Shanghai Jin Jiang International Hotels Co., Ltd. recently received feedback from the China Securities Regulatory Commission (CSRC) regarding its overseas listing filing. The specific feedback items are as follows:
1. Further clarification is required on whether the issuer's subsidiaries fall under any circumstances prohibited from overseas issuance and listing as stipulated in Article 8 of the "Trial Measures for the Administration of Overseas Securities Issuance and Listing by Domestic Enterprises."
2. In accordance with the "Regulatory Rules Application Guidelines - Overseas Issuance and Listing Category No. 2," the issuer must explain the relevant circumstances of state-owned shares in its equity structure.
3. The issuer and its subsidiaries must provide details on websites, mobile applications, mini-programs, and public accounts they develop and operate, including the scale of user information collection and storage, data collection and usage practices, whether information is provided to third parties, cross-border data flow situations, and arrangements or measures for personal information protection and data security before and after listing.
4. The following clarifications are required: (1) Details regarding tobacco retail licenses obtained by the issuer and its domestic subsidiaries; (2) Clear basis demonstrating that value-added telecommunications services of the issuer's domestic subsidiaries do not violate foreign investment access policies; (3) Apart from the above, whether the business scope and actual operations of the issuer and its domestic subsidiaries involve foreign investment prohibition or restriction areas under the "Special Administrative Measures for Foreign Investment Access (Negative List) (2024 Edition)."
5. Explanation is needed on whether the use of proceeds complies with overseas investment regulations, with clear supporting evidence.
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