Zhitong Finance App learned that on August 28, the China Securities Regulatory Commission issued the “Requirements for Supplementary Materials for Overseas Issuance and Listing Filing (August 24, 2026 to August 28, 2026)”. The International Division of the China Securities Regulatory Commission issued supplementary material requirements for a total of 5 companies. Among them, Nali's new materials are required to further explain the basis for the pricing of the company's previous capital increases and equity transfers, whether the investment was actually paid, whether there were situations where investment obligations were not fulfilled, capital evasion, and defects in investment methods, and issue clear concluding opinions on whether the establishment and successive equity changes were legal and compliant. According to the Hong Kong Stock Exchange disclosure on May 28, Yangzhou Nali New Materials Technology Co., Ltd. (abbreviation: Nali New Materials) submitted a listing application to the main board of the Hong Kong Stock Exchange, and BNP PARIBAS is its sole sponsor.
The China Securities Regulatory Commission requested Nali's new materials to further explain the following matters, and ask lawyers to check and issue clear legal opinions:
1. Regarding changes in equity: (1) Please explain the basis for the pricing of your company's previous capital increases and equity transfers, whether the capital was actually paid, whether there were any situations of failure to fulfill investment obligations, evasion of capital, and flaws in the funding method, and issue clear concluding opinions on whether the establishment and successive equity changes were legal and compliant; (2) Please explain whether the company's historical history has involved share ownership.
2. Regarding the shareholder situation: (1) Please explain whether domestic entities holding 5% or more of your company's shares have penetrated upward; (2) Please explain the progress of the processing of the state-owned shareholder logo for CCI Investment; (3) Please explain the rationality of the shareholding prices of new shareholders in the last 12 months, the reasons for the differences between these share prices, and make clear conclusions on whether there are any benefits.
3. Regarding equity incentives: (1) In accordance with the requirements of the “Guidelines for the Application of Regulatory Rules - Overseas Issuance and Listing Class No. 2”, please verify whether the five former employees of your company hold interests in accordance with the employee shareholding plan regulations or agreement, and explain the progress of the relevant personnel shareholding platform share transfer and industrial and commercial change procedures; (2) Please issue a clear concluding opinion on whether the implementation of the employee shareholding plan is legal and compliant and whether there are benefits.
4. Please explain whether the issuer's business involves the National Development and Reform Commission, the Ministry of Industry and Information Technology, etc. controlling excess production capacity, and whether it complies with the requirements of the national “anti-internal circulation” policy, and provide relevant evidence.
5. Regarding this issuance and listing: (1) Please indicate the estimated amount of capital raised after full exercise of the over-allotment rights; (2) Please indicate whether the shares held by shareholders who intend to participate in the “full circulation” have been pledged, frozen or otherwise flawed.
According to the prospectus, Nali New Materials is a world-leading new energy materials company focusing on the development and manufacture of advanced functional fluid collectors, providing advanced functional fluid collector products and technical solutions for battery manufacturers and electric vehicle manufacturers.
According to Frost & Sullivan, in terms of shipments in 2025, Nalit's new materials rank third among global functional interface fluid collector manufacturers. As of December 31, 2025, the company ranked first among global composite fluid collector manufacturers. The annual production capacity of atomic deposition fluid collector is 62.9 million square meters. It is a special composite fluid collector that has undergone atomic deposition treatment to enhance safety performance, increase energy density, and reduce costs.