The National Equities Exchange and Quotations Company Limited ("NEEQ") has recently issued the Circular on Making Good Preparations for the Implementation of the Code of Corporate Governance for Companies Listed on the National Equities Exchange and Quotations and Other Related Systems (the "Circular").
The Circular mainly sets forth requirements in eight aspects, including making good preparations for the implementation of the limits on short-swing trading set out in the latest Securities Law, implementing the provisions of the Code of Corporate Governance for NEEQ-listed Companies in respect of limits on trading during the sensitive period, and reporting of commitments. Among others, the Circular requires that a NEEQ-listed company shall, pursuant to relevant requirements set out in the Code of Corporate Governance for NEEQ-listed Companies and as against the Note of Key Points for Improvement to the Articles of Association and Other Related Systems, complete revision of its articles of association, go through the procedures for deliberation and then announce the same, by May 1, 2020. Meanwhile, the Circular expressly states that the shareholders' meeting of a NEEQ-listed company shall be held in the form of on-site meeting at a physical meeting place. For a company listed on the NEEQ's innovation tier or basic tier that has over 200 shareholders on the date of record, online voting should also be available if the shareholders' meeting will deliberate matters on which the votes will be counted separately.