Zhongxinghua Certified Public Accountants (LLP)
Zhongxinghua Bao Zi [blank] No. [blank]
To: Shenzhen Stock Exchange
We have received the "Second Round of Audit Inquiry Letter Regarding the Application of Heima Technology Group Co., Ltd. for Issuance of Shares and Cash Payment for Asset Acquisition and Raising of Supporting Funds" (Audit Letter [2025] No. 030015) (hereinafter referred to as the "Second Round Inquiry Letter") issued by your exchange on November 11, 2025. Heima Technology Group Co., Ltd. (hereinafter referred to as "Heima Technology," the "Listed Company," or the "Company"), together with relevant intermediaries, has conducted a thorough verification and implementation of the issues listed in the Second Round Inquiry Letter. Corresponding revisions and supplementary disclosures have been made in the "Report on the Issuance of Shares and Cash Payment for Asset Acquisition and Raising of Supporting Funds of Heima Technology Group Co., Ltd. (Draft)" (hereinafter referred to as the "Restructuring Report") as required. The response is as follows, please review.
Notes:
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Unless otherwise specified, the definitions of abbreviations or terms in this response are the same as those in the "Restructuring Report."
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Any discrepancies between the totals and the sums of the individual items in this response are due to rounding.
Question 3: Regarding the Authenticity of the Performance of the Target Assets
Application documents and response documents show: (1) During the reporting period, the final usage ratios of the certification certificates issued by the target assets were 31.83%, 47.97%, and 42.96%, respectively, with cases where some certificates were verified but the corresponding application could not be found on the shelves. (2) During the reporting period, the verification ratios of electronic copyright certification certificates issued by the target assets were 67.00%, 76.52%, and 51.67%, respectively, and there were cases where verification data could not be found for some certificates processed each year. (3) Regarding the lack of retained verification data for some certificates, the independent financial advisor and the accountant, in order to verify the authenticity of the business, sampled no less than 20% of the business orders without retained verification data for each period of the reporting period for special verification, and checked the relevant order information through the target asset business system. (4) During the reporting period, the third-party payment amounts of the target assets were 0.17 billion yuan, 0.29 billion yuan, and 0.13 billion yuan, respectively, including payments made by agents through third parties. During the reporting period, the independent financial advisor and the accountant selected samples of operating income involving third-party payments of [blank] transactions, [blank] transactions, and [blank] transactions, respectively, for detail testing. (5) During the reporting period, the company founded by former employees was the largest customer of the target assets.
The listed company is requested to supplement the disclosure of: (1) The specific reasons for the inability to query verification data for some certificates and the situation where certification certificates have been verified but the corresponding applications cannot be found on the shelves; the reasons for and rationality of the decline in the certificate verification ratio in the first half of 2025; and combine market data such as the market share of application distribution platforms not connected to the target asset verification interface and the audit pass rate of APP shelves to demonstrate and analyze the rationality of the target asset certificate verification ratio and the final usage ratio of certificates; whether there is a situation where the same customer has many unverified certificates, and if so, supplement the disclosure of the rationality and the authenticity of related income. (2) The reasons for and rationality of agents making payments through third parties.