[Image: Lubair Logo]
Regarding
Lubair Aviation Technology Co., Ltd.
Reply Report on the Second Round of Audit Inquiry Letters for the Application Documents for Issuance of Convertible Corporate Bonds to Unspecified Targets
Sponsor (Lead Underwriter)
[Image: Guosen Securities Logo]
(Address: 16-26/F, Guosen Securities Building, 1012 Hongling Middle Road, Luohu District, Shenzhen)
July 2026
Shenzhen Stock Exchange:
We have received your "Second Round of Audit Inquiry Letter regarding the Application of Lubair Aviation Technology Co., Ltd. for Issuance of Convertible Corporate Bonds to Unspecified Targets" (Audit Letter [2026] No. 120039) issued on July 16, 2026. Lubair Aviation Technology Co., Ltd. (hereinafter referred to as "Lubair," "the Issuer," or "the Company"), together with Guosen Securities Co., Ltd. (hereinafter referred to as "the Sponsor"), Beijing Zhonglun Law Firm (hereinafter referred to as "Issuer's Counsel"), and Tianzhi International Certified Public Accountants (Special General Partnership) (hereinafter referred to as "Issuer's Accountant") and other relevant parties, have conducted a thorough review of the questions listed in the second round of inquiry letters. The responses are as follows for your review.
Unless otherwise specified, the abbreviations used in this reply are the same as those defined in the "Prospectus for the Issuance of Convertible Corporate Bonds to Unspecified Targets of Lubair Aviation Technology Co., Ltd. (Declaration Draft)" (hereinafter referred to as "the Prospectus"). Any discrepancies between the totals and the sums of the listed figures in this reply are due to rounding.
| Inquiry Question | Bold (Bold) |
|---|---|
| Reply to Inquiry Questions | Songti (Not Bold) |
| Amendments and Supplements to the Prospectus | Kaiti (Bold) |
Question 1
According to the application documents and the response to the first round of audit inquiries, the company's operating income is mainly derived from distributed products and self-developed products. Distributed products mainly include aviation oil, aviation raw materials, and other consumables, while self-developed products mainly include polymer materials, adhesive tapes and films, aviation gas cylinders, passenger/cargo cabin parts, fine chemicals, and testing instruments.
The net proceeds from this issuance of convertible bonds to unspecified targets are intended to be used for the "Aircraft Full Life Cycle Management Project" (hereinafter referred to as the "Fundraising Project"). Its business model involves purchasing mid-to-old aircraft, engines, or aircraft asset portfolios from airlines, aircraft lessors, or aircraft asset management companies, and providing operating leasing, post-retirement dismantling and disposal, and key aviation material recycling services to aviation industry customers worldwide. Based on the issuer's original business, it has added operating leasing of aviation assets and the rental and sale of secondary aviation materials. The dismantling and disposal mainly involve high-value aircraft parts such as engines, landing gear, auxiliary power units, and avionics equipment, which differ from the company's current main distributed and self-developed products. The issuer believes that although there are certain differences between this fundraising project and the company's existing business, both are necessary for the normal operation and maintenance of civil aircraft. This project is an improvement and supplement to the existing main product system and belongs to an associated expansion based on existing business. In addition, the dismantling of retired aircraft and the qualified aviation material certification business for the rental and sale of secondary aviation materials involved in this project are all entrusted to units with relevant qualifications.