Zheng Quan Zhi Xing·2025-05-29 09:57Core Viewpoint - The legal opinion letter from Haiwen Law Firm confirms the legality and compliance of Zhengzhou Coal Mining Machinery Group Co., Ltd.'s 2025 Employee Stock Ownership Plan (ESOP) based on relevant Chinese laws and regulations [1][5][13]. Group 1: Company Qualifications - Zhengzhou Coal Mining Machinery Group Co., Ltd. is a legally existing joint-stock company, approved by the China Securities Regulatory Commission for its initial public offering in May 2010, with a total of 140 million new shares issued [5][6]. - The company holds a valid business license issued by the Zhengzhou Market Supervision Administration, confirming its status as a publicly listed company [5][6]. Group 2: Legality and Compliance of the ESOP - The ESOP has been reviewed and complies with the necessary procedures and disclosure obligations as per the relevant guidelines [6][7]. - The plan prohibits insider trading and market manipulation, ensuring adherence to regulatory requirements [7][8]. - Participation in the ESOP is voluntary for employees, with no forced distribution or allocation [7][8]. - The funding sources for the ESOP are from employees' legal salaries and self-raised funds, aligning with regulatory standards [8][9]. Group 3: Decision-Making and Approval Procedures - The company has completed necessary decision-making procedures, including soliciting employee representative opinions and obtaining board approvals for the ESOP [11][12]. - Related directors and supervisors have recused themselves from voting on the plan to ensure compliance with governance standards [12][13]. - The ESOP requires further approval from the shareholders' meeting, which must be announced prior to the meeting [13][14]. Group 4: Information Disclosure Obligations - The company has fulfilled its initial information disclosure obligations by announcing relevant board resolutions and the ESOP draft on designated platforms [13][14]. - Ongoing disclosure obligations will continue as the ESOP progresses, ensuring compliance with legal requirements [14].