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, Daqin Shu was required to provide additional explanations on matters such as the rationality of the share price of new shareholders in the last 12 months, the reasons for the differences in the share price of different shareholders, and the reason and rationality of the large differences in the price of equity incentives granted to employee shareholding platforms. According to the Hong Kong Stock Exchange disclosure on June 26, Daqin Digital Energy Technology Co., Ltd. submitted a listing application to the main board of the Hong Kong Stock Exchange, and Cathay Pacific Junan International is its sole sponsor.
The China Securities Regulatory Commission requested Daqin Shuheng to provide additional explanations on the following matters, and ask lawyers to check and issue clear legal opinions:
1. Regarding the new shareholders, please explain (1) the rationality of the share price of the new shareholders in the last 12 months and the reasons for the differences in the share price of the 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.
2. Regarding the employee shareholding platform, please explain: (1) the reason and rationality of the large difference in price of equity incentives granted between Yuanjiidaotong, Nan Zhang Ziyi and Suzhou Qin Lakeside; (2) the composition and employment status of your company's equity incentives, whether the participants are related to other shareholders, directors, supervisors, and senior managers of your company, and whether there are any laws, administrative regulations, and relevant national regulations that clearly cannot participate in corporate equity incentives; and the fairness of the share price, agreement, implementation of decision-making procedures, and standardized operation profit Send out clear concluding comments.
3. The controlling shareholder of your company has had shareholding situations. Please list the names of the proxy holders, the ratio of the proxy holdings, the start and end time of the proxy holding, the method of cancellation of the proxy holding, the reason for the stock holding, the evolution of the escrow, legal compliance, whether there are any disputes or potential disputes, and the share holding period. Ask whether the proxy holder is a subject prohibited from holding shares by laws and regulations (including whether it violates the prohibition of competition). Also, based on the above situation, explain whether there is a major ownership dispute over the shares held by the controlling shareholder in accordance with the provisions of Article 8 of the “Trial Measures on the Administration of Overseas Issuance and Listing of Domestic Enterprises”.
4. Regarding the transfer of shares, please explain the pricing basis for the fourth equity transfer in April 2022, the reasons and rationality of the differences in the pricing of the capital increase during the same period, and the transferor's income tax payments related to the above equity transfer process, and issue a clear concluding opinion on whether there is a transfer of benefits.
5. Regarding overseas business, (1) Please explain the cross-border business situation involved in your company and whether it has obtained the necessary qualifications; (2) Please explain the specific implementation of regulatory procedures such as overseas investment and foreign exchange management, and issue a concluding opinion on compliance.
6. Regarding this issuance, listing and “full circulation”: 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.
According to the prospectus, Daqin Digital Energy is a pioneer among Chinese companies in the energy storage system (ESS) industry, focusing on R&D, manufacturing and sales of household, industrial and commercial ESS products. According to Frost & Sullivan's data, the company's commercial and industrial (commercial) ESS shipments in 2025 were about 0.6 gigawatt-hours, bringing the company's total ESS shipments to about 3.1 gigawatt-hours. Among ESS companies in China, the company is one of the companies with the broadest global business footprint.
Daqin Digital Energy is one of the first Chinese companies to focus on the overseas ESS market. Since its inception, the company has adopted a global operating model based on localized services to enter local markets with products developed to meet local needs. Over the years, the company has established distribution networks covering Europe, Asia Pacific, America, Africa and the Middle East, and has accumulated localized knowledge about the power grid environment, energy consumption patterns and end user behavior in dozens of markets. This market insight enables the company to quickly adapt to different market needs and provide products that meet local application scenarios.