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"). This firm now issues the following supplementary legal opinion based on the requirements of the China Securities Regulatory Commission's letter dated June 5, 2013 (Issuance Regulatory Letter [2013] No. 92) to verify relevant facts:
Issue: Please verify and explain whether the following allegations made by the whistleblower regarding the issuer Ciming Health Checkup Management Group's Shanghai company and its subordinate branches are true:
- Hiring unqualified doctors to conduct health checkups;
- False advertising and misleading consumers, such as claiming that health checkup conclusions would be explained by experts, while the actual personnel lack relevant qualifications, professional knowledge, and clinical experience;
- Customer service phone lines are ineffective, with numerous complaints;
- Chaotic salary management, such as withholding profits and bonuses from branch staff, while company employees privately distribute shopping cards;
- Disorganized management systems, such as company documents lacking document numbers, dates, and official seals;
- Internal management chaos, such as frequent internal network failures, lack of work planning, repeated renovations, and significant waste.
If the allegations are true, please explain whether there are specific rectification measures and whether the relevant circumstances constitute obstacles to this issuance and listing. Additionally, please verify whether the issuer and other subordinate branches have similar or other management chaos and whether the issuer's franchising and health checkup management consulting business operates in a compliant manner.
Response: The lawyers of this firm, together with the sponsor, conducted on-site visits to Shanghai Ciming and other outpatient departments (excluding Linyi Ciming and Jinhua Ciming) from June 7 to June 22, 2013. Based on the list of medical personnel provided by the outpatient departments, the lawyers verified the qualifications of the medical staff on-site and re-verified through the Ministry of Health and local health authorities' official websites (for Linyi Ciming and Jinhua Ciming, verification was done through checking the list of medical personnel and copies of qualification certificates). Interviews were conducted with department heads and final inspection physicians (for Linyi Ciming and Jinhua Ciming, interviews were conducted via phone) and relevant management operation systems were verified. The verification results are as follows: