Beijing Guofeng law firm
About Hangzhou Heshun Technology Co., Ltd
Applying for IPO and listing on GEM
Supplementary legal opinion 4
Gflzz [2020] an330-22
Beijing Guofeng law firm
Grandway Law Offices
7 / F, news building, No. 26, Jianguomen inner street, Dongcheng District, Beijing zip code: 100005
Tel: 01088004488 / 66090088 Fax: 01066090016
Beijing Guofeng law firm
About Hangzhou Heshun Technology Co., Ltd
Applying for IPO and listing on GEM
Supplementary legal opinion 4
Gflzz [2020] an330-22
To: Hangzhou Heshun Technology Co., Ltd. (issuer)
According to the lawyer service agreement signed between the exchange and the issuer, the exchange accepts the entrustment of the issuer to act as the special legal adviser of the issuer for this issuance and listing.
Our lawyers have examined the documents and relevant facts provided by the issuer in accordance with the company law, the securities law, the measures for the administration of registration, the measures for the administration of securities legal business, the rules for the practice of securities legal business and other relevant laws, regulations, rules and normative documents, and in accordance with the recognized business standards, moral norms and the spirit of diligence and responsibility of the lawyer industry, And issued the legal opinion of Beijing Guofeng law firm on Hangzhou Heshun Technology Co., Ltd. applying for initial public offering and listing on the gem (hereinafter referred to as the "legal opinion") on the issuer's issue and listing The lawyer work report of Beijing Guofeng law firm on Hangzhou Heshun Technology Co., Ltd. applying for IPO and listing on the gem (hereinafter referred to as the "lawyer work report") One of the supplementary legal opinions of Beijing Guofeng law firm on the application of Hangzhou Heshun Technology Co., Ltd. for initial public offering and listing on the gem (hereinafter referred to as "one of the supplementary legal opinions") Beijing Guofeng law firm's supplementary legal opinion No. 2 on Hangzhou Heshun Technology Co., Ltd. applying for initial public offering and listing on the gem (hereinafter referred to as "supplementary legal opinion No. 2") The third supplementary legal opinion of Beijing Guofeng law firm on the application of Hangzhou Heshun Technology Co., Ltd. for initial public offering and listing on the gem (hereinafter referred to as "the third supplementary legal opinion").
According to the letter of implementation of the opinions of the audit center on Hangzhou Heshun Technology Co., Ltd. applying for IPO and listing on the gem (hereinafter referred to as the "letter of implementation of opinions") issued by Shenzhen Stock Exchange on July 19, 2021 and the requirements of the issuer, our lawyers, on the basis of further inspection of the issuer's relevant information related to this issuance and listing, Issue this supplementary legal opinion to modify, supplement or further explain the relevant contents of the legal opinion, lawyer work report and relevant supplementary legal opinions already issued by our lawyers.
Our lawyers agree to submit this supplementary legal opinion as a necessary legal document for the issuer's issuance and listing together with other materials, and bear corresponding responsibilities for this supplementary legal opinion according to law; This supplementary legal opinion is only used by the issuer for the purpose of this issuance and listing, and shall not be used for any other purpose.
The matters stated by our lawyers in the legal opinion and lawyer work report are also applicable to this supplementary legal opinion. Unless otherwise specified, the meaning of relevant terms in this supplementary legal opinion is consistent with that of the same terms in the legal opinion and lawyer's work report.
In accordance with the requirements of relevant laws, administrative regulations, rules and normative documents such as the company law, the securities law, the measures for the administration of registration, the measures for the administration of securities legal business, the rules for the practice of securities legal business and the relevant provisions of the CSRC and the stock exchange, and in accordance with the business standards, ethics and diligence recognized by the lawyer industry, The supplementary legal opinions are as follows:
1、 About business and core technology
The application documents and the reply to the audit inquiry show that:
(1) The issuer's core technology products mainly include self-produced colored photoelectric base film series, other functional film series and some transparent film products. Among them, the colored photoelectric base film is the main source of income and profit of the issuer. (2) The downstream customers of the issuer are relatively scattered, and the product application fields of the main customers are relatively extensive.
Please the issuer:
(1) Combined with the application fields of colored photoelectric base film and transparent film, the differences between the uses of the above two types of products are explained; Further explain whether the issuer's statement of "colored photoelectric base film" is accurate in combination with the role played by the colored photoelectric base film in the specific production links of the consumer electronics industry and the description of the use and characteristics of similar products of comparable companies in the same industry; If not, please modify the relevant statements in the prospectus and other application documents according to the actual use of the issuer's products, and describe the name, characteristics and use of the issuer's own products in an objective and easy to understand manner.
(2) Describe the main end consumer electronics manufacturers corresponding to the products according to the sub categories of the issuer's colored optoelectronic base film products, the specific scenarios applied in the field of consumer electronics, the types of colors involved and the number of sub colors; Further explain the market share of the issuer's products in major major consumer electronics manufacturers, the number of new colors and the proportion of corresponding income in each period of the reporting period, whether each color demand comes from consumer electronics manufacturers, whether there are subdivided colors and reasons for stopping production, in combination with the above situation, the way the issuer obtains customers, on-hand orders and corresponding color types Color type, development time, etc., indicating the expansion plan of customers in the future and its impact on the business development of the issuer.
(3) the main basis of the issuer's advanced core technology, the status of the industry and the core competitiveness are illustrated by the differences in technical indicators and the competitive advantages and disadvantages of the issuers and comparable products of the same industry. The sponsor is requested to give a clear opinion, and the lawyer of the issuer is requested to give a clear opinion on question (1).
(I) combining the application fields of colored photoelectric base film and transparent film, explain the differences between the uses of the above two types of products; Combined with the role of colored photoelectric base film in the specific production links of consumer electronics industry, whether the expression of "colored photoelectric base film" in the same industry is accurate; If not, please modify the relevant statements in the prospectus and other application documents according to the actual use of the issuer's products, and describe the name, characteristics and use of the issuer's own products in an objective and easy to understand manner.
1. Combine the application fields of colored photoelectric base film and transparent film to explain the differences of the above two types of products.
According to the statement of the issuer and the interview with the general manager of the issuer, the company's colored photoelectric base film is mainly used in the field of consumer electronics, and the company's transparent film products are widely used in many fields, such as electronics, electrical engineering, packaging and decoration. The details are as follows:
(1) Application field of colored photoelectric base film
The colored photoelectric base film produced by the company is mainly used to produce functional application materials in the manufacturing process of consumer electronics, and can also be used as electronic labels or electronic tapes.
The process application of consumer electronic products is the main application field of the company's colored photoelectric base film products. After downstream processing, colored photoelectric base film products can be used as process protective film and release film in the manufacturing process of consumer electronic products. Consumer electronic products such as smart phones, laptops and tablets are precision electronic products, and their production process involves the production, transportation, testing and assembly of thousands of components. This process will involve processes including welding, cutting, flushing and displacement, so that the components will be in the environment of high humidity, high temperature, strong acid-base and external stress, which will cause loss or negative impact on electronic devices. The company's colored photoelectric base film products can be made into protective film after being coated with adhesive by downstream manufacturers, which can protect electronic components in the manufacturing process of electronic products.
The main function of the company's colored photoelectric base film products is to protect the flexible circuit board, optical glass and optical grade diaphragm in the module structure of the display (such as reflective film, diffusion film, polarizer, etc.). The gloss, transmittance and surface electrostatic adhesion of optical film directly affect the quality of electronic products. The process protective film usually has low viscosity. After it is attached to the optical film, it can protect the surface integrity of the optical film and prevent electrostatic adhesion on its surface in the process of product manufacturing, assembly and transportation. After the production process is completed, the process protective film on the surface of the optical diaphragm can be removed without residual glue. At the same time, some optical diaphragms need to be adhered to other structures due to production process requirements. The company's polyester film products can also be made into release films after being coated with release agents by downstream manufacturers, which can protect the optical adhesive layer on the optical diaphragms from volatilization Physical impact, corrosion and other factors affect the performance and loss.
The company's colored photoelectric base film can also be used as an electronic label, as a namesector of consumer electronic products or a label of circuit boards in the manufacturing process, so as to meet the photoelectric tracking requirements of automatic equipment such as die cutting in the automatic assembly process. Colored photoelectric base film products can also be used as electronic tape to fix and protect electronic components.
(2) Application field of transparent film
The transparent film products produced by the company are widely used and can be used in many fields such as electronics, electrical engineering, packaging and decoration: first, the transparent film products of the company can be used for the process protection of consumer electronic products after downstream processing; Secondly, the company's transparent film products can also be used as the base film of insulating materials, which can be used in the fields of touch switch, flexible circuit board and motor insulation after being processed by downstream film manufacturers; Thirdly, the transparent film produced by the company can be used as the base film to produce packaging film or decorative film. Specifically, the company's products can be used as base film to produce commodity labels; After compounding with stainless steel sector, it can be made into VCM panel, etc., and then used as the panel of refrigerator, washing machine and cabinet; After aluminum plating by downstream manufacturers, it can replace aluminum foil to a certain extent and is widely used in cable shielding, air conditioning pipe packaging and waterproof materials; After downstream processing, it can be used as building material film for ceramic tile, wood board and wallpaper; After downstream processing, it can be made into decorative beads and golden onion powder.
(3) Differences between the application fields of colored photoelectric base film and transparent film of the company
A. The company's colored photoelectric base film products are mainly used in the field of consumer electronics, while the application fields of transparent film products are relatively wide
The main application field of the company's colored photoelectric base film is the consumer electronics industry. The application field is relatively clear and belongs to the company's relatively high-end products. The colored photoelectric base film is mainly used as the downstream functional substrate, and can be made into composite functional materials after deep processing such as coating and compounding by downstream manufacturers. The quality of functional base material directly affects the realization of the final functional properties of composite functional materials, so it needs to have the advantages of good flatness, good temperature resistance, strong size and color stability, so as to meet the requirements of downstream customers for the functional structure of base material; The transparent film products of the company are more widely used and can be used in many fields such as electronics, electrical engineering, packaging and decoration. In addition to a small number of special transparent films, they mainly use the properties of polyester film to realize their functions.
B. As a consumer electronics process protection application material, colored photoelectric base film can achieve more functions
The company's colored photoelectric base film and some of the company's transparent film products can be used for the process protection of consumer electronics. However, because the company's colored photoelectric base film is a colored product, it can also realize the following unique functions: distinguish different adhesive product components with color to prevent errors during assembly; "Anti stupidity", that is to reduce the eye fatigue of assembly workers (non-ferrous products are easy to distinguish) and improve production efficiency; In the automatic assembly process, cooperate with the photoelectric tracking requirements of automatic equipment such as die cutting ( Siasun Robot&Automation Co.Ltd(300024) according to the photoelectric tracking accurate positioning of different colors, the requirements for color accuracy are high, and the ordinary transparent PET film cannot be realized), so as to improve the production efficiency and yield of products.
C. When used as labels, colored photoelectric base films are mainly used for electronic labels, while transparent film products are mainly used for commodity labels
After downstream processing, the company's colored photoelectric base film products can be made into namesectors of consumer electronic products and labels of circuit boards in the process of process protection. They are usually made from the company's white photoelectric base film and black photoelectric base film after downstream processing, which has the characteristics of strong insulation and high color stability.
The company's transparent film products can be made into commodity labels after downstream processing. Now they are widely used in daily chemical, electronic, food and pharmaceutical industries. The commodity label made of polyester film mainly uses the characteristics of pet itself, which has many advantages, such as beauty, wear resistance, water resistance, corrosion resistance, not easy to be torn and good transparency. To sum up, the company's colored photoelectric base film is mainly used in the field of consumer electronics and belongs to the company's relatively high-end products. In addition to a small number of special transparent films, the transparent film products of the company mainly use the properties and functions of polyester film itself, and have a wide range of applications.
2. Further explain whether the issuer's statement of "colored photoelectric base film" is accurate in combination with the role played by the colored photoelectric base film in the specific production links of the consumer electronics industry and the description of the use and characteristics of similar products of comparable companies in the same industry; If not, please modify the relevant statements in the prospectus and other application documents according to the actual use of the issuer's products, and describe the name, characteristics and use of the issuer's own products in an objective and easy to understand manner.
According to the statement of the issuer, the main business contract and the interview with the general manager of the issuer, the colored photoelectric base film products produced by the company, after downstream processing, are mainly used for the process protection of consumer electronic products such as smart phones, laptops and tablets, and belong to consumables in the process of consumer electronic products.
According to the official website of comparable companies in the same industry or the public information disclosed by them, the descriptions of the uses and characteristics of similar products are mainly as follows:
Enterprise name main source of income product purpose and characteristic description
Product name
Sichuan Em Technology Co.Ltd(601208) optical film material optical grade polyester base film is mainly used in the fields of smart phone 2.5d/3d front and rear cover glass protection, polarizer and touch screen module matching, high-end MLCC process matching and so on.
Reflective film - White poly company produces white polyester reflective film. The products can be divided into ester reflective film, uncoated reflective film and coated reflective film according to different production processes
