Proya (603605.SH): Receives Request for Supplementary Materials in Overseas Listing Registration, Focusing on Foreign Investment Access for Cultural and Entertainment Businesses and Data Security

Recently, Proya (603605.SH), a cosmetics enterprise, has received a request for supplementary materials from the regulatory authorities in the process of overseas issuance and listing registration. The company needs to explain matters such as the use of raised funds, data security, advertising business qualifications, and foreign investment access, and lawyers shall conduct verification and issue clear legal opinions.

According to the requirements:

First, the company shall explain whether the use of the raised funds involves overseas investment and the performance of relevant approval, verification, or registration procedures.

Second, it shall explain the development and operation of products such as APPs, mini-programs, and official WeChat accounts by the company and its subsidiaries; if personal information collection and use are involved, specify the scale of user information and the status of data collection and use.

Third, it shall explain the actual operation of businesses such as advertising design, production, agency, and release included in the business scope of subsidiaries, as well as whether the necessary qualifications and licenses have been obtained.

Fourth, it shall focus on explaining compliance with foreign investment access requirements:

First, detailedly explain the specific operation and compliance of businesses such as "film production services", "radio and television program production and operation", "online cultural operation", "film distribution", "publication retail", and "performance brokerage" included in the business scope of domestic subsidiaries; comprehensively sort out whether the business scope of all subsidiaries involves the "culture, sports and entertainment" related fields in the Special Administrative Measures for Foreign Investment Access (Negative List) (2024 Edition).

Second, in addition to the aforementioned fields, further comprehensively verify whether the business scope and actual operations of the issuer and all domestic subsidiaries involve other fields prohibited or restricted for foreign investment in the Negative List.

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