Huibo Yuntong employees have doubted the relevant parties or "half -cover" in the past

"Golden Syllabus" Southern Capital Center Dew/Author Sanshi/Risk Control

Since the registration system, although the quality of the information disclosure of the prospectus has been improved, the length of length, more compliance information, investment decision -making correlation, and information disclosure are still endless. As a result, in January 2022, the Securities Regulatory Commission issued the "Guidance Opinions on Increasing the Quality of the Integrated Prospects in the Registration System", which aims to promote the high -quality development of the capital market.

For this time to go public, the information disclosure or many "loopholes" of Huibo Yunntong Technology Co., Ltd. (hereinafter referred to as "Huobo Yuntong"). Among them, from 2018-2019, two companies that were held by Huobo Yuntong employee Xiong Rui at that time overlapped with Huibo Yuntong subsidiaries. During this period, did the two companies controlled by Hui Boyuntong? In addition, a company controlled by Huibo Yuntong's controlling shareholder has not been seen, but its related parties have determined or lack.

1. Employee Xiong Rui used to be confused with Hui Boyuntong's subsidiary, and the control of the control of power emerged

Independence is self -evident to the importance of listed companies. From 2018-2019, the enterprise of Hui Boyun's employee Xiong Rui holds the contact information with Huibo Yuntong subsidiaries, and the two parties may also work on the same floor and the same floor.

1.1 Xinling Technology was established and controlled by Xiong Rui, and Xiong Rui refunded the shares in October 2020

According to data from the Beijing Market Supervision and Administration Bureau, Beijing Hebo Education Technology Co., Ltd. (now named Beijing Xinling Technology Co., Ltd., hereinafter referred to as "Xin Ling Technology") was established on March 21, 2014. On January 15, 2016, investors of Xinling Technology changed for the first time. Before the change, the investors of Xinling Technology were Xiong Rui and Yang Tian. That is, Xinling Technology may be established by Xiong Rui.

On October 22, 2020, investors of Xinling Technology changed. Xin Ling Technology was held by Xiong Rui and Zhang Yongzhao as a wholly -owned owner of Zhao Jianmin. That is, after October 22, 2020, Xiong Rui no longer holds Xinling Technology shares. On the same day, the name of the corporate company of Xinling Technology also changed. The name of the corporate company of Xinling Technology was changed from Beijing Hebo Education Technology Co., Ltd. to Beijing Xinling Technology Co., Ltd.

From 2018 to 2019, Xiong Rui and Zhang Yongzhao's capital contributed by Xinling Technology were 4.9 million yuan and 100,000 yuan, respectively, with a shareholding ratio of 98%and 2%, respectively. That is, from 2018-2019, Xiong Rui is the controlling shareholder of technology.

It can be seen that the Department of Xinling Technology was established by Xiong Rui and was once controlled by Xiong Rui. On October 22, 2020, Xiong Rui withdrew from Xinling Technology.

It should be pointed out that Xiong Rui or Hui Boyuntong employees, and once served as executives.

1.2 Xiong Rui was the deputy general manager of Huibo Yuntong, and so far is a partner or a employee of the employee holding platform

According to the public transfer manual, Xiong Rui has been the deputy general manager of Hui Boyuntong since September 2015 as a senior manager of Huibuyuntong. Xiong Rui's term is from September 14, 2015 to September 13, 2018.

The 2016 annual report disclosed during the listing of the New Third Board showed that in 2016, Xiong Rui was still the deputy general manager of Hui Boyuntong.

According to the promotional manual (hereinafter referred to as the "prospectus"), which was signed by Huibo Yuntong on April 29, 2022, as of April 29, 2022, Huibo Yuntong had 8 senior managers, respectively as the rest, respectively. Hao, Sun Yuwen, Zhang Yanpeng, Liu Bin, Xiao Yuntao, He Zhao, Shi Wei, Liu Fang. Xiong Rui did not appear in the list of senior management personnel of Huibo Yuntong.

In addition, Xiong Rui was not mentioned in the changes of senior management personnel disclosed by the prospectus in 209-2021.

After Xiong Rui expired in September 2018, he no longer served as deputy general manager of Hui Boyuntong?

It should be pointed out that although Xiong Rui has not served as an executive, it may still be Huibo Yuntong employees.

According to the prospectus, as of April 29, 2022, the signing of the prospectus, Beijing Huibo Chuangzhan Technology Center (limited partnership) (hereinafter referred to as "Huibo Innovation Exhibition"), Beijing Hetongda Enterprise Management Center (Limited Partnership) (Limited Partnership) (Limited Partnership) (Limited Partnership) The following referred to as "Hetongda") is the employee holding platform of Huobo Yuntong. Huibo Chuangzhan and Yitongda's shareholding on Huobo Yuntong were 16.67%and 10.45%, respectively, respectively, the second largest and third largest shareholders of Huibo Yuntong.

Xiong Rui holds a 0.5%share of Huibo Creation Exhibition, and holds a 25%share of Hetong. That is, Xiong Rui indirectly holds 2.7%of the equity of Huibo Yuntong through Huibo Chuangzhan and Hetongda.

According to the "Huobo Yuntong first public issuance of stocks and the review inquiry letter of the review of the stock market for the first public offering of the stock and the reply" on the GEM "(hereinafter referred to as the" first round of inquiry letter replies " ), Huibo Yuntong's resigned employees have transferred all their rights and interests in the partnership platform, which meets the relevant agreement of the equity incentive plan. The Huobo Yuntong employee holding platform is the official employee of Huobo Yuntong, and there is no external personnel.

According to public information, Xiong Rui, one of the partners of Huobo Chuangzhan, is the same person as Xiong Rui, the former controlling shareholder of Xinling Technology.

Xiong Rui has always held the shares of the two employees of Hui Boyuntong, which also means that Xiong Rui may still be the official employee of Huobo Yuntong. Xinting Technology is a company founded and controlled by Huobo Yuntong employee Xiong Rui.

The problem was not over. Xiong Rui Holdings's Xinling Technology has appeared in the case of sharing contact with Hui Boyuntong's subsidiary. 1.3 From 2018-2019, the telephone number of Xinling Technology Enterprises is consistent with Huibo Software of Huibo Yuntong

According to Huibo Yuntong's prospectus, as of December 31, 2021, Hui Boyun Tong had a total of 11 wholly -owned subsidiaries, 5 holding subsidiaries and 2 shares. Technology Co., Ltd. (hereinafter referred to as "Huibo Software"). According to the prospectus information, Huibo Software was established on November 25, 2011, mainly engaged in software development business, with a 100%shareholding of Huibo Yun.

According to Hui Boyuntong's first round of inquiry letters, in April 2015, Hui Boyun Tong intends to expand ODC business overseas and acquire 100%equity of Huibo Software.

According to data from the Beijing Market Supervision and Administration Bureau, on April 30, 2015, investors of Huibo Software changed. Before the change, Huibo Software was co -owned by four natural person shareholders of Chen Jian, Sun Yuwu, Wu Jinsong, and Xiong Rui. After the change, Huibo Software was wholly -owned by Beijing Huibo Creative Survey Technology Co., Ltd. (Hui Boyun Tong, hereinafter referred to as "Huibo Limited"). After this change, as of May 6, 2022, the investors of Huibo Software have not changed.

In 2014, Huibo Software's corporate telephone number was 62973653. By 2015, when Huibo Software became the wholly-owned subsidiary of Huibo Yuntong, the corporate contact number of Huibo Software was changed to 010-62973859. From 2016 to 2019, Huibo Software's corporate contact phone number was consistent with 2015, all of which were 010-62973859.

Public information shows that as of May 7, 2022, in addition to Huibo Software, two companies have used 010-62973859 as a corporate telephone number, including Xinling Technology.

According to data from the Beijing Market Supervision and Administration Bureau, from 2018-2019, the corporate contact information of Xinling Technology is 010-62973859. Consistent with Huobo Software 2015-2019.

That is, from 2018 to 2019, the letter and technology of Huobi Yuntong's employee Xiong Rui holds a contact information with Huibo Software of Hui Boyun Tong.

But the problem is not only there. During the reporting period, Xinling Technology also worked on the same floor as Huibo Software on the same address.

1.4 From 2016-2019, Xinling Technology also worked on the same floor as Huibo Software on the same address.

According to data from the Market Supervision and Administration Bureau, in 2016, the corporate mailing address of Huibo Software was 5-1 of Beijing Mongolian Hi-Tech A, 5-1, Beijing, Haidian District, Beijing.

In the same year, the corporate mailing address of Xinling Technology was 501st floor of Building A, 5-1, 5-1, Shanghai East Road, Haidian District, Beijing.

According to data from the Market Supervision and Administration Bureau, on December 18, 2017, the residence of Huibo Software changed. Before the change, the residence of Huibo Software was 502, Building A, 5-1 Beijing Hi-Tech A, 5-1, Shanghai, Haidian District, Beijing. Room 501 and 502, Building 4, Building 4.

On December 13, 2017, the first five days before Huibo Software changed its residence registration information in 2017, Xinling Technology also changed its residence address.

Before the change, the residence of Xinling Technology was Room 501, Building 4, No. 5, House East Road, Haidian District, Beijing; after the change, the residence of Xinling Technology was No. 4, No. 5, House East Road, Haidian District, Beijing Room 507 floor of the building.

According to data from the Market Supervision and Administration Bureau, from 2017 to 2019, the corporate communication address of Huibo Software was Room 501 and 502, Building 5, No. 4, No. 4, No. 5, Shangdi East Road, Haidian District, Beijing.

From 2017-2019, the corporate communication address of Xinling Technology was changed to Room 507, Building 5, Building 4, No. 5, Shanghai East Road, Haidian District, Beijing, and the correspondence address as Huibo Software was still on the same floor.

It is worth mentioning that Huibo Software and Xinling Technology changed in December 2017 before the change of Shanghai, Shanghai East Road, Beijing, Beijing, 5th Floor, Building 5 and the Change of Beijing Haidian District. Floor residence on the fifth floor of Building 4, No. 5, Di East Road may be the same address.

According to the public transfer instructions on January 29, 2016, the signing of Hui Boyuntong, as of January 29, 2016, on January 29, 2016, Hui Boyuntong is still performing a major housing lease contract. Tental contract between Jingmeng Hi -Tech Building.

The leaser of this part is Beijing Zhongguancun Jingmeng Hi -Tech Enterprise Incubator Co., Ltd. (hereinafter referred to as "Jingmeng Hi -Tech"). It is Building 4, No. 5 of Shangdi East Road, Haidian District, Beijing, with a lease period from November 1, 2015 to October 30, 2016.

It is not difficult to find that the housing address rented by Huibo Software in 2016 is consistent with the location of the residence address after Huobo Software and Xin Ling Technology in December 2017. They are located in Building 4, No. 4, Shangdi East Road, Haidian District, Beijing. Essence At that time, Huibo Software's corporate communication address and residence address were displayed as 5-1, Beijing Meng Mongolian Hi-Tech A, 5-1, Beijing, Haidian District, Beijing. In addition, according to Baidu Map information, the address of Building 4, No. 5, Shangdi East Road, Haidian District, Beijing is located in Block A in Beijing Mongolia High -Tech.

1.5 Data of the Market Supervision and Administration Bureau shows that from 2016-2019

According to data from the Market Supervision and Administration Bureau, from 2016 to 2019, Xinling Technology was in a state of opening. During the same period, the number of social security payments was 2, 2, 3, and 2, respectively.

According to the prospectus, Huobitongtong did not disclose its relationship with Xinling Technology in the prospectus.

However, from 2018-2019, the Department of Technology and Technology of the Xinling Science and Technology may have a shared contact information with Huibo Yuntong subsidiary Huibo Software. In addition, Xin Ling Technology has also worked on the same floor with Huibo Software on the same address. In fact, Shin Ling Technology has actually been controlled by Huibo Yuntong with Huibo Software? It is not known yet.

However, Huibo Yuntong's information disclosed that the doubts did not dispersed.

Second, Xiong Rui has shocked the "peers" company, and the email suffix used to use Huibo Yuntong's subsidiary domain name.

There are no waves and waves. Studies have found that Xiong Rui, an employee of Huobo Yuntong, also controlled another company. The company not only shared the mailbox with Xinling Technology, but also had business competition with Hui Boyuntong.

2.1 Xiong Rui became the controlling shareholder of Huizhou Xianchuang on August 8, 2018, with a shareholding ratio of 90%

According to data from the Beijing Market Supervision and Administration Bureau, Beijing Huizhou Xianchuang Technology Co., Ltd. (hereinafter referred to as "Huizhi Xianchuang") was established on March 17, 2017. On August 8, 2018, the investors of Huizhou Xianchuang changed. Before the change, Hui Zhixian Chuangchuang Yuwen, Wang Hongli, and Zhang Li three natural person shareholders were held; Two natural person shareholders hold.

On December 10, 2018, Hui Zhixian's investors changed again. Before the change, Hui Zhixian was jointly held by Xiong Rui and Zhang Nankun; after the change, Hui Zhixian was held by Xiong Rui and Yu Yan. After this change, as of May 7, 2022, Hui Zhixian's investors have not changed.

From 2018 to 2020, Xiong Rui and Yu Yan were subscribed to Hui Zhixian's capital contribution of 4.9 million yuan and 100,000 yuan, respectively, with a shareholding ratio of 98%and 2%, respectively. That is, from 2018 to 2020, Xiong Rui is Huizhou Xianchuang's controlling shareholder.

2.2 From 2018-2019, Xinling Technology and Huizhi Chuangchuang Chuangzheng shared mailbox

It is known that Xiong Rui is an employee of Huibo Yuntong and has served as an executive, and the company's letter and technology that Xiong Rui established and controlled. During 2016-2019, Huibo Software with Hui Boyuntong subsidiary was in The same floor office of the same building, and the telephone number of corporate contacts from 2018-2019.

It is worth noting that from 2018-2019, Xinling Technology had a phenomenon with Huizhi Xianzang's shared mailbox.

According to data from the Market Supervision and Administration Bureau, from 2018 to 2019, Huizhi Pioneer's e-mailbox was [email protected]. In 2020, Huizhi's corporate email box changed to [email protected]. The changing mailbox prefix is ​​completely consistent with the name of the controlling shareholder Xiong Rui.

From 2016-2017, the enterprise email of Xinling Technology is [email protected]; from 2018-2019, the e-mailbox of the corporate email of Xinling Technology becomes [email protected]. The e -mail of the enterprise overlap.

2.3 Xinling Technology Email in 2015, the corresponding domain name is held by Huibo Yuntong subsidiary

According to data from the Market Supervision and Administration Bureau, in 2015, the company's enterprise contacting the mailbox was [email protected].

As a result, [email protected], shared by Xin Ling Technology and Huizhi Pioneer, is held with [email protected]?

According to the prospectus, Huobo Yundong's website is www.hydsoft.com, and the email is [email protected]. The registered owner of the domain name Hydsoft.com is Huibo Software, a subsidiary of Huobo Yuntong.

In other words, Xinling Technology's email suffix in 2015, the corresponding domain name was held by Huibo Yuntong subsidiary, and from 2018-2019, Huobo Yuntong employee Xiong Rui Zeng controlled by Xiong Rui Zeng, and Hui Boyun Tong subsidiaries. The telephone number of Huobo Software shared by the company was controlled by Hui Boyuntong during the period? In the same period, Xiong Rui's other holding Hui Zhi Xianchuang appeared in the case of shared emails with Xinling Technology. Under various visions, Whether Hui Zhi Xianchuang was the same as Xin Ling Technology. Pass control? Doubt to be solved.

2.4 Huizhou Xianchuang and Hui Boyun Tong are engaged in the IT outsourcing service business. The two parties may have business competition according to the prospectus. Since the establishment of Hui Boyun Tong, the main business has always provided information technology outsourcing (ITO) services for corporate customers. Essence

Software Customization Development and Solution Services Department of Huibo Yuntong Software Technology Outsourcing Service Business Section, one of the business of Huibo Yuntong Mobile Intelligent terminal testing service sector. And the customers who tested the Huibo Yuntong outfield include communication operators, mobile smart terminal manufacturers, chip manufacturers.

From 2019 to 2021, the revenue of the custom development and solution services of Huibo Yuntong Software was 5.0207 million yuan, RMB 14,165,200, and RMB 1,820,400, respectively, accounting for 0.95%of the current main business income of Huibo Yuntong, respectively. 2.1%, 2%.

From 2019 to 2021, the revenue of Huibo Yuntong's out-of-field test service revenue was 84.876 million yuan, 104.394 million yuan, and 63.2357 million yuan, respectively, accounting Essence

According to the public information of the ICP/IP address/domain information filing management system of the Ministry of Industry and Information Technology, as of May 7, 2022, the ICP filing number of the website domain name is Wistive.com is Beijing ICP No. 18055062 -1, and the organizer is Beijing Huizhi Zhizhi Xianchuang Technology Co., Ltd. (hereinafter referred to as "Huizhi Xianchuang"), the review date is November 2, 2018.

According to the web snapshot at 22:39:30 on April 13, 2022, Huizhi Xianchuang Chuangchuang is committed to the IT outsourcing service business. Based on the principles of social collaboration and sharing, it is customers who have short -term IT service needs. , To provide individuals and teams with willingness to serve, provide enterprises with a professional, efficient communication and service platform, and provide high standard talent resources throughout the IT service process to ensure that they can complete the custom development development of customers quickly, securely, and effectively And project delivery.

At the same time, the external test is one of the core advantages of Huizhi Xianchuang, and Hui Zhixian provides live testing services for telecommunications operators, chip manufacturers, mobile phone solution providers and terminal manufacturers.

It is not difficult to find that Huizhou Chuangchuang is similar to the main business of Hui Boyun Tong, which also involves the IT outsourcing service industry, and there is also a business direction of software custom development and out -of -field testing. During the reporting period, Huizhou Pioneer or Hui Boyuntong had business competition.

Based on Huizhi Xianchuang 2018-2019, with the Email Email of the Enterprise of the Corporation Technology, the contact phone number of Xinling Technology and Huibo Software, whether Huizhi Xianchuang and Xinling Technology had been controlled by Huibo Yuntong Intersection Then Huizhi Xianchuang, Xin Ling Technology changed the number, and changed the mailbox to cover up the "traces" of the above -mentioned confusion of business?

But the problem is not only there.

3. The controlling shareholder controls the enterprise or is hidden, and the affiliates are determined or lacking

The complete letter is the basic requirement for the disclosure of the information disclosure of listed companies. Hui Boyuntong's disclosure or vulnerability to related parties in the prospectus.

3.1 2021, Ruisi Huixun and Hui Boyuntong controlling shareholder Shen Hui Holdings shared contact information

According to the prospectus, as of April 29, 2022, Beijing Shenhui Holdings Co., Ltd. (hereinafter referred to as "Shenhui Holdings") held 23.75%of Hui Boyuntong, which was the controlling shareholder of Huibo Yuntong. As of December 31, 2021, Shen Hui's equity structure was 99%of Yu Hao and Meng Yanfei held 1%.

As of April 29, 2022, Yu Hao directly held a 3.25%shares of Huibo Yuntong, and indirectly controlled 40.42%of the shares of Hui Boyuntong through Shen Hui Holdings and Huibo Chuangzhan. Boyuntong's 43.67%of the shares are the actual controller of Hui Boyuntong.

According to data from the Market Supervision and Administration Bureau, from 2018 to 2021, Shen Hui Holdings's corporate contact phone number was 82411710.

In 2021, Beijing Ruisi Huixun Consulting Management Co., Ltd. (hereinafter referred to as "Ruisi Huixun") was also 82411710, which was consistent with Shen Hui Holdings's corporate contact phone number in the same period.

3.2 Ma Weiguo may hold 60%of Rui Sihui News, and will be the supervisor

According to data from the Market Supervision and Administration Bureau, Ruisi Huixun was established on December 22, 2021. As of May 10, 2022, Ruisi Huixun's equity structure was 60%and 40%of the shares of natural person Ma Weiguo and Wang Suhong, respectively. Wang Suhong is the executive director and manager of Rui Sihui News, and Ma Weiguo is the supervisor of Ruisi Hui Xun. Since its establishment, Rui Sihui has no change information.

Public information shows that as of May 10, 2022, in the inquiry date, in addition to serving as a shareholder and supervisor in Ruisi Huixun, Ma Weiguo also served as a partnership in Kunshan Huitongda Enterprise Management Center (hereinafter referred to as "Huitongda") people.

According to data from the Market Supervision and Administration Bureau, Huitongda was established on January 17, 2019. On December 28, 2020, Huitongda added two natural partners of Ma Weiguo and Liu Haibin. As of May 7, 2022, Ma Weiguo still held Huitong's share.

According to the prospectus, as of April 29, 2022, as of the signing of the prospectus, the Huitongda Department of Huobo Yuntong's employee equity incentive platform.As mentioned earlier, the first round of inquiry letters revealed that the Huobo Yuntong employee holding platform is the official employee of Huobo Yuntong, and there is no external personnel.Rui Sihui News Ma Weiguo's share of Huitong reached 8%, which means that Ma Weiguo is actually a employee of Hui Boyuntong.According to the prospectus, Huobo Yuntong also did not disclose any information about Ruisi Hui News in the prospectus.

It can be seen that in 2021, the situation of Shen Hui Holdings, which appeared with Hui Boyun Tong's actual controller Yu Hao, appeared.Controld by Yu Hao?And Ma Weiguo, as a member of the Hiboyun -Tong employee's shareholding platform, is reasonable as a supervisor on Ruisi Huixun. Is it reasonable?Is there a situation where Hui Boyuntong has no hidden parties and has not worn it?unknown.

Those who want to be a big thing must be cultivated first.In the face of the above problems, how Huobo Yuntong breaks out of the situation and is still tested in the market.

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