On December 26, the China Securities Regulatory Commission (CSRC) issued the "Requirements for Supplementary Materials for Overseas Listing Filing (December 22, 2025 - December 26, 2025)." The CSRC's International Department publicly disclosed supplementary material requirements for 19 companies, including a request for LuPeng Pharmaceutical to provide additional explanations regarding the compliance of its established offshore structure and round-trip acquisitions. According to a filing disclosed by the Hong Kong Exchange on October 31, LuPeng Pharmaceutical Limited submitted a listing application to the Main Board of the HKEX, with CITIC Securities acting as the sole sponsor.

The CSRC requested LuPeng Pharmaceutical to supplement the following matters and instructed its lawyers to verify and provide clear legal opinions: Firstly, regarding the compliance of the established offshore structure and round-trip M&A, please explain: (1) the specific fulfillment of regulatory procedures involving foreign exchange management, overseas investment, foreign investment, and tax management related to the company and its domestic shareholders establishing the offshore structure and conducting round-trip investment, and provide a concluding opinion on whether it complies with the effective regulations at the time; (2) the transaction consideration, pricing basis, payment methods, payment terms, and pricing fairness for the company's acquisition of domestic operating entities, as well as the fulfillment of tax declaration obligations by the relevant transferors in the aforementioned equity transfer process, and whether it complies with the "Regulations on the Acquisition of Domestic Enterprises by Foreign Investors."

Secondly, regarding shareholder circumstances: (1) Please explain the complete ownership chain of the company's controlling shareholders, and whether any domestic entities identified after tracing upwards shareholders holding 5% or more are subject to legal prohibitions on shareholding; (2) Please explain the rationale behind the share price for shareholders added within the last 12 months, the reasons for any disparities between these prices, and provide a clear concluding opinion on whether any利益输送 (interest conveyance) exists.

Thirdly, please conduct a verification of the company's pre-IPO equity incentive plan, formulated before the filing and intended for implementation post-listing, in accordance with the requirements of the "Applicable Regulatory Guidelines for Overseas Listings No. 2." Fourthly, please explain the rights and obligations arrangements for all parties involved in the trust related to the company's actual controller based on the specific trust deed条款, and provide detailed information on all trust beneficiaries, including but not limited to beneficiary names, beneficial shares, and their relationship with the trust settlor.

Fifthly, regarding domestic operating entities: (1) Please explain the status of paid-in capital for the company's domestic operating entities, the pricing basis for all previous capital increases and equity transfers, whether capital contributions were fully paid, and whether there were instances of failure to fulfill contribution obligations, illicit withdrawal of capital, or flawed contribution methods, and provide a clear concluding opinion on the legality and compliance of the establishment and all historical equity changes; (2) Please explain the progress in补办 (retroactively completing) the fire control备案 (filing) procedures for the domestic operating entity Guangzhou LuPeng, whether it constitutes a major violation, and whether it significantly impacts the current listing; (3) Please explain the specifics of the business scope of the domestic operating entity, which includes "medical research and experimental development; organization of cultural and artistic exchange activities; engineering and technological research and experimental development; information consulting services; natural science research and experimental development; internet drug information services," whether related businesses are actually conducted and their operational details, whether necessary qualifications and permits have been obtained, and whether the business scope and actual operations involve "human stem cells, genetic diagnosis and treatment technology development and application" or other restricted or prohibited areas for foreign investment and the basis for this judgment, and whether it will continuously comply with foreign investment access policy requirements before and after the listing.

Sixthly, regarding the current listing: (1) Please explain the specific plan for the company's share subdivision and whether it affects the number of shares issued in this offering; (2) Please explain the estimated fundraising amounts before and after the exercise of the over-allotment option, the specific calculation methodology, the detailed use of proceeds, the proportion of use domestically versus overseas, and the status of obtaining necessary domestic and overseas investment approvals, ratifications, or filings.

The prospectus reveals that LuPeng Pharmaceutical is a globally leading biopharmaceutical company with its self-developed BeyondX oral drug chemistry platform. It focuses on designing, discovering, clinically developing, and commercializing orally bioavailable drugs that transcend the molecular chemical space defined by the traditional "Rule of Five" guidelines for drug discovery, aiming to address unmet medical needs for global patients with cancer and autoimmune diseases.

LP-168, the company's core product, is a BTK inhibitor currently in the NDA stage. As the world's first and only "covalent and non-covalent" dual BTK inhibitor, LP-168 possesses best-in-class potential in both oncology and autoimmune disease areas. This dual binding mechanism enables LP-168 to simultaneously clear tumor cells carrying both wild-type and drug-resistant mutant BTK, overcoming the resistance limitations associated with traditional first, second, and third-generation BTK inhibitors due to their single mode of action (either solely covalent or solely non-covalent). LP-168 has demonstrated significant clinical benefits across multiple oncology and autoimmune disease indications and exhibits an excellent safety profile, with a lower incidence of treatment-related adverse events compared to prior BTK inhibitors.