New Stock News | Zixun Technology Plans Hong Kong IPO; CSRC Requests Supplementary Explanation on the Legality and Compliance of Past Equity Changes and Other Matters

On September 30, the China Securities Regulatory Commission (CSRC) issued the "Supplementary Materials Requirements for Overseas Offering and Listing Filing (September 20, 2026 September 30, 2026)." The International Department of the CSRC issued supplementary materials requirements for a total of 5 companies. Among them, Zixun Technology was required to supplement explanations on the pricing and pricing basis of its successive capital increases and equity or share transfers, as well as the actual capital contributions, the legality and compliance of its establishment and successive equity changes, and whether there is any tunneling of benefits. According to disclosure by the Hong Kong Stock Exchange on June 24, Zixun Technology (Fujian) Co., Ltd. submitted a listing application to the Main Board of the Hong Kong Stock Exchange, with GUOTAI JUNAN I as its sole sponsor. The CSRC requested Zixun Technology to supplement explanations on the following matters, and requested lawyers to verify and issue clear legal opinions: 1. Please explain: (1) the pricing and pricing basis of your company's successive capital increases and equity or share transfers, as well as the actual capital contributions, whether there are any abnormal share subscription prices, and whether there are any circumstances of failure to perform capital contribution obligations, withdrawal of capital contributions, or defects in the method of capital contribution; (2) whether the portions involving foreign investment in your company's successive capital increases and equity or share transfers comply with relevant regulations on foreign investment; (3) whether there has been any equity holding on behalf of others in your company's historical evolution, and whether there are circumstances where entities prohibited by laws and regulations from holding shares directly or indirectly hold shares of the issuer; (4) please issue clear conclusive opinions on the legality and compliance of the issuer's establishment and successive equity changes, and whether there is any tunneling of benefits. 2. Please, in accordance with the requirements of the "Regulatory Rules Application Guidelines Overseas Offering and Listing No. 2": (1) explain the background of the establishment of the employee stock ownership plan, the composition of personnel, the fairness of pricing, the performance of decision-making procedures, and issue clear conclusive opinions on whether the employee stock ownership plan is legal and compliant. If individual external personnel participate, the share subscription price, pricing basis, and source of funds shall be explained, and clear conclusive opinions shall be issued on whether participation in the employee stock ownership plan is legal and compliant and whether there is any tunneling of benefits; (2) explain in detail the relevant circumstances of the option incentive plan, the pricing basis and fairness of the exercise price, and lawyers shall fully verify whether reserved rights and interests are set up, and issue clear conclusive opinions on whether the option incentive plan is legal and compliant. 3. Please provide a list explaining whether the business scope and actual business of your company and its subsidiaries involve restricted or prohibited areas under the "Special Administrative Measures for Foreign Investment Access (Negative List)" (2024 Edition), and whether they continuously comply with foreign investment access policy requirements before and after this offering and listing and the "full circulation." 4. Please describe in plain and easy-to-understand language in detail the core patented technologies and application scenarios, specific functions, etc. of your company's main products or services. Several of the issuer's controlling subsidiaries have no actual external business operations; please explain the reasons and specific circumstances. 5. Please supplement explanations on whether the shares held by shareholders proposed to participate in the "full circulation" in this offering are subject to pledge, freezing, or other defects in rights. The prospectus shows that Zixun Technology is an e-commerce technology company committed to transforming e-commerce operating models by combining industry expertise with AI technology. As a leading e-commerce software provider in China, the company offers a comprehensive suite of e-commerce-native software products designed to meet the core operational needs of e-commerce sellers. Based on 2025 revenue, the company is the largest provider of e-commerce security operations products. According to Frost & Sullivan, among the top four e-commerce software providers in the industry (by revenue), the company achieved the highest revenue growth rate and operating profit margin between 2023 and 2025. Leveraging the company's long-standing deep understanding of e-commerce scenarios and continuous investment in AI technology, the company launched the e-commerce AI application product matrix LinkFox in 2023. Under the LinkFox brand, the company has built a comprehensive AI agent matrix designed to optimize the core operational workflows of e-commerce store operations, bringing sellers substantial AI-based productivity.