Zhitong Finance App News, *ST Doushen (300010.SZ) announced that on November 28, 2023, the company received the “Decision on Administrative Supervision Measures Issuing a Letter of Warning against Doushen Education Technology (Beijing) Co., Ltd.” issued by the Beijing Regulatory Bureau of the China Securities Regulatory Commission.

According to the decision, at the end of 2020, the sale of shares of Jiangnan Xin'an (Beijing) Technology Co., Ltd. (Jiangnan Xin'an) Technology Co., Ltd. (Jiangnan Xin'an) and Gongqingcheng Zhongzhi Investment Management Partnership (limited partnership, Gongqingcheng Zhongzhi for short) signed an equity agreement and related letter of commitment with Ma Li. The agreement on the share transfer was unclear and the content was ambiguous, leading to disputes over subsequent transactions, which then led to arbitration matters, and the company faced major legal risks. The company has failed to take measures to establish an effective internal control and risk management system to prevent the occurrence of the above problems. The internal control system is inadequate, and corporate governance is not standardized.

Furthermore, the company did not promptly disclose the circumstances of Komsomolsk-Qingcheng Zhongzhi and Ma Li filing for arbitration on matters related to the Jiangnan Xin'an equity transfer dispute and other related matters. There is a problem where major events are not disclosed in a timely manner. The company did not disclose the circumstances of the “Letter of Commitment” issued to Zhongzhi and Ma Li of Komsomolsk-City, and the disclosure of information on the Jiangnan Xin'an equity transaction was incomplete. In June 2022, when responding to questions from investors and letters of concern from the Shenzhen Stock Exchange, the company failed to objectively and completely reflect the specific situation of the live delivery business, did not sufficiently alert the business risks, and the disclosure of relevant information was inaccurate and incomplete. After the company disclosed in public documents such as the 2022 annual report that “it plans to jointly launch the 'ByteDance Education Industry Alliance'”, in response to a letter of concern from the Shenzhen Stock Exchange in June 2023, it stated that there is no “ByteDance Education Alliance”. The aforementioned content is the work plan drawn up by the company for 2023. The company did not give sufficient risk alerts on the matters described, did not specify that it was the company's unilateral intention to cooperate, and the disclosure of relevant information was inaccurate.