shared judgment in Hong Kong: photovoltaic costs were falling continuously, AI compute demand was growing, and digital technology could improve transparency in asset operations and settlement. Chen Wei proposed that energy should not be an asset circulating only within a few institutions, but digital-era infrastructure capable of benefiting more enterprises, households, and communities through real services. Luminova's entrepreneurial origin thus took shape.

2017–2018: First Photovoltaic Asset Loop Completed

In its early stage, Luminova focused on strategic investment in new energy projects, concentrating on early photovoltaic project development in global emerging markets. Chen Wei insisted on validating the business model with real assets first, rather than leading with concepts. Drawing on international energy experience, the founding team identified sites with superior solar resources and suitable land conditions in southwest China, completing full-cycle investment in its first 50 MW photovoltaic plant. From development approval, EPC bidding, and construction management to grid-connected operation, the Luminova team was deeply involved, validating the company's first complete loop from asset screening and investment to long-term operation.

2019–2020: Toward the Global South—Brazil Opens a Second Growth Curve

After validating its China projects, Luminova did not remain in a single market, but began seeking Global South scenarios better suited to long-term distributed green energy development. Brazil's northeastern semi-arid region possesses world-class solar radiation resources, yet distributed photovoltaic penetration remained low. Chen Wei and the team judged that truly viable green energy projects must simultaneously address local community energy needs and global capital allocation needs. Based on this judgment, Luminova pioneered investment and construction of an integrated solar-storage project in Juazeiro, Bahia, deploying photovoltaic generation and storage systems together to provide stable clean power for local agricultural cooperatives while building localized development, construction, and operating capability in South American markets.

2021–2022: Asset Expansion—Three Regional Clusters Take Shape

As initial projects in China and Brazil stabilized, Luminova entered a phase of rapid asset portfolio expansion. In southwest China, the company completed acquisition and expansion of photovoltaic projects in Yongren, Yunnan, and Panzhihua, Sichuan, pushing total installed capacity of the China portfolio above 100 MW and forming regional asset cluster effects; in Brazil, it completed acquisition and retrofit of a second solar-storage project in Petrolina, Pernambuco, deepening its South American footprint. Meanwhile, Luminova expanded its horizon to the African continent, conducting nearly two years of site selection, resource assessment, and approval work around the Karoo desert near Upington, Northern Cape, South Africa, laying groundwork for African market entry.

2023: Power-Compute Integration Thesis Takes Shape—Technology Innovation System Launched

During this phase, the development of AI large models and enterprise computing demand further confirmed for the team that clean power is not only base energy sold to the grid, but can become a new factor of production supporting AI training, inference, and other high-performance computing tasks. Luminova accordingly upgraded its strategic proposition from investing in photovoltaic plants to building green compute infrastructure, and launched systematic R&D on photovoltaic, storage, GPU facilities, intelligent dispatch, and enterprise service processes.

2024–2025: From Clean Energy Investor to Green Compute Infrastructure Operator

During the strategic transition, Luminova deployed its first modular compute facilities at project sites in Brazil and China, validating engineering paths for coordinated operation of clean power and GPU loads, and began providing paid compute services to AI enterprises and other corporate customers. Meanwhile, the company established Southeast Asian operating capability in Vietnam and advanced Malaysia green power projects, gradually forming a multi-regional network spanning energy assets, compute centers, and enterprise customers.

2026: Global Headquarters Established in Hong Kong—Entering a Phase of Compliance and Global Transition

In 2026, Luminova formally established its global headquarters in Hong Kong. For the management team, this was not merely an upgrade of the management center, but a key milestone in the company's transition from a regional energy investment enterprise to a global green compute infrastructure and enterprise services operator. The Hong Kong headquarters handles strategy, technical standards, enterprise customer coordination, capital allocation, risk governance, and brand management.

In Vietnam, Luminova translates this mission into two parallel long-term paths with clear boundaries: on one hand, validating inclusive products, local user relationships, and city service networks through the Luminova "Million Green Power Plan"; on the other, supporting verified disadvantaged households to improve living conditions, education opportunities, digital capability, and employment connections through a five-year community benefit plan. The two paths may share local teams and partner resources, but eligibility, funds, personal data, and performance evaluation are managed separately.

Looking back on Luminova's decade, what the company has truly accumulated is not only power plants, storage, and compute equipment, but a set of organizational capabilities continuously validated: discovering and operating real assets, converting energy conditions into enterprise-procurable compute services, building local teams in complex markets, and forming long-term connections between infrastructure growth and user, employment, and community value.

4.3 Project and Asset Status (As of Q1 2026)

According to company project records as of Q1 2026, Luminova has deployed clean energy and compute infrastructure across multiple strategic regions. The following sections describe operating, under-construction, and planned status; unless otherwise noted, related data reflect company management definitions, and formal transaction, financing, or partnership decisions should rely on project files, contracts, licenses, and independent due diligence.

Southwest China Photovoltaic Base Cluster

Luminova operates a photovoltaic asset portfolio with total installed capacity of 110 MW in southwest China. Assets are located at three sites: Lixi Town, Huili City, Liangshan Yi Autonomous Prefecture, Sichuan; Weidi Township, Yongren County, Chuxiong Yi Autonomous Prefecture, Yunnan; and Pingdi Town, Renhe District, Panzhihua, Sichuan. Projects sit in the Jinsha River dry-hot valley and surrounding areas, with annual sunshine exceeding 2,400 hours—among the most solar-rich regions in southwest China. Projects generally adopt agrivoltaic or forestry-solar complementary models, with photovoltaic facilities developing alongside specialty agriculture and ecological planting, creating long-term local employment. The Panzhihua project includes a 10 MW/20 MWh storage facility. All projects are listed in the national renewable energy tariff surcharge subsidy catalog; the portfolio operates stably overall.

Northeast Brazil Integrated Solar-Storage Project Cluster

Luminova operates and is constructing photovoltaic assets totaling 65 MW installed capacity in northeast Brazil (including 30 MW under construction), with accompanying storage totaling 18 MWh (including 10 MWh under construction). Assets are located in Juazeiro, Bahia; Petrolina, Pernambuco; and North Limoeiro, Ceará. Projects sit in the mid-São Francisco River valley and northeastern semi-arid interior, with annual sunshine exceeding 2,800 hours and annual total solar radiation above 6 GJ/m². Projects serve irrigation power needs of local agricultural cooperatives; surplus power is sold to the grid through ANEEL's net metering compensation mechanism. The Ceará project is expected to connect to the grid in October 2026. Each project company is wholly owned and operated by a Luminova subsidiary registered locally.

Northern Cape, South Africa Solar Power Plant

Luminova operates a 30 MW solar power plant in the Karoo desert area outside Upington, Northern Cape, South Africa. This region is core to South Africa's designated renewable energy development zone, with annual sunshine exceeding 3,100 hours—among the world's top solar resource areas. The project uses single-axis horizontal tracking technology and has signed a long-term power purchase agreement with a local mining enterprise. The project is held and operated by a Luminova-controlled South African subsidiary, with a local infrastructure investment institution holding approximately one quarter.

Kedah, Malaysia Direct Green Power Supply Project

Luminova successfully signed a power purchase agreement for a 29.99 MW photovoltaic project through Malaysia's Corporate Green Power Programme, becoming one of the first approved international developers under that framework. The project is located in Sik, Kedah, in northern Peninsular Malaysia, and is expected to connect to the grid in November 2026. It is held and operated by a Luminova-controlled Malaysian subsidiary.

Compute Facility Deployment

Luminova deploys prefabricated modular compute facilities at selected project sites, converting power resources into computing capability deliverable to enterprise customers. Initial facilities completed deployment and operational validation at projects in Brazil and Panzhihua, China, featuring cooling, sealed dust protection, environmental monitoring, and remote operations design. The company plans phased expansion based on enterprise customer contracts, equipment utilization, and power and network conditions.

Asset Portfolio Summary

As of Q1 2026, by company management definitions, Luminova's operating and under-construction photovoltaic assets total approximately 235 MW installed capacity, with accompanying storage totaling approximately 38 MWh, distributed across China, Brazil, South Africa, and Malaysia. Operating and under-construction assets differ in cash flow, licensing, grid connection, and risk status and should not be understood as the same maturity when combined.

4.4 Customers and Partnership Ecosystem

Luminova's business ecosystem centers on enterprise customers, energy and equipment, professional services, and local capacity building. Partnerships are categorized by status—signed, in delivery, under technical validation, intent to cooperate, or preliminary outreach—and no partner's name is used for commercial endorsement without their consent.

Enterprise Compute Customers

The company currently provides paid compute services to AI enterprises and other organizations with computing needs, expanding demand through direct business development, solution partnerships, and customer renewals. Service scope is defined by customer contracts and may include model training and inference, graphics rendering, engineering simulation, data processing, and dedicated compute configurations.

Energy, Equipment, and Network Partners

Luminova works with partners in power generation, energy storage, grid services, GPU servers, cooling, networking, and on-site operations to ensure infrastructure delivery. Partner selection is based primarily on technical fit, supply capability, maintenance responsiveness, compliance records, and full lifecycle cost.

Professional Services and Capital Partners

As projects require, the company connects with banks, project finance institutions, insurers, auditors, legal advisors, engineering consultants, and long-term strategic investors to support cross-regional project development, risk management, and governance. Such financing is a company- or project-level arrangement, separate from consumer-facing products.

Local Talent and Community Partners

In priority markets, Luminova connects with schools, vocational training institutions, communities, social organizations, and local businesses to develop operations, customer service, digital skills, and project management talent—so infrastructure development also builds sustainable local capacity.

Chapter

Chapter 5: Business Model and the Luminova "Million Green Power Plan"

5.1 Revenue Engine: Paid Compute Services for Enterprises

Luminova's operating revenue comes first from real enterprise customers. The company builds and operates GPU compute centers, providing paid compute services directly to AI enterprises and other organizations with compliant computing needs. Customers procure computing resources and supporting services under contract; Luminova handles resource allocation, operational assurance, usage metering, delivery acceptance, and after-sales support.

Depending on task characteristics, services may be structured as pay-as-you-go usage, reserved capacity, dedicated clusters, or project-based delivery. Revenue is recognized based on contracts, actual services, and acceptance results; equipment utilization, customer pricing, service duration, collection quality, and customer concentration together determine compute business performance.

After deducting power, cooling, networking, operations, equipment depreciation, technical support, taxes, bad debt, and necessary reserves, enterprise revenue forms operating resources available for equipment renewal, business expansion, and user givebacks. The starting point of the business model is enterprise paid services; user growth is not a prerequisite for revenue validity.

The company measures compute center performance through signed and deliverable capacity, billable GPU hours, equipment utilization, service availability, revenue per compute unit, customer concentration, collection cycles, energy per unit, and renewal rates. Equipment expansion requires alignment among customer demand, power supply, operational capability, and funding.

5.2 Luminova "Million Green Power Plan"

The Luminova Million Green Power Plan is Luminova's core inclusive product and long-term user program for ordinary users in Vietnam. Built on GPU compute centers and supporting facilities already deployed, operating, and serving enterprise customers, it aims to help ordinary users learn about the company, experience digital services at a lower threshold, and become Luminova's first real users in Vietnam.

"Million" represents the long-term direction of serving users at million-scale coverage; "green power" represents the company's infrastructure direction of coordinated renewable energy, storage, and efficient compute. The name does not mean that all tasks use 100% renewable energy at all times, nor does it imply scarcity appreciation or secondary trading value.

Users receive corresponding product access, service experience, information viewing, and periodic user benefits under formal local product rules. Related equipment remains uniformly owned, scheduled, operated, and maintained by Luminova or project companies; unless explicitly stated in formal contracts, purchasing the product does not confer ownership of specific GPUs, company equity, regional company interests, or capital market rights.

The product's commercial positioning is not to raise public funds for compute center construction. Before launch in each market, the company will complete legal characterization and necessary consumer protection, licensing, filing, and risk disclosure based on actual rights, fees, terms, and giveback mechanisms; product names, limits, or non-guarantee of fixed returns cannot substitute for local legal determination.

Inclusion and Limits

At this stage, the company needs broad, genuine, and continuously engaged users more than maximum sales per individual. Therefore, the Luminova Million Green Power Plan will set per-person participation limits based on compute service capacity, after-sales resources, and user protection requirements, opening in phases so products and user givebacks reach more people. Specific units, limits, and opening schedules are governed by formal local rules.

5.3 Operating Givebacks: Why More Value Is Reserved for Users

Traditional companies entering new markets typically invest heavily in advertising, agents, and channels. Luminova chooses to allocate approved market acquisition budgets and a portion of discretionary operating resources—after ensuring taxes, operations, depreciation, risk reserves, equipment renewal, and ongoing operations—to improve first-user product experience and periodic givebacks.

In the early phase of Vietnam market entry, the company is willing to allocate a relatively higher proportion of periodic discretionary operating resources to user givebacks, because what is most scarce at this stage is broad, genuine users willing to continue using and providing feedback—not maximum profit from a few users. This policy is user acquisition and service-building investment, adjusted dynamically with operating scale, costs, user quality, and market phase; it does not constitute a permanent allocation ratio.

The commercial logic of this arrangement is to let users who genuinely use the product, provide feedback, and generate natural word-of-mouth share a portion of resources invested in market entry. The source and calculation of user givebacks must be clearly stated in formal rules; if linked to actual operating results of specific compute centers, revenue recognition, cost deductions, loss or zero-profit periods, settlement, tax, and verification methods must be separately specified and local legal requirements completed.

Transparency and Verification

The company will progressively establish product-related equipment and service capability descriptions, enterprise compute revenue definitions, major costs, user giveback budgets, and records of exceptional events and outcomes. For arrangements linked to operating results, clear accounting units, fund and ledger boundaries, related-party transaction rules, and appropriate independent verification should also be established.

5.4 From First Users to a Long-Term Service Ecosystem

The Luminova Million Green Power Plan is not the end of a sales campaign but the beginning of a long-term user relationship. Based on user density and service demand, the company will progressively build local teams in key cities to provide product guidance, digital skills training, after-sales support, feedback channels, and community activities—translating Hong Kong headquarters and compute center capabilities into locally understandable, usable services.

When user scale, activity, and local service capacity reach appropriate levels, Luminova will expand AI tools, cloud services, digital skills courses, green energy knowledge, and enterprise service connections around real demand. New services follow demand validation, capability validation, compliance assessment, and phased launch—without presenting immature business lists as existing commitments.

The value of a long-term user ecosystem comes from continued use, repeat engagement, feedback, service improvement, and local demand connections. The company will separately measure identity-verified users, actual usage, activity and retention, issue resolution, satisfaction, and local service quality—not treating single registration or sales figures as ecosystem maturity.

5.5 Key Operating Risks

Enterprise compute services are affected by GPU upgrades, equipment utilization, customer demand and concentration, contract pricing, collections, power, cooling, networking, equipment failures, data security, exchange rates, tax, and regulatory changes. Green compute also requires disclosure of power sources, storage and grid supplementation, and ownership and accounting definitions for green certificates or other environmental attributes.

Any historical data, internal estimates, user givebacks, or development targets do not represent future results. Luminova will reduce volatility through diversified enterprise customers, contract and credit management, maintenance reserves, equipment renewal, cybersecurity, and risk provisions—but cannot eliminate all operating risks.

Chapter

Chapter 6: Future Vision: Luminova's Strategic Roadmap

6.1 2026: The Year of Scale

2026 is a pivotal year for Luminova's strategic transition, with core objectives focused on scale expansion, user acquisition, and ecosystem infrastructure development.

On asset scale, Luminova will prioritize completing existing projects under construction, improving asset availability, and generating verifiable cash flow, expanding the project pipeline prudently when licensing, grid connection, financing, and unit economics meet requirements. 350 MW is a phased planning target, dependent not only on listed projects but also on due diligence, approval, and closing progress for new projects.

On compute business, Luminova will expand GPU clusters based on signed enterprise customers, pipeline demand, equipment utilization, and power network conditions, refining enterprise service systems from demand assessment and resource scheduling through service monitoring, metering, acceptance, and collections. Equipment scale must match verifiable customer demand and operational capability.

On user ecosystem, Luminova will launch product validation and service network development for the Luminova Million Green Power Plan in Vietnam as the first priority market. "Million" indicates the long-term direction of million-scale user service coverage—not sales, paying users, or operating results within a specific period; the company will separately disclose registration, identity verification, actual usage, payment, retention, and service reach metrics.

On community benefit, the company will complete demand baselines, partner screening, household eligibility and deduplication rules, privacy and child protection standards, and initial project pilots in Vietnam. Annual service scale is determined jointly by budget, service quality, partnership capacity, and follow-up capability—not by mechanically averaging a 50,000-person support target in place of actual execution.

6.2 2027–2029: Scaling and Regional Deepening

The core strategy of this phase is to deeply replicate the validated power-compute integration model in existing markets and prudently expand into new strategic regions.

On asset scale, Luminova targets raising total installed capacity of operating photovoltaic assets to over 800 MW by end-2029, with coordinated progress across China, Brazil, South Africa, and Southeast Asia.

On compute business, Luminova will use enterprise contracts, utilization, energy efficiency, customer structure, and collection quality as expansion criteria, progressively forming a cross-regional GPU compute center network while continuously optimizing modular deployment, enterprise delivery, and customer service capabilities.

On user ecosystem, Luminova targets raising global active users to over five million by end-2029, covering core markets including Vietnam, Thailand, Indonesia, and Brazil.

On community benefit, Vietnam programs will expand by region based on pilot evaluation, progressively forming tiered services for livelihood improvement, education support, digital capability, and employment connection. Expanding coverage requires that ongoing tracking, complaint handling, partner capacity, and outcome verification scale in parallel.

On carbon credit business, Luminova targets steady growth in carbon credit transaction volume by end-2029, entering the ranks of major participants in the global voluntary carbon credit market.

6.3 After 2029: Technology Leap and Ecosystem Expansion

After 2029, Luminova's strategic focus will shift from scale expansion to technology leapfrogging, building long-term competitive barriers through forward-looking technology positioning.

On energy technology, Luminova will explore the potential for coordinated deployment of small modular nuclear reactors with compute facilities, investigating innovative scenarios combining stable baseload power with compute.

On compute technology, Luminova will track next-generation GPU, cooling, networking, scheduling, and security developments, upgrading infrastructure as appropriate. The company's technology innovation system will continue investing in R&D around real enterprise customer tasks, energy efficiency, and delivery quality.

On carbon assets, Luminova will explore carbon removal credits, extending carbon asset business from emissions reduction toward negative emissions.

On enterprise service ecosystem, Luminova will progressively open standardized compute interfaces, industry solutions, and partner capabilities, enabling more AI, software, industrial, and research customers to conveniently access green compute resources.

Luminova's long-term vision is to become a major operator and standard promoter of global green compute infrastructure.

6.4 Regional Operations and Local Governance

The timeline above answers when to advance; regional organization answers how to replicate. As business expands, Luminova will form a three-tier structure of Hong Kong headquarters and professional platforms, regional companies, and project entities—enabling technology and capital to be reused across regions while anchoring operations, compliance, and social responsibility in specific markets.

Hong Kong Headquarters and Professional Platforms

Hong Kong headquarters handles global strategy, capital allocation, enterprise customer coordination, risk governance, brand, and group-level policies; professional platforms for renewable energy, modular AI compute, enterprise services, and carbon value management consolidate technical standards, procurement capabilities, operating tools, and compliance methods.

Regional Companies and Project Entities

Regional companies are responsible for local customers, project development, team building, partners, user services, and community relations, and are accountable for local operating results and compliance. Individual energy or compute projects are generally housed in project entities with clear boundaries for assets, contracts, financing, and liability, reducing risk transmission across markets and projects.

Regional Roles and Market Selection

Southeast Asia prioritizes validating user services, green power supply, and regional compute demand; Latin America supports expansion of photovoltaic, storage, and green compute nodes; Africa focuses on solar resources, edge computing, and local digital infrastructure; the Middle East targets large energy capital, green data centers, and cross-regional cooperation. China, Brazil, South Africa, and Malaysia form the existing capability base; Vietnam is the comprehensive validation market; Indonesia, Thailand, Singapore, Chile, Mexico, Kenya, Nigeria, the UAE, Saudi Arabia, and Morocco are in a phased evaluation pool—not simultaneous deployment commitments.

Each new market must pass thresholds for energy and unit economics, compute demand and connectivity, regulatory feasibility, local team and partner capability, and community needs and social acceptance. Only after verifiable results in the prior phase does the next phase begin—establishing entities, expanding assets, or launching user services.

Prerequisites for Local Capitalization

After regional companies achieve stable operations, clear asset and liability boundaries, auditable records, sustained cash flow, local management teams, and independent governance, the company may consider introducing strategic investors, independent financing, or entering local capital markets. Such arrangements must also satisfy requirements for tax, foreign exchange, data, licensing, related-party transactions, minority shareholder protection, and social impact disclosure.

Local capitalization is a possible outcome of operational maturity—not a market entry purpose, short-term financing commitment, or exit channel for product users. Users do not automatically receive regional company equity, conversion rights, IPO allocation rights, or other capital interests by purchasing services, registering on platforms, or participating in community activities; company financing, user service funds, and public benefit project budgets are managed separately.

The goal of this structure is to translate Hong Kong's global coordination capability into locally usable technology, locally sustainable operations, locally developing talent, and locally accountable responsibility—forming a more resilient green compute infrastructure network.

Chapter

Chapter 7: Shared Value: Technology Inclusion and Community Benefit

7.1 Vietnam Dual-Track Co-Building Framework

Vietnam is Luminova's first comprehensive validation market for translating global infrastructure capability into local services, local employment, and community value. The company pursues two mutually reinforcing but independently governed paths: a commercial path building real users and service networks through the Luminova Million Green Power Plan; and a social responsibility path supporting verified disadvantaged households through a five-year community benefit plan.

Synergy between the two paths comes from shared local capabilities—city service teams, digital education resources, green energy knowledge, school and community partners, employment and enterprise connections. Boundaries appear in objects, contracts, budgets, data, and performance evaluation: commercial programs measure service usage, retention, and satisfaction; community programs measure household needs, sustained accompaniment, and verifiable improvement.

The community benefit plan is independent of any product purchase, platform registration, user referral, or value-sharing mechanism. Whether households receive support is determined solely by actual need and project rules; supported households bear no obligation to purchase, promote, refer, or provide commercial data. Public benefit budgets, personal information, and project records are not used for commercial product sales.

The goal of this dual-track model is not to turn public benefit into a customer acquisition channel or to mask commercial logic with vision, but to let the company answer two questions as it takes long-term root: Can Luminova continue providing valuable services? Can Luminova's presence help local society develop more capability and opportunity?

7.2 Luminova "Million Green Power Plan": Building a Long-Term User Service Network

The Luminova Million Green Power Plan is Luminova's core product for building long-term user relationships and local digital service capability in Vietnam. "Million" represents the long-term direction of million-scale service coverage; "green power" represents the company's infrastructure direction of coordinated renewable energy, storage, and efficient compute; the name does not mean all compute tasks are powered by 100% renewable electricity at all times.

The plan is built on GPU compute centers already in operation and providing paid services to AI and other enterprise customers, establishing first connections with ordinary users through standardized products and AI tool experiences; online support and city teams handle guidance, training, after-sales, and feedback. Participation limits are set based on service capacity and user protection needs, without creating scarcity appreciation or secondary trading expectations.

The execution path progresses through three phases: product validation, city service networks, and long-term digital services. Phase one validates real usage, issue resolution, and satisfaction; phase two builds local teams when user density and after-sales capacity meet requirements; phase three expands AI tools, cloud services, digital skills, and enterprise service connections based on demand.

The plan does not treat registration or sales as the sole outcome. The company will separately report identity-verified users, actual users, activity and retention, service reach, complaint handling, local positions, training completion, and user satisfaction, and explain the power and environmental attribute definitions of "green compute."

7.3 Vietnam Five-Year Community Benefit Plan: Starting with 50,000 Supported Individuals

Over the next five years, Luminova plans to cumulatively serve 50,000 verified beneficiaries with established service records and completed deduplication, focusing on vulnerable group members facing practical difficulties in basic livelihood, education, digital capability, elder care, and employment integration.

The 50,000 beneficiaries represent a five-year cumulative direct service scale target—not all participants receiving the same program simultaneously, nor a guarantee of specific changes in living conditions, employment outcomes, or economic status. Programs will provide differentiated, prioritized, sustainably tracked support based on each group's actual difficulties, development aspirations, and available resources.

Beneficiaries may include children and youth in difficult circumstances, elderly persons living alone or lacking care, persons with disabilities, low-income workers, unemployed or employment-challenged individuals, those lacking digital skills and educational resources, and others assessed as needing support. Specific service scope will be determined progressively based on social conditions, project capacity, and partner resources across different regions of Vietnam.

Services begin with needs identification involving beneficiaries and their families. Programs will sequentially complete eligibility verification and informed consent, personal record creation and needs stratification, service plan development and resource matching, ongoing accompaniment and necessary referrals, and periodic follow-up and outcome evaluation. For minors, elderly persons, persons with disabilities, and other participants requiring special protection, guardians, caregivers, or professional institutions will be involved as appropriate.

Each beneficiary enters an appropriate service combination based on actual need—avoiding uniform material distribution in place of differentiated support, and avoiding equating brief contact, promotional participation, or one-time visits with sustained assistance.

Livelihood improvement is the first layer of support, including basic living supplies, green lighting, small energy-efficiency improvements, elder care, disability accessibility support, and daily living services—helping participants address their most urgent practical difficulties.

Education and development focuses on learning supplies, reading resources, digital learning conditions, continued schooling, and growth accompaniment for children and youth in difficulty and others with learning needs—reducing educational opportunity gaps caused by household conditions, insufficient equipment, or information disparities.

Digital capability building starts with practical skills in device use, cybersecurity, basic office work, and information literacy, progressively connecting AI tools, green energy knowledge, vocational skills, and on-the-job practice—helping participants adapt to changes brought by digital economic development.

Employment and personal development provides more sustained development opportunities for participants with labor capacity and employment willingness through skills training, vocational certification, internships, job matching, employment counseling, and stability follow-up. Programs focus not only on whether participants obtain positions but also on whether they can adapt, sustain employment, and progressively improve living stability.

Training content will be designed based on real job requirements and participants' living needs, prioritizing Vietnamese local language, actionable courses, pre- and post-training assessments, and real-task verification. Employment connection does not measure success by number of job referrals or interviews, but focuses on training completion, actual hiring, sustained employment, job adaptation, and income stability.

Green lighting, energy-efficiency improvements, and other in-kind support will also record equipment safety, actual usage, follow-up maintenance, and issue resolution—not substituting material distribution quantities for long-term social impact.

Phased Implementation

The plan launch phase focuses on baseline surveys of vulnerable group needs, service recipient standards, partner screening, service process design, and small-scale pilot validation.

The plan expansion phase will progressively broaden service regions and covered populations after service quality, ongoing tracking, complaint handling, partner capacity, and outcome verification mechanisms meet requirements—not sacrificing project quality for headcount growth.

At the end of the five-year phase, the company will conduct a comprehensive evaluation, publicly summarizing project progress, effective methods, unmet targets, and improvement directions, and decide which services can continue long-term, expand, or be replicated in other communities.

Annual service scale will be determined comprehensively based on actual budget, project capacity, partner resources, service quality, and follow-up capability—not by mechanically averaging the 50,000-person target, nor by substituting short-term concentrated registration for genuine, sustained service.

From Supported Individuals to Community Mutual Aid

Participants whose living conditions have improved, who have completed skills training, restored employment capacity, or achieved stable employment may, entirely voluntarily and without any commercial obligation, become experience sharers, volunteers, skill helpers, or community mutual aid participants.

Programs aim to foster the natural extension of goodwill, experience, and capability within communities—not to transform beneficiaries into brand promoters, product referrers, or commercial users. Participation in volunteer service, experience sharing, or community mutual aid does not affect rights to existing services and ongoing support.

Partner Ecosystem and Resource Boundaries

Luminova will lawfully connect schools, communities, social organizations, businesses, vocational training institutions, professionals, and volunteers to jointly strengthen service identification, education support, skills training, elder care, employment connection, and ongoing follow-up capabilities.

The company's annual social responsibility budget, in-kind or professional resources from partners, and lawfully accepted social donations, if any, will be separately registered and managed for designated purposes. Community benefit project funds, materials, service records, and beneficiary information will not be commingled with commercial product settlements, user giveback budgets, or regional company financing.

Before formal partnership relationships are established, the company will not make statements of support, authorization, or endorsement in the name of government departments, public institutions, schools, social organizations, or other partners.

7.4 Independent Governance and Impact Assessment

The 50,000 beneficiary target will be tracked separately across four tiers: initial outreach, formal enrollment, completed service cycle, and verified improvement.

Beneficiaries formally counted toward the five-year cumulative target must complete eligibility verification, informed consent, personal record creation, and identity deduplication, and actually receive services with defined content. Statistics are counted per independent individual; a participant receiving multiple services or help across years counts as one beneficiary.

Family members, relatives, neighbors, or community residents who benefit only indirectly are not automatically counted among the 50,000 direct beneficiaries. Indirect beneficiary counts, community activity participation, and outreach reach should be separately tracked and disclosed to avoid double counting or inflating project outcomes.

A single promotional contact, event check-in, information inquiry, gift collection, or brief visit does not directly equate to completed sustained service. The company will set corresponding minimum service standards, service periods, and completion conditions by service type.

Impact assessment simultaneously examines service coverage breadth, support depth, and actual improvement:

Livelihood improvement focuses on whether services were completed, whether equipment or materials remain usable, and whether practical difficulties were alleviated; education support focuses on continued schooling, learning conditions, and digital resource usage; digital training focuses on course completion, skills assessment, and practical application; employment connection focuses on training completion, job placement, sustained employment, and job stability; community diffusion counts only voluntary, verified mutual aid, volunteer service, and experience-sharing actions by participants.

The company will progressively disclose annual targets, actual service numbers, service completion status, verified improvements, complaints and outcomes, reasons for unmet targets, and corresponding improvement measures.

Governance mechanisms include annual budget approval, partner due diligence and procurement management, conflict of interest management, anti-fraud mechanisms, minimization of personal information collection, informed consent, protection of minors and vulnerable groups, volunteer safety, appeals and remediation, service record review, and sample verification.

When involving minors, incapacitated elderly persons, persons with disabilities, and other participants requiring special protection, programs will refine guardian consent, privacy protection, activity safety, and risk response mechanisms under applicable rules. Before cross-border sharing of personal data, legal requirements for data protection and cross-border transmission in Vietnam and relevant jurisdictions must be satisfied.

Luminova's understanding of shared value thus extends from one-time material donations to a development path that can be sustainably tracked and verified: infrastructure creates services and jobs, local teams connect knowledge and opportunity, improved personal capability further improves family life, and more resilient communities gradually form.

Enterprises cannot replace the roles of government, social organizations, and communities themselves, but through long-term operations, professional capability, stable investment, and transparent accountability, they can become long-term participants in driving social improvement.

Chapter

Chapter 8: Compliance Framework and Disclaimer

8.1 Infrastructure and Enterprise Service Compliance

Luminova advances compliance governance through the hierarchy of group policy, regional responsibility, and project execution. Each project entity obtains required registrations, licenses, and approvals before development, construction, grid connection, compute center operation, enterprise services, or cross-border transactions, according to its stage; specific status is determined by project files and regulatory authority records.

Enterprise compute services implement data and network security, customer identity and use review, export controls and sanctions, intellectual property, service levels, tax, foreign exchange, and consumer or enterprise customer protection requirements based on customer location, compute center location, and contract structure. Environmental attributes are confirmed only when ownership is clear and applicable certification is complete, avoiding duplicate claims.

8.2 Luminova Products and User Protection

Before launch in each market, the Luminova Million Green Power Plan must complete written legal characterization based on actual rights, fees, terms, givebacks, and promotional methods, and implement necessary licensing, filing, consumer protection, advertising review, suitability, refunds, complaints, tax, and data arrangements.

Regional company project financing, strategic investment, or future listing are company-level capital and governance arrangements. Luminova product users do not automatically receive regional company equity, conversion rights, allocation rights, or other capital interests by purchasing, registering, or participating in community activities.

8.3 Data, Community Programs, and Accountability Governance

Luminova processes enterprise customer, user, employee, partner, and community participant household data in accordance with applicable law, adhering to purpose limitation, minimum necessity, informed consent, access control, retention periods, and secure disposal. Enterprise customer data, ordinary user data, and community project data are managed separately according to their respective purposes.

Community benefit projects establish independent budgets and ledgers, partner screening, child and vulnerable group protection, volunteer safety, conflict of interest, anti-fraud, appeal remediation, and sample verification mechanisms. Household support is not conditional on purchasing, registering, referring, or promoting Luminova products; their personal information must not be used for commercial marketing.

8.4 Disclaimer

This white paper describes Luminova's business positioning, technical architecture, enterprise services, market strategy, Luminova user products, social responsibility, and forward-looking plans. It does not constitute investment advice, an offer to sell securities or funds, nor does it replace formal product contracts, legal documents, due diligence, or risk disclosure. The legal nature of any product is determined by applicable law, formal terms, and regulatory authority opinions.

Installed capacity, equipment deployment, enterprise customers, product design, user scale, community service targets, financing arrangements, and listing possibilities mentioned herein may be adjusted due to project due diligence, operating results, market conditions, licensing progress, funding, and partnership conditions. Company data not independently audited or verified by third parties should not be understood as audit conclusions or independent assurance.

Appendix

Appendix I: Key Term Definitions

PDP8 refers to Vietnam's eighth National Power Development Plan and its 2025 adjustment document, an important policy basis for understanding the direction of Vietnam's power system development.

Paris Agreement refers to the global climate agreement adopted in 2015, aiming to hold the increase in global average temperature to well below 2°C above pre-industrial levels and pursue efforts to limit it to 1.5°C.

DPPA refers to a Direct Power Purchase Agreement, allowing eligible power generators and electricity customers to establish direct or agreed power transaction arrangements under applicable rules.

CGPP refers to Malaysia's Corporate Green Power Programme.

Power-compute integration refers to coordinated planning, scheduling, and accounting of power systems, energy storage, GPU compute centers, and task loads to improve comprehensive utilization efficiency of energy and computing facilities.

Enterprise-grade compute services refer to GPU computing and supporting services provided by Luminova under enterprise customer contracts, including demand assessment, resource allocation, task execution, usage metering, delivery acceptance, and customer support.

Luminova Million Green Power Plan refers to Luminova's inclusive product and long-term user program for ordinary users in Vietnam, built on GPU compute centers already in operation. "Million" indicates the direction of million-scale service coverage—not sales, returns, or user guarantees within a specific period.

User givebacks refer to periodic benefits provided to users under formal rules, using approved market budgets or a portion of discretionary operating resources after meeting taxes, operations, depreciation, risk reserves, equipment renewal, and ongoing operations. They do not constitute fixed returns or principal guarantees.

Long-term user service ecosystem refers to a service network formed around real users' continued use, repeat engagement, feedback, and local demand connections—not growth driven by hierarchical recruitment or payments from new users.

Local capitalization refers to the optional path for regional companies, after achieving stable operations, auditable records, mature governance, and meeting regulatory conditions, to introduce local strategic capital, independent financing, or enter local capital markets— not constituting capital interests for Luminova product users.

Five-year cumulative beneficiaries refer to independent individuals who, during the plan period, completed eligibility verification, informed consent or necessary guardian consent, established personal service records and identity deduplication, and actually received project services. Initial outreach, formal enrollment, completed service cycles, and verified improvement are tracked separately; the same individual receiving multiple services or help across years is not double-counted. Family members, community participants, and other indirect beneficiaries are tracked separately and not counted among the 50,000 direct beneficiaries.

Dual-track co-building refers to Luminova commercial user services and community benefit plans sharing certain local capabilities while maintaining independent governance over eligibility, contracts, funds, personal data, and performance evaluation.

Green compute refers to compute services oriented toward increased renewable energy use and comprehensive energy efficiency. Power sources, matching periods, storage and grid supplementation, and green certificate and environmental attribute definitions must be disclosed separately for each project.

Appendix

Appendix II: Core Data Sources and Methodology Notes

External data prioritizes regulatory authorities, international organizations, and public reports; company assets, enterprise customers, products, projects, and operational information come from company management records. The two use different definitions; industry data does not prove company performance, nor do company plans substitute for regulatory or third-party conclusions. Key references include:

International Energy Agency, Energy and AI (2025) and Key Questions on Energy and AI (2026), for data center and AI electricity consumption trends.

Vietnam Prime Minister Decision No. 768/QD-TTg (15 April 2025) and related Ministry of Industry and Trade implementation documents, for the adjusted eighth National Power Development Plan.

International Renewable Energy Agency public reports on global renewable energy installed capacity and energy transition pathways to 2030.

UN Framework Convention on Climate Change Paris Agreement and related Nationally Determined Contribution documents.

Public regulations and regulatory authority documents in project locations regarding power, data centers, cybersecurity, environmental attributes, consumer protection, tax, and data protection.

Luminova company project files, asset registers, enterprise compute service contracts and acceptance records, equipment operation and energy consumption records, product rules, user service records, and community project records. Unless otherwise stated, such information has not been independently audited or third-party assured in the preparation of this white paper.