On May 15th, the China Securities Regulatory Commission (CSRC) published a list of requirements for supplementary materials related to overseas listing filings. Among these, Guoyi Technology was requested to provide further details regarding changes in the business scope of its subsidiaries.
As disclosed by the Hong Kong Stock Exchange on January 21st, Anhui Zhongji Guoyi Medical Technology Co., Ltd. (Guoyi Technology) submitted an application for a main board listing in Hong Kong, with Haitong International Capital Limited acting as its sole sponsor.
The CSRC has asked Guoyi Technology to supplement explanations on the following matters and has requested its legal counsel to verify and provide a clear legal opinion: 1. Details regarding the company's developed and operated products such as websites, apps, and mini-programs, including the scale of user information collected and stored, data collection and usage practices, whether it involves providing personal user information to third parties, and the arrangements or measures for personal information protection and data security before and after the listing. 2. An explanation of changes in the business scope of the company's subsidiaries. 3. The rationale behind the share purchase prices for shareholders who joined within the last 12 months, reasons for any discrepancies among these prices, and a definitive conclusion on whether any improper benefit transfers occurred. 4. The compliance of the company's implemented equity incentive plans, including the specific composition and roles of participants, any relationships between participants and other shareholders, directors, supervisors, or senior management of the issuer, as well as the fairness of pricing, agreement terms, decision-making procedures, and standard operational practices, along with a definitive conclusion on their legality, compliance, and the absence of improper benefit transfers. 5. Clarification on whether the shares held by shareholders intending to participate in the proposed "full circulation" plan are subject to pledges, freezes, or other encumbrances.
According to its prospectus, Guoyi Technology is a leader in China's third-party SPD solutions market. A Frost & Sullivan report indicates that based on 2024 revenue, Guoyi Technology is the largest third-party SPD solutions provider in China, holding a 29.2% market share. The same report notes the company was also the first third-party SPD solutions provider in China.
The prospectus explains that SPD refers to Supply, Processing, and Distribution, an innovative supply chain model designed to optimize the supply and management of medical supplies in hospitals. Recognized for its flexibility and adaptability, the model typically encompasses (i) the procurement of hospital medical supplies and management of their suppliers, (ii) the handling and circulation management of medical supplies within the hospital's central warehouse, and (iii) the distribution and issuance management of medical supplies to various departments within the hospital. Traditional hospital medical supply chain models heavily rely on manual operations and decentralized management, utilize paper records, have limited information sharing, and lack real-time visibility into inventory and procurement.
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