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中毅达: 北京市中伦律师事务所关于贵州中毅达股份有限公司向特定对象发行股票的补充法律意见书(二)

Core Viewpoint - The document provides a supplementary legal opinion regarding the stock issuance by Guizhou Zhongyida Co., Ltd. to specific investors, confirming compliance with relevant laws and regulations [1][3][4]. Group 1: Legal Compliance - The issuance scale is not to exceed RMB 210 million, with Tianjin Xinjing as the designated investor [5][9]. - Tianjin Xinjing qualifies as an investor under the relevant regulations, being a controlled entity of the major shareholder [6][9]. - The subscription agreement specifies that Tianjin Xinjing will acquire up to 68,403,908 shares at a price of RMB 3.07 per share [8][9]. Group 2: Production Capacity and Compliance - The company has reported production capacities exceeding environmental assessment limits for several products, including pentaerythritol and food-grade alcohol, with utilization rates above 120% [9][12]. - The company has faced administrative penalties in the past, including a fine of RMB 20,000 for safety violations [10][21]. - Environmental and safety compliance has been confirmed by local authorities, indicating no significant violations or penalties since 2021 [18][19][21].