Six leaked calls! Wanxiang Qianchao insider trading case: the secretary and CFO leaked insider information, and three people were fined 20.56 million

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Source: International Investment Bank Research Report

Original title: A high school classmate of the company secretary, a friend of the general manager, and a retired worker were fined 20.56 million! The Hunan Securities Regulatory Bureau disclosed three penalty orders revealing that Wanxiang Qianchao’s company secretary Wen Chao and CFO Li Pingyi leaked insider trading information!

A high school classmate of the company secretary, a friend of the general manager, and a retired worker were fined 20.56 million! The Hunan Securities Regulatory Bureau disclosed three penalty orders revealing that Wanxiang Qianchao’s company secretary Wen Chao and CFO Li Pingyi leaked insider trading information!

1. The China Securities Regulatory Commission Hunan Bureau’s website shows that the Hunan Bureau issued a penalty decision dated March 13, disclosing the Wanxiang Qianchao insider trading case.

2. The three penalty decisions point to Lu Shijun, Fu Guowei, and Jin Guanmuch. The penalty decisions reveal that Lu Shijun is an acquaintance of Wanxiang Qianchao’s general manager Li Pingyi, and the two had six communications during the sensitive period of insider information. Fu Guowei works for a subsidiary of Wanxiang Qianchao and is a high school classmate of company secretary Wen Chao, having known each other for many years. From April 3 to April 9, 2024, Fu Guowei had six call records with Wen Chao. Before his retirement, Jin Guanmuch was an employee of Wanxiang Qianchao. On April 15, 2024, at 07:49, he had a phone call with general manager Li Pingyi lasting 1 minute and 29 seconds. This brief call became a crucial point for Jin Guanmuch’s insider trading.

3. The trading results are quite interesting. Lu Shijun sold all his stocks, ultimately profiting 4,493,192.69 yuan; however, Lu Shijun had his friend Gao Mouhui purchase Wanxiang Qianchao stocks, which ultimately resulted in a loss of 17,330.29 yuan. Fu Guowei sold all his stocks, profiting 87,413.57 yuan. In contrast to Lu Shijun and Fu Guowei’s profits, Jin Guanmuch incurred a loss of 454,722.89 yuan when he sold all his stocks after the announcement.

4. The three were fined 20.56 million.

Analysis of Lu Shijun’s penalty:

• For insider trading behavior: A “one penalty for three” standard was adopted, confiscating illegal gains of 4.4932 million yuan and imposing a fine of 13.4796 million yuan.

• For advising others to buy and sell stocks: A separate fine of 500,000 yuan was imposed.

• Basis for penalty: Lu Shijun’s illegal behavior is the most serious, as he not only engaged in insider trading himself but also advised others to trade, posing the greatest social harm.

Analysis of Fu Guowei’s penalty:

• Confiscation of illegal gains of 87,413.57 yuan.

• A fine of 500,000 yuan (the statutory minimum standard).

• Considerations for punishment: Although the illegal gains were relatively small, considering his use of his spouse’s account to evade supervision and that he, as a company employee, broke the law, a heavier penalty was still imposed.

Analysis of Jin Guanmuch’s penalty:

• Due to trading losses and no illegal gains, a direct fine of 1.5 million yuan was imposed.

• Basis for penalty: Although the trading result was a loss, the illegality of insider trading lies in the act itself rather than the outcome, and the transaction amount was substantial (11.3768 million yuan), causing severe social impact.

5. Referring to the public information of Wanxiang Qianchao executives, Li Mouyi refers to the current CFO Li Pingyi, and Wen Mou refers to the current company secretary Wen Chao. With the three penalty orders handed down, friends and classmates suffered major losses. However, it seems that currently, they are all fine.

Details of insider trading

Lu Shijun: Large-scale trading by a general manager’s acquaintance

Lu Shijun is acquainted with Wanxiang Qianchao’s general manager Li Pingyi, and the two had six communications during the sensitive period of insider information. Based on the insider information obtained, Lu Shijun implemented a carefully planned insider trading operation.

Lu Shijun controlled four securities accounts for trading, including “Zhang Moujiao” Caifeng Securities account, “Lu Mouquan” Guoxin Securities account, “Lu Shijun” Caifeng Securities account, and “Lu Shijun” Maigao Securities account.

During the sensitive period from March 10 to April 17, 2024, he unidirectionally bought 2,847,200 shares of Wanxiang Qianchao, with a total purchase amount of 14,804,259 yuan.

More seriously, after being aware of the insider information, Lu Shijun also advised Gao Mouhui to buy shares of Wanxiang Qianchao. Gao Mouhui bought 173,000 shares on April 12, 2024, at a purchase amount of 891,820 yuan, but sold them after the announcement at a loss of 17,330.29 yuan.

After the company’s announcement was released on April 17, 2024, Lu Shijun sold all his stocks and ultimately profited 4,493,192.69 yuan, becoming the most profitable trader among the three.

Fu Guowei: Precise operation by a high school classmate

Fu Guowei works for a subsidiary of Wanxiang Qianchao and is a high school classmate of company secretary Wen Chao, having known each other for many years.

During the period from April 3 to April 9, 2024, Fu Guowei had six call records with Wen Chao, establishing a channel for information transmission. Fu Guowei utilized his spouse “Sun Moujia”’s Ping An Securities account for trading. From April 12 to April 16, 2024, he unidirectionally bought 284,900 shares of Wanxiang Qianchao, with a total purchase amount of 1,480,882.40 yuan. His trading time closely matched the communication time, showing obvious anomalies.

After the announcement was released, Fu Guowei sold all his stocks, profiting 87,413.57 yuan. Although the profit amount was relatively small, this behavior of using a spouse’s account to evade supervision is equally egregious.

Jin Guanmuch: Contrarian losses for a retired employee

Jin Guanmuch was an employee of Wanxiang Qianchao before retirement. On April 15, 2024, at 07:49, he had a phone call with Wanxiang Qianchao’s general manager Li Pingyi, lasting 1 minute and 29 seconds. This brief call became a crucial point for Jin Guanmuch’s insider trading.

Jin Guanmuch controlled “Zhong Moumei” Guotai Huitong Securities account and “Jin Guanmuch” Guotai Huitong Securities account for trading. During the sensitive period, he unidirectionally bought 2,152,800 shares of Wanxiang Qianchao, with a total purchase amount of 11,376,769 yuan. His trading scale was second only to Lu Shijun, showing a high level of trust in the insider information.

However, unlike Lu Shijun and Fu Guowei’s profits, Jin Guanmuch incurred a loss of 454,722.89 yuan when he sold all his stocks after the announcement. Although the trading result was a loss, this does not affect the characterization of his insider trading behavior.

Comparison of executives

Insider trading relationships and processes

Administrative penalty decision of the Hunan Securities Regulatory Bureau of the China Securities Regulatory Commission [2026] No. 3 (Lu Shijun)

Party: Lu Shijun, male, residence: Xiaoshan District, Hangzhou City, Zhejiang Province.

Based on the relevant provisions of the Securities Law of the People’s Republic of China (hereinafter referred to as the “Securities Law”), our bureau conducted an investigation into Lu Shijun’s insider trading of Wanxiang Qianchao Co., Ltd. (hereinafter referred to as “Wanxiang Qianchao” or “the Company”) stock and legally informed the party of the facts, reasons, basis for the administrative punishment, and rights entitled to the party. At the request of Lu Shijun, a hearing was held to hear the statements and defenses of Lu Shijun and his agent. This case has now been investigated and concluded.

It has been found that Lu Shijun has the following illegal facts:

1. Insider information situation

On April 17, 2024, the company disclosed the “Announcement on the Suspension of Trading for the Planning of Issuing Shares to Purchase Assets,” stating that the company intends to acquire 100% equity of Wanxiang America Corp. controlled by its controlling shareholder Wanxiang Group through the issuance of shares and payment of cash, and to raise supporting funds. This transaction is expected to constitute a major asset restructuring.

The above major asset restructuring matter complies with the provisions of Article 22, Paragraph 2, Item 7 of the China Securities Regulatory Commission’s “Administrative Measures for Information Disclosure by Listed Companies” (CSRC Order No. 182), and is a major event as defined in Article 80, Paragraph 2, Item 12 of the Securities Law, and is insider information as defined in Article 52, Paragraph 2 of the Securities Law prior to public disclosure.

The insider information was formed no later than March 10, 2024, and was made public on April 17, 2024. Wanxiang Qianchao’s general manager Li Mouyi and company secretary Wen Mou participated in this major asset restructuring project and are insiders as defined in Article 51, Item 4 of the Securities Law, both of whom were aware no later than March 10, 2024.

2. Lu Shijun’s insider trading of Wanxiang Qianchao stock

(1) Contact with insiders

Lu Shijun is acquainted with Wanxiang Qianchao’s general manager Li Mouyi, and the two had six communications during the sensitive period of insider information.

(2) Lu Shijun’s trading of Wanxiang Qianchao stock

During the sensitive period, Lu Shijun controlled “Zhang Moujiao” Caifeng Securities account, “Lu Mouquan” Guoxin Securities account, “Lu Shijun” Caifeng Securities account, and “Lu Shijun” Maigao Securities account (hereinafter referred to as the account group), unidirectionally buying 2,847,200 shares of Wanxiang Qianchao stock, with a total purchase amount of 14,804,259 yuan, all sold after the announcement, profiting a total of 4,493,192.69 yuan. The trading activities of the account group controlled by Lu Shijun are significantly abnormal and highly consistent with the insider information, and the party has no reasonable explanation.

3. Lu Shijun advising others to trade Wanxiang Qianchao stock

After being aware of the insider information, Lu Shijun advised Gao Mouhui to buy Wanxiang Qianchao stock. Gao Mouhui controlled her own Wanguo Securities account, unidirectionally buying 173,000 shares of Wanxiang Qianchao stock on April 12, 2024, with a total purchase amount of 891,820 yuan, all sold after the announcement, incurring a loss of 17,330.29 yuan. Lu Shijun constitutes advising others to trade stocks.

Lu Shijun actively cooperated with our bureau during the investigation, voluntarily providing mobile phones and other devices, as well as relevant documents.

The above facts are supported by relevant personnel inquiry records, bank statements, securities account data, and trading flow information, which are sufficient to establish the case.

Our bureau believes that Lu Shijun’s above behavior violates the provisions of Article 50 and Article 53, Paragraph 1 of the Securities Law, constituting the illegal behavior described in Article 191, Paragraph 1 of the Securities Law.

Lu Shijun and his agent raised the following defenses during the hearing:

Firstly, the acquisition of 100% equity of Wanxiang America Corp. by Wanxiang Qianchao through the issuance of shares and payment of cash is not a major asset restructuring matter and does not constitute a major event, as it did not have a significant impact on the securities market price, therefore cannot be considered insider information. This transaction is also not one of the other matters as defined in Item 19 of Paragraph 2 of Article 22 of the “Administrative Measures for Information Disclosure by Listed Companies,” and the determination of a major event based on this provision is erroneous. Secondly, Lu Shijun’s purchase of Wanxiang Qianchao stock was due to factors such as the company’s equity incentive events, stock trading software recommendations, and has justifiable reasons. Moreover, the equity incentive of Wanxiang Qianchao has a greater impact on its market price than the asset restructuring. Thirdly, the method for calculating illegal gains was not specified, and the calculation of illegal gains was erroneous. Fourthly, the “Memorandum on the Restructuring Transaction Process of Wanxiang Qianchao” was not signed by all participants at each specific stage according to the prescribed procedures, and this memorandum cannot be used as a basis for judgment, nor can it reflect the true process of major asset restructuring. Fifthly, the determination of the sensitive period is incorrect; since the major event of the equity incentive has been publicly disclosed, there is no sensitive period for insider information. Sixthly, the conversation between Lu Shijun and Gao Mouhui about Wanxiang Qianchao stocks after the announcement of the equity incentive does not constitute advising others to buy stocks. Gao Mouhui also had phone communications with Li Mouyi during the sensitive period. Seventhly, Lu Shijun did not obtain insider information, and the trading of Wanxiang Qianchao stock does not correspond with insider information, and there is no abnormal trading situation. Eighthly, Lu Shijun has mitigating circumstances and requests not to be punished or to be given a lighter penalty.

Upon re-examination, our bureau believes:

Firstly, Wanxiang Qianchao’s intention to acquire 100% equity of Wanxiang America Corp. through the issuance of shares and payment of cash meets the major asset restructuring standards as stipulated in Item 2 of Paragraph 1 of Article 12 of the China Securities Regulatory Commission’s “Administrative Measures for Major Asset Restructuring of Listed Companies” (CSRC Order No. 214) and complies with the regulations of Item 7 of Paragraph 2 of Article 22 of the “Administrative Measures for Information Disclosure by Listed Companies,” constituting a major event as defined in Item 12 of Paragraph 2 of Article 80 of the Securities Law, and was insider information before public disclosure as defined in Item 2 of Article 52 of the Securities Law. Our bureau did not determine the case as a major event based on Item 19 of Paragraph 2 of Article 22 of the “Administrative Measures for Information Disclosure by Listed Companies.”

Secondly, the reasons such as equity incentives and software recommendations are insufficient to explain the abnormality of Lu Shijun’s trading, and the progress of the equity incentive does not correspond with his trading activities.

Thirdly, the method for calculating illegal gains has been clearly shown in evidence, and both the party and the agent have reviewed and copied this evidence; the calculation of illegal gains is correct.

Fourthly, the determination of the sensitive period and timeline is accurate. Our bureau comprehensively assessed the timeline of the major asset restructuring based on the communication records, meeting minutes, internal documents, and other evidence from insiders. The insider information involved in this case concerns major asset restructuring rather than equity incentives, and the determination of the sensitive period is correct.

Fifthly, during the sensitive period of insider information regarding major asset restructuring, Lu Shijun advised Gao Mouhui to buy Wanxiang Qianchao stocks, and the inquiry records of both parties corroborate each other, thus Lu Shijun constitutes advising others to trade stocks.

Sixthly, Lu Shijun had communications with insider Li Mouyi during the sensitive period of insider information, and his trading of Wanxiang Qianchao stocks is significantly abnormal and highly consistent with the insider information.

Seventhly, the penalty amount has comprehensively considered the facts, nature, circumstances, and degree of social harm of the party’s illegal behavior, as well as the cooperation with our bureau’s investigation, making the penalty appropriate.

In conclusion, our bureau does not accept the opinions of Lu Shijun and his agent.

Based on the facts, nature, circumstances, and degree of social harm of the party’s illegal behavior, combined with the party’s cooperation with our bureau’s investigation, in accordance with Article 191, Paragraph 1 of the Securities Law, our bureau decides:

1. For Lu Shijun’s insider trading of Wanxiang Qianchao stocks, confiscate illegal gains of 4,493,192.69 yuan and impose a fine of 13,479,578.07 yuan.

2. For Lu Shijun’s behavior of advising others to trade stocks, impose a fine of 500,000 yuan.

The above parties must transfer the confiscated fines directly to the national treasury within 15 days from the date of receiving this penalty decision. The specific payment method is detailed in the instructions attached to this penalty decision. At the same time, they must submit a photocopy of the payment voucher with the party’s name to the Hunan Securities Regulatory Bureau of the China Securities Regulatory Commission for record. If the party is dissatisfied with this penalty decision, they may apply for administrative reconsideration to the China Securities Regulatory Commission within 60 days of receiving this penalty decision (the application for administrative reconsideration can be sent via express mail to the Legal Affairs Department of the China Securities Regulatory Commission) or directly file an administrative lawsuit with a competent people’s court within 6 months of receiving this penalty decision. During the reconsideration and litigation period, the above decision will not be suspended.

Hunan Securities Regulatory Bureau

March 13, 2026

Administrative penalty decision of the Hunan Securities Regulatory Bureau of the China Securities Regulatory Commission [2026] No. 2 (Fu Guowei)

Party: Fu Guowei, male, residence: Xiaoshan District, Hangzhou City, Zhejiang Province.

Based on the relevant provisions of the Securities Law of the People’s Republic of China (hereinafter referred to as the “Securities Law”), our bureau conducted an investigation into Fu Guowei’s insider trading of Wanxiang Qianchao Co., Ltd. (hereinafter referred to as “Wanxiang Qianchao” or “the Company”) stock and legally informed the party of the facts, reasons, basis for the administrative punishment, and rights entitled to the party. The party did not present any statements, defenses, or requests for a hearing. This case has now been investigated and concluded.

It has been found that Fu Guowei has the following illegal facts:

1. Insider information situation

On April 17, 2024, the company disclosed the “Announcement on the Suspension of Trading for the Planning of Issuing Shares to Purchase Assets,” stating that the company intends to acquire 100% equity of Wanxiang America Corp. controlled by its controlling shareholder Wanxiang Group through the issuance of shares and payment of cash, and to raise supporting funds. This transaction is expected to constitute a major asset restructuring.

The above major asset restructuring matter complies with the provisions of Article 22, Paragraph 2, Item 7 of the China Securities Regulatory Commission’s “Administrative Measures for Information Disclosure by Listed Companies” (CSRC Order No. 182) and is a major event as defined in Article 80, Paragraph 2, Item 12 of the Securities Law, and is insider information as defined in Article 52, Paragraph 2 of the Securities Law prior to public disclosure.

The insider information was formed no later than March 10, 2024, and was made public on April 17, 2024. Wanxiang Qianchao’s general manager Li Mouyi and company secretary Wen Mou participated in this major asset restructuring project and are insiders as defined in Article 51, Item 4 of the Securities Law, both of whom were aware no later than March 10, 2024.

2. Fu Guowei’s insider trading of Wanxiang Qianchao stock

(1) Contact with insiders

Fu Guowei works for a subsidiary of Wanxiang Qianchao. Fu Guowei has known Wen Mou for many years, and they are high school classmates, having had six call records from April 3 to April 9, 2024.

(2) Fu Guowei used his spouse “Sun Moujia” account to trade Wanxiang Qianchao stock

During the sensitive period, Fu Guowei unidirectionally bought 284,900 shares from April 12 to April 16, 2024, with a total purchase amount of 1,480,882.40 yuan, all sold after the announcement, profiting 87,413.57 yuan. Fu Guowei controlled the “Sun Moujia” Ping An Securities account to trade Wanxiang Qianchao stocks, and the securities trading activity was significantly abnormal, highly consistent with the insider information, and the party has no reasonable explanation.

Fu Guowei actively cooperated with our bureau during the investigation, voluntarily providing mobile phones and other devices, as well as relevant documents.

The above facts are supported by relevant personnel inquiry records, bank statements, securities account data, and trading flow information, which are sufficient to establish the case.

Our bureau believes that Fu Guowei’s above behavior violates the provisions of Article 50 and Article 53, Paragraph 1 of the Securities Law, constituting the insider trading behavior described in Article 191, Paragraph 1 of the Securities Law.

Based on the facts, nature, circumstances, and degree of social harm of the party’s illegal behavior, combined with the party’s cooperation with our bureau’s investigation, in accordance with Article 191, Paragraph 1 of the Securities Law, our bureau decides: to confiscate Fu Guowei’s illegal gains of 87,413.57 yuan and impose a fine of 500,000 yuan.

The above parties must transfer the confiscated fines directly to the national treasury within 15 days from the date of receiving this penalty decision. The specific payment method is detailed in the instructions attached to this penalty decision. At the same time, they must submit a photocopy of the payment voucher with the party’s name to the Hunan Securities Regulatory Bureau of the China Securities Regulatory Commission for record. If the party is dissatisfied with this penalty decision, they may apply for administrative reconsideration to the China Securities Regulatory Commission within 60 days of receiving this penalty decision (the application for administrative reconsideration can be sent via express mail to the Legal Affairs Department of the China Securities Regulatory Commission) or directly file an administrative lawsuit with a competent people’s court within 6 months of receiving this penalty decision. During the reconsideration and litigation period, the above decision will not be suspended.

Hunan Securities Regulatory Bureau

March 13, 2026

Administrative penalty decision of the Hunan Securities Regulatory Bureau of the China Securities Regulatory Commission [2026] No. 1 (Jin Guanmuch)

Party: Jin Guanmuch, male, residence: Xiaoshan District, Hangzhou City, Zhejiang Province.

Based on the relevant provisions of the Securities Law of the People’s Republic of China (hereinafter referred to as the “Securities Law”), our bureau conducted an investigation into Jin Guanmuch’s insider trading of Wanxiang Qianchao Co., Ltd. (hereinafter referred to as “Wanxiang Qianchao” or “the Company”) stock and legally informed the party of the facts, reasons, basis for the administrative punishment, and rights entitled to the party. At the request of the party, a hearing was held to hear the statements and defenses of Jin Guanmuch and his agent. This case has now been investigated and concluded.

It has been found that Jin Guanmuch has the following illegal facts:

1. Insider information situation

On April 17, 2024, the company disclosed the “Announcement on the Suspension of Trading for the Planning of Issuing Shares to Purchase Assets,” stating that the company intends to acquire 100% equity of Wanxiang America Corp. controlled by its controlling shareholder Wanxiang Group through the issuance of shares and payment of cash, and to raise supporting funds. This transaction is expected to constitute a major asset restructuring.

The above major asset restructuring matter complies with the provisions of Article 22, Paragraph 2, Item 7 of the China Securities Regulatory Commission’s “Administrative Measures for Information Disclosure by Listed Companies” (CSRC Order No. 182) and is a major event as defined in Article 80, Paragraph 2, Item 12 of the Securities Law, and is insider information as defined in Article 52, Paragraph 2 of the Securities Law prior to public disclosure.

The insider information was formed no later than March 10, 2024, and was made public on April 17, 2024. Wanxiang Qianchao’s general manager Li Mouyi and company secretary Wen Mou participated in this major asset restructuring project and are insiders as defined in Article 51, Item 4 of the Securities Law, both of whom were aware no later than March 10, 2024.

2. Jin Guanmuch’s insider trading of Wanxiang Qianchao stock

(1) Contact with insiders

Before retiring, Jin Guanmuch was an employee of Wanxiang Qianchao. At 07:49 on April 15, 2024, Jin Guanmuch had a phone call with Wanxiang Qianchao general manager Li Mouyi, lasting 1 minute and 29 seconds.

(2) Jin Guanmuch’s trading of Wanxiang Qianchao stock

During the sensitive period, Jin Guanmuch controlled “Zhong Moumei” Guotai Huitong Securities account and “Jin Guanmuch” Guotai Huitong Securities account (hereinafter referred to as the account group), unidirectionally buying 2,152,800 shares of Wanxiang Qianchao stock, with a total purchase amount of 11,376,769 yuan, all sold after the announcement, totaling a sell amount of 10,830,539 yuan, incurring a total loss of 454,722.89 yuan. Jin Guanmuch’s trading activities of the account group are significantly abnormal, highly consistent with the insider information, and the party has no reasonable explanation.

Jin Guanmuch actively cooperated with our bureau during the investigation, voluntarily providing mobile phones and other devices, as well as relevant documents.

The above facts are supported by relevant personnel inquiry records, bank statements, securities account data, and trading flow information, which are sufficient to establish the case.

Our bureau believes that Jin Guanmuch’s behavior violates the provisions of Article 50 and Article 53, Paragraph 1 of the Securities Law, constituting the insider trading behavior described in Article 191, Paragraph 1 of the Securities Law.

Jin Guanmuch and his agent raised the following defenses during the hearing: Firstly, the basis for determining Jin Guanmuch’s insider trading behavior by presumption is insufficient, and the evidence regarding Jin Guanmuch’s insider trading has not reached the level of excluding reasonable doubt. Secondly, considering Jin Guanmuch’s cooperation with the investigation and other circumstances, a request was made to reduce the penalty amount.

Upon re-examination, our bureau believes: firstly, Jin Guanmuch had communication with insiders during the sensitive period, and the securities trading is highly consistent with the insider information, and the explanations provided by the party are insufficient to exclude the abnormality of his trading, therefore the determination of insider trading is appropriate. Secondly, our bureau has fully considered the party’s cooperation with the investigation and made the penalty based on the illegal facts, trading amount, degree of social harm, etc., making the penalty appropriate.

In conclusion, our bureau does not accept the opinions of Jin Guanmuch and his agent.

Based on the facts, nature, circumstances, and degree of social harm of the party’s illegal behavior, combined with the party’s cooperation with our bureau’s investigation, in accordance with Article 191, Paragraph 1 of the Securities Law, our bureau decides: to impose a fine of 1.5 million yuan on Jin Guanmuch.

The above parties must transfer the fines directly to the national treasury within 15 days from the date of receiving this penalty decision. The specific payment method is detailed in the instructions attached to this penalty decision. At the same time, they must submit a photocopy of the payment voucher with the party’s name to the Hunan Securities Regulatory Bureau of the China Securities Regulatory Commission for record. If the party is dissatisfied with this penalty decision, they may apply for administrative reconsideration to the China Securities Regulatory Commission within 60 days of receiving this penalty decision (the application for administrative reconsideration can be sent via express mail to the Legal Affairs Department of the China Securities Regulatory Commission) or directly file an administrative lawsuit with a competent people’s court within 6 months of receiving this penalty decision. During the reconsideration and litigation period, the above decision will not be suspended.

Hunan Securities Regulatory Bureau

March 13, 2026

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Editor: Jiang Yuhan