The Zhitong Finance App learned that on June 21, the China Securities Regulatory Commission issued a notice requesting supplementary materials for overseas issuance and filing (June 14, 2024 to June 20, 2024), which mentioned requesting additional explanations on matters such as equity changes, equity incentives, and share brokerage. According to reports, Boreton recently submitted a listing application to the Hong Kong Stock Exchange, with CICC and CMB International as co-sponsors.

Specifically, the China Securities Regulatory Commission requested additional explanations on the following matters, and requested lawyers to conduct inspections and issue clear legal opinions:

1. Regarding changes in equity, please provide additional explanations: (1) The reason why your company added shareholders in the past year, the share price and pricing basis, whether the transfer of benefits is involved; (2) Shanghai Fangao Business Consulting Partnership (limited partnership) subscribed to your company's registered capital; (3) Shanghai Yijin Investment Co., Ltd. transferred your company's shares several times from 2020 to 2021, and the price difference is obvious. Please explain the reason for the transfer and the reasonable transfer price; (4) In March 2021 and August 2021, Tianjin Chuangmeida Technology Development Co., Ltd. and Shanghai Yunjin Tribe The reason for the mutual transfer of shares in venture capital centers (limited partnerships).

2. Regarding equity incentives, please provide additional information on the handling of incentive shares by equity incentive recipients in your company who have left their jobs, and whether there are any disputes or potential disputes.

3. Regarding share escrow, please further explain whether your company has any disputes or potential disputes during the cancellation of share brokerage (including resolving share brokerage issues by means of share transfers); ask a lawyer to express a concluding opinion on whether your company currently has a share brokerage situation.

4. Regarding full circulation, please further explain whether the relevant shares held by shareholders who intend to participate in the “full circulation” have been pledged or otherwise disputed.

According to the prospectus, Boleyton is a clean energy solutions provider in China, focusing on the design, development and commercialization of construction machinery powered by new energy sources. According to Insight Consulting data, based on 2023 shipments, Brereton ranked third and fourth among all new energy loader and new energy wide-body dump truck manufacturers in China, accounting for 11.2% and 8.3% of the market share, respectively. From 2021 to 2023, the company's shipments of new energy loaders and new energy wide-body dump trucks increased from 144 units to 507 units and 11 units to 96 units, respectively, with compound annual growth rates of 87.6% and 195.4%, respectively.