Junion Intelligent Receives Supplementary Materials Request for Overseas Listing Filing, Focusing on Special Shareholder Rights Arrangements and Compliance of AI Large Model Business

NewTimeSpace News: Recently, Suzhou Junion Intelligent Technology Co., Ltd. has received a request for supplementary materials issued by regulatory authorities in the course of filing for overseas listing.

As required, the company shall first clarify whether there are affiliated relationships among shareholders with a shareholding ratio below 5%. If affiliations exist, it shall specify whether their shareholdings need to be combined. Where the combined shareholding exceeds 5%, penetrating verification shall be conducted in accordance with the standards for shareholders holding more than 5% shares. Second, the company shall illustrate the reasonableness of share subscription prices for new shareholders added in the past 12 months, with a focus on explaining the specific reasons for the price gap between Shengtian Industrial and other shareholders. It shall also deliver conclusive opinions on whether the pricing is fair and reasonable and whether interest transfer exists.

Third, the company shall specify the composition and job positions of personnel participating in the equity incentive plan. It needs to verify whether these participants have affiliations with other shareholders, directors, supervisors and senior management, and whether any personnel prohibited by laws and regulations from participating in equity incentives are included. Conclusive opinions shall be given on the fairness of subscription prices, contractual provisions, decision-making procedures and standardized operation, as well as the legality and compliance of the incentive plan and the existence of interest transfer.

Fourth, the company shall disclose the complete details of special shareholder rights arrangements, specific termination clauses and completed decision-making procedures. It shall confirm whether all shareholders have reached a consensus and whether any disputes exist, and verify whether the above matters constitute substantial obstacles to this overseas listing.

Fifth, the company shall present details of its obtained business qualifications. In accordance with the 2024 Special Administrative Measures (Negative List) for the Access of Foreign Investment, it shall verify whether the businesses and business scopes of the company and its subsidiaries fall into fields restricted or prohibited by the foreign investment access negative list, and confirm continuous compliance with relevant policies before and after this listing and full circulation. It shall also explain the business model, business scope and actual operations of the company and its subsidiaries in plain language. In addition, the company needs to clarify whether its business involves AI large models. If so, it shall specify relevant details including application scenarios and core functions, verify compliance with theMeasures for the Administration of Generative Artificial Intelligence Services, and confirm whether the large model filing has been completed.

Sixth, the company shall state whether the shares held by shareholders participating in the full circulation arrangement are pledged, frozen or subject to other rights defects. Legal counsel shall complete verification procedures and issue explicit legal opinions on all the above items.