The China Securities Regulatory Commission (CSRC) has issued a request for supplementary materials concerning overseas listings. Between March 3 and March 13, 2026, the CSRC's international department sought additional information from eight companies. Among them, Puqi Pharmaceutical was asked to provide further details regarding the remediation of historical construction project defects and other specific items.
On January 21, Hong Kong Exchanges and Clearing Limited disclosed that Beijing Puqi Pharmaceutical Technology Co., Ltd. submitted a listing application to the main board of the Hong Kong Stock Exchange. CITIC Securities and CMBC Capital are acting as joint sponsors for the offering.
The CSRC has requested Puqi Pharmaceutical to provide clarifications on the following matters, with instructions for its legal counsel to verify and provide clear legal opinions:
1. Regarding shareholder structure: The company is asked to explain (1) the requirement for a穿透核查 (look-through verification) of shareholder Chifeng Mingquan, an entity controlled by the actual controller Li Yuliang, in accordance with regulations for shareholders holding more than 5%; (2) verification and explanation of entities involved in share repurchases and transfers within the last 12 months, specifically referencing 2026 transactions; and (3) whether state-owned capital exists within the company's share capital and if relevant state-owned asset management procedures should have been followed.
2. Regarding historical shareholding arrangements: The company must clarify (1) the specific reasons for the initial establishment of the company with all shares held by nominees on behalf of Li Yuliang, Wang Hongmei, and Han Yongxin, including the specific transaction arrangements and the subsequent restoration of the actual ownership, and whether this violated any laws, non-compete agreements, or management systems; (2) the specific reasons behind an arrangement where Wang Hongmei transferred funds to accounts of her brother-in-law, sister-in-law, and employees of Puqi Limited, who then remitted the funds to the account of a nominal shareholder; (3) the accuracy of the stated timing for the dissolution of these shareholding arrangements in the filing materials, considering a 2020 transfer of registered capital from Chifeng Puqi to Wang Hongmei and a 2021 transfer of all her shares to Li Yuliang; (4) the specific reasons and transaction arrangements for Li Yusen holding an interest in Chifeng Qingxi on behalf of Li Yuliang and Wang Hongmei, and the sufficiency of evidence supporting the full dissolution of this arrangement at the Chifeng Qingxi level; (5) whether the filing materials completely and accurately describe the historical shareholding arrangements and their legality; and (6) to provide a conclusive opinion on the legality of the company's establishment and all historical share changes.
3. Regarding employee stock ownership plans: The company is asked to explain (1) the rationale for establishing two employee持股平台 (shareholding platforms) with different incentive methods; (2) the specific details of Zhu Li's participation in the equity incentive plan, including the timing and price of acquiring the incentive shares, and whether this complies with relevant agreements; and (3) to provide a clear conclusion on the legality of the equity incentive plans and whether any improper benefit transfers occurred.
4. Regarding operational and project matters: The company must clarify (1) the progress of procedures for the变更 (change) in enterprise investment project filing and the重新报批 (re-application) of environmental protection construction approval for its complex formulation project, and whether any substantive obstacles exist; (2) the current status of remediating historical construction project defects, the potential risk of investigation or penalties, and whether this constitutes a substantive obstacle to the listing; and (3) whether any关联关系 (affiliate relationship) exists between the company and Chifeng Zhongyu Real Estate.
5. Regarding shares for the potential "全流通" (full circulation) scheme: The company is asked to state whether shares held by shareholders intending to participate in the scheme are subject to任何质押、冻结或其他权利瑕疵 (any pledge, freeze, or other encumbrances).
According to its prospectus, Puqi Pharmaceutical is a biotechnology company focused on the immunology and inflammation领域 (field), aiming to become a leader in locally delivered targeted therapies. Since its establishment in 2016, the company has focused on innovative original design and precise local delivery, dedicating its efforts to the treatment of chronic inflammatory diseases. Its goal is to provide innovative solutions that offer efficacy, safety, and long-term patient satisfaction.
The company has developed a core late-stage product, PG-011 (Pumeixitinib), which has two formulations: a gel for atopic dermatitis and a nasal spray for allergic rhinitis. Puqi also possesses a diversified pipeline of candidate products. This includes PG-033 tablets for pruritus, PG-018 tablets for autoimmune kidney disease, and PG-040 eye drops for glaucoma. The company is also actively exploring the expansion of Pumeixitinib's indications to include perennial allergic rhinitis, prurigo nodularis, and non-segmental vitiligo.
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