On December 26, the China Securities Regulatory Commission (CSRC) published its "Requirements for Supplementary Materials for Overseas Listing Filing (December 22, 2025 - December 26, 2025)." The CSRC's International Department disclosed supplementary material requirements for 19 companies, among which Haina Pharmaceutical was asked to provide additional explanations regarding the specific uses of the raised funds and the proportion of domestic versus overseas allocations.
Reportedly, Haina Pharmaceutical had submitted its application to the Hong Kong Stock Exchange on November 7, 2025, with China International Capital Corporation (CICC) acting as the sole sponsor. The CSRC requested Haina Pharmaceutical to supplement the following matters and instructed its lawyers to verify and provide clear legal opinions: Firstly, regarding equity changes: (1) Explain the procedural compliance of the company's capital reduction, the payment of relevant taxes and fees, and the settlement of capital reduction payments, and provide a definitive conclusion on the legality and compliance of the company's establishment and all historical equity changes; (2) In accordance with the requirements concerning share entrustment holdings in the "Applicable Regulatory Guidelines for Overseas Listings No. 2," conduct a verification of the historical instances of share entrustment holdings within the company.
Secondly, explain the specific fulfillment of regulatory procedures, such as overseas investment and foreign exchange registration, involved in the establishment of the company's overseas subsidiaries, and provide a conclusion on their compliance. Thirdly, detail the specific circumstances of the company and its subsidiaries whose business scope includes "pharmaceutical development and research; medical research and experimental development; testing services," whether such businesses are actually conducted and their operational specifics, whether necessary qualifications and permits have been obtained, and whether the business scope or actual operations involve "human stem cells, genetic diagnosis and treatment technology development and application" or other fields restricted or prohibited for foreign investment, along with the basis for such judgments, and confirm ongoing compliance with foreign investment access policy requirements before and after this issuance and listing.
Fourthly, explain the specific details of social insurance and housing provident fund payments made through third parties and any instances of underpayment by the company and its subsidiaries; provide the latest progress on any ongoing litigation or arbitration cases and assess whether they constitute a substantive obstacle to this overseas listing. Fifthly, clarify the specific uses of the raised funds, the proportion allocated for domestic versus overseas purposes, and the status of fulfilling relevant domestic and overseas investment approval, verification, or filing procedures. Sixthly, state whether the shares held by shareholders intending to participate in the "Full Circulation" scheme are subject to pledges, freezes, or other encumbrances.
The prospectus reveals that Haina Pharmaceutical is an integrated pharmaceutical R&D and manufacturing company providing CXO services; concurrently, the company possesses a proprietary product pipeline, which it primarily commercializes through pharmaceutical technology transfers. According to a Frost & Sullivan report, during the track record period and up to the last practicable date (November 2, 2025), Haina Pharmaceutical ranked second among CXO service providers engaged in drug technology transfer in China by the total number of clinical trial approvals and marketing authorizations obtained. From the same source, Haina Pharmaceutical also ranked second in terms of the total number of clinical trial and marketing authorization applications submitted during the same period.
Haina Pharmaceutical operates one of the industry's most comprehensive CXO platforms, with business covering the entire chain from drug discovery, CMC, preclinical and clinical development, registration and validation, through to commercial manufacturing. The company offers end-to-end or modular CRO and CMO solutions encompassing drug R&D and CMC, clinical and bioequivalence trial services, regulatory registration, and contract manufacturing. As of December 31, 2022, 2023, and 2024, and June 30, 2025, Haina Pharmaceutical had 242, 331, 383, and 398 ongoing CXO projects, respectively.
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