SecProbe.io

November 5, 2024
Toby Guanhua Wu
Chief Financial Officer
Aesthetic Medical International Holdings Group Limited
1122 Nanshan Boulevard
Nanshan District, Shenzhen
Guangdong Province, China 518052
Re:Aesthetic Medical International Holdings Group Limited
20-F for Fiscal Year Ended December 31, 2023
Response Letter dated October 23, 2024
File No. 1-39088
Dear Toby Guanhua Wu:
            We have reviewed your October 23, 2024 response to our comment letter and have
the following comment. Please respond to this letter within ten business days by providing
the requested information or advise us as soon as possible when you will respond. If you do
not believe a comment applies to your facts and circumstances, please tell us why in your
response. After reviewing your response to this letter, we may have additional comments.
Response Letter dated October 23, 2024
Risks relating to doing business in the PRC
We note your response to previous comment 1 with proposed revised disclosure
regarding the legal and operational risks associated with doing business in the PRC.
We also note that in your August 27, 2024 response letter, you had proposed to
include the following disclosure further on in the same paragraph:

"In particular, the operational risks associated with being based in and having
operations in mainland China may also apply to operations in the special
administrative regions of Hong Kong. With respect to the legal risks associated with
being based in and having operations in mainland China,  the laws, regulations and the
discretion of the governmental authorities in mainland China discussed in this annual
report are expected to apply to entities and businesses in mainland China, rather than
entities or businesses in Hong Kong  which operate under different sets of laws from
mainland China. However, the legal risks associated with being based in and having
operations in mainland China could apply to the operations in Hong Kong, if the laws,
regulations and the discretion of the governmental authorities in mainland China 1.

November 5, 2024
Page 2
become applicable to entities and businesses in Hong Kong in the future ." (emphasis
added)

Please confirm you will revise these subsequent statements so that your disclosure
expressly states that the legal and operational risks associated in operating in the PRC
apply to your present operations in Hong Kong. In this regard, we note that while the
proposed language from your October 23, 2024 response letter appears sufficient to
highlight the risk that the PRC government may intervene or influence your
operations in Hong Kong at any time, the subsequent language quoted above would
continue to suggest that the legal risks associated with being in and having operations
in mainland China do not apply to your operations in Hong Kong at the current stage.
            Please contact Conlon Danberg at 202-551-4466 or Margaret Sawicki at 202-551-
7153 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services