In particular, the concessions for the Changsha Landfill Project, the Pingjiang Landfill Project, and the Changsha Transfer Project were granted through processes that did not strictly follow prescribed tender procedures, as arranged by the tenderee.
Risk Factors · 第 41 页
During the Track Record Period, certain procedural irregularities occurred in the tender stage of the concession grant process for the Changsha Landfill Project, the Pingjiang Landfill Project and the Changsha Transfer Project.
On May 9, 2026, NUDT issued a notice suspending our Company, Mr. Sun in his capacity as our legal representative, and Mr. Long Zhenyu (“Mr. Long”, a former authorized representative of the bid who left the Company in November 2021), concerning suspected bid rigging in a project which we submitted tender in 2021 (the “Bidding Incident”).
Risk Factors · 第 42 页
To the best of our knowledge based on our investigation, the matter arose from the unauthorized personal conduct of a former sales employee, who had, without our knowledge, authorization or approval and in deliberate circumvention of our internal controls, provided our bidding materials to a third party, which had used such materials for non-compliant bidding purposes.
Risk Factors · 第 42 页
Assuming the Suspension had been in effect throughout the Track Record Period, the revenue attributable to projects that would have fallen within its scope would have represented only approximately 0.04%, 0.05%, 0.38% and nil of our total revenue for 2023, 2024, 2025 and the three months ended March 31, 2026, respectively; however, there is no assurance that the actual impact of the Suspension, will be limited to a similar extent, or that our reputation, customer relationships or ability to secure future military procurement contracts will not otherwise be adversely affected.