一、请说明子公司持有的互联网地图服务相关资质的具体用途，以及是否涉及外商投资限制或禁止类业务。Botai Auto Network plans to be listed on the Hong Kong stock market. The China Securities Regulatory Commission requested additional clarification on the specific uses of the Internet map service related qualifications held by the subsidiary.
The Zhitong Finance App learned that on August 9, the China Securities Regulatory Commission announced the “Requirements for Supplementary Materials for Overseas Issuance and Listing (August 2, 2024 to August 8, 2024)”, and the International Department of the Securities Regulatory Commission issued supplementary material requirements for 3 companies. Among them, Botai Auto Network is required to further explain the specific uses of the qualifications related to the Internet map service held by the subsidiary, and whether it involves businesses restricted or prohibited by foreign investment; whether the business operations involve the collection and use of personal information, etc. According to reports, on June 28, Botai Auto Network Technology (Shanghai) Co., Ltd. (“Botai Auto Network” for short) submitted a listing application to the main board of the Hong Kong Stock Exchange. CICC, Cathay Junan International, CITIC Securities were co-sponsors.
The International Department of the Securities Regulatory Commission requested Botai Auto Network to provide additional explanations on the following matters, and requested lawyers to check and issue clear legal opinions:
1. Please explain the specific uses of the qualifications related to Internet map services held by the subsidiary, and whether it involves businesses restricted or prohibited by foreign investment.
2. Please explain: (1) whether the business operation involves the collection and use of personal information; if so, please indicate the scale of collected and stored user information and data collection and use; (2) whether the business operation complies with the provisions of the “Data Security Law”, “Personal Information Protection Law”, “Interim Provisions on the Administration of Vehicle Radar Radio”, etc., and explain the arrangements or measures for fulfilling data security responsibilities and obligations before and after listing.
3. Please explain the progress of implementation of the relevant state-owned shareholders' state-owned assets management procedures.
4. Please explain whether the shares held by shareholders who intend to participate in the “full circulation” have been pledged, frozen, or in other disputed circumstances.
