On March 8, 2018, the Weibin District Procuratorate of Baoji City issued Weijian Public Prosecution Xingbuhui [2018] No. 4 document, which brought out the current vice president of Xi'an West Testing Technology Co., Ltd. (hereinafter referred to as "West Testing"). The manager Shi Pengjie had falsely issued special VAT invoices during his tenure as the manager of a subsidiary company of Aviation Industry Corporation of China (hereinafter referred to as "AVIC").The procuratorate ultimately refused to prosecute Shi Pengjie.
Let's look at the back of the impact of the West Test test on the market.According to the research conducted by the Southern Capital Center of "Jinzheng Research", it is found that there is a key laboratory site accredited by CNAS in the Western Test Test, which has not been disclosed in the prospectus, and its information disclosure is now "Rashomon".What is strange is that the companies operating in the above-mentioned undisclosed laboratory sites include 2 subordinate units of the aviation industry.During the reporting period, "Aeronautical Industry Subsidiary Unit" was the largest customer of West Test, including the aforementioned subordinate unit located on the "same road section" as the laboratory site.If the "subsidiary of the aviation industry" owns the property right of the site, and the leased site disclosed in the prospectus does not include the property, is there any suspicion of using the business site of a state-owned enterprise customer as a laboratory site for free?In addition, the West Test subsidiary was rejected nine times in two years because of its non-compliance with the bidding requirements when participating in the bidding for the aviation industry, and it was also suspected of colluding with the product manufacturer.
1
The key sites of accredited laboratories are hidden and unannounced, and the number of business sites is in a “mystery” It
should According to the prospectus signed on May 11, 2022 (hereinafter referred to as the "Prospectus"), West Test is mainly engaged in third-party inspection and testing services for the inspection and testing of military equipment and civil aircraft products, providing customers with environmental and Reliability testing, testing and screening of electronic components, electromagnetic compatibility testing and other inspection and testing services, as well as research and development, production and sales of testing equipment, as well as electrical equipment business.
Moreover, West Test stated that the national accreditation body approved and authorized by the National Certification and Accreditation Administration is the China National Accreditation Service for Conformity Assessment (hereinafter referred to as "CNAS"), which is responsible for the certification bodies, laboratories and inspection agencies. The accreditation work of the institution, carry out the ability evaluation of the conformity assessment institutions that apply at home and abroad, make the accreditation decision, and carry out the accreditation supervision and management of the accredited conformity assessment institutions.Before conducting business in the industry to which West Test belongs, it must be accredited by CNAS.
According to the research conducted by the Southern Capital Center of Jinzheng Research, under the CNAS laboratory accreditation certificate, there are three key laboratory sites that have been accredited by Xixi Testing, one of which is located in the "middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province".
According to the prospectus, West Test has obtained the CNAS laboratory accreditation certificate, the certificate number is CNASL5545, which is valid from October 19, 2020 to November 25, 2024.
According to CNAS official website data, as of May 6, 2022, the date of inquiry, there are three key laboratory sites accredited by CNAS under the laboratory accreditation certificate No. No. 16, Second Road, No. 9, Biyuan Second Road, High-tech Zone, Xi'an City, Shaanxi Province, Middle Section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province.The characteristics of the above three facilities are all "fixed", the main activities are "testing, issuance of reports and/or certificates, sample receipt, contract review", and the status is "valid."
It should be pointed out that according to the laboratory issued by CNAS Accreditation rules, on-site assessment are required in both the initial accreditation process and the re-assessment process.
According to the "CNAS Laboratory Accreditation Rules" implemented on March 1, 2020, the laboratory accreditation process includes initial accreditation, expanded accreditation scope, surveillance assessment and reassessment.
The initial accreditation process includes: application for intention, formal application and acceptance, document review, establishment of review team, on-site review, accreditation assessment, certificate issuance and publication.
In the on-site assessment session, the assessment team conducts on-site assessment on the technical capabilities and quality management activities within the scope of the applicant's application according to the CNAS accreditation criteria, rules, requirements, laboratory management system documents and relevant technical standards.The on-site review should cover all activities and related venues involved in the scope of the application.
In addition, for accredited laboratories, they should receive a re-assessment every 2 years (every 24 months).The re-evaluation adopts the method of on-site evaluation.
It can be seen that whether it is a laboratory applying for accreditation for the first time or a review of a laboratory that has been approved for accreditation, on-site assessment is required.Based on the situation that the assessment team needs to conduct on-site assessment on the above-mentioned three key sites of the accredited laboratory of West Test, the above-mentioned three sites should actually exist.
What's strange is that Xixi Testing said that the houses required for its production and operation were obtained by leasing. Among the leased properties it disclosed, there was no CNAS-approved laboratory key site located in the middle section of Jincheng Road, Xicheng District, Xingping City.
According to the prospectus, the houses required for the production and operation of West Test are all obtained by leasing. As of May 11, 2022, the date when the prospectus was signed, West Test had a total of 11 leased properties, none of which were located in Xicheng District, Xingping City, Shaanxi Province. A place in the middle of Jincheng Road.At the same time, in the housing lease contract with the annual rent amount of more than 1 million yuan disclosed in the prospectus, the laboratory space leased with the West Test test as the main body only includes No. 16 Zhangba2 Road, High-tech Zone, Xi'an City, Xi'an City No. 9, Biyuan 2nd Road, High-tech Zone.
And according to the reply to the inquiry letter for the initial public offering of shares and listing application documents on the Growth Enterprise Market (hereinafter referred to as "the first round of inquiry letter reply") signed on November 15, 2021, the Shenzhen Stock Exchange has requested Western Test and test supplementary description of the specific situation of each laboratory, including but not limited to main testing business, main assets and quantity, number of personnel, quantity of various business services in each period of the reporting period, output value, etc. actual production capacity.
In response to the above-mentioned questions, Xixi Testing replied that it has 2 CNAS accredited laboratories in Xi'an and Chengdu in 2018-2020 and January-June 2021.Among them, there are 2 laboratories located in Xi'an, namely No. 16, Zhangba 2nd Road, High-tech Zone, Xi'an City, and No. 9, Biyuan 2nd Road, High-tech Zone, Xi'an City. The main testing businesses are environmental and reliability testing, electromagnetic compatibility testing, Testing and screening of electronic components.
Obviously, in the face of the Shenzhen Stock Exchange's inquiries about the laboratory situation, the test site in the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province also "didn't mention" in the first round of inquiries.
It is worth mentioning that the latest approval dates for the above-mentioned three accredited laboratory key sites are earlier than the date of signing the prospectus.
According to the CNAS official website, as of May 6, 2022, the date of inquiry, under the laboratory accreditation certificate with the test number of L5545, the three key laboratories accredited by CNAS are 16, Zhangba2 Road, High-tech Zone, Xi'an City, Shaanxi Province. No. 9, Biyuan 2nd Road, High-tech Zone, Xi'an City, Shaanxi Province, and the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province, the latest approval date for the above key sites is January 21, 2022.
The signing date of the Western Test Prospectus is May 11, 2022.
That is to say, before the signing date of the prospectus, on January 21, 2022, the above-mentioned three key laboratory sites of West Test have passed the on-site review of the review team.If the latest accreditation approval is a re-assessment, considering the requirement that accredited laboratories should conduct a re-assessment every 2 years, it can be seen that during the reporting period, that is, from 2019 to 2021, there should be three accredited laboratories in West Test. key places.However, it only disclosed two places in the reply to the first round of inquiry letters, and did not disclose the key places located in the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province.
If it is located in a key place in the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province, and the latest accreditation approval obtained this time is the initial accreditation, then considering the early construction period and equipment purchase period of the laboratory, it can be inferred that long before the accreditation, the west The above-mentioned sites have been used for construction.At the same time, West Test said that the houses required for its production and operation are all obtained by leasing.In this case, there is no such place in the leased properties with the annual rent amount of more than 1 million yuan disclosed in the prospectus of West Test. It is the key laboratory site located in the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province. If the rent amount is less than 1 million yuan, it will not be disclosed, or are there other reasons?Or the "question mark".
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The laboratory site "points" to the real estate held by the customer, and the issue of independence or torture
is
still being staged.The key laboratory site not disclosed in the prospectus is the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province, and the companies pointed to by this address include customers of Xixi Testing.
"Jinzheng Research" Southern Capital Center found through a map software search that in the area where "the middle section of Jincheng Road in Xingping City" is located, there are two companies whose names involve "aviation industry".
According to the map software, searching through the keyword "Middle Section of Jincheng Road, Xingping City", the displayed "Middle Section of Jincheng Road" area is marked with the word "Xicheng" on one side, and there is a landmark named "Aviation Plaza" on the other side.
After further zooming in on the map, the displayed landmarks added "Aviation Industry Power Stadium" and the names of 5 companies.The five companies are Aviation Industry Shaanxi Aviation Electric Co., Ltd. (hereinafter referred to as "Shaanxi Airlines Electric"), Aviation Industry Xi'an Aviation Brake Technology Co., Ltd. (hereinafter referred to as "Xihang Brake Production Base"), Shaanxi Huaxing Auto Brake Technology Co., Ltd. (hereinafter referred to as "Huaxing Brake"), Shaanxi Tianchou Jianye Group Co., Ltd. (hereinafter referred to as "Shaanxi Tianchou"), Shaanxi San'er Construction Machinery Co., Ltd. (hereinafter referred to as "San'er Construction") .
At the same time, the map shows that on the opposite side of the road at the Aviation Plaza, there are mainly apartment buildings and retail stores.
It is worth noting that the specific addresses of the West Air Brake Production Base and Shaanxi Air Electric are directly displayed as "Middle Section of Jincheng Road, Xingping City" through the map software.
The map software shows that Shaanxi Airlines Electric covers a large area, and the specific address is displayed as "Middle Section of Jincheng Road, Xingping City, Xianyang City", and the picture of the enterprise gate on the map shows the name "AVIC Shaanxi Aviation Electric Co., Ltd.".
In addition, the specific address of the brake production base of West Air is also displayed as "the middle section of Jincheng Road, Xingping City, Xianyang City".
In addition, the map software shows that among the other three companies, the specific address of Huaxing Brake is displayed as "in the yard of the 514 factory in Xicheng, Xingping City, Xianyang City"; The specific address of Er Construction is displayed as "Qinling Precision Mould (South of the Middle Section of Jincheng Road), Xingping City, Xianyang City."
According to the public information of the Market Supervision and Administration Bureau, the places listed in the business license of San'er Construction and the company's correspondence address in the 2015-2021 annual report are both South Youyi Road, Xicheng District, Xingping City, Xianyang City, Shaanxi Province. ” may not point to the business.
The above-mentioned map software query information shows that the undisclosed place of the West Test Test - the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province, the companies pointed to include the West Air Brake Production Base and Shaanxi Airlines Electric.
The industrial and commercial registration information disclosed by the Market Supervision and Administration Bureau also shows that the business premises of Xihang Brake Production Base and Shaanhang Electric are located in the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province.
According to the public information of the Market Supervision and Administration Bureau, as of March 25, 2022, the date of inquiry, the business place in the business license of the West Air Brake Production Base is "the middle section of Jincheng Road, Xicheng, Xingping City, Xianyang City, Shaanxi Province".
At the same time, according to the change records of the brake production base of Xi'an Airlines, on October 14, 2015, the location of the brake production base of Xi'an Airlines changed its address from "Xicheng District, Xingping City, Shaanxi Province" to "Xicheng City, Xingping City, Xianyang City, Shaanxi Province". The middle section of Jincheng Road".As of March 25, 2022, the date of inquiry, the West Air Brake Production Base has no record of domicile change since then.
It can be seen that the business premises and company domicile of the industrial and commercial registration of the West Air Brake Production Base are located in the "middle section of Jincheng Road, Xicheng, Xingping City, Shaanxi Province".
At the same time, according to the official website of Shaanxi Airlines Electric, Shaanxi Airlines Electric is a large state-owned military enterprise, a member of the aviation industry, and affiliated to AVIC Electromechanical Systems Co., Ltd.Shaanhang Electric consists of two parts: R&D and manufacturing. The R&D center is located in Xi'an High-tech Industrial Development Zone, and the production base is located in Xingping City, Shaanxi Province.
According to the public information of the Market Supervision Administration, as of March 25, 2022, the date of inquiry, Shaanxi Aviation Electric Co., Ltd. Qinhang Electromechanical Branch (hereinafter referred to as "Shaanhang Electric Electromechanical Branch") is a branch established by Shaanxi Aviation Electric. The business place on the business license of the branch is "South Side of Jincheng Road, Xicheng District, Xingping City, Xianyang City, Shaanxi Province (in Shaanhang Electric Institute)", and the branch has been cancelled on December 21, 2020.
After research, it was found that the mailing addresses in the annual report of Shaanxi Airlines Electrical and Mechanical Branch were all located in the "middle section of Jincheng Road".
According to public information, from 2017 to 2019, the corporate communication addresses in the annual report of Shaanhang Electric and Electromechanical Branch are all "in the yard of the 115th factory in the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province".
In addition, according to the "Evolution of Enterprise Name" section of Shaanxi Air Electric's official website, from September 1953 to June 1957, Shaanxi Air Electric used the name "State-owned No. 115 Factory (code name to date)", and changed its name to Shaanxi in January 2017 Aviation Electric.
That is, the corporate communication address of Shaanhang Electric and Electromechanical Branch is "in the yard of No. 115 Factory in the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province", which is "Shaanxi Airlines Electric Institute in the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province".
From this, it can be seen that Shaanhang Electric is located in the business premises of Xingping City, or is also located in the "middle section of Jincheng Road, Xicheng District, Xingping City".
It can be seen from the above situation that, whether from the real-time address of the map software or from the industrial and commercial registration information filled in by the enterprise, the brake production base of Xihang Airlines and the business premises of Shaanhang Electric in Xingping City are both located in the undisclosed approved places of the Xitest test. The key laboratory site is the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province.
It is worth noting that Xihang Brake Production Base and Shaanxi Airlines Electric are both enterprises ultimately controlled by the aviation industry and are subordinate units of the aviation industry.
According to the public information of the Market Supervision Administration, as of June 6, 2022, the date of inquiry, the shareholding structure of Xi'an Aviation Brake Technology Co., Ltd. (hereinafter referred to as "West Air Brake") is Xi'an Aircraft Asset Management Co., Ltd. Fei Asset Management") holds 100% of the shares.XAC Asset Management also has only one shareholder, and the shareholding structure is that the aviation industry holds 100% of its shares.
According to the public information of the Market Supervision and Administration Bureau, the enterprise type of the West Air Brake Production Base is a branch of a limited liability company.
That is, the production base of West Air Brake is West Air Brake Branch, and West Air Brake is a wholly-owned subsidiary of the aviation industry.
In addition, according to the public information of the Market Supervision and Administration Bureau, as of June 6, 2022, the date of inquiry, the shareholding structure of Shaanxi Airlines Electric Co., Ltd. is 100% held by AVIC Electromechanical Systems Co., Ltd. (hereinafter referred to as "AVIC Electromechanical").
That is, Shaanxi Airlines Electric is a wholly-owned subsidiary of AVIC Electromechanical.
According to the 2021 annual report of AVIC, the actual controller of AVIC is the aviation industry.
According to the public information of the Market Supervision Administration, the enterprise type of the aviation industry is a limited liability company (solely state-owned).
It is worth mentioning that during the reporting period, Shaanxi Airlines Electric may have land use rights and housing property rights of 441,700 square meters in the middle section of Jincheng Road.
According to the above mentioned, Shaanxi Airlines Electric is a wholly-owned subsidiary of AVIC Electromechanical.
According to the Independent Financial Advisor Report of Guotai Junan Securities Co., Ltd. on the Company's Issue of Shares to Purchase Assets and Related Transactions (After Correction) issued by AVIC Electromechanical on January 26, 2011, the report introduced Shaanxi Airlines Electric and disclosed Shaanxi Hang Electric owns a total of 11 pieces of land, of which 7 are authorized business sites with a total area of 391,900 square meters, and 4 are leased land with an area of 103,300 square meters.
Among them, all 7 authorized business sites and 3 transfer sites are located on the north side of the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province, with a total area of 441,700 square meters.
It should be noted that the above-mentioned 7 authorized business sites with a total area of 391,900 square meters have no termination date, and the termination date of the 3 transfer sites with a total area of 49,800 square meters is January 17, 2022.
At the same time, Shaanxi Airlines Electric and its subsidiary Shaanxi Qinling Special Electric Co., Ltd. have a total of 2 real estate certificates, each corresponding to 83 and 3 buildings, with a total construction area of 144,400 square meters.The two properties are located on the north side of the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province.
Combining the information displayed by the map software and the industrial and commercial registration information, Shaanhang Electric's business site in Xingping City is located in the middle section of Jincheng Road, Xingping City, and Shaanhang Electric has the land use rights and real estate property rights in this place.
At the same time, during the reporting period, the "subsidiary unit of the aviation industry" was the largest customer of West Test.
It is worth noting that the West Air Brake Production Base and Shaanxi Airlines Electric, which are the key locations not disclosed by the West Test Test, are the final control of the aviation industry.During the reporting period, "Aeronautical Industry Subsidiary" was the largest customer of West Test, and the proportion of sales to operating income once exceeded 30%.
According to the prospectus, from 2019 to 2021, the "subsidiary unit of the aviation industry" is the largest customer of West Test, and the sales amount of West Test to them is 56.4411 million yuan, 87.4428 million yuan, and 91.2912 million yuan respectively; accounting for the same period of business of West Test. The income ratios are 34.28%, 43.25% and 37.18% respectively.
As for the specific names of the subordinate units of the aviation industry among the customers, West Test applied for exemption from disclosure, and only replaced them with digital codes.
According to the research conducted by the Southern Capital Center of "Jinzheng Research", as a subsidiary of the aviation industry, Shaanxi Airlines Electric, which has property rights in the middle section of Jincheng Road, or the name of the subsidiary of the aviation industry that is exempt from disclosure in the prospectus.
According to the prospectus signed by West Test on January 26, 2022, West Test acquired 100% equity of Xi'an Jitongli Technology Co., Ltd. (hereinafter referred to as "Jitongli") in December 2018.
According to the prospectus, from 2019 to 2021, West Test will hold 100% of the shares of Jitongli, and the scope of the consolidated statement includes Jitongli.
In other words, since December 2018, Jitongli has become a wholly-owned subsidiary of Western Testing and has been incorporated into the scope of Western Testing.
According to the prospectus, Jitongli's main business is the sales of testing equipment.
According to the announcement of the winning candidates for the 315KW drag system released on December 29, 2020 in the electronic bidding area of the official website of the aviation industry electronic procurement platform, the tenderer for this project is Shaanxi Airlines Electric, the first winning candidate is Jitongli, and the buyer's on-site price is 4.2976 million yuan.
According to the announcement of the winning candidates for the spark energy test system [re-tender] released on August 23, 2021 in the electronic bidding area of the official website of the aviation industry electronic procurement platform, the tenderer for this project is Shaanxi Airlines Electric, and the name of the first winning candidate is Jitongli. The buyer's on-site price was 1.673 million yuan.
That is to say, Shaanhang Electric, which is a subsidiary of the aviation industry, has a transaction with Jitongli, a wholly-owned subsidiary of Xixi Testing, that is, Shaanhang Electric should be included in the customer list of Xixi Testing.
Judging from the above situation, the brake production base of Xi'an Airlines and the business site of Shaanhang Electric are located in the key laboratory site not disclosed by Xixi Testing, namely the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province, and Shaanhang Electric is located in this place. Has a large area of land use rights and housing property rights.Xihang’s brake production base and Shaanxi Airlines Electric are both subsidiaries of the aviation industry. During the reporting period, the “subsidiary of the aviation industry” was the largest customer of the test. Although the specific situation of the “subsidiary of the aviation industry” was exempted from disclosure, the same period Shaanxi Airlines Electric is a customer of West Testing, so is Shaanxi Airlines Electric in the list of aviation industry subsidiaries exempted from disclosure?
In the case that the rental site disclosed in the prospectus does not include the middle section of Jincheng Road, Xicheng District, Xingping City, Shaanxi Province, does Xixi Testing use the site of a state-owned enterprise customer for free as a laboratory, and provide services or sell equipment to them at the same time?Does the experiment of the west test test depend on the customer?are to be answered.
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Subsidiary’s bids were rejected several times within two years, and product manufacturers were suspected of colluding with bidders and were “caught
”
As mentioned above, in December 2018, Jitongli became a wholly-owned subsidiary of West Test.Historically, Jitongli was the winning bidder of the Shaanxi Airlines Electric bidding project.
In the bidding of the aviation industry, Jitongli has been rejected many times because it does not meet the requirements of the bidding documents.
According to the announcement of the winning candidates for the comprehensive grinding and dust removal system released on February 24, 2022 by the electronic bidding area of the official website of the aviation industry electronic procurement platform, there is one important indicator in the bidding documents submitted by Jitongli that deviates from the requirements of the bidding documents.A copy of the business license signed by the legal person shall be provided in the bidding documents. The business license provided by Jitongli is not signed by the legal person, which deviates from the requirements of the bidding documents.After evaluation by the bid evaluation committee, Jitongli's bid was rejected.
According to the announcement of the winning candidates for the development of the secondary power supply of a test machine airborne power transmission and distribution system released on December 24, 2021 in the electronic bidding area of the official website of the aviation industry electronic procurement platform, there are key indicators in the plan invested by Jitongli that deviate from the requirements of the bidding documents. That is, if the preliminary evaluation performance proof materials do not meet the requirements, the bid will be rejected.
According to the announcement of the winning candidates for the rapid temperature change box, high and low temperature test box, and temperature shock test box released on September 3, 2021 in the electronic bidding area of the official website of the aviation industry electronic procurement platform, Jitongli did not meet the requirements for temperature uniformity, The temperature fluctuation and the external dimension requirements of the strip, and the general indicators above 3 (inclusive) are deviated, and the bid will be rejected.
According to the announcement of the winning candidates for the electric motor torque test system released on July 1, 2021 in the electronic bidding area of the official website of the aviation industry electronic procurement platform, there is an important index in the bidding documents submitted by Jitongli that deviates from the requirements of the bidding documents.The supply requirements of the bidding documents list "flow adjustment and measurement range: (0～60)L/min", and Jitongli's response to this item in its bidding documents is 0～20L/min, which deviates from the requirements of the bidding documents.After evaluation by the bid evaluation committee, Jitongli's bid was rejected.
According to the announcement of the winning candidates for the generator drag system released on June 24, 2021 in the electronic bidding area of the official website of the aviation industry electronic procurement platform, there is an important indicator in the bidding documents submitted by Jitongli that deviates from the requirements of the bidding documents.The bidding documents require "low-voltage DC load: 28VDC, not less than 50kW". Jitongli could not meet this standard in the actual implementation plan of its bidding documents, which deviates from the requirements of the bidding documents.After evaluation by the bid evaluation committee, Jitongli's bid was rejected.
According to the announcement of the winning candidates for the alternating humid heat box released on December 29, 2020 in the electronic bidding area of the official website of the aviation industry electronic procurement platform, there is an important index in the bidding documents submitted by Jitongli that deviates from the requirements of the bidding documents.The bidding documents require "Manufacturer's Authorization Letter... The authorization period includes the bid validity period...". The manufacturer's authorization period in Jitongli's bidding documents cannot cover its bidding validity period, which deviates from the requirements of the bidding documents.According to the evaluation requirements of the bidding documents, after the evaluation of the bid evaluation committee, the bid of Jitongli was rejected.
According to the announcement of the winning candidates for the QKZH-920 right power distribution center automated test system released on June 23, 2020 in the electronic bidding area of the official website of the aviation industry electronic procurement platform, there is an important index in the bidding documents submitted by Jitongli that deviates from the requirements of the bidding documents.The bidding documents require "AC and DC load distribution cabinets", and the bidding documents provided by Jitongli are high-voltage auxiliary DC generator transformers.According to the evaluation standards of the bidding documents, after the evaluation of the bid evaluation committee, the bid of Jitongli was rejected.
According to the announcement of the winning candidates for the high-low temperature and low-pressure environment box and temperature-altitude-humidity environment box project released by the electronic bidding area of the official website of the aviation industry electronic procurement platform on May 14, 2020, the bidding documents submitted by Jitongli did not provide the bidder's financial The report, after the evaluation of the bid evaluation committee, Jitongli's preliminary evaluation and evaluation result was unqualified, and the bid was rejected.
According to incomplete statistics, in less than two years from May 2020 to February 2022, Jitongli, a subsidiary of West Test, had various problems that deviate from the requirements of the bidding documents at least 8 times during the bidding process. It includes the problem that the bidding documents do not meet the formal specifications, and also includes the situation that the bidding products do not meet the requirements.
In addition to the above-mentioned problems, in a tender for aviation industry electronics, part of the bidding documents submitted by Jitongli was consistent with other companies, or there was suspicion of collusion in bidding.
According to the announcement of the winning candidates for the DZH series AC distribution box test system released by the electronic bidding area of the official website of the aviation industry electronic procurement platform on June 23, 2020, the bidding document technology submitted by Shaanxi Blue Ocean Electric Co., Ltd. (hereinafter referred to as "Shaanxi Blue Ocean") The content of the plan starts from page 152 to page 175, and the content of the technical solution in the bidding documents submitted by Jitongli starts from page 115 to page 134. The content, format, punctuation, schematic diagram and other contents are abnormal in description. consistent situation.
Chapter 2 Instructions to Bidders, Section 8.8.2, Disciplinary Requirements for Bidders in the Bidding Documents stipulates: “Bidders shall not collude with each other or with the tenderee, and shall not offer bribes to the tenderee or members of the bid evaluation committee in order to win the bid, and shall not Bid in the name of others or use fraudulent means to win the bid; bidders shall not interfere with or affect the bid evaluation work in any way.”
According to Article 40 of the Implementation Regulations of the Tendering and Bidding Law: "In any of the following circumstances, the bidders shall be deemed to have colluded with each other to bid: the bidding documents of different bidders are abnormally consistent or the bid prices are regularly different", Shaanxi Blue Ocean and Jitong The bid evaluation committee decided to reject the bid of the above two bidders after deliberation.
The "coincidence" of the picture
is that Shaanxi Blue Ocean may be a supplier of Jitongli, and the final customer of the product is the aviation industry.
Search in the "Supplier Information" column of the official website of the aviation industry electronic procurement platform, we can see that Jitongli is a supplier of the aviation industry. There are 4 products in the corresponding product list of Jitongli, the names are "single-phase broadband AC power supply" and "high voltage DC power supply". "DC power supply" and "Single-phase broadband AC power supply", the article number/order number are 3836410, 3787534, 3895659, 3895658 respectively.The manufacturers of the above four products are Shaanxi Blue Ocean.
Based on the above circumstances, Shaanxi Blue Ocean may be a supplier of Jitongli, and the two parties may take advantage of this, and there is a suspicion of collusion in bidding for the aviation industry.
The problem is not over.The proportion of non-bidding and bidding revenue in the West Test test accounts for more than 90% of the main business revenue, and it is said that it mainly acquires customers through active visits.
According to the reply to the first round of inquiries, the Shenzhen Stock Exchange asked West Test to provide additional explanations on customer acquisition methods during the reporting period, the basic process and revenue share of various customer acquisition methods including bidding and tendering.
In this regard, West Test replied that from 2018 to 2020 and from January to June 2021, the income obtained by West Test from bidding and bidding was 0 yuan, 12,837,300 yuan, 3,859,300 yuan, and 2,659,400 yuan, respectively, accounting for the main business. The proportions of income are 0%, 7.84%, 1.93% and 2.71% respectively; the income obtained through non-bidding and bidding are 128.6008 million yuan, 150.8823 million yuan, 196.3418 million yuan and 95.4945 million yuan respectively.
At the same time, West Testing said that from 2018 to 2020 and from January to June 2021, its main customers generally select inspection and testing suppliers in its qualified supplier list through inquiry, and some customers determine inspection and testing through bidding. Supplier or testing equipment supplier.
In this context, West Test takes the initiative to visit customers and recommend their qualifications and service capabilities to customers. For new customers who are contacted for the first time, if there is a cooperation intention, the customer will conduct supplier evaluation of West Test, and include them in the company after the review is passed. Qualified Supplier Directory.
For the business of customer inquiry, the customer inquires the suppliers in the qualified supplier list according to their own needs, and after the quotation is tested by the customer and selected by the customer, the customer signs a contract to carry out the business; for the bidding business, the west test passes the test. The military procurement network or other legal means to obtain the customer's bidding information, or accept the customer's invitation to bid, and sign a contract with the customer to conduct business after winning the bid.
More than that, West Test was asked by the Shenzhen Stock Exchange whether there was a situation where the tender was not tendered.
According to the reply to the first round of inquiries, the Shenzhen Stock Exchange also asked West Test to explain whether the inspection and testing of military equipment and civil aircraft products should follow the bidding procedures, and whether the inspection process and results that did not perform the bidding procedures violated independence and impartiality. requirements; whether there is a situation in which the tender was not tendered during the reporting period.
The West Test Test replied that its main customers are subsidiaries of the military industry group and scientific research institutes. As a supporting provider of inspection and testing services for downstream customers, it is basically not directly oriented to the military, and does not need to participate in the bidding process of military units.The way that WestTest obtains customer orders mainly depends on the customer, and WestTest has no right to decide the customer's purchasing method.
Under this business model of the Western Test Test, the proportion of office expenses and business entertainment expenses in sales expenses is significantly higher than the average level of peers, and the issue of business entertainment expenses has also been "two consecutive questions" by the Shenzhen Stock Exchange.
According to the reply to the first round of inquiries, the Shenzhen Stock Exchange had asked West Test to supplement the proportion of office and business entertainment expenses in sales expenses, whether it was significantly higher than the level of companies in the same industry, and whether its business entertainment activities were legal and compliant.
In this regard, the West Test Test replied that from 2018 to 2020 and from January to June 2021, the West Test test office expenses and business entertainment expenses accounted for 35.15%, 31.25%, 38.23%, and 34.95% of the sales expenses, respectively.During the same period, the average proportions of office expenses and business entertainment expenses in the same industry companies in Western Test were 17.2%, 16.2%, 14.15% and 12.5% respectively.
It is not difficult to see that from 2018 to 2020 and from January to June 2021, the proportion of office expenses and business entertainment expenses in the sales expenses of West Test was significantly higher than the average of peers.
In this regard, West Test explained four main reasons in the reply to the first round of inquiries.
First of all, West Test said that it mainly serves military customers. Such customers have high requirements on equipment performance and testing technology, and the threshold is high.The communication and confirmation during the process from customer contact and negotiation to testing and testing are relatively frequent, and the high business entertainment fee is reasonable.
Second, the West Test Test is currently in a stage of rapid development, with great efforts in market expansion and more expenditure on marketing services.
Thirdly, West Test said that its electromagnetic compatibility test and electronic component testing and screening business started relatively late, and business expansion was relatively difficult. The number of contacts with customers and business negotiations would also lead to an increase in business entertainment expenses.
Fourth, in 2020, the business department took the 10th anniversary of the establishment of West Test as an opportunity to increase marketing efforts, and entertainment activities increased, resulting in an increase in its business entertainment expenses in 2020.
The above explanation may be difficult to convince the Shenzhen Stock Exchange.
According to the "Reply to the Letter of Implementation of the Opinions of the IPO and Listing Review Center of the GEM" signed on January 26, 2022, the Shenzhen Stock Exchange further requested the West Test to explain whether there are legal or legal issues in its business entertainment activities. Compliance risk, and supplementary description of the total amount of entertainment expenses of various businesses, their proportion to the expenses during the test period of the Western Test, and the proportion of the operating income; the comparison of the above data with companies in the same industry, if there is a large difference, please explain reason and rationale.
As for the question of rationality, West Test said that its business entertainment expenses accounted for a relatively high proportion of the period expenses and operating income, which was in line with its actual operating conditions and was reasonable.
Based on the above situation, Jitongli, a subsidiary of West Test, has participated in the bidding of the aviation industry for many times, but it has been rejected at least nine times because it does not meet the requirements of the bidding documents, and it is also suspected of colluding with its product manufacturers to bid.At the same time, the proportion of office expenses and business entertainment expenses to sales expenses is significantly higher than that of its peers, and the business entertainment expenses have been "two consecutive questions" by the regulatory authorities.Under the circumstance that the revenue from bidding and tendering of the western testing test accounts for less than 10% of the main business revenue, does the western testing test use business entertainment to make up for the disadvantage of bidding?unknown.
In the beginning, it was true, but it was false.The above problem is one of the tests that the Western Test must face directly for the Western Test.
