The Zhitong Finance App learned that on September 18, the China Securities Regulatory Commission issued the “Requirements for Supplementary Materials for Overseas Issuance and Listing Filing (September 14, 2026 - September 18, 2026)”. The International Division of the China Securities Regulatory Commission issued supplementary material requirements for a total of 6 companies. Among them, Guanan information is required to provide additional information on matters such as the price and pricing basis of the company's previous capital increases and share transfers, and whether there is stock brokerage in the company's historical evolution. According to the Hong Kong Stock Exchange's disclosure on May 20, Shanghai Guanan Information Technology Co., Ltd. submitted a listing application to the main board of the Hong Kong Stock Exchange, with ICBC International and Zhongtai International as co-sponsors.
The China Securities Regulatory Commission requested additional information from Guanan to explain the following matters, and ask lawyers to check and issue clear legal opinions:
1. Please provide additional information: (1) The price and pricing basis for your company's successive capital increases and share transfers; whether there is an abnormal share price; whether there is a transfer of benefits; whether there is actual payment of capital; whether there is failure to fulfill investment obligations, evasion of funding, or flaws in the funding method; (2) whether there is share escrow in the history of your company; (3) Please issue a concluding opinion on whether the establishment of your company and the successive equity changes are legal and compliance, and the status and effective existence of your company.
2. Please further explain the pricing basis for the share price of new shareholders within 12 months before submitting the overseas issuance and listing filing application, the reasons and rationality of the difference in capital increase pricing with the same period, and the transferor's income tax payment status in connection with the above equity transfer process, and issue a clear conclusion on whether there is a transfer of benefits.
3. Please provide additional information on the progress of your company's state-owned shareholders in implementing state-owned assets management procedures such as the state-owned stock logo, as well as the status of approval or internal decision-making procedures relating to the “full circulation” of shares.
4. Please further explain the reasons why close relatives of members of the management team of your company took a stake in the employee shareholding platform, whether there are any other external personnel, whether the above personnel are legally and complying with the shares, and whether there is a transfer of benefits; and whether the employee shareholding platform has reserved shares or ungranted shares.
5. Please further explain whether your company's business scope and actual business involves areas where foreign investment is restricted or prohibited, and whether the foreign shareholding ratio and specific calculation method after the current offering and listing and “full circulation” will continue to meet the foreign investment entry requirements.
6. Please provide additional information on whether the shares held by shareholders who intend to participate in the “full circulation” have been pledged, frozen, or have other rights defects.
According to the prospectus, Guanan Information is a professional intelligent information security solution provider in China. According to the Frost & Sullivan report, in terms of revenue in 2025, Guanan Information ranked first among professional security providers providing data security platforms in China (9.7% market share), seventh (3.8% market share) among professional security providers providing data security in China, and thirteenth (1.8% market share) among professional security providers providing information security in China.
Guanan Information is also a participant in the early application of big data analysis and artificial intelligence technology in the field of information security in China. The company focuses on data security, network security and emerging security fields. Guanan Information's security solutions can specifically meet customer needs in the fields of telecommunications, energy and electricity, and government and public entities.