Sineng(SZ:300827) Zheng Quan Zhi Xing·2025-08-05 16:10Core Viewpoint - The document provides a supplementary legal opinion regarding the application of Shangneng Electric Co., Ltd. for a specific stock issuance, addressing inquiries from the Shenzhen Stock Exchange and clarifying the status of environmental and energy assessments related to a photovoltaic inverter project. Group 1: Project Status and Risks - The environmental impact assessment (EIA) and energy assessment (EA) for the project are set to expire in August 2025, and if the project does not commence within two years of the approval date, the project approval may automatically become invalid [2][3][4] - The project, which aims for an annual production capacity of 25GW of string photovoltaic inverters, has not yet started construction and has not applied for an extension, leading to potential risks of approval invalidation [3][4][11] - The company has updated the planned commencement date to 2026 and has obtained a new investment project filing certificate, thus mitigating the risk of expiration for the project [7][10][11] Group 2: Legal and Regulatory Compliance - The supplementary legal opinion is based on compliance with various laws and regulations, including the Company Law and Securities Law, ensuring that the issuance process adheres to industry standards and ethical norms [2][3] - The company has clarified that the project does not fall under the category of projects requiring approval management, as it is subject to filing management, which has no explicit validity period [6][7] - The company has taken necessary actions to comply with the regulations regarding projects that have not commenced within the stipulated timeframe, ensuring that the project can continue to be implemented [10][11] Group 3: Changes in Issuance Plan - The company has made adjustments to its issuance plan, including the addition of its controlling shareholder as a subscriber, but these changes do not constitute a significant alteration under relevant securities regulations [12][14][16] - The adjustments made to the issuance plan were approved in board meetings, and the overall fundraising amount and project details remain unchanged, indicating stability in the company's financial strategy [12][16][17] - The company has confirmed that no funds were invested in the project prior to the board's approval of the issuance plan, ensuring that all investments align with the approved financial strategy [17]