Beijing Tianda Law Firm (hereinafter referred to as "this firm") has been entrusted by Ciming Health Checkup Management Group Co., Ltd. (hereinafter referred to as "the company" or "the issuer") to act as special legal counsel for the company's initial public offering of RMB ordinary shares and listing (hereinafter referred to as "this issuance" or "this issuance and listing"). In March 2011, this firm issued the "Legal Opinion on the Initial Public Offering and Listing of Ciming Health Checkup Management Group Co., Ltd." (hereinafter referred to as "the legal opinion") and the "Lawyer's Work Report on the Initial Public Offering and Listing of Ciming Health Checkup Management Group Co., Ltd." (hereinafter referred to as "the lawyer's work report").
In accordance with the requirements of the China Securities Regulatory Commission (hereinafter referred to as "CSRC") No. 110632 "Notice of Feedback on Administrative Licensing Project Review," the lawyers of this firm conducted verification and validation of relevant matters and issued the "Supplementary Legal Opinion (I)" on September 28, 2011. Based on the issuer's accountant's review of the issuer's financial statements, the lawyers of this firm issued the "Supplementary Legal Opinion (II)" on September 28, 2011. Following verbal feedback from the CSRC reviewer on November 14, 2011, the lawyers conducted verification and validation and issued the "Supplementary Legal Opinion (III)" on November 24, 2011. Based on the verbal feedback from the CSRC reviewer on January 17, 2012, and the accountant's review of the issuer's financial statements, the lawyers issued the "Supplementary Legal Opinion (IV)" on February 29, 2012.
This supplementary legal opinion is issued in response to the matters requested for verification and opinion by the CSRC reviewer on March 7 and March 15, 2012. This firm has strictly fulfilled its statutory duties, adhered to the principles of diligence and good faith, and conducted necessary and appropriate verification of relevant documents and materials. We ensure that this supplementary legal opinion contains no false records, misleading statements, or significant omissions.
This supplementary legal opinion serves as a supplement to the "Legal Opinion," "Lawyer's Work Report," "Supplementary Legal Opinion (I)," "Supplementary Legal Opinion (II)," "Supplementary Legal Opinion (III)," and "Supplementary Legal Opinion (IV)." The matters and interpretations stated in the "Legal Opinion," "Lawyer's Work Report," "Supplementary Legal Opinion (I)," "Supplementary Legal Opinion (II)," "Supplementary Legal Opinion (III)," and "Supplementary Legal Opinion (IV)" continue to apply to this supplementary legal opinion.
This firm agrees to submit this supplementary legal opinion as a necessary legal document for the issuer's application for public offering of shares, along with other application materials, to the CSRC for review, and shall bear corresponding legal responsibilities for the supplementary legal opinion issued.
Part One: Response to Feedback on March 7, 2012
Question 1: Please verify and disclose whether there are any relationships or interests between the partners and new shareholders of the partnership enterprise and the issuer, controlling shareholders, actual controllers, directors, supervisors, senior management, and intermediaries involved in this issuance, and provide an opinion.
As of now, except for the controlling shareholders and actual controllers, among other corporate shareholders, Beijing Dinghui, Dinghui Phase I, Tianjin Baoding, Dinghui Yuanbo, Beijing Fukun, and Chongqing Fukun are limited partnership enterprises, while Shenzhen Tiantu, Ping An Innovation, Shenzhen Yide, and Dongsheng Kangye are limited companies. According to the statements provided by the aforementioned shareholders, Beijing Dinghui, Shenzhen Tiantu, Dinghui Phase I, Ping An Innovation, Tianjin Baoding, Dinghui Yuanbo, Beijing Fukun, Chongqing Fukun, Shenzhen Yide, and their partners or shareholders have no special agreements or interests with the issuer, and there are no familial or other interest relationships with the issuer, its controlling shareholders, actual controllers, directors, supervisors, senior management, and intermediaries involved in this issuance.