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Response of the Issuer and Sponsor to the Audit Inquiry Letter Regarding the Application for Issuance of Shares to Specific Objects by Chongqing Shunbo Aluminum Alloy Co., Ltd.

Chongqing Shunbo Aluminum Co., Ltd.··127 pages

✨ AI Summary

This document contains the formal response from Chongqing Shunbo Aluminum Alloy Co., Ltd. and Sealand Securities to the Shenzhen Stock Exchange's audit inquiry letter. The inquiry addresses the company's financial performance, revenue recognition, trade business operations, accounts receivable, inventory management, and historical regulatory compliance issues. The company provides detailed explanations and supplementary disclosures regarding its financial health, internal controls, and tax compliance to support its application for a private placement of shares.

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Full Translation

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[Image: Shunbo Logo]

Chongqing Shunbo Aluminum Alloy Co., Ltd.

and

Sealand Securities Co., Ltd.

Response to the Audit Inquiry Letter Regarding the Application for Issuance of Shares to Specific Objects by Chongqing Shunbo Aluminum Alloy Co., Ltd.

Sponsor (Lead Underwriter)

[Image: Sealand Securities Logo]

(No. 13 Fuxing Road, Guilin, Guangxi Zhuang Autonomous Region)

July 2026

Shenzhen Stock Exchange:

We have received the "Audit Inquiry Letter Regarding the Application for Issuance of Shares to Specific Objects by Chongqing Shunbo Aluminum Alloy Co., Ltd." (Audit Letter [2025] No. 120064) (hereinafter referred to as the "Inquiry Letter") issued by your exchange on December 25, 2025. Chongqing Shunbo Aluminum Alloy Co., Ltd. (hereinafter referred to as "Shunbo Alloy," the "Company," the "Issuer," or the "Applicant") has carefully read the entire content of the Inquiry Letter. In accordance with the requirements of the Inquiry Letter, the Company, together with Sealand Securities Co., Ltd. (hereinafter referred to as "Sealand Securities" or the "Sponsor"), Chongqing Yuanwei Law Firm (hereinafter referred to as "Yuanwei Law Firm" or "Issuer's Counsel"), and Zhonghua Certified Public Accountants (Special General Partnership) (hereinafter referred to as "Zhonghua CPA" or the "Accountant"), has verified the relevant content and issues, and has revised and supplemented the application materials. We hereby provide a written response to each item in the Inquiry Letter and the modifications to the Prospectus, and submit them to your exchange for review.

Unless otherwise specified, the abbreviations in this response have the same meanings as those in the "Prospectus for the Issuance of Shares to Specific Objects by Chongqing Shunbo Aluminum Alloy Co., Ltd." The data listed in this response may differ slightly from the results calculated directly from the relevant individual items due to rounding.

The font styles in this response represent the following:

ItemFont Style
Questions listed in the Inquiry LetterBold
Responses to the questions in the Inquiry LetterSongti
Modifications or supplementary disclosures to the Prospectus and other application documentsKai-ti Bold

Table of Contents

Question 1: 3

Question 2: 84

Other questions: 118

Question 1:

According to the application documents, the Issuer's main business is the production and sales of aluminum alloys. Other business income is mainly derived from material sales, scrap sales, interest income, rental income, and trade business income. During the reporting period, the Issuer's operating income was 11,066.3082 million yuan, 11,944.6523 million yuan, 13,976.5134 million yuan, and 11,266.0278 million yuan, respectively, showing year-on-year growth. Net profit after deducting non-recurring gains and losses attributable to the parent company was 150.2947 million yuan, 93.8653 million yuan, 94.6007 million yuan, and 185.1671 million yuan, respectively. The Issuer's other income was 112.0229 million yuan, 113.2226 million yuan, 192.7226 million yuan, and 186.3324 million yuan, respectively, including tax refunds, government subsidies, and others. The net cash flow from operating activities was 344.3920 million yuan, -415.4069 million yuan, 433.0531 million yuan, and 66.1938 million yuan, respectively.

During the reporting period, the gross profit margin of the Issuer's main business was 3.08%, 2.39%, 2.58%, and 2.75%, respectively. The gross profit margin of other businesses was 32.04%, 42.08%, 58.01%, and 34.63%, respectively. The relatively high gross profit margin of other businesses is mainly because the Issuer adopts the net method to recognize income for trade businesses such as aluminum ingots, molten aluminum, and scrap steel.

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