Hong Kong IPO disclosure precedents · 40 companies, 41 items
Failure to pay social insurance and/or housing provident fund in full or for all employees, whether due to contribution bases below actual wages, minimum-base payment, employees unwilling to bear personal contributions, new hires, or complete omission for individual employees.
Compliance matters are read from filings since 24 August 2026.
Separately, we did not make full social insurance for certain employees in strict compliance with relevant laws and regulations.
Risk Factors · p. 40
The amount of the shortfall in contributions for social insurance and housing provident fund in 2023, 2024, 2025 and the four months ended April 30, 2026 was RMB8.1 million, RMB9.3 million, RMB10.7 million and RMB4.1 million, respectively.
Risk Factors · p. 40
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 per their request, and we did not make full social insurance for certain employees in strict compliance with relevant laws and regulations.
During the Track Record Period, certain of our PRC subsidiaries did not make social insurance and housing provident fund contributions for certain of our employees in full in accordance with applicable PRC laws and regulations.
Risk Factors · p. 37
In 2023, 2024 and 2025 and the six months ended June 30, 2026, the aggregate shortfall of our social insurance and housing provident fund contributions amounted to approximately US$5.0 million, US$5.0 million, US$5.3 million and US$1.8 million, respectively.
Business · p. 163
as advised by our PRC Legal Advisor, based on the relevant regulatory policies and the facts stated above in the absence of further employee complaints, litigations or arbitrations and under the premise that there are no changes to current applicable PRC regulatory policies and regulations or to the enforcement and supervision requirements of the central and local governments or the relevant regulatory departments, the likelihood that the relevant authorities would take the initiative to require us to pay the shortfall for social insurance and housing provident fund contributions or that we would be subject to material administrative penalties due to our failure to provide full social insurance and housing provident fund contributions for our employees is remote.
During the Track Record Period, we did not fully contribute to social insurance for certain of our employees.
Risk Factors · p. 47
During the Track Record Period, there were instances where we did not make full contributions to social insurance or housing provident fund for certain employees.
During the Track Record Period, we did not make social insurance and housing provident fund contributions for certain employees in full based on the contribution bases required under applicable PRC laws and regulations.
Risk Factors · p. 43
However, there remains the possibility that the relevant authorities may determine that the contribution arrangements described above do not comply with applicable laws and regulations.
Due to historical reasons, differences in local practice and administrative complexities, certain of our PRC subsidiaries did not register for and/or make full contributions to social insurance and housing provident fund in accordance with relevant laws and regulations during the Track Record Period.
Business · p. 174
In 2023, 2024, 2025 and the five months ended May 31, 2026, the shortfall amounts were approximately RMB9.1 million, RMB11.3 million, RMB12.3 million and RMB4.0 million, respectively.
Business · p. 174
Our PRC Legal Advisor is of the view that our potential exposure to penalties from the competent authorities for failing to pay social insurance and housing provident fund contributions for certain of our employees during the Track Record Period are remote.
During the Track Record Period, social insurance for a few employees were not paid in full in accordance with PRC laws.
Risk Factors · p. 62
As of March 31, 2026, social insurance for a few foreign employees were not paid in full in accordance with PRC laws as these employees have made contributions in their home country or are unwilling to make contributions in China.
Business · p. 189
Accordingly, the maximum penalty that may be imposed on us is RMB29.3 million, if we fail to make required payment within the prescribed period, being three times the shortfall of our social insurance contribution of approximately RMB9.8 million as of March 31, 2026.
During the Track Record Period and up to the Latest Practicable Date, we did not made social insurance and housing provident fund contributions for some of our employees in full.
Business · p. 173
In 2023, 2024, 2025 and the six months ended June 30, 2026, (i) the shortfall for the social insurance payable amounted to RMB0.3 million, RMB0.7 million, RMB1.1 million and RMB0.9 million, respectively; and (ii) the shortfall for the housing provident fund payable amounted to RMB0.1 million, RMB0.5 million, RMB0.5 million and RMB0.5 million, respectively.
Business · p. 173
During the Track Record Period and up to the Latest Practicable Date, we did not made full contributions to the social insurance premium and housing provident fund based on the actual salary level of some of our employees as prescribed by relevant laws and regulations.
During the Track Record Period, we had not made social insurance and housing provident fund contributions for certain of our employees, in full, in accordance with the relevant PRC laws and regulations.
Business · p. 158
Since January 2026, we have been increasing the payment bases for our social insurance and housing provident fund contributions to the level compliant with the requirements of relevant local governmental authorities.
Business · p. 159
Based on the foregoing, our PRC Legal Advisor is of the view that the likelihood that we are subject to material administrative penalties due to our failure to make full contribution of social insurance and housing provident fund contributions during the Track Record Period is remote.
During the Track Record Period and up to the Latest Practicable Date, we did not make full contributions to the social insurance and housing provident funds with respect to certain of our employees as required by the relevant PRC laws and regulations.
Business · p. 173
During the Track Record Period, there are instances where social insurance and housing provident fund contributions for some of our employees were not fully based on their actual salary levels, and for a portion of our employees, the housing provident fund contribution procedures are not yet fully in place.
Risk Factors · p. 42
We have, since December 2025, made housing provident fund contributions for our employees who were previously not covered.
In 2023, 2024, 2025 and the three months ended March 31, 2026, the shortfall in our social insurance and housing provident fund contributions amounted to approximately RMB12.1 million, RMB11.7 million, RMB8.9 million and RMB2.4 million, respectively.
Business · p. 196
In addition, we did not make social insurance contributions and housing provident funds in full for certain employees, primarily due to varying individual preferences regarding participation levels in social benefit programs.
Risk Factors · p. 57
Based on the above, we have not made provisions for the insufficient contribution of the social insurance and housing provident fund.
During the Track Record Period, we and certain of our PRC subsidiaries did not make adequate contribution to social insurance and housing provident funds for employees.
Risk Factors · p. 49
During the Track Record Period, we and certain of our PRC subsidiaries did not make adequate contribution to social insurance and housing provident funds for employees as required by relevant PRC laws and regulations, primarily because the employees and employer are both obligated to make their own contributions to social insurance and housing provident funds under applicable laws and regulations, while certain of our employees were not willing to bear the costs associated with social insurance and housing provident funds strictly in proportion to their salaries.
Business · p. 169
our PRC Legal Advisor is of the view that, in the absence of collective employee complaints, litigations or arbitrations and under the premise that there are no significant changes to current PRC policies and regulations or to the enforcement and supervision requirements of local governments, the risk of us being penalized or required to make up payments by the relevant competent authorities with respect to the failure to provide full social insurance and housing provident fund contributions is remote.
During the Track Record Period, we did not make adequate contributions to the social insurance and housing provident fund with respect to certain of our employees, as required by the relevant PRC laws and regulations.
Risk Factors · p. 38
We did not make full contributions to the social insurance and housing provident fund for the relevant employees primarily because: (1) the relevant registration or contribution procedures could not be successfully completed for certain employees; and (2) many of our employees were not willing to bear the costs associated with social insurance and housing provident funds.
Business · p. 147
the likelihood that we would be subject to material administrative penalties or be proactively required by the relevant competent authorities to make retroactive contributions in respect of such non-compliance during the Track Record Period is remote.
During the Track Record Period, we did not make full social insurance and housing provident fund contributions for certain employees in compliance with relevant laws and regulations, considering some employees’ preference not to contribute amounts strictly calculated in proportion to their salaries.
Business · p. 187
Since September 30, 2025, we have fully rectified such practice and have made full social insurance and housing provident fund contributions for all our employees in compliance with relevant laws and regulations.
Business · p. 187
our PRC Legal Advisor is of the view that the risk of the competent authorities requiring our Group to pay shortfalls with respect to the social insurance and housing provident funds and/or taking the initiative to impose penalties on us is remote.
During the Track Record Period, we did not make full social insurance and housing provident fund contributions for certain employees as required under applicable PRC laws and regulations, primarily due to a combination of the following factors.
Business · p. 161
In 2023, 2024, 2025 and the six months ended June 30, 2026, the aggregate shortfall in our social insurance contributions and housing provident fund contributions amounted to approximately RMB18.8 million, RMB6.0 million, RMB6.3 million and RMB3.4 million, respectively, each representing less than 5% of our net profit for the respective year.
Risk Factors · p. 43
During the Track Record Period and up to the Latest Practicable Date, we had not received any written warning notices from the relevant government authorities, nor had we been subject to any administrative penalties or other disciplinary actions, in each case in relation to the historical shortfalls in our social insurance contributions and housing provident fund contributions.
During the Track Record Period and up to the Latest Practicable Date, we did not make full social insurance and housing provident fund contributions for certain of our employees.
Risk Factors · p. 35
We estimate that the shortfalls that we may be required to contribute to social insurance and housing provident fund for these employees would be approximately RMB9.6 million, RMB10.9 million, RMB12.6 million and RMB4.7 million in 2023, 2024, 2025 and the six months ended June 30, 2026, respectively.
Business · p. 174
As further advised by our PRC Legal Advisor, the likelihood that the relevant social insurance and housing provident fund authorities would require us to pay for the shortfall of social insurance and housing provident fund or impose administrative penalties on us due to our failure to make full payment of the social insurance and housing provident fund is remote, on the basis that (i) we have not received any notifications from the relevant authorities requiring us to pay the shortfalls, (ii) we have not been subject to any administrative penalties relating to inadequate contributions of social insurance and housing provident fund during the Track Record Period and up to the Latest Practicable Date, (iii) the relevant government authorities confirmed that they generally would not proactively take enforcement actions against us, (iv) we were neither aware of any material employee complaints nor were involved in any material labor disputes with our employees with respect to social insurance or housing reserve funds, and (v) we undertake to pay any shortfall within the prescribed time period upon request by relevant government authorities or upon the complaint by any affected employee.
During the Track Record Period, the aggregate shortfall amount of social insurances and housing provident fund contributions to our employees was RMB10.4 million and RMB6.7 million, respectively.
Risk Factors · p. 58
During the Track Record Period, we did not make adequate contributions to the social insurance and housing provident funds with respect to certain of our employees as required by the relevant PRC laws and regulations, primarily because certain employees were unwilling to pay the social insurance and housing provident funds in full as it requires additional contributions from our employees.
Business · p. 169
(ii) the risk of us being required by the relevant authorities to make centralized payments of historical shortfalls in social insurance and housing provident fund contributions, or being subject to material administrative penalties as a result, is remote
During the Track Record Period, we did not calculate such contributions for certain employees based on the statutory base (being the employees’ average monthly wages in the previous year) and instead used a lower contribution base.
Risk Factors · p. 40
The shortfall in social insurance and housing provident funds contributions amounted to RMB71.8 million, RMB66.6 million, RMB61.0 million and RMB31.2 million in 2023, 2024 and 2025 and for the six months ended June 30, 2026, respectively.
Business · p. 180
Based on the foregoing, our PRC Legal Advisor is of the view that, absent material changes in applicable PRC laws and regulations, the risk of the Company and its PRC subsidiaries being required by the competent social insurance authorities or housing provident fund management centers to make large-scale supplementary contributions for historical shortfalls is remote.
During the Track Record Period, as confirmed by our Directors to the best of their knowledge, our Group has generally complied with the payment requirements for social insurance and housing provident fund contributions, although there were limited instances where contributions were not made at all or not made in full.
Risk Factors · p. 39
According to our PRC Legal Advisor, during the Track Record Period and up to the Latest Practicable Date, notwithstanding that we did not effect the full payment for social insurance and housing provident fund contributions, or in extremely rare cases, fail to make payment for such contributions for some of our employees, the likelihood of our Group being subject to the recovery of historical shortfalls or material penalties is considered remote.
Business · p. 167
Accordingly, our PRC Legal Advisor is of the view that the likelihood of our Group being subject to recovery of historical shortfalls or any material penalties is considered remote, and there have been no instances of non-compliance that could result in any material adverse impact on our Group's operations or financial condition.
Our PRC Legal Advisor is of the view that the New Judicial Interpretation will not have a material adverse effect on our business, financial condition or results of operations, based on the following considerations: (i) upon its implementation, the New Judicial Interpretation did not affect the compliance status of our contributions to social insurance or expand our potential risk exposure arising from any failure to make full payment of the social insurance during the Track Record Period and up to the Latest Practicable Date; (ii) during the Track Record Period and up to the Latest Practicable Date, we had not entered into any agreement with, or otherwise required, any of our employees to waive, release or exempt us from our obligation to make social insurance contributions; and (iii) we have made arrangements for the payment of the relevant social insurance contributions for all of our employees during the Track Record Period and up to the Latest Practicable Date.
During the Track Record Period and up to the Latest Practicable Date, certain of our PRC subsidiaries did not make social insurance and housing provident fund contributions in full for certain employees in accordance with applicable PRC laws and regulations.
Risk Factors · p. 55
As advised by our PRC Legal Advisor, the maximum penalty payable by the Group for our outstanding social insurance and housing provident fund shortfall during the Track Record Period is approximately RMB26.9 million.
Risk Factors · p. 55
The Group had already commenced rectification of the shortfalls, and the outstanding unpaid amount for social insurance and housing provident fund during the Track Record Period was RMB10.9 million.