CHINA TUNGSTEN HIGHT(SZ:000657) Zheng Quan Zhi Xing·2025-07-28 16:38Core Viewpoint - The legal opinion letter from Beijing Jiayuan Law Firm confirms the compliance and achievement of conditions for the third unlock period of the 2021 restricted stock incentive plan and the second unlock period for reserved grants of Zhongtung High-tech Materials Co., Ltd [1][2][20]. Summary by Relevant Sections Approval Procedures - Zhongtung High-tech has completed the necessary approval procedures for the release of restrictions and the repurchase of stocks, including the review and approval of relevant proposals by the board and the remuneration and assessment committee [4][20]. Unlock Conditions Achievement - The conditions for the third unlock period of the restricted stock incentive plan have been met, including: - No negative audit opinions or profit distribution commitments from the company. - Company performance metrics achieved, with a net profit of 334.07 million yuan and a total profit of 657.29 million yuan for 2023, surpassing industry averages [5][6][9]. - For the second unlock period of reserved grants, similar conditions were also met, with a net asset return rate exceeding 4% and a total profit growth rate of 43.15% [9][10]. Stock Quantity and Recipients - A total of 22.99 million shares were granted in the first phase, with 7.37 million shares eligible for release from restrictions for 125 recipients, representing 0.3234% of the total share capital [9][10]. - For the reserved grants, 2.09 million shares were allocated, with 676,800 shares eligible for release for 34 recipients, representing 0.0297% of the total share capital [10][11]. Repurchase and Cancellation - The company plans to repurchase and cancel 349,980 shares due to various reasons, including retirement and performance-related failures to meet unlock conditions [15][16][20]. - The total share capital will decrease from 2,278,954,380 shares to 2,278,604,400 shares following the repurchase [19][20]. Conclusion - The legal opinion concludes that all necessary procedures have been followed in accordance with the relevant regulations, confirming the legality and validity of the decisions made regarding the stock incentive plan [20].