Securities abbreviation: Shenzhen Kingsino Technology Co.Ltd(002548) Stock Code: Shenzhen Kingsino Technology Co.Ltd(002548) Shenzhen Kingsino Technology Co.Ltd(002548)
And
Citic Securities Company Limited(600030)
Reply to feedback on non-public offering of shares
(Revised Version)
Sponsor (lead underwriter)
March, 2002
China Securities Regulatory Commission:
According to the notice of the CSRC on the first feedback on the examination of administrative licensing projects (No. 220163) (hereinafter referred to as the “feedback”) issued by your commission on February 22, 2022, Shenzhen Kingsino Technology Co.Ltd(002548) (hereinafter referred to as ” Shenzhen Kingsino Technology Co.Ltd(002548) ,” issuer “,” company “or” applicant “) and the recommendation institution Citic Securities Company Limited(600030) (hereinafter referred to as” Citic Securities Company Limited(600030) “and” recommendation institution “) Guangdong Huashang law firm (hereinafter referred to as the “applicant’s lawyer”) and Tianjian Certified Public Accountants (special general partnership) (hereinafter referred to as the “accountant”) have checked and implemented the problems involved in the feedback one by one. Now the relevant replies are reported as follows one by one for review.
Unless otherwise specified, the abbreviation in this reply has the same meaning as that in the due diligence report of Citic Securities Company Limited(600030) on Shenzhen Kingsino Technology Co.Ltd(002548) non-public offering of shares (hereinafter referred to as the due diligence report). The data listed in this reply may be slightly different from the results calculated based on the relevant single data listed in the reply due to rounding.
explain:
The font in this reply report represents the following meanings:
Bold (BOLD): questions listed in the feedback
Arial (not bold): reply to the questions listed in the feedback
Italics (BOLD): revision and supplement to the answers to the questions listed in the feedback
catalogue
Question 1 3 question 2 12 question 3 15 question 4 20 question 5 32 question 6 43 question 7 79 question 8 135 question 9 152 question 10 165 question 11 190 question 12 195 question 13 two hundred and six
Question 1. The applicant is requested to supplement whether the administrative penalties imposed by the listed company and its subsidiaries within the scope of consolidated statements in the last 36 months comply with the provisions of Article 39 of the measures for the administration of securities issuance by listed companies. The recommendation institution and lawyers are invited to give verification opinions.
[reply]
1、 Whether the administrative penalties imposed by the listed company and its subsidiaries within the scope of consolidated statements in the last 36 months comply with the provisions of Article 39 of the measures for the administration of securities issuance by listed companies
The details of the administrative penalty of more than 10000 yuan imposed by the listed company and its subsidiaries within the scope of consolidated statements in the last 36 months are as follows:
No. subject punished, reason of punishment authority and basis of punishment, issuance and analysis of rectification certificate
In July 2018, due to the unauthorized change of forest land use, according to the people’s Republic of China
Paragraph 1 of Article 43 of the regulations for the implementation of the forest law “without the approval of the people’s government at or above the county level
Those who change the use of forest land without authorization with the examination and approval of the competent forestry department of the people’s Government shall be punished by the people’s government at the county level
The competent forestry department of the people’s Government of Shanghai shall order the restoration to the original state within a time limit and impose illegal changes
“A fine of 10 to 30 yuan per square meter of forest land for different purposes”, received the “administrative punishment”
Written decision (Yanlin punishment hearing right notice Zi [2018] No. 09), penalty amount
1380300 yuan
Due to the unauthorized change of forest land use in July 2018, According to the first paragraph of Article 43 of the regulations of the people’s Republic of China on the implementation of the forest law issued by the forestry bureau of Yanping District, Nanping City on May 28, 2020, “without the clarification of the people’s government at or above the county level:” in accordance with the discretion rules of Fujian Province on forestry administrative penalties , if the competent forestry department of the people’s government examines and agrees to change the use of forest land without authorization, the county level shall impose a fine on the basis of light and general application. The company has been promptly ordered by the competent forestry department of the people’s government to restore to the original state within a time limit and pay a fine in full for the illegal change. ” Therefore, there is no penalty of 10 to 30 yuan per square meter for serious damage to the purpose of forest land in the above punishment. “This decision is made in response to the situation that the administrative punishment harms the legitimate rights and interests of investors and the social and public interests (Yanlin punishment hearing right notice Zi [2018] No. 10), The amount of penalty for this non-public offering does not constitute a material obstacle.
Nanping Yanping paid a fine of 225100 yuan in time and made positive progress
In July 2018, the District Forestry Bureau changed the use of forest land without authorization and made rectification in accordance with the regulations of the people’s Republic of China
Paragraph 1 of Article 43 of the regulations for the implementation of Nanping Jinxin forest law “without the approval of the people’s government at or above the county level
Those who change the use of forest land without authorization with the examination and approval of the competent forestry department of the government of agro ecological breeding shall be punished by the county level
3. The competent forestry department of the people’s government above the limited company shall order it to restore to the original state within a time limit and impose illegal changes
“A fine of 10 to 30 yuan per square meter of forest land for different purposes”, received the “administrative punishment”
Written decision (Yanlin punishment hearing right notice Zi [2018] No. 11), penalty amount
68120 yuan
In October 2020, due to unauthorized change of forest land use, According to paragraph 1 of Article 43 of the regulations for the implementation of the forest law of the people’s Republic of China on September 24, 2021, issued by the forestry bureau of Yanping District, Nanping City, “without the consent of the people’s government at or above the county level: “Nanping Shenzhen Kingsino Technology Co.Ltd(002548) the above-mentioned punishment has been closed, and the competent forestry department of the above-mentioned government has examined and approved to change the use of forest land without authorization. The administrative punishment at the county level does not belong to major administrative punishment, and the relevant acts do not belong to more than 4 people’s governments. The competent forestry department of the people’s Government shall order the restoration within a time limit and impose illegal rectification. The circumstances are serious Violations of laws and regulations “.
Therefore, the above punishment is a fine of 10 to 30 yuan per square meter of forest land with unchanged use “and the discretion benchmark of forestry administrative punishment of department minlin [2017] No. 9 in Fujian Province, which seriously damages the legitimate rights and interests of investors and social and public interests, The receipt of administrative punishment does not constitute a material obstacle to this non-public offering.
Written decision (Yanlin penalty Zi [2020] 01031), the penalty amount is 34000 yuan
In January 2022, aquaculture wastewater was discharged into the water body, According to Article 93 of the law of the people’s Republic of China on the prevention and control of ecological water pollution issued by Nanping Ecological Environmental Protection Bureau on February 7, 2022, “enterprises and institutions have paid fines in time and made positive progress in one of the following acts: “The company has paid the fines and confiscations on January 27, 2022. If the environmental protection bureau is completed, the competent environmental protection department of the people’s government at or above the county level shall order it to make corrections; if the circumstances are rectified into rectification, it is actively cooperating with the work of ecological damage compensation. If it is serious, it shall be fined not less than 20000 yuan but not more than 100000 yuan: (II) After the illegal act of water pollution did not cause serious environmental pollution and heavy casualties, the emergency plan for water pollution accident was not started in time, and the relevant measures were taken or the social impact was bad, so there was no serious damage to the social and public interests
No. subject punished, reason of punishment authority and basis of punishment, issuance and analysis of rectification certificate
“Emergency measures” and other relevant laws and regulations and the situation of administrative punishment for ecological environment in Fujian Province. Therefore, the above illegal acts did not lead to the provisions of the rules and benchmarks of serious environmental quantity (Trial), pollution, major casualties or adverse social impact after receiving the decision on administrative punishment, There is no Yan (Minnan Huanjing (2022) No. 3), and the penalty amount is 22000 yuan, which seriously damages the social and public interests, and does not constitute a material obstacle to this non-public offering.
In December 2018, due to violations of work safety, according to the first article of the work safety law
Article 109, paragraph 1, item 1: “in case of production safety accident, on May 20, 2020, Huangpi District Emergency Management Bureau issued a certificate that Wuhan Huangpi production and business operation unit, in addition to requiring it to bear corresponding compensation and other liabilities according to law, Anming: “Wuhan Tianzhong has no major safety since October 2017. 6 the supervision and Administration Department of safety production in Wuhan Tianzhong rain area shall impose a fine in accordance with the following provisions: (I) once the fine is paid in time, the accident will be completed immediately”. Therefore, if there is no such accident as seriously damaging the supervision and Administration Bureau of Taishan branch, a fine of more than 200000 yuan and less than 500000 yuan shall be imposed; (II) the situation of the legitimate rights and interests of the corresponding rectifiers and the social and public interests has been found, which is more serious for the non-public students this time
