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Zhong Lun Law Firm's Supplementary Legal Opinion on Guangdong Jinma Amusement Park Co., Ltd.'s Private Placement of Shares

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Zhong Lun Law Firm provides a supplementary legal opinion regarding Guangdong Jinma Amusement Park's private placement of shares. The opinion addresses inquiries from the Shenzhen Stock Exchange concerning administrative penalties faced by the company and its subsidiary, Zao Meng Youle. It concludes that these penalties do not constitute major violations and will not pose a substantial legal obstacle to the offering.

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Supplementary Legal Opinion

The meanings of terms, names, and abbreviations used in this Legal Opinion are the same as those in the Original Legal Opinion and the Lawyer's Work Report, unless otherwise specified.

Unless otherwise stated, the matters declared by the Firm's lawyers in the Original Legal Opinion and the Lawyer's Work Report apply to this Legal Opinion.

To issue this Legal Opinion, the Firm's lawyers have conducted investigations and verifications on the relevant issues involved in this Legal Opinion in accordance with the requirements of relevant laws, administrative regulations, normative documents, and the Firm's business rules, adhering to the principles of prudence and materiality.

The Firm and the handling lawyers have fulfilled their statutory duties in accordance with the "Securities Law," the "Administrative Measures for Securities Legal Business of Law Firms," and the "Practice Rules for Securities Legal Business of Law Firms (Trial)," and based on facts that have occurred or existed prior to the issuance of this Legal Opinion. They have adhered to the principles of diligence and good faith, conducted thorough verification, and ensured that the facts identified in this Legal Opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without any false records, misleading statements, or material omissions, and are willing to bear corresponding legal responsibilities.

In accordance with the provisions of Article 19 of the "Securities Law," and in accordance with the generally recognized business standards, ethical norms, and the spirit of diligence in the legal profession, the Firm's lawyers have conducted investigations and verifications on the relevant documents, materials, and facts related to the issuer's current issuance (the foregoing content is limited to the matters on which this Legal Opinion expresses opinions), and hereby issue the supplementary legal opinion as follows:

I. Inquiry Letter Question 1

"During each reporting period, the company's main business revenue was RMB 73,422.81 million, RMB 56,643.99 million, RMB 481.48 million, and RMB 15,245.02 million, respectively, and net profit was RMB 4,591.82 million, RMB 445.79 million, RMB 7,773.97 million, and RMB 2,687.40 million, respectively. The revenue from the immersive virtual reality amusement project during the reporting periods was RMB 26,756.49 million, RMB 3,737.26 million, RMB 2,276.55 million, and RMB 884.96 million, respectively. From January to March 2026, a new cultural tourism and entertainment robot business was launched, with sales of RMB 504.42 million, accounting for 3.31% of the main business revenue for the period. During the reporting period, the company's comprehensive gross profit margin was 34.57%, 31.00%, 36.49%, and 44.45%, respectively; the gross profit margin for cultural tourism investment and operation business was 32.90%, 30.19%, 19.57%, and 10.76%, respectively."

During each reporting period, the company's overseas revenue was RMB 1,383.95 million, RMB 7,125.14 million, RMB 11,938.05 million, and RMB 7,575.43 million, accounting for 1.87%, 12.35%, 17.41%, and 49.15%, respectively, showing a year-on-year increase. In 2024 and 2025, the company's overseas sales gross profit margin was significantly higher than its domestic sales gross profit margin.

In July 2023, the company received a "Letter of Concern" from the Guangdong Regulatory Bureau of the China Securities Regulatory Commission for failing to disclose environmental administrative penalty information in the 2022 annual report. During the reporting period, the company and its holding subsidiaries had administrative penalties, including the company's subsidiary illegally operating sealed special equipment in 2025.

As of March 31, 2026, the company's long-term equity investment amounted to RMB 5,002.95 million, which was recognized as a financial investment, representing the company's 47.66% stake in Zhongshan Jinma Times Bole Industrial Investment Partnership (Limited Partnership).

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