Jingtong New Materials: CSRC requires explanation on foreign investment access, proceeds for production bases in Europe and Thailand, among 10 items

NewTimeSpace News: On 11 September 2026, the International Cooperation Department of the CSRC published the supplementary material requirements for overseas issuance and listing filing for the period from 7 September 2026 to 11 September 2026, requiring Zhejiang Kingdom New Material Group Co., Ltd. to provide supplementary explanations on 10 items, with its PRC legal counsel required to conduct verification and issue clear legal opinions.

On shareholding structure, the Company is required to explain whether shareholders holding less than 5% of the shares are related to each other and, if so, whether their shareholdings should be aggregated, with those exceeding 5% subject to look-through verification as shareholders holding 5% or more; and to explain the specific pricing basis and rationality of the subscription prices of shareholders newly added in the past 12 months and the reasons for differences in such prices, and to issue a clear conclusive opinion on whether such prices are fair and reasonable and whether there is any transfer of benefits. The Company is also required to explain the composition and positions of participants in its equity incentive plan, whether they are related to other shareholders, directors, supervisors and senior management, whether any person is prohibited by laws, administrative regulations and relevant state provisions from participating in equity incentives, and the fairness of subscription prices, contractual arrangements, decision-making procedures and standardised operations; it must also supplement the full and specific contents of special shareholder rights arrangements, the specific circumstances of termination clauses, the decision-making procedures performed, whether all shareholders have reached consensus, whether there are disputes and whether they constitute a material obstacle to the overseas offering, as well as the progress of state-owned shareholder identification for Zhejiang Kefeng Venture Capital and the performance of state-owned asset management procedures.

On business and funding, the Company is required to explain, with reference to the Special Administrative Measures for Foreign Investment Access (Negative List) (2024 Edition), whether the businesses and scope of business of the Company and its subsidiaries involve restricted or prohibited areas under the negative list and whether they will continue to comply with foreign investment access policies before and after the offering and "full circulation", and to explain the operation and compliance of its business involving "technology import and export". Regarding its business model and core competitiveness, the Company must explain in plain language with reference to its principal products or businesses, major customers and suppliers, industry position and comparable companies, and explain the legality and compliance of its business operations, internal control, corporate governance and compliant operations in respect of administrative penalties it has received from fire and customs authorities. In addition, the Company must explain the performance of regulatory procedures relating to overseas investment and foreign exchange administration in respect of its overseas subsidiaries and the specific circumstances of the proceeds to be used for the construction of production base projects in Europe and Thailand, whether such use complies with the relevant regulations on overseas investment and the basis therefor, and the performance of the relevant approval, verification or filing procedures; if such procedures are in progress, it must issue an undertaking to repatriate all proceeds to the PRC. The Company must also supplement whether the shares held by shareholders intending to participate in the "full circulation" are subject to pledge, freezing or other title defects.

View announcement.

NewTimeSpace Disclaimer: All content herein is the original work of NewTimeSpace. Any reproduction, reprinting, or use of this content in any other manner must clearly indicate the source as "NewTimeSpace". NewTimeSpace and its authorized third-party information providers strive to ensure the accuracy and reliability of the data, but do not guarantee the absolute correctness thereof. This content is for reference only and does not constitute any investment advice. All transaction risks shall be borne by the user.