Analysis of the Undisclosed RMB 2 Billion+ Related-Party Procurement Transaction Between JA Solar Technology and Yongzhen Co., Ltd.

According to an investigative report from the Southern Capital Center of Golden Securities Research [1], a related-party procurement transaction exceeding RMB 2 billion between JA Solar Technology and Yongzhen Co., Ltd. was not disclosed as required, attracting regulatory attention.

• August 2021
  : JA Solar Technology acquired shares in Yongzhen Co., Ltd., with a shareholding ratio of no more than 5% [1]
• 2022-2023
  : The total procurement amount of JA Solar Technology from Yongzhen Co., Ltd.
  exceeded RMB 2 billion
  [1]

According to the prospectus of Yongzhen Co., Ltd., JA Solar Technology was the 2nd, 2nd, and 1st largest customer of Yongzhen Co., Ltd. in 2021, 2022, and 2023 respectively:

Year	Sales Amount (RMB 100 million)	Percentage of Yongzhen Co., Ltd.'s Main Business Revenue
2021	8.52	32.53%
2022	12.29	27.18%
2023	11.53	21.69%

: The total procurement amount of JA Solar Technology from Yongzhen Co., Ltd. in 2022-2023 was [1]

• Yongzhen Co., Ltd. disclosed JA Solar Technology as a related party [1]
• In 2022-2023, Yongzhen Co., Ltd. conducted related-party procurements from JA Solar Technology, with the procurement amounts being RMB 19.7541 million and RMB 24.099 million respectively [1]

• JA Solar Technology
  did not identify Yongzhen Co., Ltd. as a related party
• Did not disclose the relevant transaction
  [1]

According to the articles of association of JA Solar Technology, other legal persons or organizations that have a special relationship with JA Solar Technology and may cause JA Solar Technology’s interests to tilt towards them, identified in accordance with the principle of substance over form, are deemed related legal persons.

• A certain supplier was
  disclosed as a related party
  by JA Solar Technology because an enterprise controlled by Jin Baofang, the actual controller of JA Solar Technology, indirectly held 1.02% of its shares, and the transaction amount reached billions of RMB [1]
• However, JA Solar Technology
  did not identify Yongzhen Co., Ltd. as a related party
  even though its shareholding ratio in Yongzhen Co., Ltd. was also less than 5% and the transaction amount exceeded RMB 2 billion [1]

In the procurement process between JA Solar Technology and Yongzhen Co., Ltd., there is an intermediary named [1]:

1. Jingkang Photovoltaic procures products from Yongzhen Co., Ltd.
2. Jingkang Photovoltaic sells the products to Hebei Jinglong, a subsidiary of JA Solar Technology
3. Yongzhen Co., Ltd. delivers the products directly to Hebei Jinglong

• Founded in 2020 and deregistered in 2022, with an existence period of
  less than three years
  [1]
• A director of GLC HK, a shareholder of its controlling shareholder, is Huang Jionxiang
• The general manager of Jingkang Photovoltaic before deregistration had the same name as a key employee of JA Solar Technology [1]

• JA Solar Technology submitted an application for listing on the Hong Kong Stock Exchange on April 28, 2025
• The prospectus expired six months later
• As of January 16, 2026, it has not resubmitted the application [1]

In the supplementary material requirements for overseas issuance and listing filing, JA Solar Technology was required to explain:

• Whether there are other production safety liability accidents and the specific details
• Whether it constitutes a relevant situation that restricts financing [1]

According to relevant regulations such as Accounting Standard for Business Enterprises No. 36 - Disclosure of Related Parties and Listing Rules, although JA Solar Technology’s shareholding ratio in Yongzhen Co., Ltd. does not exceed 5%, the two parties have a significant transaction amount, and thus should identify and disclose the relationship as a related party in accordance with the principle of substance over form.

1. Impairment of Investors’ Right to Know
   : Information on major related-party transactions is not open and transparent
2. Risk of Interest Transfer
   : The existence of the intermediary link may involve complex interest arrangements
3. Risk of Regulatory Penalty
   : May face administrative penalties from the CSRC [1]

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[1] Southern Capital Center of Golden Securities Research - “JA Solar Technology: Hong Kong Listing Application Expired for Over Two Months, Suspicion Looms Over Related-Party Identification Behind the Over RMB 2 Billion Procurement” (https://i.ifeng.com/c/8pyINEDpKt1)