On January 9, the China Securities Regulatory Commission (CSRC) issued the "Requirements for Supplementary Materials for Overseas Listing Filing (January 5, 2026 - January 9, 2026)." The CSRC's International Department issued supplementary material requirements to 10 companies, including Shanjin International Gold Co.,Ltd., which was asked to provide additional details on the basic information of its ultimate shareholders after upward穿透 and the progress of approvals, ratifications, or filings for domestic and overseas fundraising projects related to this issuance.
As disclosed by the Hong Kong Stock Exchange on September 24, 2025, Shanjin International Gold Co.,Ltd. (000975.SZ) submitted a listing application to the Main Board of the HKEX, with CITIC Securities, China International Capital Corporation (CICC), and UBS Group AG acting as its joint sponsors.
The CSRC requested Shanjin International to supplement and clarify the following matters, instructing its lawyers to verify and issue a clear legal opinion: First, with reference to the "Applicable Regulatory Guidelines for Overseas Listings No. 2," (1) explain the basic information of the company's ultimate shareholders after upward穿透; (2) based on the shareholder穿透 verification, accurately describe any affiliated or concerted action relationships among shareholders, and whether control will change after this issuance and listing, along with the relevant basis for determination.
Second, supplement and clarify the progress of approvals, ratifications, or filings for the domestic and overseas fundraising projects related to this issuance.
Third, (1) provide a clear conclusive opinion on whether any workplace safety incidents constitute a financing restriction or other disqualification for listing as stipulated in the "State Council's Notice on Further Strengthening Workplace Safety in Enterprises"; (2) supplement and clarify the specific further measures to address the non-conversion procedures for leased agricultural land.
Fourth, supplement and clarify whether the company and its subsidiaries belong to the "high-energy-consumption" or "high-emission" industries; verify whether existing, under-construction, and planned projects are classified as "high-energy-consumption" or "high-emission" projects, and provide the relevant basis.
The prospectus shows that Shanjin International is one of China's leading gold producers, primarily engaged in the exploration, mining, and processing of gold, silver, lead, zinc, and other non-ferrous metals, as well as metal trading. According to Frost & Sullivan, Shanjin International is the most profitable and cost-effective gold producer among listed Chinese gold companies, based on gross profit margin and cost per unit of gold production.
Shanjin International ranks sixth in gold production and fourth in gold reserves among Chinese gold producers. The company's gold resources increased significantly during the track record period, reaching 284.6 tonnes as of June 30, 2025, nearly doubling from 146.7 tonnes as of December 31, 2023.
For the year ended December 31, 2024, Shanjin International's all-in sustaining cost (AISC) for gold was $683.5 per ounce, placing it in the top 10% of the global gold mining AISC curve, while the global average for the same year was $1,438.1 per ounce.
Shanjin International owns and operates six mining enterprises located in China and Namibia. Among them, five gold mining enterprises hold six mining licenses, 29 exploration licenses, and four exploration license applications, while one polymetallic mining enterprise holds three mining licenses and six exploration licenses.
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