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Response to the Audit Inquiry Letter Regarding the Application for Issuance of Shares to Specific Targets by Xi'an International Medical Investment Co., Ltd.
Sponsor (Lead Underwriter): Guotai Haitong Securities Co., Ltd.
(No. 618 Shangcheng Road, China (Shanghai) Pilot Free Trade Zone)
July 2026
Shenzhen Stock Exchange:
We have received the "Audit Inquiry Letter Regarding the Application for Issuance of Shares to Specific Targets by Xi'an International Medical Investment Co., Ltd." (Audit Letter [2026] No. 120028) (hereinafter referred to as the "Inquiry Letter") issued by your exchange. In accordance with your requirements, Xi'an International Medical Investment Co., Ltd. (hereinafter referred to as the "Issuer," "Company," or "International Medical"), together with the sponsor (lead underwriter) Guotai Haitong Securities Co., Ltd. (hereinafter referred to as the "Sponsor" or "Sponsoring Institution"), the issuer's legal counsel Beijing Kangda Law Firm (hereinafter referred to as "Issuer's Counsel"), and the reporting accountants Zhongshen Asia-Pacific Certified Public Accountants (Special General Partnership) (hereinafter referred to as "Reporting Accountants" or "Accountants"), have implemented and responded to the questions raised in the Inquiry Letter item by item and have made corresponding supplements to the application documents. We hereby submit this for your review.
Unless otherwise specified, the terms, names, and abbreviations used in this response have the same meanings as those in the prospectus.
The fonts used in this response represent the following meanings:
| Category | Font |
|---|---|
| Questions listed in the Inquiry Letter | Bold (not thickened) |
| Responses to Inquiry Letter questions and intermediary verification opinions | Songti (not thickened) |
| Supplementary and revised disclosure content in the prospectus | Kaiti (thickened) |
Table of Contents
Table of Contents 2
Question 1 3
Question 2 39
Question 1
During the reporting period, the Issuer's main business income was primarily derived from the medical industry, with the main operating entities being Xi'an Gaoxin Hospital (hereinafter referred to as "Gaoxin Hospital") and Xi'an International Medical Center Hospital (hereinafter referred to as "International Medical Center"). From 2022 to the first nine months of 2025, the Issuer's main business income showed a growth trend, amounting to 266,248.68 ten thousand yuan, 450,602.48 ten thousand yuan, 474,116.17 ten thousand yuan, and 290,706.93 ten thousand yuan, respectively. The lower income in 2022 was mainly due to the impact of the hospital's suspension and rectification that year. From 2022 to the first nine months of 2025, the Issuer continued to suffer losses, with net profits attributable to the parent company after deducting non-recurring gains and losses being -112,273.75 ten thousand yuan, -49,900.22 ten thousand yuan, -28,692.81 ten thousand yuan, and -31,161.27 ten thousand yuan, respectively, mainly due to the large scale of initial investment in the International Medical Center, insufficient bed utilization rates during the reporting period, and the impact of medical insurance cost control policies. From 2022 to the first nine months of 2025, the Issuer's gross profit margins were -6.57%, 9.55%, 9.45%, and 6.59%, respectively, which were higher than the average gross profit margin of medical businesses of comparable companies in the same industry. From 2022 to the first nine months of 2025, the net cash flows generated from the company's operating activities were 46,133.87 ten thousand yuan, 108,733.44 ten thousand yuan, 100,911.98 ten thousand yuan, and 92,100.39 ten thousand yuan, respectively.
According to the application materials, from the end of 2022 to the end of September 2025, the Issuer's current ratios were 0.67, 0.46, 0.39, and 0.27, respectively; quick ratios were 0.66, 0.44, 0.37, and 0.25, respectively, all lower than the average level of comparable companies in the same industry; asset-liability ratios were 67.95%, 66.29%, 67.36%, and 68.80%, respectively, higher than the average level of comparable companies in the same industry.