Golden Sun and Chairman Yang Lu receive regulatory letter from the Shenzhen Stock Exchange regarding multiple violations including financial accounting and related-party transactions

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Dongguan Jintaiyang Grinding Co., Ltd. (hereinafter referred to as “Jintaiyang”) and the company’s actual controller, Chairman, and General Manager Yang Lu recently received a regulatory letter (Shenzhen Stock Exchange ChiNext Regulatory Letter [2026] No. 35) issued by the Management Department of the Shenzhen Stock Exchange’s ChiNext. The regulatory letter pointed out that Jintaiyang has multiple violations, including inaccurate accounts receivable accounting, delays in reviewing and disclosing certain related party transactions, and irregular management of insider information, for which Yang Lu bears significant responsibility.

According to the disclosure in the regulatory letter, Jintaiyang’s violations mainly include three aspects. First, in terms of accounts receivable accounting, the company’s customer Chongqing Tongding Electronic Technology Co., Ltd. (hereinafter referred to as “Chongqing Tongding”) has multiple payment funds that are related to Jintaiyang, including some payment funds coming directly from Jintaiyang, mainly from financing lease payments guaranteed by Jintaiyang, as well as repayment funds for financing leases closely related to the company’s actual controller. The above situation indicates that the relevant accounts receivable risk is still mainly borne by Jintaiyang, but the company has terminated the recognition of relevant accounts receivable and has not made provisions for bad debts, which does not comply with the relevant provisions of the “Enterprise Accounting Standards,” resulting in inaccurate financial data in the company’s 2023 annual report.

Secondly, the company has some related party transactions that were not reviewed and disclosed in a timely manner. On one hand, the company’s customer Kaifeng Liyan Polishing Materials Co., Ltd. (hereinafter referred to as “Kaifeng Liyan”) mainly sourced its operating funds from prepayments from Jintaiyang during 2022 and 2023, had large financial transactions with the company’s directors and executives, and had employee overlap, which should be recognized as a related party, and the relevant transactions constitute related party transactions. Statistics show that Jintaiyang’s procurement business amount with Kaifeng Liyan in 2022 and 2023 was 27.5051 million yuan and 10.3848 million yuan, accounting for 4.59% and 1.48% of the corresponding year’s net assets, respectively, but the above related party transactions were not reviewed and disclosed in a timely manner. On the other hand, the general manager of the company’s subsidiary, Liu Chun, has served as the executive director and manager of the customer Foshan Ruiyan Abrasives Co., Ltd. (hereinafter referred to as “Foshan Ruiyan”) since November 2021. The company has recognized this customer as a related party in 2023, but in 2022, it did not recognize it as a related party despite no change in control relationship, resulting in the related party transaction of 28.8519 million yuan for sales to Foshan Ruiyan (accounting for 4.82% of the corresponding year’s net assets) not being reviewed and disclosed in a timely manner.

In addition, Jintaiyang also has issues with the irregular management of insider information, mainly manifested in the fact that the date of knowledge of the audit personnel and financial responsible persons in the annual report registration of 2021 was later than the actual date of knowledge, resulting in inaccurate registration; and the relevant personnel in the insider information knowledge person files for 2021 and 2022 did not sign and confirm.

The regulatory letter pointed out that Jintaiyang’s above actions violated the “ChiNext Stock Listing Rules” and the “Guideline No. 5 for Self-Regulation of Listed Companies - Management of Information Disclosure Affairs.” Yang Lu, as the actual controller, chairman, and general manager of the company, failed to perform his duties diligently and fulfill his obligations of honesty and diligence, bearing significant responsibility for all the above violations, which also violated the relevant provisions of the “ChiNext Stock Listing Rules.”

The Shenzhen Stock Exchange requires Jintaiyang’s board of directors to fully pay attention to the above issues, learn lessons, rectify promptly, and prevent similar issues from occurring again, reminding listed companies to seriously and timely fulfill their information disclosure obligations in accordance with national laws and regulations and exchange rules. All members of the board of directors must ensure that the content of information disclosure is true, accurate, and complete, with no false records, misleading statements, or significant omissions, and shall assume individual and joint liability for their guarantees.

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Editor: Xiaolang Express

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