Supplementary Legal Opinion (I)
Table of Contents
- Interpretation
- Response to the Inquiry Letter
- Updates During the Supplementary Verification Period
- Evaluation of Legal Risks in the Prospectus
- Conclusion
Interpretation
In this supplementary legal opinion, unless otherwise specified, the following terms have the meanings assigned to them:
- This Supplementary Legal Opinion refers to the "Supplementary Legal Opinion (I) on the Issuance of Convertible Bonds by Jinsanjiang (Zhaoqing) Silicon Materials Co., Ltd."
- The "Legal Opinion" refers to the "Legal Opinion on the Issuance of Convertible Bonds by Jinsanjiang (Zhaoqing) Silicon Materials Co., Ltd."
- The "Inquiry Letter" refers to the inquiry letter issued by the Shenzhen Stock Exchange on November 14, 2025.
Response to the Inquiry Letter
Inquiry Letter Question 2
According to the application materials, the company's products are primarily used in the toothpaste sector, while the company is also expanding into food and pharmaceuticals, high-end industrial applications (such as PE battery separators and silicone rubber), and high-performance tires. This issuance aims to raise no more than 290 million yuan for the construction of a silica production base in Malaysia, which is expected to add 50,000 tons of silica production capacity for toothpaste use. The projected sales revenue upon reaching full production is approximately 503.54 million yuan, with an average annual net profit of 93.01 million yuan. The investment payback period (after tax, including the construction period) is 6.72 years, with an after-tax internal rate of return of 17.32%. The project has received the "Overseas Investment Project Filing Certificate" issued by the Guangdong Provincial Development and Reform Commission, approving the establishment of Jinsanjiang (Malaysia) Co., Ltd. with a total investment of 8 million USD. As of now, the local environmental assessment approval documents in Malaysia have not been obtained, and the transfer of land use rights has not been completed. After the issuance is completed, the total bond balance will account for 49.64% of the latest net assets.