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惠城环保: 北京市中伦律师事务所关于青岛惠城环保科技集团股份有限公司2022年限制性股票激励计划授予价格调整、首次授予部分第三个归属期归属条件成就、预留授予部分第二个归属期归属条件成就的法律意见书

Core Viewpoint - The legal opinion letter from Beijing Zhonglun Law Firm confirms that Qingdao Huicheng Environmental Technology Group Co., Ltd.'s stock incentive plan has met the necessary conditions for the third vesting period of the initial grant and the second vesting period of the reserved grant, in compliance with relevant regulations and internal guidelines [1][2][27]. Group 1: Legal Framework and Compliance - The legal opinion is based on the review of relevant laws, including the Company Law, Securities Law, and the Management Measures for Equity Incentives of Listed Companies [2][3][4]. - The law firm asserts that all documents provided by the company are authentic, accurate, and complete, with no significant omissions [3][4][27]. - The adjustments and vesting matters have received the necessary approvals and authorizations, aligning with the Management Measures and Listing Rules [27]. Group 2: Incentive Plan Details - The incentive plan includes a first grant of restricted stock with a vesting period starting from July 26, 2022, and the third vesting period is set from July 26, 2025, to July 25, 2026 [16][19]. - The second vesting period for the reserved grant is based on performance metrics, requiring a revenue growth rate of at least 40% compared to 2021 [21][22]. - The total number of shares for the first grant's third vesting period is 844,200 shares, with a vesting price adjusted to 4.52 yuan per share [22][25]. Group 3: Performance Conditions - The performance conditions for the third vesting period require either a revenue growth rate of 40% or a net profit growth rate of 40% compared to 2021 [19][21]. - The company has achieved a revenue growth rate of 303.42% for the 2024 fiscal year, meeting the performance criteria for the reserved grant [21][22]. - The individual performance assessments for the incentive recipients are categorized into four levels (A, B, C, D), with the majority achieving an A rating, resulting in a 100% vesting ratio for the current period [22][24].