Jinjing Technology and the actual controller Ding Maoliang were notified of the criticism of the illegal appropriation of funds

Source: China Economic Network

China Economic Network Beijing, October 15, 2019 The website of the Shanghai Stock Exchange recently announced the "Decision on Notifying and Criticizing Shandong Jinjing Technology Co., Ltd., the actual controller Ding Maoliang, the related party Zibo Zhilian Litai Trading Co., Ltd. and relevant responsible persons" ([2021] No. 127). According to the facts and related announcements ascertained in the Decision on The Measures of Issuing Warning Letters to Shandong Jinjing Technology Co., Ltd., Wang Gang and Luan Shangyun ([2021] No. 28) issued by the Shandong Supervision Bureau of the China Securities Regulatory Commission, Shandong Jinjing Technology Co., Ltd. (hereinafter referred to as "Jinjing Technology", 600586.SH) and its actual controller Ding Maoliang, and its related party Zibo Zhilian Litai Trading Co., Ltd. (hereinafter referred to as Zhilian Litai) have disclosed information and standardized their operations. The person responsible for the relevant person has committed the following irregularities in the performance of his duties.

(1) There is a non-operating capital occupation between the company and related parties

According to the Company's reply to the inquiry letter disclosed on June 19, 2021, the transaction of the above-mentioned related funds was related to the Company's soda ash business, and the then director Zhang Ming was responsible for the Company's soda ash business and the allocation of funds related to it; the then Chairman Wang Gang and the then General Manager Cao Tingfa were aware of the above-mentioned related party transactions and failed to correct them in a timely manner; luan Shangyun, the then Financial Director, was responsible for the overall management of funds and financial risk control, and failed to perform the reporting obligations and supervision duties on the above-mentioned capital transactions and occupation matters in a timely manner Dong Baosen, the secretary of the board of directors at the time, failed to perform the duties of supervision and information disclosure on the above-mentioned capital transactions and occupation matters.

From February to March 2021, the Company and the related party controlled by the actual controller Ding Maoliang, Zhilian Litai, had non-operating capital transactions without the substance of the transaction, involving an amount of 56 million yuan, accounting for 1.28% of the company's audited net assets at the end of the previous year. As of July 14, 2021, the related party has returned the above-mentioned funds occupied.

(2) The company has a daily related party transaction and fails to perform the information disclosure obligation in a timely manner

From 2018 to 2020, Zhaolian Litai and the company's subsidiaries engaged in soda ash procurement, purchase and sales business. The annual sales amount of the above-mentioned daily related party transactions was 35.3567 million yuan, 56.5851 million yuan and 36.9405 million yuan, accounting for 0.84%, 1.34% and 0.91% of the company's audited net assets at the end of the previous year, respectively, which met the standards that should be disclosed through an interim announcement, but the company did not disclose it in a timely manner until June 19, 2021 in the reply announcement to the inquiry letter.

(3) Inaccurate disclosure of financial information

From February to March 2021, the Company did not account for the 56 million yuan transferred to Zhilian Litai, resulting in an inflated bank deposit amount of 56 million yuan disclosed in the company's first quarter report of 2021, accounting for 0.54% of the total assets in the company's first quarter 2021 report. In addition, the company recognized the sales revenue of a customer's January 2021 shipment in 2020, which did not comply with the company's revenue recognition policy, resulting in an inflated revenue of about 3.66 million yuan in the company's 2020 annual revenue, accounting for 0.075% of the company's operating income for the year.

The company's provision of funds to enterprises controlled by the actual controller constitutes non-operating capital occupation, and it fails to perform information disclosure obligations in a timely manner for daily related party transactions, and some financial information disclosures in periodic reports are inaccurate. The above conduct violates Article 1 of the Notice on Several Issues Concerning the Regulation of Capital Exchanges between Listed Companies and Related Parties and the External Guarantee of Listed Companies, the Rules for the Compilation of Information Disclosure of Companies Offering Securities to the Public No. 15 - General Provisions on Financial Reporting, and Articles 1.4, 2.1, 2.5 and 10.2.4 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange (hereinafter referred to as the Rules Governing the Listing of Stocks).

Related party Zhilian Litai illegally occupied the funds of listed companies. The actual controller, Ding Maoliang, violated the principle of good faith and used his control position over the company to damage the independence of the company, resulting in the occurrence of capital occupation, and bears the main responsibility for the above-mentioned capital occupation behavior. The above conduct violates Article 1 of the Notice on Several Issues Concerning the Regulation of Capital Exchanges between Listed Companies and Related Parties and the External Guarantee of Listed Companies, Article 1.4 of the Rules Governing the Listing of Stocks, and Articles 1.3, 1.5 and 2.4 of the Guidelines for the Conduct of Controlling Shareholders and Actual Controllers of Listed Companies on the Shanghai Stock Exchange.

In terms of responsible persons, the company's then chairman Wang Gang as the company's main responsible person and the first responsible person for information disclosure, then general manager Cao Tingfa as the main person in charge of daily operation and management matters, then financial director Luan Shang as the company's financial person in charge, then secretary of the board of directors Dong Baosen as the specific person in charge of information disclosure affairs, then director Zhang Ming as the person in charge of the relevant fund allocation business, all failed to be diligent and responsible for the company's capital occupation related violations. In addition, Dong Baosen and Luan Shangyun were also responsible for the company's failure to disclose daily related party transactions in a timely manner and inaccurate disclosure of financial information. The conduct of the above-mentioned persons violates the relevant provisions of Articles 2.2, 3.1.4, 3.1.5 and 3.2.2 of the Stock Listing Rules and the commitments made in the Declaration and Undertaking of Directors (Supervisors and Senior Management).

In view of the fact that the company has taken corrective measures to recover the above-mentioned occupied funds, to a certain extent, the adverse effects of the violation have been mitigated, and they have been considered as appropriate. For this disciplinary action, the company and the relevant responsible persons have no objection to the reply.

In view of the above-mentioned facts and circumstances of the violation, in accordance with Articles 16.2, 16.3 and 16.4 of the Stock Listing Rules, the Measures for the Implementation of Disciplinary Sanctions and Regulatory Measures of the Shanghai Stock Exchange, the Guidelines for the Application of the Self-Discipline Supervision Rules of Listed Companies on the Shanghai Stock Exchange No. 2 - Standards for the Implementation of Disciplinary Sanctions, and other relevant provisions, the Shanghai Stock Exchange made the following disciplinary decision: Shandong Jinjing Technology Co., Ltd., the actual controller Ding Maoliang, The related party Zibo Zhilian Litai Trading Co., Ltd. and the company's then chairman Wang Gang, then general manager Cao Tingfa, then financial director Luan Shangyun, then secretary of the board of directors Dong Baosen, then director Zhang Ming issued a notice of criticism. For the above-mentioned disciplinary sanctions, the SSE will notify the CSRC and record them in the integrity file of the listed company.

Through the inquiry of the reporter of China Economic Network, Jinjing Technology was established on December 31, 1999, with a registered capital of 142877 million yuan, and was listed and traded on the Shanghai Stock Exchange on August 15, 2002, with a stock code of 600586. The company's main business is the production and sales of float glass, online coated glass and ultra-white glass. As of September 30, 2021, the major shareholder of Jinjing Technology is Shandong Jinjing Energy Saving Glass Co., Ltd., holding 32.03% of the shares.

According to the 2020 annual report of Jinjing Technology, the actual controller of the company is Ding Maoliang; Zibo Zhilian Litai Trading Co., Ltd. is another related party of Jinjing Technology, and the main related party transactions are the purchase of materials and the sale of goods.

On June 19, Jinjing Technology disclosed the "Announcement of Reply to the Inquiry Letter of Jinjing Technology's 2020 Annual Report", saying that in 2020, the non-operating capital transactions between Zhilian Litai and the company were mainly in the following two aspects, one was because the subsidiary of the company's controlling shareholder, Zhilian Litai, bridged funds through the account of Haitian Biologics. The amount incurred was 273.40 million yuan; second, due to the capital needs of Zhilian Litai, it temporarily borrowed the funds of haitian biochemical co., Ltd. and Shandong Jinjing Coated Glass Co., Ltd., a subsidiary of the company, and returned part of the money in 2020. The total amount of the above two capital transactions is 364.1905 million yuan, and as of the end of 2020, 318.6025 million yuan has been repaid, and the remaining part will be fully returned in April 2021.

Jinjing Technology said that the main person handling the above money is Liu Meng, a financial officer, and the main responsible person is Zhang Ming. Zhang Ming is a director of Jinjing Technology and the general manager of Shandong Haitian Biochemical Co., Ltd. Zhang Ming is responsible for the company's soda ash business and the allocation of funds related to it, and the transaction of the above-mentioned related funds is related to the company's soda ash business, and Zhang Ming should be mainly responsible. Wang Gang, chairman of Jinjing Technology, and Cao Tingfa, general manager of Jinjing Technology, were aware of the above-mentioned related party transactions and failed to correct the occurrence of such matters in a timely manner in accordance with the relevant laws, regulations and company systems, and Wang Gang and Cao Tingfa were responsible for negligence in this violation. Luan Shangyun, the chief financial officer, was responsible for the overall management of funds and the control of financial risks, and failed to perform the reporting obligations and supervision duties in a timely manner on the capital transactions and occupation matters between such related parties. The secretary of the board of directors, Dong Baosen, failed to perform the duties of supervising and disclosing information on the capital transactions and occupation of such related parties. In addition to the above-mentioned personnel, other directors, supervisors and senior management of the Company failed to know in a timely manner of the capital transactions and occupation matters between such related parties.

On August 11, Jinjing Technology disclosed the announcement that Jinjing Technology received the "Decision on Administrative Regulatory Measures" from the Shandong Supervision Bureau of the China Securities Regulatory Commission. The Company recently received the Decision on Issuing Warning Letters to Shandong Jinjing Technology Co., Ltd., Wang Gang and Luan Shangyun issued by the Shandong Supervision Bureau of the China Securities Regulatory Commission ([2021] No. 28). After investigation, the company had the following irregularities: (1) the related party's capital transactions did not perform the approval procedures and information disclosure obligations; (2) the financial information disclosure was inaccurate. The above conduct violates Article 2 of the Administrative Measures for Information Disclosure of Listed Companies (Order No. 40 of the CSRC). Wang Gang, chairman of the board of directors of the company, and Luan Shangyun, financial director, have the main responsibility for the above problems. According to Article 59 of the Measures for the Administration of Information Disclosure of Listed Companies (Order No. 40 of the CSRC), the Shandong Supervision Bureau of the CSRC is now taking administrative supervision measures of issuing warning letters against Jinjing Technology, Wang Gang and Luan Shangyun.

Rules:

Article 1 of the Notice on Several Issues Concerning the Regulation of Capital Transactions between Listed Companies and Related Parties and the External Guarantee of Listed Companies: Further regulate the capital transactions between listed companies and controlling shareholders and other related parties

The capital transactions between a listed company and the controlling shareholder and other related parties shall comply with the following provisions:

(1) In the course of operating capital transactions between controlling shareholders and other related parties and listed companies, the use of the listed company's funds shall be strictly restricted. Controlling shareholders and other related parties shall not require listed companies to advance their salaries, benefits, insurance, advertising, etc. for the period, nor shall they bear costs and other expenses on each other's behalf;

(2) The listed company shall not directly or indirectly provide the funds to the controlling shareholder and other related parties for use in the following ways:

1. Borrow the company's funds for a fee or without compensation for the use of controlling shareholders and other related parties;

2. Entrusted loans to related parties through banks or non-bank financial institutions;

3. Entrust controlling shareholders and other related parties to carry out investment activities;

4. Issuing commercial acceptance drafts for controlling shareholders and other related parties without real trading background;

5. Repay debts on behalf of controlling shareholders and other related parties;

6. Other methods determined by the CSRC.

(3) In auditing the annual financial accounting report of the listed company, the certified public accountant shall issue a special explanation for the existence of funds occupied by the controlling shareholder and other related parties of the listed company in accordance with the above provisions, and the company shall make an announcement on the special explanation.

Article 1.3 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: An application for listing of shares and their derivatives on the SSE shall be subject to the review and approval of the SSE and a listing agreement shall be signed with the SSE before listing to clarify the rights, obligations and relevant matters of both parties.

Article 1.4 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: Issuers, listed companies and their directors, supervisors, senior management personnel, shareholders, actual controllers, acquirers, counterparties to major asset restructuring transactions and their relevant personnel, as well as sponsors and their sponsoring representatives, securities service institutions and their related personnel, shall comply with laws, administrative regulations, departmental rules, other normative documents, these Rules and other provisions of the SSE.

Article 1.5 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: In accordance with laws, administrative regulations, departmental rules, other normative documents, these Rules and other provisions of the Firm and the authorization of the China Securities Regulatory Commission, the SSE supervises listed companies and their directors, supervisors, senior management, shareholders, actual controllers, acquirers and other institutions and their related personnel, as well as sponsors and their sponsor representatives, securities service institutions and their related personnel.

Article 2.1 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: Listed companies and relevant information disclosure obligors shall disclose information in a timely and fair manner in accordance with laws, administrative regulations, departmental rules, other normative documents, these Rules and other provisions of the SSE, and ensure that the disclosed information is true, accurate and complete.

Article 2.2 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: The directors, supervisors and senior management of listed companies shall ensure that the company discloses information in a timely and fair manner, as well as the truthfulness, accuracy and completeness of the information disclosure, and that there are no false records, misleading statements or material omissions. Where the content of the announcement cannot be guaranteed to be true, accurate, or complete, a corresponding statement shall be made in the announcement and the reasons explained.

Article 2.3 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: Listed companies and relevant information disclosure obligors shall disclose all major events (hereinafter referred to as material information or major events) that may have a greater impact on the trading prices of the listed company's stocks and their derivatives within the period prescribed in these Rules.

Article 2.4 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: Listed companies and relevant information disclosure obligors shall publicly disclose material information to all investors at the same time to ensure that all investors have equal access to the same information and may not disclose or leak it to individual or partial investors.

If the documents submitted by the company to shareholders, actual controllers and other third parties involve undisclosed material information, it shall promptly report to the SSE and disclose it in accordance with the relevant provisions of the SSE.

Article 2.5 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: The disclosure of information by listed companies and relevant information disclosure obligors shall be based on objective facts or judgments and opinions with factual basis, truthfully reflecting the actual situation, and there shall be no false records.

Rule 3.1.4 of the Rules Governing the Listing of Shares on the Shanghai Stock Exchange: Directors, supervisors and senior management shall perform the following duties and make commitments in the Declaration and Undertaking of Directors (Supervisors and Senior Management):

(1) Abide by and promote the company to comply with laws, administrative regulations, departmental rules, etc., and perform the duty of loyalty and diligence;

(2) Comply with and urge the Company to comply with these Rules and other provisions of the Firm and accept the supervision of the Firm;

(3) Comply with and promote the Company's compliance with the Articles of Association;

(4) Other duties and other commitments that the Firm deems to be performed.

Supervisors shall also undertake to supervise the directors and senior management in complying with their commitments.

Senior management personnel shall also undertake to report to the board of directors in a timely manner on matters that may have a greater impact on the trading price of the company's stock and its derivatives in the company's operations or finances.

Rule 3.1.5 of the Rules Governing the Listing of Shares on the Shanghai Stock Exchange: The term of office of directors shall not exceed 3 years, and they may be re-elected at the end of their term of office. Directors are elected and replaced by a general meeting of shareholders and may be removed from office by a general meeting of shareholders before the expiration of their term of office.

The duty of loyalty and diligence that a director should perform includes the following:

(1) In principle, they should attend the meeting of the board of directors in person, act diligently with reasonable caution, and express clear opinions on the matters discussed; if they are unable to attend the meeting of the board of directors for any reason, they shall carefully select the trustee;

(2) Carefully read the company's various business and financial accounting reports and major reports on the company in the public media, timely understand and continue to pay attention to the company's business operation and management status and the major events that have occurred or may occur in the company and their impact, timely report to the board of directors the problems existing in the company's business activities, and must not shirk responsibility on the grounds of not directly engaging in operation and management or not knowing the relevant problems and circumstances;

(3) The relevant provisions of the Securities Law, the Company Law and other duties of loyalty and diligence recognized by the society.

Article 3.2.2 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: The secretary of the board of directors shall be responsible to the listed company and the board of directors and perform the following duties:

(1) Responsible for the external disclosure of company information, coordinating the company's information disclosure affairs, organizing the formulation of the company's information disclosure affairs management system, and supervising and urging the company and relevant information disclosure obligors to comply with relevant information disclosure provisions;

(2) Responsible for investor relations management, coordinating information communication between the company and securities regulators, investors, securities service agencies, media, etc.;

(3) Organize the preparation of board meetings and shareholders' meetings, participate in shareholders' meetings, board meetings, board meetings and meetings of senior management personnel, and be responsible for the minutes of board meetings and signing;

(4) Responsible for the confidentiality of the company's information disclosure, and promptly report and disclose to the SSE when no material information is disclosed;

(5) Pay attention to media reports and take the initiative to verify the authenticity of the reports, and urge the board of directors of the company to respond to the inquiries of the firm in a timely manner;

(6) Organize the company's directors, supervisors and senior management to conduct training on relevant laws, administrative regulations, these Rules and related provisions, and assist the aforementioned personnel in understanding their respective responsibilities in information disclosure;

(7) When it is known that the directors, supervisors and senior management of the company have violated laws, administrative regulations, departmental rules, other normative documents, these rules, other provisions of the firm and the articles of association of the company, or when the company makes or may make decisions that violate relevant regulations, it shall remind the relevant personnel and immediately report to the firm;

(8) Responsible for the company's equity management affairs, keeping the company's directors, supervisors, senior management, controlling shareholders and their directors, supervisors and senior management holding information on the company's shares, and responsible for disclosing the changes in the shareholding of the company's directors, supervisors and senior management;

(9) Other duties required by the Company Law, the China Securities Regulatory Commission and the SSE.

Article 10.2.4 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: Related party transactions between a listed company and an affiliated legal person with a transaction amount of more than 3 million yuan and accounting for more than 0.5% of the absolute value of the company's latest audited net assets (except for guarantees provided by the listed company) shall be disclosed in a timely manner.

Article 16.2 of the Rules Governing the Listing of Stocks on the Shanghai Stock Exchange: Issuers, listed companies, relevant information disclosure obligors and other responsible persons who violate these Rules or make commitments to the SSE may be punished as follows, depending on the seriousness of the circumstances:

(1) Circulating criticism;

(2) Public condemnation.

Article 16.3 of the Rules Governing the Listing of Shares on the Shanghai Stock Exchange: If a director, supervisor or senior management of a listed company violates these Rules or makes a commitment to the SSE, the SSE may impose the following penalties depending on the seriousness of the circumstances:

(2) Public condemnation;

(3) Publicly determining that he or she is not suitable to serve as a director, supervisor or senior manager of a listed company for more than 3 years.

The punishments in items (2) and (3) above may be implemented together.

Article 16.4 of the Rules Governing the Listing of Shares on the Shanghai Stock Exchange: If the secretary of the board of directors of a listed company violates these Rules, the SSE may impose the following penalties depending on the seriousness of the circumstances:

(3) Publicly determining that he is unfit to serve as the secretary of the board of directors of the listed company.

The following is the original text:

Shanghai Stock Exchange Disciplinary Decision

[2021] No. 127

Decision on the notification and criticism of Shandong Jinjing Technology Co., Ltd., the actual controller Ding Maoliang, the related party Zibo Zhilian Litai Trading Co., Ltd. and the relevant responsible persons

Parties: Shandong Jinjing Technology Co., Ltd., A-share securities abbreviation: Jinjing Technology; A-share securities code: 600586;

Ding Maoliang, the actual controller of Shandong Jinjing Technology Co., Ltd.;

Zibo Zhilian Litai Trading Co., Ltd., a related party of Shandong Jinjing Technology Co., Ltd.;

Wang Gang, then chairman of Shandong Jinjing Technology Co., Ltd.;

Cao Tingfa, then general manager of Shandong Jinjing Technology Co., Ltd.;

Luan Shangyun, then Chief Financial Officer of Shandong Jinjing Technology Co., Ltd.;

Dong Baosen, secretary of the board of directors of Shandong Jinjing Technology Co., Ltd.;

Zhang Ming was a director of Shandong Jinjing Technology Co., Ltd. at the time.

I. Violations by listed companies and related entities

According to the facts and related announcements ascertained in the Decision on The Measures of Issuing Warning Letters to Shandong Jinjing Technology Co., Ltd., Wang Gang and Luan Shangyun ([2021] No. 28) issued by the Shandong Supervision Bureau of the China Securities Regulatory Commission, Shandong Jinjing Technology Co., Ltd. (hereinafter referred to as the Company) and its actual controller Ding Maoliang and its related party Zibo Zhilian Litai Trading Co., Ltd. (hereinafter referred to as Zhilian Litai) have the following violations in the performance of their duties in terms of information disclosure and standardized operation.

On April 23, 2021, the Company disclosed the audit report on the occupation of funds by the Company's controlling shareholders and their related parties issued by the annual audit accounting firm. The above report shows that The related party controlled by the company's actual controller, Zhilian Litai, has non-operational occupation of the company's funds. In 2020, the Company and its subsidiaries Shandong Haitian Biochemical Co., Ltd. and Shandong Jinjing Coated Glass Co., Ltd. provided 364.1905 million yuan of funds to Zhilian Litai, accounting for 8.93% of the company's audited net assets at the end of the previous year. The above-mentioned funds occupied the ending balance of 46.7534 million yuan, accounting for 1.15% of the company's audited net assets at the end of the previous year. The Company disclosed on the same day that Zhilian Litai had returned all the money and interest to the Company before April 2, 2021. Due to the above-mentioned capital occupation matters, the company's 2020 internal control report was issued with an audit report with an emphasis on the matters.

From February to March 2021, the Company and the related party controlled by the actual controller Ding Maoliang, Zhilian Litai, had non-operating capital transactions without the substance of the transaction, involving an amount of 56 million yuan, accounting for 1.28% of the company's audited net assets at the end of the previous year. As of July 14, 2021, the related party has returned the above-mentioned funds occupied.

From 2018 to 2020, Zhaolian Litai and the company's subsidiaries engaged in soda ash procurement, purchase and sales business. The annual sales amount of the above-mentioned daily related party transactions was 35.3567 million yuan, 56.5851 million yuan and 36.9405 million yuan, accounting for 0.84%, 1.34% and 0.91% of the company's audited net assets at the end of the previous year, respectively, which met the standards that should be disclosed through the interim announcement, but the company did not disclose it in a timely manner until June 19, 2021 in the reply announcement to the inquiry letter.

From February to March 2021, the Company did not account for the RMB56 million transferred to ZLITY, resulting in an inflated bank deposit amount of RMB56 million disclosed in the Company's first quarter 2021 report, representing 0.54% of the total assets in the Company's Q1 2021 report. In addition, the company recognized the sales revenue of a customer's January 2021 shipment in 2020, which did not comply with the company's revenue recognition policy, resulting in an inflated revenue of about 3.66 million yuan in the company's 2020 annual revenue, accounting for 0.075% of the company's operating income for the year.

II. Determination of responsibility and decisions on sanctions

(1) Determination of liability

(2) Disciplinary punishment decisions

In view of the above-mentioned facts and circumstances of the violation, in accordance with Articles 16.2, 16.3 and 16.4 of the Stock Listing Rules, the Measures for the Implementation of Disciplinary Sanctions and Regulatory Measures of the Shanghai Stock Exchange, the Guidelines for the Application of the Self-Regulatory Rules for Listed Companies on the Shanghai Stock Exchange No. 2 - Standards for the Implementation of Disciplinary Sanctions, the Shanghai Stock Exchange (hereinafter referred to as the SSE) made the following disciplinary decision: Shandong Jinjing Technology Co., Ltd., the actual controller Ding Maoliang, The related party Zibo Zhilian Litai Trading Co., Ltd. and the company's then chairman Wang Gang, then general manager Cao Tingfa, then financial director Luan Shangyun, then secretary of the board of directors Dong Baosen, then director Zhang Ming issued a notice of criticism.

For the above disciplinary sanctions, the firm will notify the CSRC and record them in the integrity file of the listed company.

The company shall take this as a warning, operate in strict accordance with the provisions of laws, regulations and the Stock Listing Rules, and conscientiously perform the obligation of information disclosure; the controlling shareholders, actual controllers and their affiliates of the listed company shall strictly abide by the laws and regulations and the business rules of the firm, consciously maintain the order of the securities market, conscientiously perform the obligation of information disclosure, timely inform the company of relevant major matters, and actively cooperate with the listed company to do a good job in information disclosure; directors, supervisors and senior management personnel shall perform the obligations of loyalty and diligence. Promote the company's standardized operations and ensure that the company discloses all material information in a timely, fair, truthful, accurate and complete manner.

Shanghai Stock Exchange

September 30, 2??