Reply to the Second Round of Inquiry Letter on Guangdong Siquan New Materials Co., Ltd.'s Application for Issuance of Shares to Specific Objects
Shenzhen Stock Exchange:
According to the "Second Round of Inquiry Letter on Guangdong Siquan New Materials Co., Ltd.'s Application for Issuance of Shares to Specific Objects (Inquiry Letter (2025) 020070)" issued by your exchange on November 14, 2025, Great Wall Securities Co., Ltd. (hereinafter referred to as "Great Wall Securities," "the Sponsor," or "the Sponsorship Institution"), as the sponsor (underwriter) for Guangdong Siquan New Materials Co., Ltd. (hereinafter referred to as "Siquan New Materials," "the Issuer," "the Company," or "the Company"), has, together with the Issuer, the Issuer's reporting accountant Zhicheng Certified Public Accountants (Special General Partnership) (hereinafter referred to as "Reporting Accountant"), and the Issuer's lawyer Beijing Zhongyin Law Firm (hereinafter referred to as "Issuer's Lawyer"), in accordance with the principles of diligence, integrity, and good faith, conducted thorough investigations and discussions on the issues raised in the inquiry letter, and now submits the following reply for your review.
The abbreviations used in this reply have the same meaning as those in the "Prospectus for Guangdong Siquan New Materials Co., Ltd.'s Application for Issuance of Shares to Specific Objects in 2025."
The font description for this inquiry letter reply is as follows: Reply to the issues listed in the inquiry letter | Bold Songti Issues listed in the inquiry letter | Songti Supplementary disclosure and amendments to the prospectus | Bold Kaiti
In this reply, any difference between the sum of individual items and the total amount due to rounding is due to rounding.
Issue One
Question Reply:
(1) Regarding the background and latest developments of the customs investigation, please explain the current HS code classification for the issuer's artificial graphite products, whether they continue to be declared under the original HS code; if the HS code is changed, whether a substantive customs classification review has been conducted; whether it affects the issuer's relevant export business; whether there is a risk of new investigations or penalties; and further explain whether the issuer's internal control measures for compliant operation of customs declaration and export tax are sound and effectively implemented.
(A) Regarding the background and latest developments of the customs investigation, please explain the current HS code classification for the issuer's artificial graphite products, whether they continue to be declared under the original HS code; if the HS code is changed, whether a substantive customs classification review has been conducted.
1. Background and Latest Developments of the Customs Investigation
On April 2, 2024, the Issuer's export goods were investigated and inspected by Baiyun Airport Customs. The Issuer received the "Customs Investigation Notice" (Customs Investigation Notice (2024) 202451410001) issued by the Guangzhou Baiyun Airport Customs of the People's Republic of China. The investigation commenced on April 8, 2024, and covered the authenticity and legality of goods declared to Baiyun Airport Customs under general trade from April 9, 2023, to April 8, 2024.
On August 13, 2024, the Issuer received the "Customs Investigation Opinion Solicitation Letter" (2024) 202451410001), which determined that the thermal conductive film/graphite products declared by the Issuer under general trade to Baiyun Airport Customs from April 20, 2021, to March 28, 2024, were declared under an incorrect HS code.
On September 19, 2024, the Issuer received the investigation conclusion for the aforementioned investigation notice. The investigation conclusion stated that the HS code declared for thermal conductive film/graphite products exported by the Issuer to Baiyun Airport Customs from April 20, 2021, to March 28, 2024, was inconsistent with the HS code that should have been declared. This matter has been transferred to the relevant department of Baiyun Airport Customs for handling.