The Zhitong Finance App learned that on September 11, the China Securities Regulatory Commission issued the “Notice on Requirements for Supplementary Material Filing for Overseas Issuance and Listing (September 7, 2026 to September 11, 2026)”. The International Division of the China Securities Regulatory Commission issued supplementary material requirements for a total of 9 companies. Among them, Jingtong New Materials is required to explain the specific circumstances of the capital raised for the construction of production base projects in Europe and Thailand, and whether it complies with regulations relating to overseas investment, etc. According to the Hong Kong Stock Exchange disclosure on May 27, Jingtong New Materials submitted a listing application to the main board of the Hong Kong Stock Exchange, and CICC is its sole sponsor.
The China Securities Regulatory Commission requested Jingtong's new materials to further explain the following matters, and ask lawyers to check and issue clear legal opinions:
1. Please indicate whether there is a relationship between shareholders holding less than 5% of the shares. If so, whether the shareholding ratio should be calculated collectively, and those over 5% should be thoroughly checked by 5% or more shareholders.
2. Please explain: (1) the specific pricing basis and rationality of the shareholding prices of new shareholders in the last 12 months, and the reasons for differences in the shareholding prices of different shareholders; (2) issue a clear conclusion on whether the share price of the new shareholders within the last 12 months is fair and reasonable, and whether there is a transfer of benefits.
3. Please explain the composition and employment status of the equity incentive personnel in your company, whether the participants have relationships with other shareholders, directors, supervisors, and senior managers of your company; whether there are people whose laws, administrative regulations, and relevant national regulations clearly cannot participate in corporate equity incentives; as well as the fairness of the share price, agreement, implementation of decision-making procedures, and standardized operation, and issue clear concluding opinions on whether they are legal and compliant and whether there are benefits.
4. Please provide additional information on the progress of processing the state-owned shareholder logo of Zhejiang Ke Venture Capital and the implementation of state-owned assets management procedures.
5. Please explain the full details of the special shareholders' rights arrangement, the details of the termination clause and the decision-making process for implementation, whether all shareholders have reached an agreement, whether there are any disputes, and whether it constitutes a substantial obstacle to the current overseas issuance and listing.
6. Please explain: (1) The relevant business qualifications obtained by your company, and explain in conjunction with the “Special Administrative Measures for Foreign Investment Access (Negative List)” (2024 edition) whether your company and its subsidiaries' business, business scope, etc. are restricted or prohibited in the negative foreign investment access list, and whether they continue to meet the requirements of the foreign investment access policy before and after the current listing and “full circulation”; (2) The business scope of your company and its subsidiaries includes “technology import and export”. Please explain the relevant business development and compliance.
7. (1) Please explain the business model and core competitiveness in easy-to-understand language based on the main products or business, major customers and suppliers, industry positions, comparable companies in the same industry, etc.; (2) If your company has administrative penalties such as fire, customs, etc., please explain the legal compliance of your company's business operations, internal control, corporate governance and compliance operations.
8. Please provide additional information on the specific implementation of overseas investment, foreign exchange management and other regulatory procedures involving your company's overseas subsidiaries, and issue a concluding opinion on compliance.
9. Please explain whether the shares held by shareholders who intend to participate in the “full circulation” have been pledged, frozen, or have other rights defects.
10. Please explain the specific circumstances of the funds raised for the construction of production base projects in Europe and Thailand, whether they comply with the relevant regulations and basis for overseas investment, and explain the implementation of relevant approval, approval or filing procedures. For example, please issue a commitment to return all of the funds raised to the country during the implementation of the relevant procedures.
According to the prospectus, Jingtong New Materials is an industry-leading supplier of new polymer decorative stone crystal composites. It focuses on the R&D, production and sales of green and sustainable multi-purpose decorative board products. The products mainly include novel polymer decorative stone crystal composite flooring and wall panels, which are widely used in residential, commercial and public spaces.
According to Frost & Sullivan, mainland China is the world's leading exporter of the PVC decorative materials market, accounting for about 45% of global export value in 2025. According to the total export value of mainland China in 2025, the company ranked first among all suppliers in the PVC decorative materials market; according to the total export value to Europe in 2025, the company ranked first among all Chinese suppliers in the PVC decorative materials market.
On the financial side, from 2023 to 2025, the company achieved operating income of 1,598 billion yuan, 2,219 billion yuan, and 2,307 billion yuan respectively, and net profit of 230 million yuan, 337 million yuan, and 361 million yuan respectively.