Payment via third-party HR agencies

Hong Kong IPO disclosure precedents · 23 companies, 24 items

Social insurance and housing fund paid for employees through third-party human resources agencies rather than the employer's own account, e.g. for staff in cities without a local entity or employees wishing to contribute at their residence, which is not strictly compliant.

Compliance matters are read from filings since 24 August 2026.

2026-09-30Application ProofNon-compliance
ACROBIOSYSTEMS CO., LTD北京百普赛斯生物科技股份有限公司

During the Track Record Period, we engaged third-party human resources agencies to pay on our behalf social insurance premium and housing provident funds for a small portion of our employees.

Risk Factors · p. 42

As of July 31, 2026, we had ceased engaging third-party human resources agencies to make social insurance and housing provident fund contributions for a small portion of our employees, and all such contributions had since been made directly by us or our PRC subsidiaries and branches in accordance with applicable PRC laws and regulations.

Business · p. 171

as advised by our PRC Legal Advisor, the relevant risk of us being subject to material penalties as a result of paying the social insurance premium or housing provident fund through third-party agencies is remote

Business · p. 171
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-09-30PHIPNon-compliance
Amicro Technology Co., Ltd.珠海一微科技股份有限公司

During the Track Record Period, our PRC subsidiaries engaged third-party human resources agencies to pay social insurance premiums and housing provident funds for only a few employees per their request.

Risk Factors · p. 40

As of the Latest Practicable Date, we had not received any notice for payment of penalties of social insurance premium or housing provident funds from the competent authorities, nor any administrative penalty or labor arbitration application from employees for the agency arrangement with third-party human resources agencies.

Risk Factors · p. 40
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-09-29Application ProofNon-compliance
YUDO HOLDINGS CO., LIMITED柳道实业控股有限公司

During the Track Record Period, since some of our employees, for example, those located in cities where we did not have subsidiaries, prefer their social insurance and housing provident funds to be paid at their respective resident places for convenience of utilizing such benefits locally and there may only be limited number of employees in one city, we engaged third-party agents to pay social insurance and housing provident funds for them.

Business · p. 163

As of the Latest Practicable Date, we had ceased such abovementioned arrangements.

Business · p. 163
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-09-28Application ProofNon-compliance
Shandong Linuo Pharmaceutical Packaging Co.,Ltd.山东力诺医药包装股份有限公司

In addition, during the Track Record Period, we engaged a third-party human resources agency to make social insurance and housing provident fund contributions for certain employees.

Risk Factors · p. 43

During the Track Record Period, the Company also made social insurance and housing provident fund contributions for certain employees through its subsidiaries, Linuo Glass Products Marketing and Linuo Intelligent Robot.

Risk Factors · p. 44
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-09-28ProspectusNon-compliance
Beijing ESWIN Computing Technology Co., Ltd.北京奕斯伟计算技术股份有限公司01256.HK

In addition, during the Track Record Period, we engaged third-party human resource agencies to pay social insurance and housing provident fund for certain of our employees.

Risk Factors · p. 62

As of the Latest Practicable Date, our subsidiaries have obtained the written confirmation issued by the third-party human resource agencies confirming the full payment of social insurances and housing fund contributions with respect to such employees, and such employees have issued written undertaking to acknowledge that they are aware of the legal risks of requesting to entrust a third-party human resource agency to pay social insurances and housing fund contributions and bear all the liabilities arising therefrom by himself/herself.

Business · p. 189

We plan to complete the rectification of such non-compliance within two years after the Listing.

Business · p. 190
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-09-22ProspectusNon-compliance
Shenzhen Camsense Technologies Co., Ltd.深圳市欢创科技股份有限公司06802.HK

In addition, during the Track Record Period and up to the Latest Practicable Date, we engaged certain third-party human resources agencies to make social insurance and housing provident fund contributions on behalf of certain employees in the localities where they worked or resided.

Business · p. 196

Such arrangements, although not uncommon in China, are not in strict compliance with relevant PRC laws and regulations.

Business · p. 196

During the Track Record Period, we engaged third-party human resource agencies to pay social insurance and housing provident fund for two of our employees at their request because we accommodated their preferences for participating in social insurance and housing provident fund schemes in their respective place of residency.

Risk Factors · p. 57
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-09-21ProspectusNon-compliance
RoboTechnik Intelligent Technology Co., Ltd.罗博特科智能科技股份有限公司03757.HK

During the Track Record Period, we engaged a third-party human resources agency to pay social insurance premium and housing provident funds for certain of our employees.

Risk Factors · p. 60

Pursuant to the PRC laws and regulations, we are required to pay social insurance premium and housing provident funds for our employees under our own accounts instead of making payments under third-party accounts.

Risk Factors · p. 60
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-09-21ProspectusNon-compliance
Red Avenue New Materials Group Co., Ltd.彤程新材料集团股份有限公司09607.HK

During the Track Record Period, social insurance and housing provident funds contributions in respect of certain employees were made through a third-party agent.

Risk Factors · p. 39

Nevertheless, the social insurance and housing provident funds contributions in respect of certain of our employees (the "Relevant Employees") were made through third-party agents (the "Payment Arrangement"), at the request of the Relevant Employees.

Business · p. 157

Therefore, our PRC Legal Adviser is of the view that, barring any material change in the PRC policies and regulations and the implementation an regulatory requirements of the local governments, the likelihood of us being subject to administrative penalties as a result of the Payment Arrangement is remote

Business · p. 157
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-09-14ProspectusNon-compliance
Shenzhen Forms Syntron Information Co., Ltd.深圳四方精创资讯股份有限公司06700.HK

We also engaged third-party human resources agencies to make social insurance and housing provident fund contributions for a portion of our employees, which is not in strict compliance with relevant PRC regulations.

Risk Factors · p. 58

As of the Latest Practicable Date, none of our employees had their contributions made through such agencies.

Business · p. 170

(i) the engagement of third-party agencies to make social insurance and housing provident fund contributions on behalf of certain employees is unlikely to have a material adverse impact on our business operations

Business · p. 170
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-09-11ProspectusNon-compliance
Transwarp Technology (Shanghai) Co., Ltd.星环信息科技(上海)股份有限公司06727.HK

Due to the preference of certain employees to participate in local social insurance and housing provident fund schemes in their place of residency, we used third party agencies to pay social insurance and housing provident fund contribution for a few employees in certain locations where we had no branch or legal entity during the Track Record Period on time and in full.

Risk Factors · p. 52

As advised by our PRC Legal Advisors, the risk of us being imposed of material penalties is remote, provided that we rectify the third-party payment arrangements for our social security and housing provident fund contributions in a timely manner after receiving notices to rectify the non-compliance from the relevant PRC authorities.

Business · p. 176

We undertake to rectify these matters as soon as practicable after Listing and it is expected that the rectification will be completed by the end of the year ending December 31, 2027.

Business · p. 177
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-08-31Application ProofNon-compliance
Zhejiang IPLUSMOBOT Technology Co., Ltd.浙江迦智科技股份有限公司

During the Track Record Period, our PRC subsidiaries engaged third-party human resources agencies to pay social insurance premiums and housing provident funds for several employees, and we did not make housing provident fund contribution or make full social insurance and housing provident fund contribution or make full social insurance and housing provident fund contribution for our employees.

Risk Factors · p. 55

During the Track Record Period, we engaged third-party agencies to make social insurance and housing provident fund contributions for certain of our employees in certain locations where they work, which was primarily attributable to the wide geographical coverage of our sales network and the preferences of certain employees to have their contributions made in the locations where they were actually working or habitually residing for personal convenience.

Business · p. 193

Based on the above, provided that there are no material changes to the current social insurance and housing provident fund policies and regulations, or to the enforcement and supervision requirements of local governments, our PRC Legal Advisor is of the view that the likelihood of us being fined due to above non-compliance issues is remote.

Business · p. 193
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-08-31ProspectusNon-compliance
Excelland Robotics (Wuxi) Co. Ltd.优地机器人(无锡)股份有限公司03231.HK

During the Track Record Period, we engaged a third-party human resource agency to make contributions to social insurance and housing provident funds for certain employees working in cities where we do not have office premises.

Business · p. 197

Such arrangement, although not uncommon in China, is not in strict compliance with relevant PRC laws and regulations.

Risk Factors · p. 38

We made provisions of RMB11,000, RMB0.76 million, RMB0.76 million and RMB0.20 million in FY2023, FY2024, FY2025 and 3M2026, in respect of the potential shortfall arising from the relevant social insurance and housing provident fund contribution arrangements.

Business · p. 197
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-08-30Application ProofNon-compliance
Hangzhou Bangshun Pharmaceutical Co., Ltd.杭州邦顺制药股份有限公司

During the Track Record Period, we engaged an independent third-party agency to pay, on behalf of the Company, the relevant contribution for two employees.

Risk Factors · p. 51

During the Track Record Period, we engaged a third-party human resources agency to make social insurance and housing provident fund contributions on our behalf for certain employees, primarily because such employees preferred to have their contributions made at their respective places of residence for the convenience of accessing the relevant benefits locally.

Business · p. 195

Accordingly, the engagement of the third-party human resources agency to make such contributions did not strictly comply with applicable PRC laws and regulations.

Business · p. 196
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-08-30Application ProofNon-compliance
Beijing XSKY Technology Co., Ltd.北京星辰天合科技股份有限公司

During the Track Record Period, we engaged third-party human resources agencies to pay social insurance premium and housing provident funds on our behalf for certain employees in 15 cities where we did not have local subsidiary or branch.

Business · p. 203

During the Track Record Period, we engaged third-party human resources agencies to pay social insurance premium and housing provident funds on behalf of us.

Risk Factors · p. 49

As of the Latest Practicable Date, we had not received any notices of rectification or penalty related to the engagement of third-party agencies to pay social insurance.

Business · p. 203
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-08-28Application ProofNon-compliance
VivaVision Biotech (Zhejiang) Co., Ltd.维眸生物科技(浙江)股份有限公司

During the Track Record Period, we did not fully contribute to social insurance for two of our employees, and between January and April 2024, we engaged third-party human resource agencies to pay social insurance and housing provident funds for six of our employees due to the relocation of our headquarters.

Risk Factors · p. 56

our PRC Legal Advisers are of the view that provided that there are no significant changes in the current policies, regulations, and the enforcement of local authorities, the likelihood of us being subject to active and collective demands for retroactive social security and housing fund payment, or administrative penalties resulting in material adverse effects on our business, financial condition by relevant competent authorities is low.

Risk Factors · p. 57
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-08-28Application ProofNon-compliance
Betta Pharmaceuticals Co., Ltd.贝达药业股份有限公司

During the Track Record Period, our Company and some of our PRC subsidiaries engaged third-party human resources agencies to pay social insurance premium and housing provident funds for certain of our employees.

Risk Factors · p. 50

Such arrangements, although not uncommon in China, are not in strict compliance with relevant PRC laws and regulations.

Business · p. 209

We have not fully rectified this non-compliance primarily because (i) our sales personnel are dispersed across various cities where our Group lacks legal entities, and these employees generally prefer to make the relevant contributions in their place of residence so as to enjoy the applicable local benefits.

Business · p. 209
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-08-28Application ProofNon-compliance
Nanjing Novlead Biotechnology Co., Ltd.南京诺令生物科技股份有限公司

We made full social insurance and housing provident fund contributions for our employees during the Track Record Period, except that we engage third-party human resources agencies to do so for employees whose work locations differed from our main operating entities, which involves potential risks.

Business · p. 187

As advised by our PRC Legal Advisor, there are currently no national laws or regulations that explicitly specify penalties specifically targeting employers that use third-party human resources agencies to make social insurance and housing provident fund contributions for their employees.

Business · p. 200

We ceased the engagement of third-party human resources agencies for social insurance and housing provident fund contributions with effect from April 1, 2026.

Business · p. 200
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-08-28Application ProofNon-compliance

Additionally, during the Track Record Period, certain of our PRC subsidiaries historically engaged third-party agencies to make social insurance and housing provident fund contributions on behalf of a small number of their employees, which is not in compliance with relevant PRC regulations requiring employers to handle such payments directly.

Business · p. 208

As of the Latest Practicable Date, we have ceased the practice of using third-party agencies for contribution payments.

Business · p. 209

In addition, the required contribution under the relevant laws to some of our employees were paid by third parties on behalf of the relevant subsidiaries of the Company.

Risk Factors · p. 59
The company's explanation, the adviser's view and the page in the filing: see Matters
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