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 · 第 187 页
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 · 第 187 页
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 engaged a third-party human resources agency to pay social insurance premium and housing provident funds for certain of our employees.
Risk Factors · 第 60 页
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.
彤程新材料集团股份有限公司Red Avenue New Materials Group Co., Ltd.09607.HK
社保及公积金经第三方代理缴纳
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 · 第 39 页
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 · 第 157 页
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
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 · 第 161 页
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 · 第 43 页
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.
Our PRC Legal Advisor have advised that, as the New Judicial Interpretation does not repeal the currently effective PRC social insurance laws and regulations, the related risks and the potential impact on our business and financial performance are relatively limited.
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 · 第 35 页
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 · 第 174 页
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.
深圳四方精创资讯股份有限公司Shenzhen Forms Syntron Information Co., Ltd.06700.HK
社保及住房公积金未足额缴纳
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 · 第 58 页
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 · 第 169 页
(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
深圳四方精创资讯股份有限公司Shenzhen Forms Syntron Information Co., Ltd.06700.HK
通过第三方人力资源机构缴纳社保公积金
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 · 第 58 页
As of the Latest Practicable Date, none of our employees had their contributions made through such agencies.
Business · 第 170 页
(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
深圳四方精创资讯股份有限公司Shenzhen Forms Syntron Information Co., Ltd.06700.HK
劳动争议司法解释(二)不加重本集团责任
as advised by our PRC Legal Advisors, the aforementioned regulation does not expand penalty exposure or repeal existing laws, our Directors believe the aforementioned regulation will not have material adverse impact on our business operations and financial position.
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 · 第 40 页
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 · 第 180 页
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 · 第 39 页
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 · 第 167 页
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.
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 · 第 52 页
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 · 第 176 页
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.
In compliance with PRC regulations, we participate in and contribute to social insurance, including pension, medical, maternity, work-related injury and unemployment insurance, and the housing provident fund.
Business · 第 157 页
We maintain all the mandatory insurance policies required by PRC laws and regulations and consistent with industry practice.
广东微电新能源股份有限公司Guangdong Mic-Power New Energy Co., Ltd.
部分子公司未足额缴纳社保及住房公积金
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 · 第 55 页
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 · 第 55 页
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.
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.
Risk Factors · 第 46 页
Our shortfall of social security insurance and housing provident fund contribution amounted to RMB19.4 million, RMB25.9 million, RMB25.0 million and RMB7.6 million in 2023, 2024, 2025, and the four months ended April 30, 2026, respectively.
Business · 第 185 页
We intend to progressively adjust the applicable contribution bases and use our best efforts to complete the rectification by the end of 2028.
During the Track Record Period and up to the Latest Practicable Date, our Company and certain of our PRC subsidiaries did not make full social insurance and housing provident fund contributions for certain employees based on their actual wages.
Business · 第 204 页
The shortfall in social insurance and housing provident fund contributions amounted to RMB26.7 million, RMB30.1 million, RMB34.6 million, and RMB18.0 million in 2023, 2024, 2025, and the six months ended June 30, 2026, respectively.
Business · 第 204 页
During the Track Record Period, our Company and certain of our PRC subsidiaries did not make full social insurance and housing provident fund contributions for certain employees based on their actual wages.
During the Track Record Period, we had not made full contributions to the foregoing employee benefits for our employees.
Business · 第 141 页
Our PRC Legal Advisor is of the view that, taking into account the current regulatory environment and enforcement practice, provided that (i) there are no material changes in the applicable laws, regulations or local enforcement policies and (ii) we complete the rectification measures and make any required supplementary contributions within the prescribed periods if so ordered, the risk of us being subject to centralized collection of outstanding historical social insurance and housing provident fund contributions, or material penalties arising from such non-compliance during the Track Record Period, is remote.
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 · 第 55 页
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 · 第 193 页
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.
宁波舜宇智行科技股份有限公司Ningbo Sunny Smart Autotech Company Limited
往绩记录期间社保及住房公积金未足额缴纳
During the Track Record Period, we did not make full contribution to social insurance and the housing provident funds as required under PRC laws and regulations.
Risk Factors · 第 45 页
Considering the relevant regulatory policies, regulatory confirmations or interviews and the facts as mentioned above, our PRC Legal Advisor is of the view that on the premise that no significant changes of the current policies and regulations, as well as implementation and supervision requirements of the local governments, (i) the risk of us being required by relevant PRC authorities to pay the material shortfall of social insurance and housing provident fund contributions is remote, and (ii) the risk of us subject to material administrative penalties for failing to make social insurance and housing provident funds in full is remote.
Risk Factors · 第 45 页
during the Track Record Period, we did not entered into any agreements that waived social insurance payment obligations with our employees or otherwise required our employees to make any such waiver