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
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:
彤程新材料集团股份有限公司Red Avenue New Materials Group Co., Ltd.09607.HK
RA Zhenjiang部分自有建筑未取得房产证
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
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.
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
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.
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.
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
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.
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
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.
As of June 30, 2026, our Company and Major Subsidiaries had several ancillary structures in China with an aggregate area of approximately 3,000 sq.m. which had not obtained title certificates, because certain construction approval procedures had not been completed during construction.
As of the same date, our Company and Major Subsidiaries had one building in China, primarily for office use, with a gross floor area of approximately 44,612.60 sq.m. which had obtained the relevant underlying land title and construction approvals and had completed the construction completion filing.
Business · 第 152 页
As of the Latest Practicable Date, the application for this building’s title certificate was in process.