New Stock News | XETong is planning to list on the Hong Kong Stock Exchange, the China Securities Regulatory Commission requires additional disclosure of shareholder information and other matters.

On December 26th, the China Securities Regulatory Commission (CSRC) issued the "Supplementary Materials Requirements for Overseas Issuance and Listing Registration (December 22, 2025 - December 26, 2025)." The CSRC's International Department issued supplementary material requirements for 19 companies, including a request for Xiaoe Inc. to provide additional information on shareholder situations. According to a disclosure from the Hong Kong Stock Exchange on August 22nd, Xiaoe Inc. submitted an application for listing on the main board of the Hong Kong Stock Exchange, with CICC as its exclusive sponsor. The CSRC requested Xiaoe Inc. to provide clarification on the following matters, have a lawyer verify and provide clear legal opinions: 1. Concerning the establishment of offshore structures and compliance with reverse merger arrangements, please explain: (1) the specific compliance with foreign exchange management, overseas investment, foreign investment, tax management, and other regulatory procedures related to the establishment of offshore structures and reverse investments by your company and domestic shareholders, and whether they comply with the conclusions of the then-effective regulatory provisions; (2) the basis and method of pricing for the transactions with the domestic operating entity, fairness of pricing, and tax declaration obligations related to equity transfers in the context of the adjustment of the shareholding structure, and whether they comply with the provisions of the "Regulations on Mergers and Acquisitions of Domestic Enterprises by Foreign Investors"; (3) the reasons for and payment details of each capital reduction during the shareholding structure adjustment process, whether it involves false capital contributions or diversion of capital, and details on the decision-making process, tax payments, and compliance with the "Company Law" and relevant tax laws and regulations. 2. Regarding shareholder situations: (1) Please explain the complete penetration of the controlling shareholder of your company; (2) as required by the "Regulatory Rules Applicable Guidelines - Overseas Issuance and Listing Number 2," explain the penetration of shareholders holding more than 5% of your company, the basic information of the domestic entities after upward penetration, and whether there are entities prohibited from holding shares by laws and regulations; (3) Please explain if there have been instances of shareholding proxy in the historical evolution of your company; (4) Please explain the reason for the differences in the prices of newly added shareholders' stakes in the past 12 months, and provide a clear conclusion on whether there is any transfer of benefits. 3. Regarding trust arrangements: (1) Please explain the reasons and rationale behind family trusts holding shares of your company through multi-layer structures; (2) Explain the rights and obligations arrangements of all parties involved in the trust, based on the specific terms of the trust agreement, and provide detailed information on all trust beneficiaries, including but not limited to beneficiaries, share of benefits, and relationships with the settlor. 4. In accordance with the requirements of the "Regulatory Rules Applicable Guidelines - Overseas Issuance and Listing Number 2," conduct a verification of your company's equity incentive plan, and explain the reasons why options were not granted to some incentive recipients, and provide a clear conclusion on the existence of any benefit transfers and the legality and compliance of the plan. 5. Concerning the domestic operating entity: (1) Explain the actual payment of registered capital of your company's domestic operating entity, the basis for previous increases in capital and pricing for equity transfers, whether the capital has been actually paid, any instances of unfulfilled contribution obligations, capital diversion, or flaws in the contribution method, and provide a clear conclusion on the legality and compliance of the establishment and past equity changes; (2) Supplement the information on your company's domestic operating entity as required by the "Regulatory Rules Applicable Guidelines - Overseas Issuance and Listing Number 2" in the legal opinion, currently only verifying and explaining the main situation of the domestic operating entity; (3) Explain the specific situation of the domestic operating entity's business scope, including "advertising design, agency; internet data services; value-added telecommunications services," whether the related business has actually been conducted, the specific operational situation, whether the necessary qualifications and licenses have been obtained, whether the scope of operations and actual business activities involve restrictions on foreign investment access or prohibited areas, and whether they continue to meet the requirements of foreign investment access policies before and after this issuance and listing. 6. Concerning this issuance and listing: (1) Please explain the specific plan and arrangement for splitting the shares of your company, and whether it affects the number of shares issued this time; (2) Explain the specific purposes of the funds raised, the proportion of domestic and overseas use, and the compliance with domestic and foreign investment approval, review, or filing processes. According to the prospectus, Xiaoe Inc. is a leading product-driven SaaS solutions provider in the field of private domain operations, empowering enterprises to build, operate, and expand their decentralized e-commerce infrastructure. The company's cloud-based integrated solution includes e-commerce, digital marketing, and CRM modules, seamlessly integrating private domain operations from traffic conversion to customer relationship management and facilitating transactions throughout the entire lifecycle. By eliminating the inefficiencies and fragmentation of traditional tools, the company empowers enterprises to conduct product marketing and transactions in a scalable, data-driven, and efficient manner.