Reply to the examination and inquiry letter on the application documents for initial public offering and listing on the gem of Ganzhou Yihao new materials Co., Ltd. Tian shiye Zi [2022] No. 166156
catalogue
Reply to the inquiry letter on the examination of the application documents for initial public offering and listing on the gem ------ 1
About Ganzhou Yihao New Material Co., Ltd
Application documents for initial public offering and listing on GEM
Reply to audit inquiry letter
Tian Zhi Ye Zi [2022] No. 166156 Shenzhen Stock Exchange:
According to the requirements of the examination and inquiry letter on the application documents for initial public offering and listing on the gem of Ganzhou Yihao new materials Co., Ltd. (hereinafter referred to as the "inquiry letter") issued by your exchange on September 29, 2021, Tianzhi International Certified Public Accountants (special general partnership) (hereinafter referred to as "we" or "reporting accountant") as the reporting accountant of Ganzhou Yihao new materials Co., Ltd. (hereinafter referred to as "issuer", "company" or "Yihao new materials"), based on the principles of diligence, honesty and trustworthiness, carefully discussed, verified and implemented the questions raised in the inquiry letter one by one, and replied and explained them one by one. The specific reply is attached.
Explanation on the content, interpretation, format, supplementary and updated disclosure of the reply:
1. Unless otherwise specified, the abbreviations or terms used in this reply are consistent with the prospectus of Ganzhou Yihao new materials Co., Ltd. for initial public offering and listing on the gem (application draft);
2. Unless otherwise specified in this reply, all amounts are in RMB 10000 yuan;
3. In this reply, if the mantissa of the total count is inconsistent with the mantissa of the sum of the listed values, it is caused by rounding.
1、 Question 4 Waste water and environmental protection
The application materials show:
(1) The pollutants produced by the issuer in the production process include waste gas, waste water, solid waste, noise, etc.
(2) The main wastewater generated in the production process of the issuer's electronic circuit copper foil workshop is copper containing wastewater, zinc chromium containing wastewater, reverse osmosis backwashing water, other filter backwashing water, workshop ground cleaning water and other wastewater, domestic sewage, etc; The main wastewater generated in the production process of the issuer's aluminum based copper clad laminate workshop is production wastewater and domestic sewage.
(3) In addition to general solid wastes such as packaging materials, leftover materials and domestic garbage, the hazardous solid wastes produced by the company's electronic circuit copper foil workshop are mainly water treatment sludge, waste activated carbon, waste resin, etc; The hazardous solid wastes produced in the aluminum based copper clad laminate workshop of the company are mainly waste heat conduction oil, waste liquid pressure oil, acid-base leaching waste residue, etc.
(4) The business scope of Yihao Meike, an enterprise controlled by Yihao group, the controlling shareholder of the issuer, includes the processing and treatment of metal waste and debris. The unaudited net profits in 2020 and the first half of 2021 were 45.245 million yuan and 171055 million yuan respectively.
Please explain to the issuer:
(1) Whether the issuer has the ability and relevant qualifications to treat copper containing wastewater and zinc chromium containing wastewater, whether it entrusts others to treat copper containing wastewater, and whether the relevant expenses match the production and operation of the issuer.
(2) During the reporting period, the issuer's expenses and income related to the treatment of hazardous solid wastes generated by metal scrap and electronic circuit copper foil workshop, the rationality of the issuer's waste water not being processed or sold, and the reasons for the differences with companies in the same industry.
(3) Whether Yihao Meike processed the wastewater and waste generated from the issuer's production and operation during the reporting period; During the reporting period, the main source of income of Yihao Meike was whether there were capital transactions with the issuer.
(4) Whether the treatment measures taken by the issuer for waste gas, waste water, solid waste and noise comply with the relevant provisions of relevant national environmental protection, and whether the environmental protection qualification and environmental protection administrative license (such as pollutant discharge license, environmental assessment approval and environmental protection acceptance of all built projects, projects under construction and equity investment projects) necessary for the issuer's production and operation have been obtained.
(5) During the reporting period, whether the costs and future expenditures related to environmental protection, relevant environmental protection investment, environmental protection facilities and daily pollution control expenses match the pollution generated by the issuer's production and operation, and whether the operation of the issuer's relevant emission and pollution treatment facilities is normal and effective.
Ask the sponsor and the issuer's lawyer to express clear opinions. The sponsor and the reporting accountant are requested to explain the relevant verification means, scope and standards on the treatment of the issuer's wastewater and waste, whether the issuer's wastewater and waste are processed or sold through other entities, whether the actual controller of the issuer bears the costs for the issuer or infringes the interests of the issuer in this way, whether the verification is sufficient, and whether the relevant information disclosure is true, accurate and complete.
reply:
1、 Whether the issuer has the ability and relevant qualifications to treat copper containing wastewater and zinc chromium containing wastewater, whether it entrusts others to treat copper containing wastewater, and whether the relevant expenses match the production and operation of the issuer
(I) the issuer's ability to treat wastewater containing copper, zinc and chromium and relevant qualifications
The issuer's copper containing wastewater and zinc chromium containing wastewater are mainly produced in the production process of electronic circuit copper foil workshop. The issuer has the process, equipment and qualification to treat copper containing wastewater and zinc chromium containing wastewater. The specific conditions are as follows: 1. Treatment process
Copper containing wastewater comes from green foil, surface treatment, solidification and other processes. Fresh water is extracted by two-stage RO reverse osmosis and reused. After concentrated water is concentrated by nanofiltration membrane, the generated copper containing concentrated solution is returned to green foil material solution system for use.
The wastewater containing zinc and chromium comes from the galvanizing and chromium plating process of the surface processor. The fresh water is extracted through reverse osmosis, reused, and the concentrated water flows into the chromium reduction system. It is treated by oxidation-reduction, flocculation sedimentation, pressure filtration, etc., and the generated chromium containing sludge is handed over to a qualified third party for treatment.
Reverse osmosis backwashing water, filter backwashing water, workshop floor cleaning water and other wastewater contain certain copper ions, which are treated by neutralization, sedimentation, pressure filtration and copper extraction. The generated copper sector is returned to the copper dissolution system as raw materials, and the copper containing sludge is handed over to a qualified third party for treatment.
The production wastewater generated after the above treatment enters the reclaimed water reuse system to extract fresh water. The fresh water is recycled and other wastewater is discharged to the sewage treatment plant in the park.
2. Treatment facilities
During the reporting period, the issuer's relevant facilities and treatment capacity for treating copper containing wastewater and zinc chromium containing wastewater are as follows:
Processing equipment and quantity and processing capacity corresponding to the category
3 sets of copper containing wastewater treatment facilities (144 copper containing primary reverse osmosis membranes, 3600 tons of copper containing wastewater / day)
54 copper containing secondary reverse osmosis membranes, 13 nanofiltration membranes, etc.)
3 sets of wastewater treatment facilities containing zinc and chromium (120 pieces of reverse osmosis membrane containing zinc and chromium)
Wastewater containing zinc and chromium, etc.); 2 sets of chromium reduction systems (including 2 sets of acidification systems, 1440 tons / day of reduction and reverse zinc chromium containing wastewater; 2 chromium reduction tanks, 2 flocculation and sedimentation tanks, 2 inclined tube precipitators and 480 tons / day of pressure treatment facilities)
2 filters, 2 collection drums, etc.)
5 sets of reverse osmosis backwashing water and its filter press; 2 sets of reclaimed water reuse system (including neutralization and sedimentation reaction)
There are 5 backwashing and filling filters, 2 multi-media filters, 2 disc filters, and 1800 tons / day ultra reclaimed water reuse system
32 filter membranes for workshop floor cleaning water, 100 reverse osmosis membranes, etc.)
Other wastewater
During the reporting period, the above-mentioned treatment facilities operated normally and effectively, the treatment capacity of the facilities matched the production and operation of the issuer, and the issuer's wastewater was discharged up to the standard without being subject to administrative punishment by the competent environmental protection department.
3. Relevant qualifications
The issuer's copper containing wastewater and zinc chromium containing wastewater are mainly generated from the copper foil production line of electronic circuits. The issuer has obtained the reply on the environmental impact report of Ganzhou Yihao Industrial Co., Ltd. with an annual output of 10200 tons of high-grade electrolytic copper foil production line project issued by Jiangxi Environmental Protection Bureau (Gan Huan Du Zi [2008] No. 145), and has gone through the relevant environmental assessment and acceptance procedures. Meanwhile, the issuer holds the pollutant discharge permit issued by Ganzhou Zhanggong ecological environment bureau.
In conclusion, during the reporting period, the issuer has the ability and relevant qualifications to treat copper containing wastewater and zinc chromium containing wastewater. (II) the issuer does not entrust others to treat copper containing wastewater
During the reporting period, the copper containing wastewater and reverse osmosis backwashing water containing copper ions and other wastewater generated by the issuer's electronic circuit copper foil workshop were treated by reverse osmosis, and the copper containing concentrated solution, copper sector and fresh water were recycled. The copper containing sludge was handed over to a qualified third party for treatment. The externally discharged wastewater met the discharge standards, and there was no case of entrusting others to treat the copper containing wastewater, There are also no expenses related to entrusting others to treat copper containing wastewater.
(III) whether the relevant expenses match the production and operation of the issuer
During the reporting period, the details of the issuer's expenses related to environmental protection such as copper containing wastewater and zinc chromium containing wastewater are as follows:
Unit: 10000 yuan
Year on year change rate of the project in 2021, 2020 and 2019
Water treatment feeding fee 188.24 2.25% 184.09 19.13% 154.52
Hazardous waste treatment fee 82.03 5.45% 77.79 - 5.59% 82.40
Total daily pollution control cost 270.27 3.20% 261.88 10.54% 236.92
Current copper foil output (ton) 1303377 21.92% 1069044 11.20% 961355
The daily pollution control expenses of the issuer match the production and operation of the issuer, and the specific analysis is as follows: 1. The feeding cost of water treatment and the change of copper foil output in the current period
In 2020, the issuer's copper foil output increased by 11.20% year-on-year, and the feeding fee for water treatment increased by 19.13% year-on-year, slightly higher than the growth rate of copper foil output, mainly due to the increase in the dosage of calcium chloride, a water treatment material, in order to improve the sedimentation efficiency of water treatment sludge.
In 2021, the issuer's copper foil output increased by 21.92% year-on-year, and the feeding fee for water treatment increased by 2.25% year-on-year, slightly lower than the growth rate of copper foil output, mainly due to the decline in the unit price of liquid alkali and calcium chloride. At the same time, in 2021, the issuer enabled MBR membrane system and surface treatment high-efficiency water-saving process technology, reducing the use of calcium chloride and other water treatment materials.
2. Change of hazardous waste treatment fee and current copper foil output
During the reporting period, the issuer's expenses related to the disposal of hazardous solid wastes are as follows:
Unit: 10000 yuan
Year on year change rate of project value in 2021, 2020 and 2019
Current copper foil output (ton) 1303377 21.92% 1069044 11.20% 961355
Hazardous solid waste disposal fee 82.03 5.45% 77.79 - 5.59% 82.40
Including: chromium containing sludge disposal fee 57.66-10.48%, 64.41-1.62%, 65.47%
Copper containing sludge disposal fee 3.60 - 45.57% 6.61 14.07% 5.79
Others 20.77 206.79% 6.77 - 39.17% 11.13
In each period of the reporting period, the issuer's hazardous solid waste treatment fees were 824000 yuan, 777900 yuan and 820300 yuan respectively, mainly including chromium containing sludge treatment fees. The specific analysis is as follows:
In 2020, the issuer's chromium containing sludge disposal fee decreased year-on-year, mainly due to the change of disposal unit price caused by the increase of chromium containing sludge disposal suppliers. The issuer added Ji'an chuangcheng Environmental Protection Technology Co., Ltd. (hereinafter referred to as "Ji'an chuangcheng") as a chromium containing sludge disposal supplier in the second half of 2019, and its quotation was relatively low. In 2019 and 2020, The average disposal price of the issuer is about 3000 yuan / ton and 2400 yuan / ton respectively. In 2021, the issuer's chromium containing sludge disposal fee decreased by 10.47% year-on-year, mainly due to:（
