港股IPO招股书披露先例 · 22 家公司，27 项
自有土地房产及建设手续事项，一般指自有物业未取得权属证书、建设工程未取得规划或施工许可、未完成竣工验收或消防验收，以及土地闲置等情形。招股书多在概要、风险因素、业务及财务资料章节披露，说明涉及物业的面积、用途及形成原因，并测算潜在罚款。申请人常辅以主管部门确认函及法律顾问意见，通过补办手续、申领权证、承诺赔偿等方式解释或整改，并说明对经营影响有限。
合规类事项自 2026 年 8 月 24 日起递交的文件开始收录。
公司的解释、律师意见及原文页码定位：在 Matters 中查看Our PRC Legal Adviser confirmed that, as of the Latest Practicable Date, we had obtained all relevant land use rights certificates for this property in China.
Business · 第 180 页
We have not obtained valid land use rights certificates, building ownership certificates or other required approvals for certain of these properties.
Risk Factors · 第 54 页
As of the Latest Practicable Date, our Group was using but had not obtained title certificates for parcels of land with an aggregate area of approximately 3,159,373.4 sq.m., comprising:
Business · 第 143 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看As of the Latest Practicable Date, our Group was using but had not obtained building ownership certificates for buildings with an aggregate GFA of approximately 9,619.6 sq.m., comprising:
Business · 第 144 页
We constructed three ancillary structures at our Kunshan production base, comprising two water-recycling equipment rooms as well as an air-compressor equipment and power-distribution equipment room, with an aggregate gross floor area of approximately 2,087 square meters (the “Relevant Structures”), without completing the applicable environmental impact assessment, construction project planning, construction permit and other approval procedures. Accordingly, we have not obtained real estate ownership certificates for the Relevant Structures.
Risk Factors · 第 34 页
our Directors and our PRC Legal Advisor are of the view that the lack of real estate ownership certificates for the Relevant Structures will not have a material adverse effect on our Group’s overall production and business operations.
Risk Factors · 第 34 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看On May 11, 2023, the Comprehensive Administrative Enforcement Bureau of the Kunshan Economic and Technological Development Zone agreed in writing that demolition of the relevant equipment rooms could be deferred.
Risk Factors · 第 34 页
During the Track Record Period, the production lines of rubber resins and additives and PBAT of the RA Chemical factory had been in use prior to obtaining the required acceptance of completed construction project.
Business · 第 143 页
Based on the total contract price of the relevant buildings, the maximum potential fines in respect of the above non-compliances are estimated to be approximately RMB7.3 million.
Business · 第 143 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看As at the Latest Practicable Date, we had obtained the relevant acceptance of completed construction project and building ownership certificate for the properties of RA Chemical.
Business · 第 143 页
As at 30 June 2026, we owned a total of 32 properties within the PRC and we have obtained property ownership certificates and/or building ownership certificates for our owned properties, except that RA Zhenjiang had not obtained the relevant building ownership certificate in respect of buildings with a total gross floor area of approximate 9,321.68 sq.m..
Business · 第 143 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看As advised by our PRC Legal Adviser, the lack of building ownership certificates does not affect our normal use of the properties or subject us to any administrative penalty under applicable PRC laws and regulations, but it may affect the exercise of our rights in the transfer, mortgage or disposal of the underlying properties.
Business · 第 143 页
During the Track Record Period, we did not obtain construction permits or make required filings for certain construction and renovation projects in a timely manner, with a project contract value of RMB1.3 million, primarily due to inadvertent oversight and unfamiliarity with evolving regulatory requirements which prevented timely completion of the necessary application.
Business · 第 192 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看The potential maximum penalty in respect of fines that we may be exposed to due to the lack of construction permits or filings amounted to approximately RMB27 thousand.
Risk Factors · 第 41 页
During the Track Record Period, we had not obtained the requisite construction planning permit (建設工程規劃許可證), construction commencement permit (施工許可證) and/or acceptance of completed construction project prior to the commencement of construction and/or operations of certain production facilities, which may subject us to administrative penalties under the applicable PRC laws and regulations.
Risk Factors · 第 39 页
Due to the lack of relevant records, we were unable to ascertain whether the Pre-acquisition Properties had obtained the relevant construction planning permit and construction commencement permit prior to their construction.
Business · 第 144 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看our PRC Legal Adviser is of the view that, barring any material change in the PRC policies and regulations and the implementation and regulatory requirements of the local governments, the risk that the relevant government authority would impose administrative penalties on RA Zhenjiang with respect to the above non-compliances is remote, and such non-compliance incidents would not have any material adverse effect on the normal use and operation of the properties of RA Zhenjiang.
Business · 第 144 页
In addition, the remaining buildings with approximately 1,435.96 sq.m. that were constructed after our acquisition of RA Zhenjiang had been in use prior to obtaining the required acceptance of completed construction project ("Post-acquisition Properties").
Business · 第 144 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看As at the Latest Practicable Date, we have obtained the building ownership certificate in respect of the Post-acquisition Properties.
Business · 第 144 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看As of April 30, 2026, we had obtained all ownership certificates and necessary title documents with respect to the aforementioned land and properties.
Business · 第 159 页
As of the Latest Practicable Date, our Group had not obtained the building ownership certificates for 12 of our owned buildings, which are all based on our self-owned land, with an aggregated gross floor area of approximately 182,436 sq.m. in the PRC.
Business · 第 166 页
In addition, as of the Latest Practicable Date, we had not obtained the real property ownership certificates for 12 properties occupied by us, with an aggregate gross floor area of approximately 182,436 sq.m.
Risk Factors · 第 46 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看Subject to the review and approval procedures of the competent authorities, we expect to complete the rectification procedures and obtain the building ownership certificates for the remaining ten buildings by December 31, 2027.
Business · 第 167 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看In relation to the absence of certain construction project completion and acceptance certificates, fire safety acceptance and planning verification documents, we have engaged third-party professional institutions to conduct site inspections, surveying, verification and other technical work, and are liaising with the relevant local authorities to complete rectification procedures or obtain substitute documents under current policies.
Business · 第 166 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看All such properties have valid and complete land-use rights certificates and property-ownership certificates issued by the relevant authorities.
Business · 第 173 页
Specifically, as of the Latest Practicable Date, fifteen properties with an aggregate GFA of 2,689.6 sq.m., primarily as production auxiliary buildings or domestic living quarters, did not possess title certificates, and represent approximately 0.96% of our Group's completed building area (except for one property the certificate of which is being processed).
Business · 第 168 页
Our PRC Legal Advisor has provided a clear opinion on this matter, confirming that the absence of title certificates does not constitute a material violation of applicable laws or regulations.
Business · 第 168 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看Specifically, as of the Latest Practicable Date, fifteen properties with an aggregate GFA of 2,689.6 sq.m., primarily comprising production auxiliary buildings and domestic living quarters, did not possess title certificates.
Risk Factors · 第 46 页
As of June 30, 2026, we owned three properties in Chinese Mainland with an aggregate gross floor area (GFA) of approximately 536.0 sq.m.
Business · 第 163 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看As confirmed by our PRC Legal Advisor, we have obtained valid legal titles to these properties and land use rights for the land these buildings occupy, and we are entitled to legally occupy, use, benefit from, transfer, lease, mortgage or otherwise dispose of these properties.
Business · 第 163 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看As of the Latest Practicable Date, we owned 13 properties with an aggregate gross floor area of approximately 262,546 square meters in China and the U.S. We have obtained title certificates for all properties.
Business · 第 173 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看As of the Latest Practicable Date, we owned two properties in Chinese Mainland, with an aggregate GFA of approximately 430.91 sq.m., which are used as office premises. We have obtained the real property title certificates for these properties.
Business · 第 144 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看As at the Latest Practicable Date, our legal advisors confirmed that we had obtained all relevant land use rights certificates of the above parcels.
Business · 第 166 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看In addition, as of the Latest Practicable Date, we had constructed a temporary storage shed (with an aggregate gross floor area of approximately 875 sq.m.) and a foundry ancillary room (with an aggregate gross floor area of approximately 520 sq.m.) (collectively, the ''Ancillary Facilities'') for which no prior approval had been obtained from the Yulin Natural Resources Bureau, the competent local authority.
Business · 第 158 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看Our PRC Legal Advisor has confirmed that the use of these parcels of land does not contravene the use specified in the land use rights certificates.
Business · 第 210 页
Specifically, the registration procedures for workshops and offices owned by Hailiang Alltop, with a gross floor area of approximately 28,014 sq.m., could not be completed due to adjustments in local land planning use.
Business · 第 178 页
We have obtained a confirmation letter dated March 19, 2026 from the Tongling Shizishan High-tech Industrial Development Zone Planning and Construction Bureau confirming that the office building and ancillary facilities of our subsidiary Anhui Hailiang can continue to be used for production and operations and that no material non-compliance with land, planning, construction or real estate regulations has been identified.
Business · 第 178 页
公司的解释、律师意见及原文页码定位：在 Matters 中查看Furthermore, the factories, R&D buildings, and other facilities owned by Gansu Hailiang, with a gross floor area of approximately 270,207 sq.m., are currently undergoing final acceptance procedures, and we will apply for the relevant certificates immediately upon the completion of such acceptance.
Business · 第 178 页