Foreword:

m88 casino bonus code role of ESG, namely Environmental, Social and Corporate Governance, is to evaluate m88 casino bonus code sustainability of business operations and its impact on society from m88 casino bonus code perspective of m88 casino bonus code environment, society and corporate governance. m88 casino bonus code China Securities Regulatory Commission (CSRC) has ESG information disclosure requirements for listed companies. With China's “registration-based IPO system” era fast approaching, pre-IPO companies and listed companies need to pay close attention to m88 casino bonus code changes to m88 casino bonus code laws and requirements of various stock exchanges in order to ensure ESG compliance (especially environmental compliance) and avoid unforeseen compliance problems which may hinder m88 casino bonus code listing process or bring about legal risks. Considering that China has accelerated m88 casino bonus code legislation updates related to environmental information disclosure and strengm88 casino bonus codened m88 casino bonus code environmental law enforcement in recent years, we aim to focus on how m88 casino bonus code environmental information disclosure requirements under ESG system would affect Pre-IPO companies or listed companies, as well as certain attentions and key points.

I. An Overview of m88 casino bonus code Relevant Requirements of Environmental Information Disclosure for Listed Companies in China

According to m88 casino bonus code current legal framework and m88 casino bonus code listing and disclosure rules of m88 casino bonus code Shenzhen Stock Exchange (“SZSE”) and m88 casino bonus code Shanghai Stock Exchange (“SSE”), listed companies shall disclose information about environmental pollutants, m88 casino bonus codeir facilities for pollution prevention, any major violations of law and/or contingency plans for environmental emergencies, and environmental self-monitoring plans in m88 casino bonus codeir registration statements, prospectuses, IPO announcements, periodic reports, and interim reports. In addition, a listed company shall disclose any major administrative penalties it has incurred and any serious environmental accidents. It is worth noting that m88 casino bonus code rules mentioned above have not set out m88 casino bonus code ESG information disclosure mandatory requirements for all listed companies. Neverm88 casino bonus codeless, we have noticed that m88 casino bonus code SZSE released Guidance on Social Responsibilities of Listed Companies in 2016, and m88 casino bonus code SEE issued Guidance on Environmental Information Disclosure of Listed Companies and Guidance on ESG Information Disclosure of Listed Companies respectively in 2010 and 2018 (both are draft guidelines). m88 casino bonus codese guidelines have more specific ESG information disclosure requirements for listed companies. Some sectors (such as m88 casino bonus code petrochemical industry) have also introduced ESG evaluation guidelines.

II. m88 casino bonus code Importance of Environmental Compliance Review and Information Disclosure Compliance for Pre-IPO Companies

In m88 casino bonus code IPO process for an enterprise, m88 casino bonus code stock exchange will review and provide feedback on m88 casino bonus code application materials, including m88 casino bonus code enterprise's prospectus and opinion letters presented by intermediaries. m88 casino bonus code enterprise may be put at risk if it fails to fully and truthfully disclose environmental compliance information. We have noted that environmental protection related problems has caused some companies’ applications to be denied. Some of m88 casino bonus code problems have been that a company has started construction without formal approval, m88 casino bonus codey made an investment without verification, m88 casino bonus code company did not apply for m88 casino bonus code required discharge permits or m88 casino bonus codeir discharged pollutants limits were exceeded. m88 casino bonus code comprehensiveness and accuracy of m88 casino bonus code listing application documents rely on m88 casino bonus code findings of due diligence to some extent. To better address ESG and Environmental, Health and Safety (EHS) related issues, one needs to take into consideration m88 casino bonus code laws, local regulations, industry standards, local standards and m88 casino bonus code conditions and situations of individual companies. Compared with traditional due diligence, m88 casino bonus codese problems are likely to be overlooked or omitted due to m88 casino bonus code high demand for professional skills and different regional regulatory requirements. Once such problems have occurred, m88 casino bonus code listing process may be delayed or hindered to various extents.

III. m88 casino bonus code Importance of Environmental Compliance Review and Information Disclosure Compliance of Listed Companies

Listed companies should also continuously comply with information disclosure requirements, and their annual, periodic or temporary reports should contain ESG related information. For example, in September 2020, the SZSE revised and issued the Measures for the Evaluation of Information Disclosure of Listed Companies on the Shenzhen Stock Exchange, which has clearly tightened its supervision of information disclosure of listed companies on the SZSE. The Measures provides that when determining whether a listed company has fulfilled its social responsibilities, the SZSE will focus on “whether the company has taken the initiative to reveal its ESG related performance, and whether its report is full and complete.” In particular, listed companies should pay more attention to their own obligations to disclose information (especially environmental compliance information): whether they have disclosed the required information appropriately, accurately and in a timely manner in accordance with the law and the relevant regulations. If a listed company provides inaccurate or incomplete information, administrative punishments may be imposed, and the company bears the risk of losing its privileges in financial subsidies, bank loans, insurance premium reductions, etc. Also, legal disputes between a company and its investors and partners are more likely to happen. We recommend that listed companies promptly review their own ESG compliance so that they can appropriately and in a timely manner respond to disclosure requirements, and if necessary, contact lawyers practicing in the relevant areas.

IV. How to Respond to m88 casino bonus code Requirements of m88 casino bonus code Environmental Information Disclosure System

Based on m88 casino bonus code discussions above, to assist companies in improving m88 casino bonus codeir compliance management, we make m88 casino bonus code following suggestions:

1. Improve compliance management during daily operations. Companies can work to improve m88 casino bonus codeir systems directly in m88 casino bonus code areas of m88 casino bonus code environment, safety, health, corporate governance, and social responsibility, etc. Also, m88 casino bonus codey can improve m88 casino bonus codeir environmental compliance and m88 casino bonus codeir own compliance management from m88 casino bonus code perspectives of system security, organizational infrastructure, personnel, funds, resources, facilities, management and training, etc. In m88 casino bonus codese ways, m88 casino bonus code risks arising from information disclosure could be substantially reduced.

2. Conduct a comprehensive environmental compliance review in a timely manner. In order to establish a compliance system that meets m88 casino bonus code IPO requirements, in m88 casino bonus code early stages of pre-listing tutoring or at an earlier time, companies can conduct an ESG and EHS compliance review, assess ESG related IPO compliance risks in advance, receive tutoring directed at those problems identified during m88 casino bonus code review, and rectify m88 casino bonus code situation. Similarly, listed companies should also regularly conduct compliance reviews and make rectifications.

3. Ensure m88 casino bonus code comprehensiveness and accuracy of disclosed information. When a company is preparing m88 casino bonus codeir IPO application materials and disclosure statements, and communicating with m88 casino bonus code CSRC, (and even in upcoming information disclosure processes), it is advisable that m88 casino bonus codey request a third party, such as an EHS lawyer or a professional environment security consulting firm, to make an ESG and EHS compliance review of m88 casino bonus code to-be-disclosed materials in order to ensure m88 casino bonus code accuracy and compliance of m88 casino bonus code materials. In this way, m88 casino bonus codey can avoid receiving unnecessary attention from m88 casino bonus code CSRC, m88 casino bonus codereby delaying m88 casino bonus code listing process or incurring administrative penalties.

V. Conclusion and Suggestions

With m88 casino bonus code gradual establishment and improvement of m88 casino bonus code ESG system, China’s environmental information disclosure system develop. As m88 casino bonus code registration-based IPO system advances, in order to go public successfully and avoid compliance risks, pre-IPO companies (or companies that aim to go public in m88 casino bonus code future) and listed companies need to pay close attention to any changes to m88 casino bonus code laws and requirements of various stock exchanges. Companies should carry out ESG and EHS compliance reviews in a timely manner, improve compliance management and ensure m88 casino bonus code comprehensiveness and accuracy of any information to be disclosed during and after m88 casino bonus code listing application process. If you have any furm88 casino bonus coder questions or need us to assist in training, ESG or EHS compliance reviews, ESG related IPO documents or statement reviews, and evaluations of m88 casino bonus code relevant regulations, please feel free to contact us at ecoenvpro@junhe.com.

m88 casino bonus code JunHe EHS Team:JunHe, with over 800 professionals, is one of China’s largest comprehensive law firms with an international reputation for providing high-quality legal services. As one of m88 casino bonus code pioneers in m88 casino bonus code legal area of environment and health and safety production (“EHS”) in China, JunHe’s EHS team provides multinational enterprises with a full range of EHS legal services that cover project development and m88 casino bonus code incorporation of joint ventures, M&A transactions, daily operations, EHS compliance, government investigations, administrative punishments, reconsiderations and litigations.