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Pony Testing International Group Co.Ltd(300887) : reply report on the examination and inquiry letter of Pony Testing International Group Co.Ltd(300887) application for issuing shares to specific objects (Revised Version)

Pony Testing International Group Co.Ltd(300887)

And

Huatai United Securities Co., Ltd

about

Pony Testing International Group Co.Ltd(300887) reply to the examination and inquiry letter of applying for issuing shares to specific objects sponsor (lead underwriter)

(401, building B7, Qianhai Shenzhen Hong Kong fund Town, 128 guiwan fifth road, Nanshan street, Qianhai Shenzhen Hong Kong cooperation zone, Shenzhen) December, 2001

Shenzhen Stock Exchange:

We have received the inquiry letter on Pony Testing International Group Co.Ltd(300887) application for issuing shares to specific objects (audit letter [2021] No. 020293) (hereinafter referred to as “audit inquiry letter”) issued by your exchange on November 17, 2021. Pony Testing International Group Co.Ltd(300887) (hereinafter referred to as “the company”, “300887}” or “the issuer”) and Huatai United Securities Co., Ltd. (hereinafter referred to as “the sponsor”) )、 Beijing Deheng Law Firm (hereinafter referred to as “lawyer”), Lixin Certified Public Accountants (special general partnership) (hereinafter referred to as “accountant”) and other relevant parties have verified the problems listed in the audit inquiry letter, and carefully revised, supplemented and explained the application materials. Now, the implementation of the audit inquiry letter and Pony Testing International Group Co.Ltd(300887) The amendments to the prospectus for the issuance of shares to specific objects and listing on the gem (hereinafter referred to as the “prospectus”) shall be replied in writing one by one and submitted to your exchange for review. Special instructions:

Unless otherwise specified, the abbreviation in the reply to the inquiry letter has the same meaning as the abbreviation in the prospectus, and the contents related to the modification of the application documents have been marked in bold italics.

Review the questions listed in the inquiry letter in bold

Reply in Song typeface to the questions listed in the audit inquiry letter

Bold in italics involves modifying the contents of the prospectus and other application documents

In the reply to the inquiry letter, if there is any difference in the mantissa between the sum of the total and the sub item values, it is caused by rounding.

catalogue

Question 1 3 question 2 16 question 3 63 question 4 68 other questions seventy-two

Question one

In the most recent year, the operating income of the issuer was 1426166600 yuan and 1341708500 yuan respectively

The ending balance of accounts receivable is 379.2411 million yuan and 82106.23 yuan respectively

The balance and proportion in operating revenue continued to grow. In addition, the issuer’s net cash flow from operating activities in the latest period

The amount was -107.0726 million yuan, a year-on-year decrease of 8701.94%.

The issuer is requested to supplement: (1) in combination with the credit policy of accounts receivable, aging, post period collection

The situation of comparable companies in the same industry, indicating whether the change of accounts receivable matches the change of operating revenue, and accounts receivable

The reason and rationality of the continuous decline of accounts receivable turnover rate, and whether the provision for bad debts of accounts receivable is sufficient; (2) Most

The reason and rationality of the negative net cash flow from operating activities in the recent period; (3) Main business in the latest period

The reason and rationality of the substantial increase in revenue, and whether the performance growth is sustainable compared with the same period in 2020.

The issuer is requested to fully disclose the risks related to (3). The sponsor is requested to check and express clear opinions, and will

The auditor shall check (1) and (2) and give clear opinions.

reply:

1、 Combined with the credit policy of accounts receivable, aging, post period collection and the situation of comparable companies in the same industry,

Explain whether the change of accounts receivable matches the change of operating revenue, and the reason why the turnover rate of accounts receivable continues to decline

Whether the provision for bad debts of accounts receivable is sufficient due to and rationality

In the most recent year and the first period, the operating income of the issuer was 1426166600 yuan and 1341708500 yuan respectively,

The net accounts receivable are 379.2411 million yuan and 82.10623 million yuan respectively, accounting for the proportion of the company’s operating revenue

26.59% and 61.20% respectively, showing an increasing trend; The turnover rate of accounts receivable of the issuer was 3.87 times and 2.01 times respectively

Times, showing a downward trend. The decline of the issuer’s accounts receivable turnover rate in the last year and the first period was mainly due to the decrease of accounts receivable

The growth rate of accounts receivable exceeded that of operating revenue. At the end of September 2021, the issuer’s accounts receivable increased significantly

The specific analysis is as follows:

(i) At the end of September 2021, compared with the end of 2020, the increase of the company’s accounts receivable mainly comes from one year

Increase in accounts receivable within (including 1 year)

The aging of the issuer’s accounts receivable in the latest year and period is as follows:

Unit: 10000 yuan;%

Aging: accounts receivable from September 30, 2021 to December 31, 2020

Proportion of balance in net bad debt provision proportion of balance in net bad debt provision change amount

80652.7489 within 1 year 454,032.6476,620.1034,103.7578. 481705.1932398.5644221.54 (including 1 year)

1-2 years 6306.516 991,891.954,414.566,402.9714. 731920.894482.08-67.52 (including 2 years)

2-3 years 2143.132 381,071.561,071.572,086.954. 801,043.481,043.4728. 10 (including 3 years)

More than 3 years 1057.831 171,057.83-862.771. 99862.77–

Total 90160.22100 008,053.9982,106.2343,456.44100. 005,532.3237,924.1144,182.11

In the accounts receivable of the issuer in the latest year and period, the accounts receivable within 1 year (including 1 year) accounted for

The ratio is 78.48% and 89.45% respectively. The accounts receivable of the company within one year (including one year) account for a relatively high proportion, and

Showing an increasing trend. At the end of September 2021, compared with the end of 2020, the issuer’s net accounts receivable increased by 44182.11

Of which, the accounts receivable within one year (including one year) increased by 44.2215400 yuan, and the accounts receivable of the company

The increase is mainly from accounts receivable within 1 year (including 1 year).

The main reason for the significant increase in the issuer’s accounts receivable balance at the end of September 2021 compared with the end of 2020 is

The aging structure formed by the sales revenue of the latest period is reasonable.

The credit cycle given by the issuer to customers generally does not exceed 12 months. By the end of September 2021, the issuer has issued

The main debtors aged over 1 year are as follows:

Unit: 10000 yuan,%

Sn customer name accounts receivable balance proportion business type

1 Tangshan Guye District market supervision and Administration Bureau 232.702 45 food testing

2 Shanxi Academy of Environmental Sciences 209.202 20 environmental testing

3 Zhongke environmental remediation (Tianjin) Co., Ltd. 146.201 54 environmental testing

company

4 Hangzhou Jiangcheng construction investment group has 126.001 33 environmental testing

Limited company

5 Zhengzhou Ecological Environment Bureau 121.401 28 environmental testing

6 Suiping county market supervision and Administration Bureau 107.141 13 food testing

7 Dingzhou agricultural and rural Bureau 91.000 96 food testing

8 Guxian Environmental Protection Bureau 86.800 91 environmental testing

9 Henan geological environment planning and Design Institute has 79.540 84 environmental testing

Limited company

10 Guangzhou Metro Group Co., Ltd. 79.020 83 environmental testing

Total 1279.0013 45–

Note: the above proportion is the proportion of the issuer’s balance of accounts receivable for more than one year by the end of September 2021.

(2) The company does not relax its credit policy

The industry to which the issuer belongs is the inspection and testing industry. The customers of the inspection and testing industry are mainly market transaction subjects (manufacturers, traders, etc.) of various products and services and government regulatory departments at all levels. The issuer divides customers into four categories A, B, C and d according to the transaction scale, timeliness of historical payment collection and the nature of customers. The issuer’s credit policies for customers are as follows:

Customer category customer other information credit cycle

Government organs at or above the county level under the provincial capital (municipality directly under the central government), well-known Chinese enterprises or state-owned enterprises

A large enterprise, vehicle manufacturer, customers with standardized management and no abnormal credit records for more than 2 years, or customers in new fields and key regions

Government organs of cities other than provincial capitals (municipalities directly under the central government) and government agencies at or above the county level

B pass, through understanding that enterprise customers have a certain market scale, standardized management, 2-10 months’ demand for long-term inspection, and new customers with good credit

C. by understanding the customer and customer industry, online query enterprise customers have no bad records, and preliminarily locate the customer level through the estimated cooperation amount in 1-4 months

D communicates with customers through sales. Customers belong to one-time cooperation, and the enterprise scale is small. Providing credit without credit period brings great risk of bad debt. They are set as grade D customers and no credit accounting period is given

As mentioned above, from the aging structure, Compared with the end of 2020, the increase of the company’s accounts receivable at the end of September 2021 is mainly within one year The increase of accounts receivable (including 1 year) accounts for more than 99%; that is, the new accounts receivable at the end of September 2021 mainly comes from the income generated in the current period. From the perspective of credit policy, the issuer’s credit policy to customers does not exceed 12 months. By the end of September 2021, more than 90% of the company’s accounts receivable balance is still in the credit period, and the company’s credit policy to major customers It has been implemented consistently, and there is no case of increasing operating revenue by extending the credit policy.

The overdue accounts receivable of the issuer during the reporting period are as follows:

Unit: 10000 yuan

Overdue amount of accounts receivable

year

 

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