SINO MED Receives Further Supplementary Material Requirements for Overseas Listing Filing, Focusing on Business Involvement of Brain-Computer Interface Technology and Verification of External Participants under Equity Incentive Scheme

NewTimeSpace News: Recently, Sino Medical Sciences Technology Inc. received further supplementary material requirements issued by regulatory authorities in the course of filing for overseas securities offering and listing.

Second, disclose implementation status of regulatory procedures including overseas investment and foreign exchange registration applicable to the establishment of overseas subsidiaries, and deliver definitive compliance conclusions.

Third, clarify whether all participants under the employee equity incentive plan are bona fide employees of the Company, specify participant composition and employment status, and verify whether participants are connected with other shareholders, directors, supervisors and senior management of the issuer. If external persons participate, verification and disclosure shall be conducted with reference to relevant requirements on external participants set out in the regulatory guidance. For incentive recipients retaining incentive shares after resignation, explain whether such arrangements comply with original contractual terms and whether any disputes or potential disputes exist. Disclose subscription prices and pricing fairness under equity incentive schemes; for external participants, elaborate reasons and background for share subscription, subscription price, pricing basis and sources of funding. If their subscription prices are identical or close to those offered to employees, assess whether any benefit transfer exists. Deliver definitive conclusions on lawfulness and potential benefit transfer risks relating to implemented equity incentive plans and proposed post-listing option incentive schemes.

Fourth, explain the basis for identifying the controlling shareholder and ultimate controller, and illustrate the rationale and reasonableness with reference to shareholdings of each shareholder. Fifth, confirm whether the business scopes and actual operations of the issuer and its subsidiaries involve sectors restricted or prohibited under theSpecial Administrative Measures (Negative List) for Foreign Investment Access (2024 Edition), and verify sustained compliance with foreign investment access requirements after the proposed listing. Sixth, clarify whether the Company’s actual operations involve advanced brain-computer interface technology and provide relevant particulars.

Legal counsel shall complete verification procedures covering all above matters and issue definitive legal opinions.