Pre-Initial Public Offering (“Pre-IPO”)

In order to list on the Stock Exchange of Hong Kong (SEHK) Practice Note 21 (PN21), the Sponsor must conduct due diligence on the Listing Applicant. This is to ensure that the Applicant has established adequate procedures, systems, and controls (including accounting and management systems) to comply with the Listing Rules and other relevant legal and regulatory requirements. The Sponsor must also ensure that these procedures, systems, and controls are sufficient for the Listing Applicant's directors to properly assess the financial position and prospects of the Applicant and its subsidiaries before and after listing. This includes an assessment of the Applicant's compliance manuals, policies, and procedures, including corporate governance policies and any letters of representation.