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Zhong Lun Law Firm's Supplementary Legal Opinion on Guangdong Jinma Amusement's Private Placement of Shares (Revised Draft)

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This document is a supplementary legal opinion from Zhong Lun Law Firm regarding Guangdong Jinma Amusement's private placement of shares. It addresses inquiries from the Shenzhen Stock Exchange concerning administrative penalties and compliance. The opinion concludes that the company's past violations do not constitute major legal breaches and do not pose a substantial obstacle to the offering.

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Supplementary Legal Opinion

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 supplementary legal opinion.

To issue this supplementary legal opinion, the firm's lawyers have, in accordance with relevant laws, administrative regulations, normative documents, and the firm's business rules, conducted investigations and verifications on the issues involved in this supplementary legal opinion with prudence and a focus on materiality.

The firm and the handling lawyers have, in accordance with the "Securities Law," the "Measures for the Administration of 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 supplementary legal opinion, strictly performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough verification, and ensured that the facts identified in this supplementary legal opinion are true, accurate, and complete, that the conclusions expressed are legal and accurate, and that there are no 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 accepted business standards, ethical norms, and the spirit of diligence in the legal profession, the firm's lawyers, after investigating and verifying the relevant documents, materials, and facts of the issuer's current offering (the foregoing content is limited to the scope of the firm's opinions expressed in this supplementary legal opinion), 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 virtual immersive amusement project during each reporting period 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 and tourism 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 overall gross profit margin was 34.57%, 31.00%, 36.49%, and 44.45%, respectively; the gross profit margin for the cultural and 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 "Supervisory Concern Letter" 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 using 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 classified as a financial investment, representing the company's 47.66% stake in Zhongshan Jinma Times Bole Industrial Investment Partnership (Limited Partnership).

The issuer is requested to: ... (3) Combined with the rectification of the issuer's relevant administrative penalties and relevant certifications from authorities, explain whether the issuer has committed any major illegal acts that seriously harmed investors' legitimate rights and interests or public interests in the past three years, and whether it complies with Article 11 of the "Registration Measures" and the "Guiding Opinions on the Application of Laws for Securities and Futures" No. 18. ...

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