Stock Abbreviation: Sunhan New Material
Stock Code: 301076
Response to the Second Round of Audit Inquiry Letter Regarding the Application of Jiangsu Sunhan New Material Co., Ltd. for Issuance of Shares to Specific Targets
Sponsor (Lead Underwriter): CITIC Securities Company Limited
Address: North Tower, Excellence Times Plaza (Phase II), No. 8 Center 3rd Road, Futian District, Shenzhen, Guangdong Province
Date: July 2026
Shenzhen Stock Exchange:
We have received the "Second Round of Audit Inquiry Letter Regarding the Application of Jiangsu Sunhan New Material Co., Ltd. for Issuance of Shares to Specific Targets" (Audit Letter [2026] No. 020065) (hereinafter referred to as the "Audit Inquiry Letter") issued by your exchange on July 20, 2026. Jiangsu Sunhan New Material Co., Ltd. (hereinafter referred to as "Sunhan New Material," the "Issuer," or the "Company"), together with CITIC Securities Co., Ltd. (hereinafter referred to as "CITIC Securities," the "Sponsor Institution," or the "Sponsor") and Tianjian Certified Public Accountants (Special General Partnership) (hereinafter referred to as the "Accountants"), have conducted a thorough discussion and verification of the issues raised in the Audit Inquiry Letter. We have implemented the requirements for written explanations and verifications by the Issuer and relevant intermediaries, and have responded to each question in the Audit Inquiry Letter in accordance with the principles of diligence, duty, and integrity. Please review.
Notes:
-
Unless otherwise specified, the abbreviations or proper nouns used in this response report have the same definitions as those in the "Jiangsu Sunhan New Material Co., Ltd. 2026 Prospectus for Issuance of A-Shares to Specific Targets (Declaration Draft)." In this response report, any discrepancies between the sum of individual items and the total are due to rounding.
-
The font styles in this response report have the following meanings:
| Font Style | Meaning |
|---|---|
| Bold Blackbody | Questions listed in the Audit Inquiry Letter |
| Songti (Bold/Regular) | Responses to Audit Inquiry Letter and intermediary verification opinions |
| Kaiti (Bold) | Supplementary disclosures and amendments to the prospectus |
Table of Contents
Table of Contents 2
Question 1 3
Question 2 19
Question 1
According to the Issuer's response to the first round of inquiries, the primary reasons for the multiple delays in the previous fundraising projects include product planning adjustments, production line changes, and increased construction costs. The commissioning time for the second-phase project (Workshop 3) of the 8,000-ton aromatic ketone and supporting project was extended from December 31, 2023, to June 30, 2026. In 2024, the Issuer adjusted the production capacity of this project, mainly reducing the capacity for certain core raw materials for special engineering plastics and cosmetic raw materials, while increasing the capacity for HDO among cosmetic raw materials. The capacity utilization rate of this project is 32.62%, and the actual benefits are far lower than the promised benefits.
The Issuer is requested to: (1) Explain whether there is a risk of further delays in the current fundraising project, combined with the specific reasons for the changes and delays in the previous fundraising projects. (2) Explain the reasons and rationality for the newly added production capacity of core raw materials for special engineering plastics in the current fundraising project, combined with the specific reasons for reducing the capacity of certain core raw materials for special engineering plastics in 2024. (3) Explain the specific reasons for the insufficient or low capacity utilization of the previous fundraising projects, whether it involves relevant commitments, and whether relevant risks have been fully disclosed, combined with the benefits, production progress, capacity utilization rate, and gross profit margin of the previous fundraising projects, as well as the approval and progress of the current fundraising project.