Oleitech Group Co., Ltd. (hereinafter referred to as "Oleitech") responded to the Shenzhen Stock Exchange's first-round inquiry on September 7. Regarding its equity structure, at the company's inception, 406,500 shares held by a foreign shareholder were entrusted to Fan Jiang through Aofeixiang, and the restoration of this arrangement took nearly four years. As of the first-round inquiry response, the company has yet to obtain a certificate of no violation from the foreign exchange authority, relying solely on the "expiration of the administrative penalty statute of limitations" as a compliance defense. Moreover, supplementary agreements signed between Series A to C investors and the actual controller contain automatic reinstatement clauses, meaning that if the IPO application is withdrawn or rejected, the repurchase obligations would immediately resume legal effect. In terms of governance, Fan Jiang commands 91.93% of voting rights through direct shareholding and 14 shareholding platforms, concurrently serving as both chairman and general manager. The supervisory board has been abolished, and his spouse, Xiao Meiqin, who served as director of the marketing center for an extended period, only resigned from her directorship two months before the filing. Notably, financial officer Wang Zhijian, a former signing accountant for Kangdexin's annual reports, shares a prior working relationship with the signing accountant for Oleitech's current IPO, while independent director He Lu also previously worked alongside the signing accountant on the Anker Innovations project.

On the operational front, revenue from Amazon's channel climbed from 41.72% to 54.17%, while the brand's official website share contracted to 30.23%, rendering the "dual-engine" growth model no longer accurate. In 2025, net profit reached a record RMB 84.232 million, yet net operating cash flow plunged 30% to RMB 79.1898 million. Inventory swelled to RMB 267 million, accounting for over 40% of current assets. In related-party transactions, Changyuanfeng, a company controlled by an employee's relative, engaged in two-way purchases and sales with Oleitech, and its total optical component procurement was inexplicably lower than the amount sourced from a single supplier, presenting an anomalous reconciliation. For the planned fundraising projects, the land for the production base has not yet been listed for auction, yet the company plans to allocate RMB 150 million of raised funds to replenish working capital, despite having distributed cumulative dividends exceeding RMB 44.87 million during the reporting period.

Four-Year Entrustment Without Forex Compliance Approval: Put Options Could "Resurrect" at Any Time

At Oleitech's founding, 406,500 shares held by a foreign shareholder were entrusted to Fan Jiang via Aofeixiang, with the company citing "the cumbersome procedures for establishing foreign-invested enterprises and the prolonged timeline for overseas capital contribution" as justification. However, the restoration of this entrustment was only completed between 2021 and 2023, spanning nearly four years. It is noteworthy that the issuer solely relies on the "expiration of the administrative penalty statute of limitations" as its compliance defense, and as of the first-round inquiry response, the certificate of no violation from the foreign exchange authority remains unattained. According to the prospectus, supplementary agreements signed between Series A to C investors and the company and its actual controller include automatic reinstatement clauses; should the IPO filing be withdrawn or rejected, the repurchase obligations would immediately regain legal binding force. Additionally, Fan Jiang controls 91.93% of the company's voting rights through direct shareholding and by serving as the executive partner of 14 shareholding platforms, while also holding the positions of chairman and general manager. The company has abolished its supervisory board, relying solely on independent directors and the audit committee to exercise oversight functions. Notably, Fan Jiang's spouse, Xiao Meiqin, holds only an indirect 1.56% stake through Xinxiang'ao but has long served as director of the marketing center, effectively overseeing overseas market expansion, and only resigned her directorship two months before the IPO filing. The company's financial officer and board secretary, Wang Zhijian, was formerly a signing accountant for Kangdexin's annual reports. Kangdexin is a landmark case of financial fraud in the A-share market, involving the inflation of profits by over RMB 10 billion. An auditor who once signed off on the annual reports of a fraudulent listed company now serves as the financial helm of a prospective IPO firm. More critically, Wang Zhijian and the signing accountant for Oleitech's current IPO "were formerly colleagues," while current independent director He Lu was the team leader during the company's initial tutoring phase and previously shared intermediary responsibilities with the IPO signing accountant on the Anker Innovations project.

From 2023 to 2025, Oleitech recognized cumulative share-based payment expenses of approximately RMB 92.14 million. In 2024, out of RMB 42.2533 million, RMB 12.3666 million was a one-time expense arising from the actual controller's repurchase of employee shares without re-granting, accounting for 11.14% of profit before tax excluding share-based payments. In its inquiry response, the company projected share-based payment expenses of RMB 28.0614 million, RMB 24.1622 million, and RMB 18.3927 million for 2026 through 2028, totaling over RMB 70 million. This implies that, even with continued revenue growth, reported net profit will remain persistently suppressed by equity incentive amortization.

Production Base Land Not Yet Bid: Two-Way Transactions with Employee's Relative's Company

Regarding distribution channels, the prospectus repeatedly emphasizes a "Amazon + brand website" dual-engine model, yet Amazon's revenue share rose from 41.72% in 2023 to 54.17% in 2025, while the brand website's share shrank from 45.39% to 30.23% over the same period. In 2025, B2B customer sales through the brand website accounted for only 7.03% of online sales revenue. From 2023 to 2025, the company's revenue was RMB 1.192 billion, RMB 1.35 billion, and RMB 1.665 billion, respectively, with net profit attributable to the parent company at RMB 57.1462 million, RMB 54.3237 million, and RMB 84.2320 million. In 2025, Oleitech's net profit attributable to the parent hit RMB 84.232 million, a three-year high, but net operating cash flow plummeted 30% from RMB 113 million in 2024 to RMB 79.1898 million, showing a divergence between net profit and operating cash flow. The book value of inventory rose from RMB 206 million to RMB 267 million, accounting for 41.93% of current assets.

In related-party transactions, Dongguan Changyuanfeng Precision Hardware Products Co., Ltd. is 59%-owned by Lin Gen, the brother-in-law of Oleitech employee Zhang Chaoyi, who also serves as its general manager. During the reporting period, Oleitech's procurement from Changyuanfeng amounted to RMB 31.5571 million, RMB 30.4675 million, and RMB 30.0687 million, respectively. Simultaneously, the company sold products to Changyuanfeng, with sales of RMB 1.608 million in 2024 and RMB 2.0775 million in 2025, indicating bidirectional purchases and sales. Notably, data shows that in 2025, Oleitech's procurement of optical components from supplier Y reached RMB 67.7324 million, while the total procurement of optical components for the same period was only RMB 66.2375 million; the former significantly exceeds the latter, presenting an anomalous discrepancy.

Among the fundraising projects, the mobile lighting production base construction project, which requires the largest investment, has only seen a strategic cooperation framework agreement signed with the management committee of the Cuiheng New Area in Zhongshan. The land bidding, auction, and listing procedures have not yet commenced, and the state-owned land use rights have not been obtained. Despite the lack of a solid foundation for implementing the core fundraising project, the company plans to allocate RMB 150 million of raised funds to replenish working capital. Meanwhile, between 2023 and 2025, the company had already accumulated dividend distributions totaling RMB 44.8789 million.