New Trading Suspension Rule: A Double-Edged Sword - Presentation to INED - Deloitte
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New Trading Suspension Rule: A Double-Edged Sword Presentation to INED 17 October 2019 Information Classification: Internal
Part I © 2019. For information, contact Deloitte China. For internal discussion only 2
What’s new about 13.50A (“new suspension rule”)
Old regime New regime
Suspension
Suspension
Trading
Trading
Issuer Regulator Issuer Regulator
© 2019. For information, contact Deloitte China. For internal discussion only 3
Mainboard - 13.50A (GEM Listing Rule 17.48B)
“The Exchange will normally require suspension of trading in an issuer’s
securities if it publishes a preliminary results announcement for a financial year
as required under rules 13.49(1) and (2) and the auditor has issued, or has
indicated that it will issue, a disclaimer of opinion or an adverse opinion on
the issuer’s financial statements. The suspension will normally remain in force
until the issuer has addressed the issues giving rise to the disclaimer or adverse
opinion, provided comfort that a disclaimer or adverse opinion in respect of such
issues would no longer be required, and disclosed sufficient information to enable
investors to make an informed assessment of its financial positions.”
“This consultation was about improving the quality and reliability of financial
information of issuers to safeguard market quality,”
“The new Rule encourages issuers to maintain appropriate and effective risk
management and internal control systems, and where necessary, requires them
to act promptly to resolve issues with their auditors,”
- David Graham, HKEX’s Head of Listing
© 2019. For information, contact Deloitte China. For internal discussion only 4
Audit opinions that will trigger suspension
Audit
Opinion
Unmodified Modified
opinion Opinion
Clean
Opinion with
Clean Qualified Disclaimer Adverse
Emphasis of
Matter
© 2019. For information, contact Deloitte China. For internal discussion only 5
Example of disclaimer
Material uncertainties related to issuer’s abilities to continue as a
going concern
Limitation of scope on valuation of assets due to lack of books and
records and/or supporting documents, etc.
• Failure to substantiate carrying amounts investment or other
fixed assets
• Certain books and records of the issuers being lost or
inaccessible
• Fire or natural disaster resulting in loss of primary evidence
• De-consolidation of subsidiaries from the group’s consolidated
financial statements as the issues were unable to exercise
control over time and have no access to the books and records
© 2019. For information, contact Deloitte China. For internal discussion only 6
Example of disclaimer
Disclaimer Opinion (846)
“… Management was not able to provide us with satisfactory explanations as
to the commercial substance of these transactions, and provide us with
adequate documentary evidences to support the nature and source of these
receipts from and payments to the above company …”
“… we have independently identified significant amounts of payments to
and receipts from (including the payments and receipts described in the
above sections) a number of companies ... Such payments and receipts
were not supported by legitimate documentary evidence. …”
“Given the above, together with our concerns on those transactions
described in the sections … we have requested the board of directors of the
Company to form an independent committee to commission an independent
investigation on the authenticity and commercial substance of these
transactions (the “Proposed Investigation”) …”
© 2019. For information, contact Deloitte China. For internal discussion only 7
Example of resignation of auditor
Auditors cease work and resign (1007)
Before the deadline for publication of the audited account, the Auditors
resigned.
In the auditors’ letter of resignation, it was said: “We continue to have
concerns about matters pervasive to the financial statements including (1)
… transactions brought to the attention of management and acknowledged
by them to be fraudulent; (2) unexplained differences between sales receipt
notes …; (3) the explanation provided by management … for removing
accounting records which were then not available to us continuously during
the audit; (4) the validity and commercial substance of acquisition.”
The HKEx imposed a resumption condition for the Company to conduct a
forensic investigation on the audit issues (including the certain potentially
fraudulent transactions).
© 2019. For information, contact Deloitte China. For internal discussion only 8
Exemption #1: Going concern
The disclaimer or adverse opinion relates solely to going
concern
Year 1 Year 2
Material uncertainties about Completed an equity
the company’s ability to fundraising for repayment of
continue as a going concern debts and working capital, and
issued convertible bonds to
material uncertainties about the settle certain amounts due to
company’s ability to continue as a creditors
going concern Improvement in the company’s
operating performance during
Disclaimer the year
Clean Opinion with an emphasis of matter
relating to the going concern issue
© 2019. For information, contact Deloitte China. For internal discussion only 9
Exemption #2: Issue resolved
the underlying issue is resolved before the issuer publishes
the preliminary results announcement
the audit issues would not have an ongoing effect on the
issuer’s financial statements for the succeeding financial years
Fire accident
Loss of books and
records Disclaimer
Reconstruct
accounting records
Publication of financial
results for the year
© 2019. For information, contact Deloitte China. For internal discussion only 10Other highlights Effective Date • Apply to preliminary annual results announcements for the financial years commencing on or after 1 September 2019 Longer remedial period • For issues remains unresolved outside the issuer’s control, HKSE may allow longer remedial period, with the duration of the period being determined on a case by case basis. Transitional Arrangement • Extend the remedial period to 24 months for the financial years commencing between 1 September 2019 and 31 August 2021 © 2019. For information, contact Deloitte China. For internal discussion only 11
New Trading Suspension Rule
The proactive and reactive approaches
How to prevent suspension
Current Listing Rules
and delisting?
Main Proactive
GEM •
Board Identify and resolve the issues giving
rise to disclaimer and or adverse
opinions before publication of the
preliminary results announcement.
Suspension
18 months 12 months Reactive
(Prescribed remedial period) • Identify and resolve the issues giving
rise to disclaimer and or adverse
opinions within 18 months (or 12
months for GEM issuers)
Delist
© 2019. For information, contact Deloitte China. For internal discussion only 12Part II - Seeking a resumption © 2019. For information, contact Deloitte China. For internal discussion only 13
New delisting regime New delisting regime with an aim to delist prolonged suspended companies became effective on 1 August 2018: © 2019. For information, contact Deloitte China. For internal discussion only 14
Recent regulatory updates The objective of the new delisting rules (Para. 8 of GL95-18) © 2019. For information, contact Deloitte China. For internal discussion only 15
What is the new delisting regime?
Old Regime New Regime
Delist a company immediately without Delist a company immediately (LR 6.10)
suspension (LR 6.10)
Delist a company after a Specified
Delist a company after a specified Remedial Period (LR 6..10)
remedial period (with a specific 3-stage
delisting procedures for PN 17 Delist a company for failure to remedy
companies (being companies unable to the issues causing its suspension of
comply with LR13.24)) (LR 6.10) trading, to re-comply with the rules and
resume trading before the end of the
prescribed remedial period of 18
months (the “Prescribed Remedial
Period”). (LR 6.01A and 6.10A)
© 2019. For information, contact Deloitte China. For internal discussion only 16Other highlights of the new delisting regime
Effective date: 1 August 2018.
Transition period:
Companies suspended for more than 12 months before August 2018: 31 July 2019.
Companies suspended for less than 12 months before 1 August 2018: 31 January
2020.
According to the monthly prolonged suspension status report of the
HKEx (as at 30 September 2019)
18 suspended companies with PRP expired on 31 July 2019.
At least 9 of them were delisted by the HKEx in August and September 2019 under
the new LR6.01A for failure to resume trading by the end of the PRP.
11 suspended companies with PRP expiring on 31 January 2020.
© 2019. For information, contact Deloitte China. For internal discussion only 17Regulatory landscape © 2019. For information, contact Deloitte China. For internal discussion only 18
Recent regulatory updates
Listed companies governance is one of the top enforcement
priorities for regulators in Hong Kong:
© 2019. For information, contact Deloitte China. For internal discussion only 19Recent regulatory updates
It was rare for the SFC to exercise its power to suspend, but this has changed in recent years:
Year Companies suspended by the SFC
2010 - 30/03/ 2010: Hontex (0946)
2011 - Nil.
2012 - 22/08/2012: China High Precision (591)
2013 - 20/12/2013: Qunxing Paper (3868)
2014 - 14/02/2013: China Longevity Group Company Limited (1863)
- 04/12/2014: Sijia Group (1863)
2015 - 15/07/2015: Hanergy (566)
- 15/12/2015: Superb Summit (1228)
2016 - 20/01/2016: Changgang Dunxin Enterprise Company Limited (2229)
- 16/04/2016: Sound Global (967)
- 28/06/2016: Real Gold Mining (246)
- 05/08/2016: National United Resources Holding (254)
- 27/09/2016: Hua Han Health Industry Holdings (587)
- 13/10/2016: China Fiber Optic Network (3777)
2017 - 22/02/2017: GME (8188)
- 04/07/2017: Nationa Agricultural Holdings Limited (1236)
- 08/05/2017: Huishan Dairy (6863)
- 17/05/2017: CG Dunxin (2229)
- 25/05/2017: Tianhe Chemicals (1619)
- 06/06/2017: Lerado Financial Group Company Limited (1225)
- 17/07/2017: China Household Holdings Limited (692)
- 06/10/2017: New Ray Medicine International Holdings Limited (6108)
- 09/11/2017: Tech Pro Technology Development Limited (3823)
- 24/11/2017: First Credit Finance Group Limited (8215)
- 27/11/2017: China Wah Yan Healthcare Limited (648)
- 27/11/2017: Town Health International Medical Group Limited (3886)
2018 - 04/07/2018: Real Nutriceutical Group Limited (2010)
- 20/11/2018: Hua Han Health Industry Holdings Limited (587)
2019 - 08/03/2019: China Ding Yi Feng Holdings Limited (612)
- 29/05/2019: Combest Holdings Limited (8190)
© 2019. For information, contact Deloitte China. For internal discussion only 20Recent regulatory updates Many listed companies were suspended from trading as a result of certain issues or regulatory concerns: © 2019. For information, contact Deloitte China. For internal discussion only 21
Recent regulatory updates HKEx continued to focus on the four Enforcement Themes: © 2019. For information, contact Deloitte China. For internal discussion only 22
Regulatory environment
Auditors Shareholders Regulators
SFC HKEx
Whistle-blowers Creditors Company/INEDs
Suspension Trading
Regulators resumed
Company Auditors Sponsors Regulators
to approve
Delisting
Auditors
Investigation Creditors Forensic Restructuring
accountants
Company/INEDs PL/JL
Liquidation
White knight Controlling / major
shareholders Company
© 2019. For information, contact Deloitte China. For internal discussion only 23Seeking a resumption © 2019. For information, contact Deloitte China. For internal discussion only 24
Seeking a resumption
• Reasons for suspension
− Material breaches of the LR
− Fails to publish financial statements within time limit
− Fails to maintain sufficient operation or assets
− Fails to maintain sufficient public float
− Receives disclaimer or adverse opinion (new suspension rule)
• Depending on the underlying issues, the regulators will impose
different resumption conditions on the company
• The principle, however, remains the same: no resumption will be
allowed unless and until all issues leading to the suspension have
been properly resolved
© 2019. For information, contact Deloitte China. For internal discussion only 25Seeking a resumption
• 3 key categories of suspension cases
PN 17 companies/ Companies with material Companies with insufficient
companies with insufficient irregularities (accounting/ public float
operation or assets or in corporate irregularities)
financial difficulties
• Demonstrate that it has a • Accounting irregularities: • Devise a plan to restore the
business that has substance and discrepancy between group required the minimum public
is viable and sustainable in the account records and information float.
longer term. obtained by auditors; concerns
over authenticity of the • Placing of existing shares by the
• If due to insufficient operation/ documents; concerns over the controlling or substantial
assets, acquisition – Note: a commercial substance of certain shareholders; or placing of new
suspended issuer that ceased to material transactions shares by the issuer.
carry on the original principal
business or to retain any • Corporate irregularities: fraud;
material assets is a listed shell misappropriation of assets; other
and any acquisition by it will be a fraudulent activities
RTO and be treated as a new
listing application. • Address the irregularities: (1)
form a IBC; (2) forensic
• If due to financial difficulties, investigation; (3) address audit
undertake corporate action to concerns; (4) audit qualification;
resolve the financial difficulties, (5) internal control review; (6)
such as capital reorganization, remedial measures; (7) no
equity fundraising and a scheme concern about management
of arrangement. integrity; (8) disclose all material
information and publish all
financial statements.
© 2019. For information, contact Deloitte China. For internal discussion only 26Key criteria for resumption
Forensic
investigation
Address Disclose
auditor’s information to
concern the market
Demonstrate
Take
adequate
appropriate
internal control
remedial action
system
Demonstrate
the integrity
and competence
of directors
© 2019. For information, contact Deloitte China. For internal discussion only 27Case study
Old PN 17 company: case study – Grande (186)
Date Chronology of events
30/05/2011 - Suspended upon the presentation of creditors’ winding up
31/05/2011 - Provisional liquidation
08/09/2011 - Grande was placed in the 1st stage of delisting procedure
31/05/2012 - A resumption proposal was submitted but was rejected by the HKEx
05/07/2012 - Grande was placed in the 2nd stage of delisting procedure
25/09/2012 - Grande requested a review of the Listing Division’s decision to place it in the 2 nd stage
of delisting procedure. Review not successful.
21/06/2013 - A resumption proposal was submitted but was rejected by the HKEx
11/07/2013 - Grande was placed in the 3rd stage of delisting procedure
12/09/2013 - A winding up order made against Grande
12/02/2014 - Grande submitted a resumption proposal to the HKEx
29/05/2015 - HKEx approved the resumption proposal, and made (among others) the completion of
all transactions contemplated under the resumption proposal as one of the
resumption conditions
30/05/2016 - Fulfilled all resumption conditions and resumed trading
© 2019. For information, contact Deloitte China. For internal discussion only 28Case study: PN 17 company
Resumption
Grande (186) Publication of material
Total current liabilities
information: outstanding financial
over HKD 3.9 billion information
Total assets around
Internal control review:
HKD1.3 billion internal control review, remedial measures, new CFO and
Issues regarding Company Secretary
amounts due to related Strengthening existing business:
companies No acquisition, steps taken to strengthen its business
Disclaimer Group Reorganization: liquidating certain
Internal control issues subsidiaries: to improve financial position, and to address audit issues
regarding certain subsidiaries.
Scheme of arrangement: Bermuda and Hong Kong
schemes: discharging of all claims (excluding intercompany debts), by cash and
creditors shares
Open offer: 5 offer shares for every 2 shares: raising
Suspension proceeds of around HKD100 million for the Scheme
Capital Reorganization: capital cancellation
(unissued), capital reduction (reduce par value), increase authorized share
capital: remove 1/3 accumulative losses, and enabling Open Offer and Scheme.
© 2019. For information, contact Deloitte China. For internal discussion only 29Case study
Companies with material issues: case study – Kaisa (1638)
Date Chronology of events
Late 2014/ - The Company had liquidity issues. Loans defaulted. Many litigations were commenced
early 2015 against the Company. CEO resigned.
08/03/2015 - Announced restructuring proposal.
31/03/2015 - Trading suspended as a result of its failure to publish the 2014 annual results.
29/04/2015 - Announced that auditors need additional audit evidence on certain matter for its 2014
audit.
23/07/2015 - HKEx imposed resumption conditions on the Company, which included, among others,
demonstrating sufficient working capital and investigation of matters raised by the
Company’s auditors in the course of the audit.
18/09/2015 - Auditors identified various audit issues. Auditors ceased work. The Company formed an
independent committee to investigate matters.
10/06/2016 - Schemes for restructuring of offshore debts were sanctioned by HK and Cayman court
12/07/2016 - Offshore debts restructuring became effective.
15/07/2016 - Auditor resigned and new auditors appointed.
19/12/2016 - Forensic accountants published its findings. Recommended action against wrongdoers
and remedial steps to be taken.
24/03/2017 - Internal control review completed.
26/03/2017 - Published the outstanding annual results for 2014 to 2016
27/03/2017 - All resumption conditions fulfilled.
- Trading resumed.
© 2019. For information, contact Deloitte China. For internal discussion only 30Case study: material issues
Resumption
Kaisa (1638)
Publication of the
Serious liquidity issues
Onshore debts outstanding financial
(RMB49.6 billion) information: New auditors appointed,
and published outstanding financial information.
Offshore debts (USD2.9
billion) Internal control review: internal control
Loan default; material review, various weaknesses identified and remedial measures
implemented.
litigation
Material audit issues Forensic investigation of audit
issues: Engage a forensic accountant to investigate audit issues:
findings (a) certain former employees were involved in a scheme using
fictitious agreements, substantial improper and unauthorized payments,
incorrect accounting and collusion with third parties, to obscure the existence
of certain borrowing agreements; (b) certain payment transactions were
without clear business purposes or had no identifiable business purposes; (c)
certain acquisitions were not properly authorized and approved.
Recommended the Company to report the wrongdoing to the authorities and
to implement remedial measures.
Suspension Debt restructuring: Restructuring onshore debts by refinancing,
restructuring offshore debts by scheme of arrangement: to improve the Company’s financial
position
© 2019. For information, contact Deloitte China. For internal discussion only 31Seeking a resumption (Cont.)
Example of a company no longer suitable for listing
- False and misleading IPO prospectus: Hontex (946)
Hontex (946)
- 24/12/2009: Hontex was listed on the HKEx
- 30/03/2010: SFC sought injunction to freeze
IPO proceeds , alleging that Hontex materially
overstated its turnovers and cash in the IPO
prospectus.
- 20/06/2012: SFC obtained a repurchase order,
requiring Hontex to repurchase shares from
7,700 public shareholders.
- 29/10/2012: Repurchase completed – 0.42%
public float
- 22/11/2012: LC decided to delist, on the basis
of disclosure of false and misleading
information in the IPO prospectus and lack of
public float.
- 23/09/2013: Delisted.
© 2019. For information, contact Deloitte China. For internal discussion only 32Seeking a resumption of trading (Cont.)
Initial listing obtained by fraud: China Metal Recycling
(773)
Facts SFC v. China Metal Recycling (HCCW
210/2013)
- 22/06/2009: China Metal was listed - First public interest winding up
on the HKEx. - Justice Harris: “Although the economic
- 28/01/2013: Trading suspended. interests of creditors and minority
- 26/07/2013: SFC petitioned to wind shareholders are relevant in
up the Company on public interest determining a petition such as the
basis under section 212 of the SFO. present, as the authorities to which I
SFC alleged that China Metal involved have referred make clear, the
in a highly complex, sophisticated and overarching consideration is the
dishonest scheme which inflated its broader interest of market participants
performance, revenue (over HKD 8 as a whole. That interest requires that
billion) and profit (over HKD 1 billion) serious misconduct is subject to
dating back to the time of its IPO unequivocal censure. The appropriate
prospectus in 2009. order in a case where a listing has been
obtained by wholly dishonest
- 26/02/2015: Winding up order made. fabrication of accounts would, in my
- 04/02/2016: Delisted, on the basis view, almost invariably be a winding-up
that it obtained its initial listing by order”
fraud.
© 2019. For information, contact Deloitte China. For internal discussion only 33Preparing for investigations
• A resumption of trading is unlikely to be the end of the
matter
• It usually marks the beginning of investigation by the
regulators into the problematic companies and/or their
officers for past breaches of rules and regulations
• One of the enforcement objectives: to punish
wrongdoers
• It is important to bear in mind the likelihood of
investigations and enforcement actions by the
regulators, and to manage the relevant risks as
appropriate
© 2019. For information, contact Deloitte China. For internal discussion only 34Investigations carried out by HKEx
Issues under Investigations in 1H2019
No. of Investigations
120
100
80
60
40
20
0
2015 2016 2017 2018 1H2019
Main Board GEM
No. of Directors subject to Director's duties
Disciplinary Sanctions Failure to cooperate with an Exchange investigation
120
100 Inaccurate, incomplete and/or misleading disclosure in
80 corporate communication
Failure to comply with procedural requirements in respect of
60 notifiable/connected transactions
40 Repeated breaches of the Listing Rules
20
Financial reporting - delays, or internal controls and corporate
0 governance issues
2015 2016 2017 2018 1H2019
Multiple themes
ED NED INED
Others
Sources: HKEX website
© 2019. For information, contact Deloitte China. For internal discussion only 35Investigations carried out by SFC
250
200
150
100
50
0
13/14 14/15 15/16 16/17 17/18
Corporate disclosure Corporate misgovernance Insider dealing
Intermediary misconduct Market manipulation Unlicensed activities
150
100
50
0
13/14 14/15 15/16 16/17 17/18
Prosecutions Civil proceedings Disciplinary proceedings Maket Misconduct Tribunal proceedings
Sources: SFC Annual Report 2017-18
© 2019. For information, contact Deloitte China. For internal discussion only 36More key takeaways …
“No Mistake.”
“No do-overs.”
“Whatever it takes!”
“Alright, we have a plan. Six Stones. Three teams. One Shot. Five
years ago we lost. All of us. We lost friends. We lost family. We lost a
part of ourselves. Today we have a chance to take it all back. You
know your teams. You know your mission. Get the stones. Get them
back. One round trip each. No mistakes. No Do-overs. Most of us are
going somewhere we know, but that doesn’t mean we should know
what to expect. Be careful. Look out for each other. This is the fight of
our lives. We are going to win. Whatever it takes. Good Luck.”
Steve Rogers, Avengers: Endgame
https://youtu.be/nLRnHaf3t54
© 2019. For information, contact Deloitte China. For internal discussion only 37© 2019. For information, contact Deloitte China. For internal discussion only 38
Juvenia Ho Joseph Chu
Partner, Hong Kong Partner, Hong Kong/ Beijing
Tel: +852 2852 1018 Tel: + 852 3919 0505/ +86 10 8588
4505
Email: juveniaho@deloitte.com.hk
Email: Joseph.Chu@simmons-
simmons.com
Juvenia Ho is a Partner in Deloitte Forensic practice in Hong Joseph is a partner in the Dispute Resolution Group. He
Kong. She has over 20 years of experience specializing in advises and represents clients in arbitration, banking,
forensic accounting, financial/management fraud general commercial, tax and trust disputes and
investigations, litigation support and fraud risk compliance investigations, with a particular focus on international
review throughout Greater China . arbitration, regulatory investigations and cross-border
litigation.
Juvenia’s extensive forensic accounting experiences includes
investigation into white collar crime, corruption particularly Joseph joined Simmons & Simmons as a partner in October
in the context of Foreign Corrupt Practices Act and money 2013. He was admitted in Hong Kong in 2003, England in
laundering, asset tracing inquiries, bribery & corruption risk 2008 and qualified as a lawyer in the PRC in 2012. He is one
assessments. of the authors of Sweet & Maxwell’s Arbitration in Hong
Kong: A Practical Guide, 2nd Edition, and was a contributing
Juvenia’s investigative experiences cover a wide range of editor of Hong Kong Civil Procedure (the “White Book”).
industries but in particular she has worked extensively in the
Pharmaceutical, medical device, media & entertainment, Joseph has been recognized as “up and coming” in
gaming, real estate, retail and manufacturing sectors. International Arbitration by Chambers Global in 2016. He
has been described as “best known for his expertise
Juvenia is also experienced in preparing accounting expert representing Mainland China-based businesses on cross-
reports and exhibits for court hearing, in both civil and border arbitrations” and “knowing the Mainland China
criminal cases for family/estate disputes, share placements market more than most” by Chambers Global. Joseph was
and insider dealing. also identified by the Asian Legal Business in 2016 as one of
the “Top 15 Rising Lawyers” in the PRC.
© 2019. For information, contact Deloitte China. For internal discussion only 39About Deloitte Global Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”), its network of member firms, and their related entities. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as “Deloitte Global”) does not provide services to clients. Please see www.deloitte.com/about to learn more about our global network of member firms. Deloitte provides audit & assurance, consulting, financial advisory, risk advisory, tax and related services to public and private clients spanning multiple industries. Deloitte serves over 80 percent of the Fortune Global 500® companies through a globally connected network of member firms in more than 150 countries and territories bringing world-class capabilities, insights, and high-quality service to address clients’ most complex business challenges. To learn more about how Deloitte’s approximately 286,000 professionals make an impact that matters, please connect with us on Facebook, LinkedIn, or Twitter. About Deloitte China The Deloitte brand first came to China in 1917 when a Deloitte office was opened in Shanghai. Now the Deloitte China network of firms, backed by the global Deloitte network, deliver a full range of audit & assurance, consulting, financial advisory, risk advisory and tax services to local, multinational and growth enterprise clients in China. We have considerable experience in China and have been a significant contributor to the development of China's accounting standards, taxation system and local professional accountants. To learn more about how Deloitte makes an impact that matters in the China marketplace, please connect with our Deloitte China social media platforms via www2.deloitte.com/cn/en/social-media. This communication is for internal distribution and use only among personnel of Deloitte Touche Tohmatsu Limited, its member firms, and their related entities (collectively, the "Deloitte Network"). None of the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte China.
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