IPO News | Xinde Semiconductor plans to list Hong Kong stocks, China Securities Regulatory Commission requires additional explanation of the company's business model and other matters

Zhitongcaijing · 5d ago

The Zhitong Finance App learned that on December 26, the China Securities Regulatory Commission issued the “Requirements for Supplementary Materials for Overseas Issuance and Listing Filing (December 22, 2025 to December 26, 2025)”. The International Department of the China Securities Regulatory Commission announced supplementary material requirements for 19 companies. Among them, Xinde Semiconductor was requested to further explain the pricing basis, fairness, and equity incentives for additional shareholders in the last 12 months. According to the Hong Kong Stock Exchange's disclosure on October 31, Jiangsu Xinde Semiconductor Technology Co., Ltd. (abbreviation: Xinde Semiconductor) submitted a listing application to the main board of the Hong Kong Stock Exchange, and Huatai International is the sole sponsor.

The Securities Regulatory Commission requested additional clarification on the following matters, and requested lawyers to check and issue clear legal opinions:

1. Please explain the reasons and rationality of NingPuxin releasing the company's shares from the pledge and promising the bank not to pledge or transfer them to other third parties, and that they will re-pledge after listing, and whether related circumstances may cause changes in the company's control.

2. Please explain the pricing basis and fairness of the share prices for new shareholders in the last 12 months, the reasons for the differences between these share prices, whether there are any abnormalities in the share consideration, and issue a clear conclusion on whether there is a transfer of benefits.

3. Please refer to the requirements of the “Guidelines for the Application of Regulatory Rules - Overseas Issuance and Listing Category No. 2: Guidelines on the Content and Format of Filing Materials”, (1) explain the specific use and corresponding ratio of domestic and foreign funds raised, whether specific fund-raising projects are involved, and whether the necessary approval, approval or filing procedures have been carried out.

4. Regarding equity incentives, please explain the progress of procedures relating to the transfer of property shares of former employees, and whether there are any disputes or potential disputes.

5. Please describe the company's business model in detail in easy-to-understand language and explain the specific circumstances of the business scope of the company and its subsidiaries involving integrated circuit manufacturing, integrated circuit chip and product manufacturing.

6. 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, Xinde Semiconductor is a semiconductor packaging and testing technology solution provider, mainly engaged in developing package design and providing customized packaging products and packaging product testing services.

According to Frost & Sullivan, in the post-Moorish era, where transistor density growth was close to the limit of its scale, reliance on novel semiconductor packaging architectures (such as miniaturization, thinness, high efficiency, heterogeneous integration, etc.) as a key aspect of connecting chip design and application became a key driving force for improving chip performance, efficiency, and functional flexibility. The company is one of the first companies with advanced packaging technology capabilities in China. It can drive breakthroughs in semiconductor innovation technology in the post-Moore era and support the development trend in the AI+ era.