To ensure the implementation of a concerted action agreement, we recommend that the target company becomes a party to the agreement and the target company’s obligations to secure the exercise of the right of mandatory voting is explicitly stipulated. Even more protective is putting the right of mandatory voting into the target company’s articles of association.

In April 2024, the People's Bank of China (PBOC), together with the State Administration for Market Regulation (SAMR), issued the Measures for the Administration of Beneficial Owner Information (the "Administrative Measures") (see JunHe Client Briefing: Key Points of the Measures for the Administration of Beneficial Owner Information). The Administrative Measures came into effect and were implemented on November 1, 2024.