IPO雷达｜“钱包”模式？斯瑞达回应合规问询，实控人常因个人需求拆借资金

Core Viewpoint - The regulatory authorities have raised concerns regarding Jiangsu Sruida Material Technology Co., Ltd. (Sruida) due to irregularities in financial internal controls, including fund transfers, related party fund occupation, and third-party salary payments [1] Group 1: Company Overview - Sruida specializes in the research, production, and sales of functional polymer materials, primarily focusing on polymer coating materials and film materials for industries such as consumer electronics and new energy vehicles [2] - The company has successfully localized the supply chain for OLED process protective film materials for leading domestic display manufacturers and has been supplying functional materials for new energy battery modules to major companies like BYD and CATL [2] Group 2: Financial Performance - The company's revenue for the years 2022, 2023, and 2024 is reported as 96.26 million, 168 million, and 313 million yuan respectively, while the net profit attributable to the parent company is 5.04 million, 28.51 million, and 84.67 million yuan respectively [3] - Total assets as of December 31, 2024, are reported at approximately 358.12 million yuan, with total equity of about 275.84 million yuan, and a debt-to-asset ratio of 22.98% [4] Group 3: Related Party Transactions - During the reporting period, Sruida engaged in fund transfers amounting to 93.5 million yuan, with 47.5 million yuan used for operational purposes and 46 million yuan occupied by related parties [5] - The actual controller of the company has been involved in frequent borrowing from related enterprises for personal expenses, which raised concerns about governance [5] Group 4: Financial Internal Control Issues - The company has faced issues with third-party salary payments, where a total of 1.36 million yuan was distributed through a third party for confidentiality and tax planning reasons, representing 5.98% of the total salary provision for 2023 [7] - Other irregularities included the use of large denomination bills for payments exceeding the settlement amount, and third-party payments amounting to 50,100 yuan, which accounted for 0.03% of the annual revenue [7] Group 5: Special Investment Terms - The company has special investment terms that may affect its equity structure, with obligations that could be reinstated if the public offering is withdrawn or terminated [8] - Sruida clarified that all special investment terms, except for the buyback rights, have been irrevocably terminated, but the buyback rights remain effective under certain conditions [9][10]