The Zhitong Finance App learned that on July 10, the China Securities Regulatory Commission announced the disclosure of supplementary materials for overseas issuance and filing (July 6, 2026 to July 10, 2026). The Securities Regulatory Commission requested Sino Healthcare to provide additional information on the specific implementation of overseas investment and foreign exchange registration procedures involving the company's establishment of overseas subsidiaries, and issue a concluding opinion on compliance. Whether the company's business is involved in advanced brain-computer interface technology and specific circumstances in actual operation. According to the Hong Kong Stock Exchange disclosure on May 27, Sano Healthcare (688108.SH) submitted a listing application to the main board of the Hong Kong Stock Exchange, and CMB International was its sole sponsor.
In addition, the Securities Regulatory Commission requested Sino Healthcare to provide additional explanations on the following matters, and requested lawyers to check and issue clear legal opinions:
Explanation: According to the requirements of the “Guidelines for the Application of Regulatory Rules - Overseas Issuance and Listing Class No. 2: Guidelines on the Content and Format of Filing Materials”, explain in detail the establishment of the company and changes in share capital and shareholders since establishment, including but not limited to capital increases, share transfers and related price payments; lawyers express opinions on whether there are relationships between shareholders, whether there are situations of entrustment of shares or other transfer of benefits, the establishment of issuers, and whether previous equity changes are legal and compliant.
Description: Whether the participants in the employee equity incentive plan are company employees, specific personnel composition and employment status, whether the participants are related to the issuer's other shareholders, directors, supervisors, and senior managers; whether there are external personnel, if any, check the relevant requirements of external personnel in the “Guidelines for the Application of Regulatory Rules - Overseas Issuance and Listing Category No. 2”; whether the incentive target still holds the relevant incentive share after leaving the job, whether there are any disputes or potential disputes; the share price and fairness of the equity incentive plan; the reasons for the participation of external personnel Also, the background, share price, price basis, and funding source, such as the share price being the same or close to the employee, indicate whether there is a transfer of benefits; and issue a clear conclusion on whether the implemented equity incentive plans and the options incentive plan implemented after listing are legal and compliant, and whether there is a transfer of benefits.
Explanation: The basis for determining the controlling shareholder and actual controller of the company, explain the reason and rationality of the determination based on the shareholders' shareholding ratio. Whether the business scope and actual business of the company and its subsidiaries involve areas where the “Special Administrative Measures on Foreign Investment Access (Negative List) (2024 Edition)” restricts or prohibits foreign investment, and whether they continue to meet the foreign investment entry requirements after this issuance and listing.
According to reports, Sano Healthcare is a global enterprise focusing on the field of interventional medical devices. It is committed to meeting unmet clinical needs and providing curation-oriented, clinically proven solutions. The company was founded by Dr. Sun Jianhua in 2007. It has established a global operating layout covering R&D, manufacturing and commercialization, and operates in about 30 countries and regions.