Core Viewpoint - The document provides a supplementary legal opinion regarding the issuance of A-shares by Guangzhou Baiyun International Airport Co., Ltd., detailing the company's business operations, particularly in advertising and internet services, and confirming compliance with relevant laws and regulations [1][2][3]. Group 1: Advertising Business - The company engages in advertising through its subsidiaries, primarily focusing on advertising media resource management and rights transfer [4][5]. - Revenue from advertising operations during the reporting period amounted to 57,177.89 million yuan, with gross profit margins varying across different periods [7]. - The advertising business operates under two models: rights transfer and self-operated, with the rights transfer model being the primary revenue source [5][6]. Group 2: Internet Business - The company has developed internet services through websites, apps, and mini-programs, focusing on enhancing customer experience and operational efficiency [8][9]. - Internet sales revenue from various platforms, including "Airport Pass" and other services, was reported at 14.23 thousand yuan, 60.69 thousand yuan, and 36.78 thousand yuan for the years 2022 to 2024, with 58.82 thousand yuan in the first half of 2025 [20]. - The internet business primarily serves as a channel for existing offline services and does not constitute a significant portion of the company's overall revenue [16][20]. Group 3: Compliance and Legal Matters - The company has confirmed that its advertising and other cultural media businesses do not require special licenses under the current regulatory framework [29]. - There have been no significant administrative penalties related to the company's operations, indicating compliance with relevant laws and regulations [25][29]. - The company has implemented measures to ensure the protection of personal information in accordance with national laws, including the Personal Information Protection Law and the Cybersecurity Law [22][24].
白云机场: 北京市奋迅律师事务所关于广州白云国际机场股份有限公司2024年度向特定对象发行A股股票的补充法律意见书(三)