The Zhitong Finance App learned that on January 26, the China Securities Regulatory Commission announced supplementary material requirements for overseas issuance and listing (January 19, 2024 to January 25, 2024). Among them, the announcement mentioned requesting Baishanyun to further explain the concluding opinions on legal compliance with foreign exchange registration, overseas investment, foreign investment, tax payment, etc. involved in overseas construction of offshore structures and return investments. According to the Hong Kong Stock Exchange's disclosure on December 29, 2023, Baishanyun submitted a listing application to the main board of the Hong Kong Stock Exchange, with CICC and Haitong International as co-sponsors.

The Securities Regulatory Commission announced that Baishanyun was requested to provide additional explanations on the following matters, and that lawyers were requested to conduct inspections and issue clear legal opinions:

1. Please supplement the issuer's concluding observations on legal compliance with regulatory procedures such as foreign exchange registration, overseas investment, foreign investment, and tax payment involving overseas offshore structures and return investments.

2. Please indicate whether the additional shareholders had abnormal share consideration within 12 months before the issuer submitted the application.

3. Please indicate whether issuers and domestic operating entities are enterprises in important infrastructure, important information technology and Internet products and services, key technology, and other important fields relating to national security as stipulated in Article 4 (2) of the “Foreign Investment Security Review Measures”.

4. Please explain: (1) Whether issuers and domestic operating entities have established effective data security management systems and data security protection measures in accordance with laws, regulations and policy requirements such as the “Data Security Law of the People's Republic of China”, “Data Outbound Security Assessment Measures”, and “Data Security Management Measures in the Industrial and Information Technology Field (Trial)”; (2) Whether data exit security assessments are carried out in accordance with the law and regulations before providing relevant data to overseas controllers; (3) Specific measures to strengthen security protection throughout the entire life cycle of data collection, transmission, storage, provision, and commissioned processing; (3) Specific measures to strengthen security protection throughout the entire life cycle of data collection, transmission, storage, provision, and commissioned processing; (3) Specific measures to strengthen security protection throughout the entire life cycle of data collection, transmission, storage, provision, and commissioned processing; ( 4) The scale of collected and stored user information, data collection and usage, personal information protection and data security arrangements or measures before and after listing.

According to the prospectus, according to the Insight Consulting Report, Baishan Cloud is the second-largest independent edge cloud service provider in China based on total revenue in 2022, and has strong global expansion capabilities. According to the same source, based on 2022 overseas revenue, the company is also the fastest growing independent edge cloud service provider in China with mature overseas business.

The company provides enterprises and their end users with high-speed, secure, and economical digital experiences at the edge of the Internet closer to users. With an integrated edge cloud platform for networking, security, and computing power, the company helps enterprises ensure network availability, bypass congested paths, optimize content delivery, improve computing efficiency, and prevent cyber attacks. As of June 30, 2023, the company has deployed more than 1,700 global edge nodes in more than 300 cities in more than 50 countries and regions, with a network bandwidth of more than 80 Tbps.