Grandway Law Offices
Supplementary Legal Opinion No. 1 on the 2024 Issuance of Shares to Specific Targets by Xiamen Hongxin Electron-Tech Group Co., Ltd.
Document No.: Grandway Law Securities [2025] AN157-18
To: Xiamen Hongxin Electron-Tech Group Co., Ltd.
Pursuant to the "Legal Service Agreement" signed between this firm and the issuer, this firm has been engaged as the special legal counsel for the issuer's current offering and hereby issues this supplementary legal opinion. This firm has examined the documents and relevant facts provided by the issuer in accordance with the provisions of relevant laws, regulations, rules, and normative documents, as well as the business standards, ethical norms, and the spirit of diligence and responsibility generally accepted in the legal profession. We have previously issued the "Legal Opinion of Grandway Law Offices on the 2024 Issuance of Shares to Specific Targets by Xiamen Hongxin Electron-Tech Group Co., Ltd." (hereinafter referred to as the "Legal Opinion") and the "Lawyer's Work Report of Grandway Law Offices on the 2024 Issuance of Shares to Specific Targets by Xiamen Hongxin Electron-Tech Group Co., Ltd." (hereinafter referred to as the "Lawyer's Work Report").
In accordance with the "Audit Inquiry Letter on the Application for Issuance of Shares to Specific Targets by Xiamen Hongxin Electron-Tech Group Co., Ltd." (Audit Letter [2025] No. 020054, hereinafter referred to as the "Inquiry Letter") and the requirements of the issuer, this firm's lawyers have conducted further verification of matters related to the issuer's current offering and listing. Based on this, we issue this supplementary legal opinion to amend, supplement, or further explain the relevant contents of the previously issued Legal Opinion and Lawyer's Work Report.
This firm's lawyers agree to submit this supplementary legal opinion as a required statutory document for the issuer's current offering along with other materials and shall bear corresponding legal responsibilities for this supplementary legal opinion in accordance with the law. This supplementary legal opinion is intended solely for the purpose of the issuer's current offering and may not be used for any other purpose.
The statements made in the "Legal Opinion" and "Lawyer's Work Report" by this firm's lawyers also apply to this supplementary legal opinion. Unless otherwise specified, the terms used in this supplementary legal opinion have the same meanings as those in the "Legal Opinion" and "Lawyer's Work Report."
This firm's lawyers have conducted verification of the documents and relevant facts provided by the issuer in accordance with the requirements of the "Company Law," "Securities Law," "Registration Management Measures," "Business Management Measures," "Business Practice Rules," and other relevant laws, administrative regulations, rules, and normative documents, as well as the business standards, ethical norms, and the spirit of diligence and responsibility generally accepted in the legal profession, and hereby issue the following supplementary legal opinion:
Inquiry Letter Question 1
During the reporting period, the company's operating income was 2,792.3841 million yuan, 3,478.2967 million yuan, 5,875.0964 million yuan, and 3,493.8257 million yuan, respectively. Net profit after deducting non-recurring gains and losses was -362.206 million yuan, -449.0477 million yuan, -65.321 million yuan, and 47.5062 million yuan, respectively. Net cash flow from operating activities was 100.6305 million yuan, 142.7777 million yuan, 202.5951 million yuan, and 51.0519 million yuan, respectively. During each period of the reporting period, the issuer's comprehensive gross margin was 4.80%, 2.39%, 10.04%, and 12.07%, respectively, with significant fluctuations in the gross margins of printed circuit boards, backlight modules, and computing power and related businesses. During each period of the reporting period, the proportion of sales to the top five customers to the current operating income was 54.05%, 58.32%, 51.96%, and 34.78%, respectively, with some overlap between customers and suppliers.