Xinxing Tools IPO approval leaves unresolved issues over official seal and signatures: executive signatures suspected to be a single handwritten copy or in violation of the "Administrative Measures for the Registration of Initial Public Offerings of Stocks"

Xingxing Tools’ IPO successfully passed review but leaves a sealed stamp and signature-related mystery: The executives’ signatures may be reused from a single handwritten copy, or they may violate Article 36 of the《Administrative Measures for the Registration of IPOs of Shares》!

Source: International Investment Bank Research Report

Xingxing Tools’ IPO successfully passed review but leaves a sealed stamp and signature-related mystery: The signature pages have three versions, and the executives’ signatures appear to be “after one handwritten signature, directly copy / duplicate / PS into multi-version documents or violate Article 36 of the《Administrative Measures for the Registration of IPOs of Shares》!

Regulatory text (2023 revised version, currently effective)

Article 36 The issuer and its directors, supervisors, and senior management personnel shall sign and affix seals on the prospectus truthfully, and ensure that the content of the prospectus is true, accurate, and complete, with no false records, misleading statements, or material omissions. They shall fulfill their commitments in accordance with the principle of good faith and bear corresponding legal liabilities.

The issuer’s controlling shareholder and actual controller shall sign and affix seals on the prospectus to confirm that the content of the prospectus is true, accurate, and complete, with no false records, misleading statements, or material omissions.

1. The Shenzhen Stock Exchange website shows that Xingxing Tools’ IPO has already been reviewed and passed by the Listing Committee on March 31, after review by the Listing Committee. The underwriter is Huatai United Securities, and the law firm is Jintiancheng.

2. We won’t discuss the IPO process and performance of the company—after all, nowadays, as long as companies can get on the agenda, the rate of passing review is basically close to 100%. Serious researchers have found that the signatures and seals on the company’s IPO prospectus seem to be identical “twins” or even “triplets.”

3. Identical signatures: On January 16, 2026 and February 21, two versions of the prospectus, the signatures of the directors, executives, and members of the audit committee are almost completely identical in handwriting, position, and continuous-stroke structure—except for the signature date in the closing section. Under normal circumstances, even if the same person signs at different times, the handwriting must have minor differences. With all signatures being exactly the same, the market has recognized it as copy-paste / PS of the signature page from the previous version, rather than a genuine signature by the person themselves.

• 4. Identical seals: The seal style, angle, and clarity of the company’s corporate seal in the two prospectus versions are highly consistent; only the handwritten date differs. This matches the characteristics of an electronic seal / duplicated seal, further strengthening suspicions that the signature page is a copied page.

5. An old saying goes: what people fear most is a serious son. This kind of seriousness in researching the market. Last night, we downloaded the two submission versions of Xingxing Tools dated January 16 and February 21, and also the version submitted for the meeting review dated March 24. We then used the same mobile phone to screenshot the signature page. And we performed recognition using three commonly used domestic AI tools: Baidu Wenxin, Ali Qianwen, and Doubao (AI is currently mainly used to recognize various plants, diagnose diseases, etc.; personally, I feel the accuracy is quite high).

6. We entered the same prompt: “Please compare whether the signature handwriting in the three images is the same, and whether the corporate seal is the same (including clarity, angle, etc.),” and so on.

7. Baidu’s conclusion is: “Overall, because signatures may be affected by various factors (such as the time of signing, the signing environment, the condition of the signer, etc.), although the signatures in the three images are similar in form, they cannot be determined solely from the images whether they were signed completely by the same group of people under the same conditions.” The corporate seals in the three images are likely to be impressions made by the same corporate seal at different times or on different documents.

8. Qianwen’s conclusion. Signature handwriting: The signatures of all individuals in the three images are completely identical, and should be signed by the same person. Corporate seal: The corporate seals in the three images are impressions made by the same physical corporate seal.

9. Doubao’s conclusion is.

Signature handwriting: In the three images, the signatures of all directors, senior executives, and audit committee members are from the same source set of original signatures, with no traces of forgery, replacement, or alteration; the handwriting is completely consistent.

Corporate seal: The corporate seals in the three images are all impressions made using the same physical corporate seal of Zhejiang Xingxing Tools Co., Ltd. The only normal differences are in the way the seal is affixed (electronic seal / physical stamp), the darkness of the ink pad, scan clarity, and the angle of affixing; the corporate seal itself is the same.

Compliance statement: The three documents are submission documents at different stages of the Zhejiang Xingxing Tools IPO project (the 2024 version submitted for review by the meeting, and the two 2026 submission drafts). The consistency between the signatures and the corporate seals fully meets the compliance requirements for signing the prospectus under the《Measures for the Administration of Initial Public Offering and Listing》. However, the handwritten signatures being “completely identical handwriting,” across versions and across dates in the IPO submission documents, is absolutely non-compliant. It directly violates regulatory requirements such as the《Administrative Measures for the Registration of IPOs of Shares》, and constitutes a serious violation of forgery / alteration of signatures. It is not a compliant situation.

10. AI is indeed powerful. From my personal view, the stamps on the two submission drafts of the company are the same; the version submitted for the meeting review is different. But based on Doubao’s conclusion, the two submission drafts may use an electronic seal, while the version submitted for the meeting review is what the secretary of the board affixed by hand. That should be compliant. However, regardless of whether it’s me or the AI, we both believe that the signatures of all executives in the three versions are seemingly completely identical. Because the core characteristic of handwritten signatures by natural persons is uniqueness and non-repeatability: handwriting signed by the same person on different dates and on different pieces of paper will inevitably have minor differences in pen pressure, continuous-stroke details, tilt angle, and spacing between positions—so it cannot be 100% exactly identical. But whether it is specifically the secretary of the board and the underwriter copying and PS’ing needs the regulators to check the original working papers, or to ask a professional institution to authenticate it. After all, AI can’t replace doctors, just like AI diagnosing illnesses.

11 Article 36 of the《Administrative Measures for the Registration of IPOs of Shares》: The issuer and its directors, supervisors, and senior management personnel shall sign and affix seals on the prospectus truthfully, and ensure that the content of the prospectus is true, accurate, and complete, with no false records, misleading statements, or material omissions. They shall fulfill their commitments in accordance with the principle of good faith and bear corresponding legal liabilities.

• Article 52 of the《Administrative Measures for the Initial Public Offering and Listing of Shares》（current effective regulatory interpretation）: If the signatures and seals of the issuer or its directors, supervisors, or senior management personnel are forged or altered, in addition to penalties under the《Securities Law》, the CSRC will take regulatory measures to terminate the review and not accept the issuer’s application for issuance of shares within 36 months.

Screenshots of the signature pages in the three submission drafts and the meeting-review submission draft

Baidu Wenxin

By carefully comparing the three images, we can draw the following analysis regarding signature handwriting and the corporate seal:

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Signature handwriting

Director signatures:

Zhu Dongwei, Zhu Hulin, Yao Hongfei, Tang Xueguang, Zhu Lixiang, Wang Shulin, Zha Guobin: These signatures appear basically identical across the three images; the handwriting style and writing habits are similar.

Other signatures (if there are differences): Because signatures may be signed by different people at different times, or handwriting may vary when the same person signs at different times, it is difficult to determine whether they were signed by the same person solely based on the appearance of the signatures. However, from the images, these signatures maintain a certain level of consistency in form.

Signatures of senior executives and members of the audit committee:

Zhu Hongmei and Yu Qijuan’s signatures are also consistent across the three images.

The audit committee members Zhu Lixiang, Wang Shulin, and Zha Guobin’s signatures are also consistent across the three images.

Overall, because signatures may be affected by multiple factors (such as the time of signing, signing environment, and signer condition, etc.), although the signatures in the three images are similar in form, it is impossible to determine from the images alone whether they were signed completely by the same group of people under the same conditions.

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Corporate seal

Corporate seal content: The corporate seal content in all three images is “Zhejiang Xingxing Tools Co., Ltd.”, and the font, layout, etc. remain consistent.

Corporate seal clarity: From the images, the clarity of the corporate seals in the three images is similar; there is no obvious blur or difference.

Corporate seal angle: The angle of the corporate seal in the three images is also consistent, with no obvious rotation or tilt.

Based on the observations above, the corporate seals in the three images are likely to be impressions made using the same corporate seal at different times or on different documents. However, to determine whether the corporate seals are completely the same, it is also necessary to consider multiple factors such as the physical characteristics of the corporate seal and the impression environment. These factors cannot be accurately assessed from the images alone.

If a more accurate judgment is needed, it is recommended to further verify the original documents or contact the relevant signatories to confirm.

Ali Qianwen

Okay, I have received your request. I will perform a detailed comparative analysis of the signatures and corporate seals in these three images.

Answering process

To give you an accurate response, I will proceed in two steps: first, compare the handwriting signatures of all individuals, and then analyze the company’s corporate seal at the bottom right.

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Signature handwriting comparison

I reviewed one by one the handwriting of each signer in the three images, including all individuals under the three categories: “directors,” “senior executives other than directors,” and “members of the audit committee.”

• Directors:

• • Zhu Dongwei, Zhu Hulin, Yao Hongfei, Tang Xueguang, Zhu Lixiang, Wang Shulin, Zha Guobin

• Senior executives other than directors:

• • Zhu Hongmei, Yu Qijuan

Comparison results:

After careful comparison, all individuals’ signatures across the three images show a high degree of consistency in writing style, stroke continuity, character structure, and tilt angle. Although there may be minor differences in ink density or details due to handwriting and scanning, overall it can be determined that these signatures are all made by the same person. No signs of forgery or someone else signing on their behalf were found.

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Corporate seal comparison

Next, I analyzed the red corporate seal of “Zhejiang Xingxing Tools Co., Ltd.” at the bottom right of the three images.

2. Content and style: The textual content (company name), font, and the five-point star pattern in the center of the three corporate seals are completely identical.

4. Clarity and color: The red ink pad color, clarity, and ink distribution among the three corporate seals differ slightly.

• The corporate seals in the first image (date is January 16) and the second image (date is February 27) are relatively clear.

• The corporate seal in the third image (date is March 20) is slightly blurred in some strokes. This may be due to uneven pressure when sealing, or differences in the condition of the paper and the ink pad.

Angle and position: The sealing angle and the position relative to the text of the three corporate seals are basically the same, but there are very subtle shifts and rotations, which matches the normal situation that each manual stamping cannot be reset with perfect precision.

Key identifying features: During the production and use of a corporate seal, some unique physical characteristics are formed that are difficult to change—such as tiny nicks on the edges, spots or scratches on the seal surface. I carefully compared these detail characteristics of the three corporate seals and found they match exactly. For example, some minor defects in the seal edge and internal text appear at the exact same positions across the three images.

Comparison results:

Although there are minor, normal differences in clarity and sealing position caused by manual operations, based on the core physical characteristics of the corporate seal, the three images use the same physical corporate seal.

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Final conclusion

Based on the analysis above, the following conclusions can be drawn:

• Signature handwriting: The signatures of all individuals in the three images are completely identical and should be signed by the person themselves.

• Corporate seal: The corporate seals in the three images are impressions made using the same physical corporate seal.

Doubao

Doubao

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Comparison analysis of the signatures and corporate seals in Zhejiang Xingxing Tools’ prospectus

1. Comparative analysis of signatures by person (annotated version)

I have annotated all signatures in the three images person by person and stroke by stroke, clearly showing the consistency of the handwriting:

Figure 1 (submission draft dated 2026.1.16) signature annotation

• Director section: Zhu Dongwei, Zhu Hulin, Yao Hongfei, Tang Xueguang, Zhu Lixiang, Wang Shulin, Zha Guobin

• Executive section: Zhu Hongmei, Yu Qijuan

• Audit committee section: Zhu Lixiang, Wang Shulin, Zha Guobin

Figure 2 (submission draft dated 2026.2.21) signature annotation

• All signatures’ stroke trajectories, continuous-stroke structures, signature outlines, and Figure 1 match 100%; there are no visually identifiable differences in handwriting. They are repeated printouts of the same original set of signatures.

Figure 3 (meeting-review submission draft dated 2024.3.26) signature annotation

• The core forms and continuous-stroke logic of all signatures are completely identical to Figure 1 / Figure 2. Only differences exist in the ink darkness and line thickness caused by printing / scanning. These are different physical carrier versions of the same person signing with the same signature, with no traces of forgery or replacement.

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Row-by-row authentication statement for the signatures and corporate seals in Zhejiang Xingxing Tools’ prospectus

1. Comparative analysis of signatures by person (annotated version)

I have annotated all signatures in the three images person by person and stroke by stroke, clearly showing the consistency of the handwriting:

Figure 1 (submission draft dated 2026.1.16) signature annotation

• Director section: Zhu Dongwei, Zhu Hulin, Yao Hongfei, Tang Xueguang, Zhu Lixiang, Wang Shulin, Zha Guobin

• Executive section: Zhu Hongmei, Yu Qijuan

• Audit committee section: Zhu Lixiang, Wang Shulin, Zha Guobin

Figure 2 (submission draft dated 2026.2.21) signature annotation

• All signatures’ stroke trajectories, continuous-stroke structures, signature outlines, and Figure 1 match 1100%; there are no visually identifiable differences in handwriting. They are repeated printouts of the same original set of signatures.

Figure 3 (meeting-review submission draft dated 2024.3.26) signature annotation

• The core forms and continuous-stroke logic of all signatures are completely identical to Figure 1 / Figure 2. Only differences exist in the ink darkness and line thickness caused by printing / scanning. These are different physical carrier versions of the same person signing with the same signature, with no traces of forgery or replacement.

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3. Corporate seal comparison by dimension and authentication

1. Core information of the corporate seal

• Corporate seal entity: Zhejiang Xingxing Tools Co., Ltd.

• Unified Social Credit Code / Registration number: 33042410039097 (Figure 3 is fully visible; Figures 1 / 2 are blurred due to light stamping / electronic seal)

• Style: Circular with a five-point star in the middle, with the company name surrounding it; it meets national standards for corporate seals

2. Detailed comparison of the corporate seals in the three images

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4. Final formal authentication conclusion

2. Signature handwriting: The signatures of all directors, senior executives, and audit committee members in the three images are all from the same source version of the original signatures, with no traces of forgery, replacement, or alteration; the handwriting is completely consistent.

4. Corporate seal: The corporate seals in the three images are impressions made using the same physical corporate seal of Zhejiang Xingxing Tools Co., Ltd. The only normal differences are in the stamping method (electronic seal / physical fresh seal), the darkness of the ink pad, scan clarity, and the stamping angle; the corporate seal itself is the same.

6. Compliance statement: The three documents are submission documents at different stages of the Zhejiang Xingxing Tools IPO project (the 2024 meeting-review draft and two 2026 submission drafts). The consistency between the signatures and the corporate seals fully complies with the compliance requirements for signing the prospectus under the《Administrative Measures for the Administration of Initial Public Offering and Listing》. However, handwritten signatures being “completely identical handwriting” are absolutely non-compliant in IPO submission documents across versions and across dates, directly violating regulatory requirements such as the《Administrative Measures for the Registration of IPOs of Shares》. This is a serious violation of forging / altering signatures and is absolutely not a compliant situation.

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5. Supplementary notes (for use in a formal report)

• Core basis for handwriting consistency: Personal handwriting characteristics such as the way the pen starts, how it moves, how it ends, the continuous-stroke structure, and the overall outline of the signatures match completely, in line with the core standards for handwriting identity authentication.

• Core basis for corporate seal consistency: The corporate seal’s text layout, the position of the five-point star, font style, registration number, and other unique identifiers are completely consistent. Differences in clarity and angle are caused by physical stamping / scanning and do not affect the corporate seal’s identity.

Electronic seal vs physical seal: Complete breakdown of the core differences

Based on the Zhejiang Xingxing Tools prospectus documents you provided, I’ll provide you with a clear comparison statement that can be used directly in practice, across dimensions such as legal effect, visual characteristics, usage scenarios, and anti-forgery methods.

1. Core definitions

• Physical seal (tangible corporate seal): A metal / rubber stamp corporate seal filed with the public security authorities, which is stamped on paper by dipping in ink pad—this is the traditional form of corporate seal.

• Electronic seal (electronic corporate seal): Based on the《Electronic Signature Law》, issued by a third-party CA institution and a digital certificate consistent with the appearance of a physical seal. It is affixed on electronic documents using electronic signature technology. In essence, it is a digital signature plus a visual seal image style.

3. Precisely distinguish based on the documents you provided

1. Figure 3 (meeting-review draft dated 2024.3.26): physical fresh seal

• Key identifying points:

• • The color is dark red, with evenly distributed ink density; it has the ink texture of a physical seal impression;

  • The corporate seal edges are clear and sharp. The company name, five-point star, and registration number 33042410039097 are fully discernible;

  • The stamping angle is close to a perfect circle, which is the normal state of manual stamping;

  • Used for paper meeting-review drafts; it meets the requirement for original physical seal documents in IPO submissions.

2. Figures 1 / 2 (submission draft dated 2026.1.16 / 2.21): electronic seal

• Key identifying points:

• • The color is light pink, with uniform color and no variation in ink density; it does not have the ink smearing/halo characteristic of a physical seal;

  • The corporate seal edges are soft and blurred, and the registration number cannot be fully recognized—this is a feature of template printing / scanning for an electronic seal;

  • The corporate seal angle, style, and clarity are completely identical between the two images; it is repeated stamping using the same electronic seal template;

  • Used for electronic submission drafts; it complies with the CSRC’s requirements for online electronic seal stamping.

In IPO submissions, executive signatures absolutely cannot be used in the form “after one handwritten signature, directly copy / duplicate / PS into multi-version documents”—this constitutes forgery and alteration of signatures and is a serious violation.

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1. Rules and risks (directly compare)

• Red lines in regulations

• • The《Registration Administration Measures》 and the《Securities Law》 clearly state: signatures must be signed by the person themselves, ensuring they are true, accurate, and complete.

  • Forged or altered signatures: the CSRC may terminate the review, not accept the filing for 3–5 years, and pursue legal liability.

• Practical recognition (cases you are focusing on, such as Xingxing Tools)

• • In multi-version prospectuses and Q&A responses, if executives’ handwriting is completely identical and the continuous-stroke strokes / angles / positions are exactly the same, it is directly recognized as copied and duplicated signatures, not signed by the person themselves.

  • For different documents signed by the same person on close dates, normal handwriting must have minor differences; completely identical handwriting indicates suspected falsification.

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2. What constitutes compliant “signature reuse” (only 2 legally valid types)

1. Compliant electronic signature (CA certificate; verifiable) ✅

• Executives complete a one-time real-name collection on the CA platform / via the electronic business license (handwritten / handwriting tablet).

• For subsequent online signing in the IPO system and brokerage systems: each time, an electronic signature with a timestamp is generated; it is tamper-evident, and can be verified.

• Visual appearance: consistent each time, but legal, traceable, and recognized by the exchange.

2. “Signature page reuse” within the same version (only for the same submission round) ✅

• The same prospectus and the same Q&A round: one time personally signed → color scanned → used for the electronic version.

• Prerequisite: applicable only to the same document, the same submission round, and signatures on the same day.

3. Absolutely prohibited: copy-paste (violation scenario) ❌

• Cross-version copying: signatures in the 2026 version prospectus → directly copied into the 2026 second version and the 2026 Q&A responses.

• Cross-date copying: signatures in 2025 → copied into 2026 documents, only changing the date.

• PS / image pasting: turn signatures into an image, paste into different PDFs, with no digital signature and not verifiable.

• Consequences:

• • Exchange / CSRC asks questions and challenges, requiring re-signing and lawyer authentication.

  • If serious: suspension / termination of review, and recorded in the integrity file by the China Securities Regulatory Commission.

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4. IPO practice standards (how to sign safely)

2. For each version of the prospectus and each round of Q&A: you must re-sign

• New version = new content = new responsibility = must be personally handwritten again / electronically signed again.

Electronic signatures are preferred (recommended)

• Use CA electronic signatures: one-time collection; each time you sign online, it leaves a trail and is verifiable.

Paper signatures: color scanning + keep the original on file

• For the same version document: one-time personal signing → color scanning → electronic version; archive the original.

Intermediaries (broker / lawyers / accountants): must re-sign for each version

• Intermediary signatures absolutely cannot be copied; the exchange will focus on comparing.

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5. One-sentence conclusion (IPO practice wording)

Handwritten signatures: only for scan reuse within the same version and same submission round; copying across versions or across dates = forgery, a serious violation.

Compliant approach: use CA electronic signatures (reusable legally) or personally re-sign for each version file.

Massive information and precise interpretation are all in the Sina Finance APP

责任编辑：石秀珍 SF183