Revenue generated from sales to customers in Comprehensively Sanctioned Countries was nil, RMB283.8 thousand and RMB4.2 million, representing approximately nil, nil and 0.02% of our total revenue in 2023, 2024 and 2025, respectively.
Summary · 第 15 页
During the Track Record Period, we sold certain commercial products including fitness equipment, hardware tools and machinery, building decoration materials and daily household goods to Russia, which were settled through third-party payments in USD (‘‘Russian Transactions’’).
Business · 第 178 页
During the Track Record Period, we procured certain advertising services from a supplier that has been listed on the Entity List by the BIS since May 21, 2019 (the ‘‘EL Supplier’’).
The payments received during the Track Record Period for USD-denominated transactions in relation to Iran USD Sales and Syria USD Sales were in an aggregate amount of approximately US$22.75 million, approximately 0.2% of our aggregated revenue for the Track Record Period.
Summary · 第 15 页
After consulting with our International Sanctions Legal Advisors, we made an initial notification of VSD to OFAC on September 26, 2025 and a comprehensive VSD report to OFAC on April 29, 2026 related to the Iran USD Sales and the Syria USD Sales.
Summary · 第 15 页
Since September 26, 2025, we have ceased all business activities in connection with Iran and Syria, which are subject to comprehensive sanctions.
During the Track Record Period and up to the Latest Practicable Date, we have sold our products to various non-sanctioned customers and distributors in Belarus, Democratic Republic of the Congo, Egypt, Guinea, Hong Kong, Myanmar, Russia (excluding Crimea, so-called Donetsk People’s Republic (“DPR”) and Luhansk People’s Republic (“LPR”) regions, Zaporizhzhia and Kherson regions), Turkey, Tunisia, Ukraine (excluding Crimea, DPR, LPR, Zaporizhzhia and Kherson regions) and Zimbabwe (“Relevant Regions”).
Business · 第 168 页
The total revenue generated from our sales to our customers in the Relevant Regions (excluding Hong Kong) was less than 10% for the three years ended December 31, 2025.
Business · 第 168 页
As advised by our International Sanctions Legal Advisor, given that (i) the products our Group sold to Russia and Belarus were limited to Chinese-origin self-designed construction machinery, such aerial work platform and mining equipment, which do not fall within scope of products listed on the Russia Critical Items Determination issued pursuant to subsection 11(a)(ii) of EO 14024 nor the Common High Priority List issued by the BIS on February 23, 2024; (ii) our Group did not engage in any sales to sanctioned entities in Russia or Belarus, including those listed on the SDN List at the time of transaction; and (iii) our Group’s sales to Russia and Belarus (direct and indirect) throughout the Track Record Period were immaterial (below 10%) and is declining, the risk is low that our Group’s activities with the Relevant Regions would be viewed as Secondary Sanctionable Activities that would result in the imposition of sanctions on the Relevant Persons.
During the Track Record Period, we had transactions with one customer in Iran in 2024, and we received payments in USD for such transaction.
Business · 第 132 页
As advised by our International Sanctions Advisor and taking into account that (i) all Iran historical transactions were completed by November 2024 and only one payment was received during the Track Record Period, (ii) the Iran historical transactions only involve optical connectivity products manufactured in the PRC, (iii) the aggregate revenue derived from the Iran historical transactions represented 0.001% of our Group’s total revenue during the Track Record Period which was negligible in terms of revenue, (iv) the only Iranian customer was not designated on any sanctions list; and (v) as of the Latest Practicable Date, our Group has not been notified or received any notification from the relevant authorities or banks in connection with the Iran historical transactions, it is reasonable to conclude that sanctions risks (including designation as a Sanctioned Target) on our Group shall be relatively remote.
Business · 第 133 页
We have implemented a sanction-related internal policy to govern our approach to identifying, assessing, and mitigating OFAC-related risks.
山推工程机械股份有限公司Shantui Construction Machinery Co., Ltd.
向受制裁相关地区的客户销售产品
During the Track Record Period, our Group has sold our Chinese-origin construction machinery and spare parts to various non-sanctioned customers located in the Relevant Regions.
Business · 第 161 页
Such wide definition may capture our sales activities.
Business · 第 162 页
Therefore, as advised by Hogan Lovells International LLP, our legal advisor to International Sanction laws, our activities are unlikely to be viewed as activities targeted by secondary sanctions focused on the Russian manufacturing sector.
Our transactions with Sanctioned Targets amounting to approximately RMB34.9 million in aggregate, representing approximately 7.0% of our total revenue during the Track Record Period.
Summary · 第 4 页
As advised by our International Sanctions Legal Advisor after conducting the relevant due diligence, (i) our activities with customers in the Relevant Regions did not represent Primary Sanctioned Activity in violation of the applicable International Sanctions in the Relevant Jurisdictions that could result in any material sanctions risk to the Relevant Persons.
Summary · 第 5 页
As of the Latest Practicable Date, we had (i) fully ceased our transactions with the Sanctioned Counterparties and (ii) closed our account in the Sanctioned Russian Clearing Bank.
湖南明珠矿用化工科技股份有限公司Hunan Mingzhu Mining Chemical Technology Co., Ltd.
对俄罗斯、朝鲜等受制裁国家的销售及美国制裁风险
During the Track Record Period, we have certain sales transactions involving Russia, Zimbabwe, Myanmar and North Korea.
Business · 第 147 页
Among these sales, a total of RMB2.5 million (approximately USD369,000) in six payments were received by us through an account at the Shanghai Branch of VTB Bank PJSC (“VTB Shanghai”) during the period from December 2024 to June 2025.
Business · 第 148 页
our Legal Advisor as to U.S. Sanctions and Export Control Laws is of the view that the Russian sales and the associated receipt of payment through VTB Shanghai did not appear to implicate material U.S. primary sanctions risks in the absence of U.S. nexus.
31, 2023, 2024 and 2025, respectively, and the revenue generated from our sales to Russia amounted to RMB1.5 million, RMB1.8 million and RMB0.2 million, representing approximately 0.4%, 0.4% and less than 0.1% of our total revenue in the years ended 31 December, 2023, 2024 and 2025.
Business · 第 157 页
As advised by our legal advisors as to International Sanctions, given that (i) our sales to Iran and Russia were dominated in RMB and did not involve any U.S. nexus; (ii) our sales to Iran and Russia did not involve any items that are subject to the EAR; and (iii) the humanitarian nature of the our products and the raw materials for such products, our transactions with the Relevant Regions (i) did not represent a violation of the applicable U.S. primary sanctions; and (ii) we are unlikely to be viewed as engaging in certain Iran-related activities and/or operating in certain sectors of Russia that would result in U.S. secondary sanctions designations risk during the Track Record Period.
Summary · 第 8 页
We undertake that the [REDACTED] from the [REDACTED] or any other funds raised through the Exchange will not be applied to finance or facilitate any sanctioned activity.
浙江凯乐士科技集团股份有限公司Zhejiang Galaxis Technology Group Co., Ltd.02729.HK
俄罗斯业务及实体清单供应商的制裁风险敞口
During the Track Record Period, we had operations in Russia, a country that has been subject to expanding sanctions since February 2022.
Business · 第 186 页
We have ceased all business transactions with customers in Russia since October 2025.
Business · 第 186 页
our Directors are of the view that the risk that our activities during the Track Record Period will cause us to be designated under secondary laws is low, primarily because our activities in Russia are unlikely to be viewed as any of the activities listed in the definition of Russian manufacturing, technology or electronics sectors which are currently subject to sectoral sanctions, as our business activities in Russia were limited to the sale of MSRs, lifts, CSRs for warehousing and logistics purposes and accounted for an insignificant portion of our overall revenues.
In 2023, 2024 and 2025, our revenue generated from the Relevant Regions amounted to approximately RMB11.56 million, RMB12.63 million and RMB19.79 million, respectively, which represented less than 5% of our total revenue during the same period.
Business · 第 180 页
During the Track Record Period, we recognized revenue of approximately RMB0.61 million, RMB0.95 million and RMB0.91 million in 2023, 2024 and 2025, respectively, from sales of dental products to one customer in Syria (the “Syrian Customer”).
Business · 第 180 页
As at the Latest Practicable Date, we have ceased all business with Myanmar.
During the Track Record Period, Jinxun DR Congo sold certain copper cathode to our Singapore subsidiary internally.
Business · 第 231 页
These transactions involving DR Congo did not involve any exports or transactions of any items subject to the Export Administration Regulations nor relate to any sanctioned entities.
Business · 第 231 页
therefore, our business operations involving DR Congo during the Track Record Period did not represent a violation of the International Sanctions, a Primary Sanctioned Activity or a Secondary Sanctionable Activity.
In 2022, 2023 and 2024 and the four months ended April 30, 2025, we sold our products to certain customers located in regions subject to sanctions imposed by the Relevant Jurisdictions, including the Democratic Republic of the Congo, Burundi, Zimbabwe, Guinea, South Sudan and Somalia (together, the “Relevant Regions”), which contributed an aggregate of US$5.8 million, US$3.5 million, US$19.6 million and US$11.0 million, representing approximately 1.8%, 0.8%, 4.3% and 6.8% of our total revenue, respectively.
Business · 第 271 页
Our International Sanctions Legal Advisors have not identified any violation of International Sanctions by us after evaluating the sanctions risks of our business activities in relation to the Relevant Regions during the Track Record Period.
Business · 第 271 页
In light of the foregoing, as advised by our International Sanctions Legal Advisors, our transactions with customers and vendors located in the Relevant Regions during the Track Record Period did not constitute Primary Sanctioned Activities or Secondary Sanctionable Activities for the purpose of Chapter 4.4 of the Guide.
In particular, during the Track Record Period, our revenue generated from Hong Kong amounted to RMB60.0 million, RMB21.6 million, RMB1.9 million, and RMB1.4 million; our revenue generated from Iraq amounted to RMB114,000, nil, RMB37,000, and RMB2.4 million; and our revenue generated from Lebanon amounted to RMB55,000, RMB75,000, nil, and nil, respectively.
Business · 第 268 页
As advised by our International Sanctions Legal Advisors after performing the procedures they consider necessary, these transactions involving Relevant Regions did not involve any sanctioned entities or exports or transactions of any items subject to the EAR, and hence did not represent a Primary Sanctioned Activity or violation of International Sanctions; and, the risk of these transactions being viewed as a Secondary Sanctionable Activity is low because there were no activities targeted by extra-territorial provisions of sanctions law or regulation in the Relevant Jurisdictions.
During the Track Record Period, we sold certain construction machinery and equipment to non-sanctioned customers located in the Relevant Countries.
Business · 第 300 页
With respect to our business activities involving Russia, the Group’s sales to Russia during the Track Record Period were settled in Russian Ruble only, and the revenue from sales to Russia accounted for less than 7.0% of our total revenue in 2022, 2023, 2024 and the four months ended April 30, 2025.
Business · 第 301 页
we do not engage in local manufacturing but simply conduct sales into Russia, which reduces our exposure to sanctioned Russian economy.
The revenue generated from our sales to Russia were represented approximately 13.4%, 25.5%, 17.7% and 10.7% of our total revenue for the period during the Track Record Period, respectively.
Business · 第 299 页
To mitigate sanctions risks, the Group had ceased its sales with Iran and Cuba as of December 31, 2024.
Business · 第 299 页
Based on the aforementioned, as advised by our International Sanctions Legal Advisers, we believe the risk of secondary sanctions risk is fairly low for the Group's operation in general and in relation to our sales to Russia.
The revenue generated from such sales to the Relevant Regions was approximately RMB59.2 million, RMB84.0 million, RMB90.0 million and RMB8.0 million, representing approximately 1.5%, 2.0%, 2.0% and 0.4% of our total revenue in 2022, 2023 and 2024 and the five months ended May 31, 2025, respectively.
Summary · 第 7 页
The revenue generated from our sales to Russia (excluding the Crimea, Kherson, Zaporizhzhia, and LPR/DPR regions) was approximately RMB3.9 million, RMB11.8 million, RMB10.9 million and nil, representing approximately 0.1%, 0.3%, 0.2% and 0.0% of our total revenue in 2022, 2023 and 2024, and the five months ended May 31, 2025, respectively.
Business · 第 251 页
Our International Sanctions Legal Adviser is of the view that our Group is not subject to material sanctions risks, after evaluating the sanctions risks of our historical business activities with customers in the Relevant Regions during the Track Record Period and up to the Latest Practicable Date.
Our revenue generated from sales and/or deliveries to the Relevant Countries amounted to RMB5.0 million, RMB7.4 million and RMB5.9 million, representing 0.5%, 0.6% and 0.4% of our total revenue for each of FY2022, FY2023 and FY2024, respectively.
Business · 第 257 页
As advised by our International Sanctions Legal Advisers, our activities during the Track Record Period did not appear to implicate restrictions under International Sanctions laws and regulations.
Business · 第 257 页
As at the Latest Practicable Date, we have completed the delivery of products to and ceased all our sales transactions with customers located in the Relevant Countries.
新琪安集团股份有限公司Newtrend Group Holding Co., Ltd.02573.HK
涉及受国际制裁地区（包括俄罗斯）销售
Our revenue generated from the sale to the Identified Regions amounted to approximately RMB109.1 million, RMB52.6 million and RMB35.0 million, respectively, representing approximately 14.3%, 11.8% and 6.2% of our total revenue for the three years ended 31 December 2022, 2023 and 2024, respectively.
Business · 第 222 页
As our products sold to Russia and the other Identified Regions are sucralose and food-grade glycine, which are food additives and were being sold for human food and pet food purposes, they fall within the scope of General License No. 6D.
Business · 第 224 页
Based on the facts and our confirmations set out above, our International Sanctions Legal Advisers have further advised that during the Track Record Period and up to the Latest Practicable Date, our business activities in the Identified Regions did not violate applicable sanctions laws of the Relevant Jurisdictions that are material to our Group’s business and do not constitute sanctioned activates that would give rise to material sanctions risks under the Guide for New Listing Applicants.
容大合众(厦门)科技集团股份公司Rongta Technology (Xiamen) Group Co., Ltd.09881.HK
曾向受制裁国家伊朗客户销售产品
During the Track Record Period, we sold printing equipment to a customer located in Iran (the “Iran Customer”), a country subject to comprehensive International Sanctions.
Summary · 第 12 页
We have ceased all of our transactions relating to Iran since January 2024.
Summary · 第 12 页
Our Company confirms and undertakes not to enter into any future business or make any future sales to Iran or any comprehensive sanctioned countries or targets that would implicate restrictions under International Sanctions.
During the Track Record Period, we have sold our babycare products, feminine care products and adult incontinence products to Russia (excluding Crimea, LPR, DPR, Kherson and Zaporizhzhia regions), Hong Kong, Myanmar, Ukraine (excluding Crimea, LPR, DPR, Kherson and Zaporizhzhia regions) (collectively, “Relevant Regions”, please refer to “Definition” for further details), which are subject to various forms of sanctions programs maintained by the Relevant Jurisdiction (includes the U.S., the UK, the EU, the UN and Australia), but none of the programs were general and comprehensive export, import, financial or investment embargo, i.e. none of the Relevant Regions is a Comprehensively Sanctioned Country.
Summary · 第 8 页
Revenue generated from such transactions with customers based in the Relevant Regions amounted to approximately RMB105.9 million, RMB209.6 million, RMB384.9 million, and RMB221.5 million, representing approximately 40.2%, 51.4%, 58.8%, and 42.6% of our total revenue during the Track Record Period, respectively.
Business · 第 188 页
During the Track Record Period, our sales attributable to the Sanctioned Russian Customer were nil, approximately RMB1.9 million, RMB1.8 million and nil representing nil, approximately 0.5%, 0.3% and nil of our total revenue, respectively.