Basic requirements for lawyer working papers

1. The working papers should be complete in content, clearly recorded, clear in conclusion, and marked with index numbers and sequence numbers. At the same time, they should be prepared by two or more lawyers with securities qualifications and their law firms with qualifications in securities practice. The official document of legal business qualifications shall be signed and stamped by the personnel.

2. The working papers should provide a detailed and complete statement of the facts, laws and lawyer's judgments on which each legal opinion involved in the "Legal Opinion" is based.

3. The law firm is responsible for the management of working papers and the contract concluded with the client. Ownership of the work papers belongs to the law firm. Law firms shall submit the working papers they provide to lawyers associations, judicial administrative departments, and relevant government agencies to the above-mentioned organizations for reference. Law firms have the right to require personnel from the above-mentioned institutions to issue confidentiality commitments to prevent the disclosure of client information during inspections. When a dispute arises between a law firm and the above-mentioned institutions or other institutions over whether to provide working papers, both the law firm and the corresponding institution may request the affiliated bar association for mediation, and the affiliated bar association will make a ruling. Disputes involving the local bar association itself should be submitted to the superior bar association for handling.

4. Lawyers’ work performance shall be kept for at least ten years. If a law firm is divided or merged, it shall fulfill the obligation to keep the lawyer's work results of the previous year in the law firm division or merger agreement. If a law firm is dissolved and the period for keeping lawyers' working papers cannot be determined, the lawyers' working papers shall be kept by the Lawyers Association or an institution designated by the lawyers association.

5. Lawyers conducting due diligence should have a corresponding understanding of the characteristics of the industry under investigation and special policies and regulations related to the industry, and this should be reflected in the scope, content, and working methods of due diligence. Errors or omissions in the lawyer's due diligence due to the lawyer's lack of sufficient understanding of the industry characteristics of the due diligence target cannot exempt the lawyer and the law firm from liability.

6. Lawyers should promptly record discussions on major matters with management, governance and other personnel, including the content, time, location and participants of the discussions.