On June 5th, the China Securities Regulatory Commission (CSRC) issued its latest set of supplementary information requests for companies seeking overseas listings. The CSRC's international department has asked ten firms for additional documentation.

Among them, Pula Pharmaceutical has been requested to provide further details regarding the specific fulfillment of regulatory procedures, such as foreign investment and foreign exchange management, involving its overseas subsidiaries. Pula Pharmaceutical submitted its application for a main board listing on the Hong Kong Exchange on February 13th, with CITIC Securities acting as its sole sponsor.

The CSRC has asked Pula Pharmaceutical to clarify the following points and instructed its legal counsel to verify and provide a clear legal opinion:

Key Information Requests

First, the company must supplement the explanation of the specific fulfillment of regulatory procedures, including foreign investment and foreign exchange management, for its overseas subsidiaries, and provide a conclusive opinion on compliance.

Second, an update is required on the progress of obtaining state-owned shareholder identification and the fulfillment of state-owned asset management procedures.

Third, the company must explain the rationale behind the share price for new shareholders who joined within the last 12 months, the reasons for any price discrepancies among them, and provide a clear conclusion on whether any improper benefit transfers occurred.

Fourth, details are needed on the compliance of the company's already implemented equity incentive plans. This includes the specific composition and roles of participants, any relationships between participants and other shareholders, directors, supervisors, or senior management, as well as the fairness of pricing, agreement terms, decision-making processes, and standard operational execution. A clear conclusion on legality, compliance, and the absence of improper benefit transfers is required.

Fifth, the company must clarify whether the shares held by shareholders intending to participate in the proposed "full circulation" plan are subject to any pledges, freezes, or other encumbrances.

Company Background

According to its prospectus, Pula Pharmaceutical is a leading innovative antimicrobial peptide (AMP) therapy company founded in April 2009. It focuses on four core therapeutic areas: anti-infectives, metabolic diseases, oncology, and autoimmune diseases, aiming to address significant unmet global health needs through its proprietary breakthrough technologies and drug candidates.

As of the latest practicable date, the company has nine drug candidates, including one core product (PL-5) and two key products (PL-3301 and PL-18). Data from Frost & Sullivan indicates that the company's core product, PL-5 (Pelecanan), is the first drug in its class to have a New Drug Application (NDA) submitted globally. PL-3301 is a potential first-in-class thermosensitive peptide gel for treating oropharyngeal candidiasis.