Suzhou Green Control Transmission Technology Co., Ltd. (hereinafter "Green Control Transmission") has made its second attempt at an A-share IPO within three years. The company initially applied for a listing on the Shanghai Stock Exchange's STAR Market in December 2022, entering the inquiry phase the following January. However, just two months later, Green Control Transmission and its sponsor, China International Capital Corporation Limited (CICC), voluntarily withdrew the application.
In December 2025, Green Control Transmission restarted its IPO journey. While CICC remains the lead underwriter, the company has shifted its listing target to the Shenzhen Stock Exchange's ChiNext board, increasing its planned fundraising amount from the previous 1.072 billion yuan to 1.58 billion yuan.
During its preparations for the second listing attempt, Green Control Transmission experienced a significant performance surge. In 2024 and the first half of 2025, the company not only saw its revenue increase by 72.92% and 127.83% year-on-year respectively but also achieved a turnaround from loss to profitability. This performance recovery is precisely what enabled the company to relaunch its IPO ambitions.
Currently, Green Control Transmission's IPO has re-entered the inquiry stage. The Shenzhen Stock Exchange has raised 12 questions covering areas such as business model and growth prospects, corporate history, related-party transactions, revenue growth and customer changes, accounts receivable, inventory, and cash flow. Key points of inquiry include: 1. Whether employee shareholding platforms include partners who are not company employees, and whether the company, its controlling shareholders, actual controllers, or third parties provided rewards, subsidies, loans, or other forms of financial assistance to incentivize participation in the shareholding plans. 2. The specific reasons for the substantial revenue increase in 2024, and clarification on whether electric drive system products are subject to annual price reductions, as well as the rationale for reducing warranty provision ratios. 3. The causes and justification for the significant gross margin increase since 2023, and the specific reasons for the substantial difference between the company's gross margins and those of comparable industry peers for similar products. 4. The reasons and justification for high customer concentration, and whether there are any relationships with major clients Sany Group, XCMG Group, and Dongfeng Motor. 5. The causes and rationale behind the high volatility and frequent negative figures in cash flow from operating activities, and the mismatch between net profit and cash flow. 6. The justification and necessity for adding new production capacity against the backdrop of declining production-to-sales ratios, and the company's capability and specific measures to absorb the additional capacity from the proposed fundraising projects.
**TCL and Wuliangye Backing; Founder's Wife Concealed in Employee Share Platform** Green Control Transmission's predecessor was established in December 2011 by eight shareholders, including Li Lei, Li Shanshan, Huang Quanan, He Guowang, Wei Junmin, Song Peng, Zhang Guosheng, and Li Hu, with a total registered capital of 1 million yuan. The company exhibits strong family characteristics: among the founding shareholders, Li Hu, Li Shanshan, and He Guowang are respectively Li Lei's father, sister, and brother-in-law, while Wei Junmin and Song Peng are mother and son.
In 2018, Green Control Transmission completed its股份制 reform, with a net asset value of 172 million yuan. Due to subsequent audit adjustments, in April 2025, the net asset value at the reform benchmark date was adjusted to 118 million yuan. This adjustment has drawn regulatory attention, requiring an explanation for the reasons and basis behind it. The significant adjustments primarily involved capital reserve, estimated liabilities, retained earnings, and inventory data, with adjustments of 75.9366 million yuan, 45.3824 million yuan, -120 million yuan, and -18.7646 million yuan respectively. Among these, the share-based payment adjustment was mainly due to the company's actual controller, Li Lei, and some existing shareholders increasing their stakes at prices below fair value, while the initial reform financial statements did not account for share-based payment expenses for this equity incentive. In March 2018, capital reserve was cumulatively adjusted upward by 75.9366 million yuan, and retained earnings were adjusted downward by the same amount. Additionally, the company made supplementary provisions for quality assurance deposits and recalculated inventory aging, leading to increases in estimated liabilities and inventory.
Since 2022, Green Control Transmission has conducted four capital increases and eight equity transfers. During these changes, 31 private equity funds entered the company's shareholder roster, including Zhiyi Shengfu, Zhaoyin Xiandai, Minpu Yunsheng, Xinzhi Feng, Wuliangye Fund, Dongwu Kechuang, Future Auto, Xuzhou Intelligent, Qingdao Fangxin, and Anhui Jia'an. Upon穿透inspection, these investors are backed by major capital players such as Zhiyi Investment, CMB International Capital, Guanya Investment, Dongwu Venture Capital, Zifeng Capital, and Kunfu Venture Capital, as well as well-known enterprises like Sany Heavy Industry Co.,Ltd. (600031.SH), XCMG Group, Wuliangye Yibin Co.,Ltd. (000858.SZ), Tcl Technology Group Corporation (000100.SZ), and Dongfeng Motor.
Several shareholders acquired stakes by purchasing shares from the company's founding shareholders. Li Lei cumulatively transferred 3.787 million shares, Huang Quanan transferred 1.6131 million shares, and the couple He Guowang and Li Shanshan jointly transferred 2.936 million shares. Green Control Transmission's shareholding structure is relatively dispersed. Prior to the application, there were 55 shareholders, including 15 individuals and 40 institutions.
The company's controlling shareholder and actual controller is Li Lei, who directly holds 32.23% of shares and indirectly controls 11.41% through the employee shareholding platform Wujiang Qiantian, resulting in a combined control of 43.64%. His family members Li Shanshan and He Guowang hold 1.77% and 2.27% respectively. Among external shareholders, private equity funds under Zhiyi Investment collectively hold 7.76%; the couple Liu Jingxia and Huang Yimin, along with their controlled entities Guanfeng Yu and Guanxin Venture Capital, collectively hold 5.92%; the mother-son pair Wei Junmin and Song Peng hold 5%; CMB International Capital holds 2.71%; Dongfeng Motor's affiliate Xinzhi Feng holds 2.17%; Sany Heavy Industry Co.,Ltd. holds 1.89%; XCMG Group and Wuliangye Group indirectly hold 1.81% and 1.15% respectively; Tcl Technology Group Corporation indirectly holds 0.3% through Anhui Jia'an.
There are six employee shareholding platforms among Green Control Transmission's shareholders: Wujiang Qiantian, Green Control Management, Green Control Investment, Green Control No.1, Green Control No.2, and Green Control No.3. The Shenzhen Stock Exchange has inquired about this, requesting the company to explain the establishment background of these platforms, whether they include partners who are not company employees, and whether the company, its controlling shareholders, actual controllers, or third parties provided any rewards, subsidies, loans, or other assistance to incentivize participation, or if there are any entrusted shareholding or other undisclosed interest arrangements.
According to the company's response, there are three partners in the employee shareholding platforms who are not company employees: Liu Zhenfa, Zhang Yaxin, and Wang Wenwen. Liu Zhenfa holds a 2.13% stake in Green Control Management; Zhang Yaxin holds a 1.50% stake in Green Control Investment; Wang Wenwen holds a 0.2211% stake in Green Control Investment and a 0.0005% stake in Green Control No.3. Among them, Liu Zhenfa and Zhang Yaxin are former employees, while Wang Wenwen is the spouse of Li Lei. She, designated by the actual controller Li Lei as a third party, repurchased the equity shares of departed employees from the relevant employee shareholding platforms.
In December 2013, Green Control Transmission provided loans totaling 1.4999 million yuan to Li Lei, Yang Jun, Lü Tingke, Lu Jin, Zhang Xijian, and Li Hongzhi for出资related to equity incentives. All loans have been repaid.
**Core Team with Tsinghua Background; Family Member Exits Board** Green Control Transmission's core team includes several high-achievers from Tsinghua University. Chairman and General Manager Li Lei, born in the 1980s, earned his bachelor's, master's, and doctoral degrees from Tsinghua University. Since being admitted to Tsinghua's Automotive Engineering program in 2001, Li Lei has forged a strong connection with the automotive industry, laying a solid foundation for his future establishment of Green Control Transmission. Additionally, Supervisory Board Chairman Huang Quanan, Supervisor Chen Youfei, and Central Research Institute Dean Li Hongzhi are also graduates of Tsinghua University's Automotive Engineering Department.
Lu Jianjun serves as the company's second-in-command, holding the positions of Vice Chairman and Deputy General Manager. The 54-year-old executive joined Green Control Transmission as early as September 2013, previously serving as Head of the Process Department, Operations Director, and Deputy General Manager before being promoted to Vice Chairman in March 2022. Another non-independent director, Liu Yongrui, is appointed by shareholder Zhiyi Investment. Since December 2016, he has served as Managing Director of Huaxin Zhiyuan (Shenzhen) Investment Management Co., Ltd. and Zhuhai Zhiyi Huaxin Private Fund Management Co., Ltd. Liu Yongrui holds a bachelor's degree from Renmin University of China and a master's degree from the Hong Kong University of Science and Technology.
During the previous listing attempt, He Guowang was also a company director and served as Deputy General Manager. However, the current prospectus shows that He Guowang has exited the board of directors. Before July 2025, he also served as the company's Board Secretary; he now holds only the position of Director. His past resume indicates that He Guowang holds an undergraduate degree from the School of Economics at Fudan University and a master's degree from the Guanghua School of Management at Peking University.
The company's CFO, Wang Jinhuai, previously worked at Sany Heavy Industry Co.,Ltd., where he held positions for 12 years, serving as Accountant and Finance Manager at Sany Heavy Machinery Co., Ltd., and CFO at subsidiaries Changshou Huawei Crawler Co., Ltd. and Suote Transmission Equipment Co., Ltd.
Regarding compensation, in 2024, only Li Lei received an annual salary exceeding one million yuan, at 1.1125 million yuan. Meanwhile, Lu Jianjun and Huang Quanan received salaries of 989,800 yuan and 958,400 yuan respectively, approaching the one-million-yuan mark. Wang Jinhuai received a salary of 706,500 yuan.
**Explosive Performance Growth; Reduction in Warranty Provision Ratio** Green Control Transmission is a manufacturer of electric drive systems for new energy commercial vehicles, primarily providing electric drive systems, components and parts, and related technology development and services. Its products include motors, controllers, and automatic transmissions, used in pure electric, hybrid, and fuel cell commercial vehicles, as well as in off-road mobile machinery sectors.
The company holds a leading position in the new energy heavy-duty truck segment. According to third-party research data, from 2022 to 2024, its market share in supporting motors for new energy heavy-duty trucks consistently ranked first in the industry. The company's product technology and innovation have drawn regulatory attention, with the exchange requesting explanations on key indicators of technological advancement, the company's technical level and competitive advantages, the core technological advantages of its main products compared to those of peers, and the authority, objectivity, and independence of the third-party research data.
During the reporting period spanning 2022 to 2024 and the first half of 2025, Green Control Transmission achieved revenues of 712 million yuan, 770 million yuan, 1.328 billion yuan, and 1.219 billion yuan respectively. Net profits were -99.4282 million yuan, -12.3338 million yuan, 48.0427 million yuan, and 68.2955 million yuan respectively. Clearly, the company's performance experienced explosive growth in 2024 and the first half of 2025, with revenue increasing significantly by 72.33% and 83.68% (annualized) year-on-year respectively, and net profit turning from loss to profit, with the H1 2025 net profit exceeding the full-year 2024 figure.
In its inquiry letter, regulators requested Green Control Transmission to specify the reasons for the substantial revenue increase in 2024 and to clarify whether its electric drive system products are subject to annual price reductions. The company explained that the primary reason was a significant decrease in power battery costs, which led to lower terminal prices for new energy vehicles and a marked improvement in the full-lifecycle economics of new energy commercial vehicles, thereby increasing customer purchase willingness and driving significant growth in terminal demand. This performance change aligns with industry trends. During the reporting periods, the company's sales volume of electric drive systems were 22,000 sets, 24,900 sets, 42,500 sets, and 40,200 sets respectively.
Green Control Transmission further stated that its framework procurement contracts with customers mainly stipulate principle agreements on pricing arrangements and do not include specific annual price reduction clauses for product supply prices. According to industry practice, customers and the company negotiate product prices at the year-end or beginning of the year. From 2023 to 2024 and the first half of 2025, the value of products for which prices were reduced amounted to 265 million yuan, 570 million yuan, and 527 million yuan respectively, accounting for 39.16%, 48.86%, and 46.42% of relevant revenue. The average selling price of the company's electric drive systems during these periods was 28,900 yuan/set, 27,200 yuan/set, 27,400 yuan/set, and 28,200 yuan/set respectively, remaining relatively stable overall.
Behind the substantial growth in net profit, Green Control Transmission lowered its warranty provision ratio from the original 6% to 4%. After this adjustment, the company's net profit for 2024 and the first half of 2025 increased by 20.0665 million yuan and 19.3374 million yuan respectively, accounting for 41.77% and 28.31% of the net profit for those periods. The Shenzhen Stock Exchange requested an explanation for the rationale behind this reduction. The reply letter indicated that the ratio of actual warranty expenses incurred to sales revenue has been continuously declining, recorded at 5.89%, 3.89%, 3.46%, and 2.14% for each period respectively. Since 2023, this ratio has been below 4%, with actual warranty expenditures incurred in each period being less than the amount of estimated liabilities provisioned for that period.
Green Control Transmission's gross margin also increased significantly, recorded at 7.13%, 16.77%, 19.78%, and 19.38% for the reporting periods respectively, representing a 1.72-fold increase overall. The company attributed this mainly to a significant decrease in raw material procurement prices. Specifically, the gross margin for its electric drive systems was 4.82%, 15.06%, 19.3%, and 18.98% respectively, while the average gross margin for the same business segment among comparable peers was 8.46%, 9.23%, 12.88%, and 12.95% respectively. Thus, the company shifted from having a gross margin below the peer average to exceeding it.
The Shenzhen Stock Exchange required a quantitative analysis of the reasons and justification for the significant gross margin increase since 2023, and the specific reasons for the substantial difference between the company's gross margins and those of comparable industry peers for similar products. During the reporting period, the company's main business costs consisted of direct materials, direct labor, manufacturing overhead, and warranty expenses. The proportion of direct materials showed an increasing trend, rising from 74.87% to 79.86%, while the proportions of direct labor and warranty expenses showed a decreasing trend. In 2023, as the global supply chain gradually recovered, procurement prices for major raw materials such as magnetic steel, gears/shafts, and housings decreased significantly by 52.25%, 20.95%, and 18.47% year-on-year respectively, reducing the unit material cost per product from 20,800 yuan/set to 17,100 yuan/set. In 2024, the scale effect brought by rapid growth in motor production volume became prominent, contributing to reductions in unit direct labor, unit manufacturing overhead, and unit other costs.
Regarding the higher gross margin compared to peers, Green Control Transmission stated that its products are primarily applied in new energy commercial vehicles, whereas other listed companies focus mainly on passenger vehicles, and the market competition landscape for commercial vehicle electric drive systems is relatively stable.
During the reporting period, R&D expenses were 55.3463 million yuan, 47.6746 million yuan, 76.8533 million yuan, and 50.4182 million yuan respectively, showing an overall increasing trend. However, the R&D expense ratio was 7.77%, 6.19%, 5.79%, and 4.14% respectively, showing a year-on-year decreasing trend, primarily affected by the growth rate of operating revenue. Concurrently, the proportion of R&D personnel also declined. As of the end of the first half of 2025, Green Control Transmission had 207 personnel in R&D positions, accounting for 14.82% of the total. In contrast, in 2022, there were 168 R&D personnel, accounting for 30.38%.
**Major Client Stake Acquisition Draws Scrutiny; Company 'Pays' After Controller's Low-Price Share Transfer** The explosive growth of Green Control Transmission's business is closely linked to strong support from major clients. Its primary customers include XCMG Group, Sany Group, Shenxiang Technology, Dongfeng Motor, Xiamen King Long, Geely New Energy, Beiqi Foton, China National Heavy Duty Truck Group (CNHTC), and Zoomlion.
During the reporting period, sales revenue from the top five customers amounted to 478 million yuan, 486 million yuan, 825 million yuan, and 731 million yuan respectively, accounting for 67.12%, 63.07%, 62.15%, and 59.95% of total revenue, indicating a high degree of customer concentration. In 2024, Shenxiang Technology was added as a major customer, while Beiqi Foton dropped out of the top five but maintained cooperation. In the first half of 2025, Geely New Energy was added as a new top-five customer.
Regulators pointed out that Green Control Transmission's disclosure regarding changes in top five customers and newly added major customers was relatively brief, requesting detailed explanations for the specific reasons behind the changes, the causes and justification for high customer concentration, and whether the company possesses the ability to continuously acquire new customers and develop new products.
Green Control Transmission replied that the downstream market segments served by its electric drive systems all exhibit high market concentration, with the combined market share of the top five整车厂remaining at high levels. For example, in the first half of 2025, the combined market shares of the top five整车厂in the new energy heavy-duty truck, light truck, large bus, and medium bus segments were 57.58%, 49.11%, 75.64%, and 68.54% respectively. However, from 2022 to 2024, Green Control Transmission's customer concentration was slightly higher than the industry average, which was 59.72%, 62.93%, and 57.4% respectively.
Among its major clients, Sany Group and XCMG Group consistently held the top two customer positions, with transaction volumes growing rapidly. During the period, these two clients collectively contributed revenue of 331 million yuan, 342 million yuan, 556 million yuan, and 414 million yuan respectively, accounting for 46.43%, 44.4%, 41.87%, and 33.94% of total revenue.
Sany Group and XCMG Group are not merely customers; they are also indirect shareholders of Green Control Transmission. This situation attracted regulatory attention, requesting an analysis of whether the disclosure of关联关系is complete. Combining the shareholding situations of Sany Heavy Industry Co.,Ltd., Xuzhou Yunxiang, Minpu Yunsheng, and Xinzhi Feng, and their relationships with the company's customers Sany Group, XCMG Group, and Dongfeng Motor, regulators asked for an analysis of whether these three customers are related parties of the company.
The prospectus shows that in December 2021 and February 2022, Sany Heavy Industry Co.,Ltd. acquired a total of 1.22 million shares in Green Control Transmission through share transfer and capital increase, representing a 2.07% stake initially (later diluted to 1.89%). Shortly after Sany's investment, Green Control Transmission's sales to Sany's controlling subsidiary, Sany Group, surged from 50.0676 million yuan in 2021 to 197 million yuan in 2022, an increase of 293%. In the same year, Sany Group became the company's largest customer.
Similarly, in February 2022, Minpu Yunsheng and Xuzhou Yunxiang also became shareholders, holding a combined 1.1677 million shares initially (1.98%, later adjusted to 1.81%). These two entities are backed by XCMG Group. In 2022, the company's sales to XCMG Group also increased significantly by 117% from 61.5259 million yuan in 2021 to 134 million yuan.
Furthermore, Xinzhi Feng, which is under the same controlling entity as the top-five customer Dongfeng Motor, currently holds a 2.17% stake in the company. This indicates that Green Control Transmission's growth is largely supported by its shareholders.
In its reply, Green Control Transmission stated that according to the definitions of related parties under the Company Law, Accounting Standards for Business Enterprises, and relevant regulations of the China Securities Regulatory Commission (CSRC), Sany Group, XCMG Group, and Dongfeng Motor are not related parties of the company. The introduction of these shareholders was a market-based financing行为, and there were no instances of利益输送or granting shares to customers in exchange for more商业利益.
A previous prospectus for the Shanghai listing showed that in December 2021, Sany Heavy Industry Co.,Ltd. acquired shares in Green Control Transmission by purchasing 1.2 million shares held by Li Lei and Huang Quanan. In January 2022, XCMG Group acquired 53,000 shares held by Wujiang Qiantian. The share transfer price for both transactions was 39 yuan per share, with Sany and XCMG investing 46.8 million yuan and 2.067 million yuan respectively. Merely three months later, the transfer price for other external shareholders reached 66 yuan per share, 1.69 times the price paid by Sany and XCMG.
Interestingly, after the actual controller Li Lei and Supervisory Board Chairman Huang Quanan transferred shares to Sany Heavy Industry Co.,Ltd. at a low price, the resulting 'price difference' was accounted for on the company's books. In 2021, Green Control Transmission's selling expenses suddenly included a significant share-based payment expense of 49.0634 million yuan, compared to -39,300 yuan the previous year. At the time, the company explained that this was due to share-based incentives for sales personnel and the provision for share-based payments related to the entry of clients like Sany Heavy Industry Co.,Ltd.
Beyond close relationships with multiple major clients, Green Control Transmission also previously had significant related-party transactions with one关联方. In 2022 and 2023, the company purchased transportation services, rent and utilities, vehicle leases, and conducted debt/claim transfers from Suzhou Lvshui Qingshan Intelligent Logistics Co., Ltd. (hereinafter "Lvshui Qingshan"), amounting to 12.1103 million yuan and 1.3392 million yuan respectively. Since June 2023, the company has ceased transactions with Lvshui Qingshan. Tianyancha records show that Lvshui Qingshan was established in June 2020, primarily engaged in multimodal transport and transport agency, with its actual controller being Li Guanghui.
**Volatile Operating Cash Flow; Significant Increase in Capacity Utilization** Although Green Control Transmission has achieved a turnaround to profitability, its cash flow from operating activities remains negative. In 2022, 2024, and the first half of 2025, the net cash flow from operating activities was -297 million yuan, -185 million yuan, and -61.6469 million yuan respectively. It was only slightly positive in 2023, at 5.1991 million yuan. Regulators requested an explanation for the "reasons and justification behind the high volatility and frequent negative figures in cash flow from operating activities, the mismatch between net profit and cash flow, and whether this trend is consistent with comparable peers."
Green Control Transmission explained that this was primarily due to strategic working capital investments made to support rapid sales revenue growth, specifically reflected in stockpiling to cope with raw material price fluctuations and the capital tied up in accounts receivable and inventory accompanying business expansion.
In 2024 and the first half of 2025, Green Control Transmission's accounts receivable and inventory continued to climb, occupying significant funds. During the reporting period, the balance of accounts receivable was 269 million yuan, 404 million yuan, 518 million yuan, and 833 million yuan respectively. From 2022 to 2024, accounts receivable as a percentage of revenue was 46.47%, 59.42%, and 43.9% respectively. By the end of June 2025, accounts receivable had increased by 315 million yuan compared to the end of 2024.
Simultaneously, the inventory balance was 244 million yuan, 270 million yuan, 399 million yuan, and 613 million yuan respectively, increasing by 47.78% year-on-year in 2024 and by a further 214 million yuan in the first half of 2025. Inventory primarily includes raw materials, work-in-progress, finished goods, and goods in transit. The value of finished goods was 64.0131 million yuan, 66.9515 million yuan, 107 million yuan, and 167 million yuan for each period respectively, with its proportion of total inventory increasing from 22.5% to 25.19%. The value of goods in transit was 32.91 million yuan, 54.5076 million yuan, 74.114 million yuan, and 164 million yuan respectively, with its proportion increasing from 11.57% to 24.84%, indicating a rise in finished product scale.
Behind the increasing inventory, Green Control Transmission's capacity utilization rate saw significant growth, recorded at 76.7%, 54.06%, 90.03%, and 120.2% for the reporting periods respectively. However, the production-to-sales ratio declined, recorded at 98.17%, 90.52%, 91.76%, and 84.5% respectively.
The decline in the production-to-sales ratio is related to Green Control Transmission's sales model. During the reporting period, the company achieved sales through a direct sales model. Part of this involved a consignment model, with consignment revenue accounting for 59.12%, 66.72%, 66.10%, and 71.66% of total revenue in each period respectively, showing an overall increase. Under the consignment model, the company ships products to designated warehouses based on customer instructions, and customers actually withdraw consigned products as needed. In this model, the company can only recognize revenue after the customer physically withdraws the goods, leading to a noticeable lag in the revenue recognition point compared to production and shipment data. The increasing proportion of consignment sales further amplifies the inter-period impact on production and sales data.
For this IPO, Green Control Transmission plans to invest 1.38 billion yuan to expand production capacity for new energy medium and heavy-duty commercial vehicle electric drive systems. The project is expected to be completed and reach full capacity by the end of 2028, adding 100,000 sets of new capacity. Against the backdrop of a gradually declining production-to-sales ratio for its main products during the reporting period, the exchange inquired about the "rationale and necessity for adding new production capacity," requesting an analysis of whether the fundraising project possesses technological advantages, the rationality of the planned capacity setting, and the company's capability and specific measures to absorb the additional capacity from the project.
As of the end of June 2025, Green Control Transmission had monetary funds of approximately 300 million yuan, short-term borrowings of 587 million yuan, and non-current liabilities due within one year of 73.1452 million yuan, indicating a short-term debt gap of at least 287 million yuan. From 2022 to 2024, the company's asset-liability ratio continued to increase, reaching 69.54%, 74.78%, and 75.88% respectively. In the first half of 2025, following a financing round, the ratio decreased to 73.41%, but it remains higher than the industry average of 66.88%.
Appendix: List of Intermediary Institutions for Green Control Transmission's IPO Sponsor and Lead Underwriter: China International Capital Corporation Limited (CICC) Issuer's Legal Counsel: Beijing DeHeng Law Offices Auditor: Rongcheng Certified Public Accountants (Special General Partnership) Appraisal Institution: JZ (Shanghai) Assets Appraisal Co., Ltd.
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