On June 26, the China Securities Regulatory Commission (CSRC) issued a set of supplementary information requirements for overseas listing filings. Among these, Hexia Technology was asked to provide a detailed breakdown regarding a past shareholding arrangement involving its controlling shareholder. The request includes listing the names of the parties involved, the percentage of shares held under the arrangement, the start and end dates, and clarifying whether there are any significant ownership disputes over the shares held by the controlling shareholder.
According to a filing with the Hong Kong Stock Exchange on February 10, Zhejiang Hexia Technology Co., Ltd. submitted an application for listing on the GEM board of the HKEX, with Gold Link Capital acting as its sole sponsor.
The CSRC has requested that Hexia Technology provide additional clarifications on the following matters and has asked for its legal counsel to verify and issue a clear legal opinion:
First Set of Inquiries
Please provide supplementary details on: (1) the pricing and basis for pricing in all previous capital increases and share transfers within your company, whether there were any abnormal share subscription prices, whether there was any transfer of benefits, whether capital contributions were fully paid, and whether there were instances of failure to fulfill capital contribution obligations, illicit withdrawal of capital, or defects in the methods of capital contribution. (2) Please provide a conclusive opinion on the legality and compliance of your company's establishment and all historical changes in shareholding, as well as on your company's legal status and effective continued existence.
Second Set of Inquiries
Please provide supplementary details on the pricing basis for shares subscribed by new shareholders within the 12 months prior to submitting the overseas listing filing application, the reasons for and rationale behind any differences in pricing compared to contemporaneous capital increases, and the tax payment status of relevant transferors related to the aforementioned share transfers. Also, please issue a clear, conclusive opinion on whether there was any transfer of benefits.
Third Set of Inquiries
Please provide supplementary details on whether the employee shareholding platform has any reserved or unallocated shares, and whether situations where incentive recipients continue to hold relevant incentive shares after leaving the company comply with the relevant agreement stipulations, and whether there are any existing or potential disputes.
Fourth Set of Inquiries
Your company's controlling shareholder previously had a shareholding arrangement. Please provide a list detailing the names of both parties in the arrangement, the percentage of shares held, the start and end dates of the arrangement, the method of its termination, the reasons for the arrangement, its evolution, its legality and compliance, whether there are any existing or potential disputes, and whether the party whose shares were held during the arrangement period was a subject prohibited from holding shares under laws and regulations (including whether it violated non-competition provisions). Based on the above, and in accordance with Article 8 of the "Interim Measures for the Administration of Overseas Securities Issuance and Listing by Domestic Enterprises," please clarify whether there are any significant ownership disputes over the shares held by the controlling shareholder.
Fifth Set of Inquiries
Please provide supplementary details on whether the business scope and actual operations of your company and its subsidiaries involve areas restricted or prohibited for foreign investment, and whether they will continue to meet foreign investment access requirements after the proposed listing and the implementation of the "full circulation" scheme.
Sixth Set of Inquiries
Please provide supplementary details on whether the shares held by shareholders intending to participate in the "full circulation" scheme are subject to pledge, freeze, or have any other defects in rights.
According to its prospectus, Hexia Technology primarily provides automotive testing services to automobile and component manufacturers. Its core business encompasses three main areas: automotive testing, testing system integration, and automotive component sales. According to a Frost & Sullivan report, the company has developed into a leading provider of automotive testing solutions in Zhejiang Province, with testing facilities covering Zhejiang, Hubei, Jiangsu, Guangdong provinces, and Shanghai. The company's testing services include new internal combustion engine vehicles, new energy vehicles, and their component testing, and expanded to include ADAS testing from 2022. As of February 3, 2026, it possessed over 430 major pieces of testing machinery and equipment.
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