Correspondence 0001213900-23-097834 from First High-School Education Group Co., Ltd. (CIK 0001786182)
First High-School Education Group Co., Ltd. (CIK 0001786182)
Date: Dec. 22, 2023 · CIK: 0001786182 · Accession: 0001213900-23-097834
AI Filing Summary & Sentiment
File numbers found in text: 001-40150
Referenced dates: December 8, 2023, October 18, 2023
Letter
First High-School Education Group Co., Ltd.
No. 1-1, Tiyuan Road, Xishan District,
Kunming, Yunnan Province 650228,
People’s Republic of China
VIA EDGAR
December 22, 2023
Division of Corporation Finance
Office of Trade & Services
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: First High-School Education Group Co., Ltd. (the “Company”)
Responses to the Staff’s Comments on
Form 20-F for the Fiscal Year Ended December 31, 2022 Filed May 1, 2023
And Correspondence Filed October 18,
File No. 001-40150
Ladies and Gentlemen,
This letter sets forth the Company’s responses to the comment letter from the staff (the “Staff”) of the Securities and Exchange Commission dated December 8, 2023 relating to the above referenced filing in connection with the Form 20-F for the fiscal year ended December 31, 2022 filed on May 1, 2023 (the “2022 Form 20-F”).
The Staff’s comments are repeated below in bold and are followed by the Company’s responses.
Correspondence Filed October 18, 2023
Introduction, page ii
1. We note your revised disclosure in response to comment 5. Please further revise to also include a cross reference to the condensed consolidating schedules in your proposed disclosure in response to comment 11.
RESPONSE: In response to the Staff’s comment, the Company intends to revise the proposed disclosures in the response to the Company’s response letter dated October 18, 2023 as follows (marked by underlines and strikethroughs), and undertakes to revise the relevant disclosure in its future Form 20-F filings as follows, subject to such updates and adjustments to be made in connection with any material developments of the subject matter being disclosed.
“INTRODUCTION
…
Our Holding Company Structure and Contractual Arrangements with the VIE
…
December 22, 2023
Page 2
Cash and Asset Flows through Our Organization
…
Our PRC subsidiaries received RMB282.4 million, RMB137.7 million and RMB122.9 million from the VIE in 2020, 2021 and 2022, respectively, which include cash advances and service fees made by the VIE to our PRC subsidiaries for daily operations. The VIE received RMB43.0 million, RMB270.8 million and RMB139.6 million from our PRC subsidiaries in 2020, 2021 and 2022, respectively, which include the repayment of aforementioned cash advances for daily operations. For more information relating to cash and asset flows through our organization, see information disclosed in “—Financial Information Related to the VIE.” For risks relating to our corporate structure, see “Item 3. Key Information—D. Risk Factors—Risks Related to Our Corporate Structure—If the PRC government determines that the contractual arrangements constituting part of the VIE structure do not comply with PRC regulations, or if these regulations change or are interpreted differently in the future, we may be unable to assert our contractual rights over the assets of the VIE, and our ADSs or ordinary shares may decline in value or become worthless.”
“ITEM 5. OPERATING AND FINANCIAL REVIEW AND PROSPECTS
B. Liquidity and Capital Resources
…
In 2020, 2021 and 2022, First High-School Education Group Co., Ltd. did not make any capital contribution or loans to our PRC subsidiaries or VIE except that First High-School Education Group Co., Ltd. made loans of RMB63.2 million to Yunnan WFOE in 2021. Our PRC subsidiaries received RMB282.4 million, RMB137.7 million and RMB122.9 million from the VIE in 2020, 2021 and 2022, respectively, which include cash advances and service fees made by the VIE to our PRC subsidiaries for daily operations. The VIE received RMB43.0 million, RMB270.8 million and RMB139.6 million from our PRC subsidiaries in 2020, 2021 and 2022, respectively, which include the repayment of aforementioned cash advances for daily operations. For more information relating to cash and asset flows through our organization, see information disclosed in “Introduction—Financial Information Related to the VIE.”
2. We note your response to comment 8 and reissue in part. Provide a diagram of the company’s corporate structure, identifying the person or entity that owns the equity in each depicted entity, such as the diagram included on page 69. Ensure that, with respect to relationships with the VIE, the diagram uses dashed lines without arrows, and make conforming changes on page 69. In this regard, we note your diagram on page 69 includes dashed lines with arrows.
RESPONSE:
* Shareholders of First High-School Education Group Co., Ltd. include Visionsky Group Limited, Long-Spring Education Management Limited, Long-Spring Education International Limited, Minglin Wu, Brightenwit Group Limited, others and public shareholders. See “Item 6. Directors, Senior Management and Employees—E. Share Ownership” for more details.
December 22, 2023
Page 3
(1) Mr. Shaowei Zhang and Ms. Yu Wu hold 86.76% and 9.64% equity interests in Long-Spring Education, respectively. The remaining 3.6% equity interests of Long-Spring Education are held by five limited partnerships established to hold interests for certain of our employees.
(2) The 10 schools comprise Kunming Xishan Long-Spring Experimental Secondary School, Kunming Chenggong Long-Spring Experimental Secondary School, Yiliang Long-Spring Experimental Secondary School, Qujing Hengshui Experimental Secondary School, Yunnan Yuxi Hengshui Experimental High School, Yunnan Hengshui Experimental Secondary School—Xishan School, Yunnan Long-Spring Foreign Language Secondary School, Zhenxiong Long-Spring Advanced Secondary School, Qiubei Long-Spring Experimental Secondary School, and Mengla Long-Spring Experimental Secondary School.
(3) We have registered Xinping Long-Spring Advanced Secondary School as Xinping Long-Spring Advanced Secondary School Co., Ltd., and Xishuangbanna Long-Spring Experimental Secondary School as Xishuangbanna Long-Spring Experimental Secondary School Co., Ltd., all of which were registered as for-profit private schools.
(4) As the private school operation permit for Hengshizhong Education Tutorial School has been cancelled, we diverted its Gaokao repeater program and extra-curricular services related programs to Yunnan Long-Spring Education Holding Group Hengshui Experimental Middle School Management Co., Ltd, Kunming Wuhua District Zhuorui Cultural Training School Co., Ltd., and Kunming Guandu Hengshizhong Education Training School Co., Ltd. We have registered Guizhou Zunyi Tutorial School as Zunyi Hengshi Education Technology Co., Ltd. We have registered Shaanxi Hengshi Tutorial School as Shaanxi Hengshi Hengzhong Education Technology Co., Ltd.
(5) The seven regional new vocational education companies comprise Guizhou New Vocational Education Technology Co., Ltd., Guangxi New Vocational Education Technology Co., Ltd., New Vocational Education (Hebei) Education Technology Co., Ltd., New Vocational Education (Henan) Education Technology Co., Ltd., New Vocational Education (Yunnan) Cultural Development Co., Ltd., New Vocational Education (Shandong) Cultural Development Co., Ltd., and New Vocational Education (Chengdu) Cultural Development Co., Ltd.
December 22, 2023
Page 4
In response to the Staff’s comment, the Company undertakes to revise the diagram of the Company’s corporate structure disclosed in “Item 4. Information of the Company—C. Organizational Structure” of the 2022 Form 20-F to remove the arrows for dashed lines with respect to relationships with the VIE, as illustrated in the diagram above (marked by underlines for the footnote newly added). The Company undertakes to update and disclose the revised corporate structure together with its footnotes to the section headed “Our Holding Company Structure and Contractual Arrangements with the VIE” in the beginning of the Introduction section in its future Form 20-F filings.
3. We note your response to comment 10 and reissue in part. State affirmatively whether you have received all requisite permissions or approvals and whether any permissions or approvals have been denied with respect to your ability to offer securities to investors, as you have done with respect to your business operations. In addition, you disclose that you were “advised” by counsel, but it is still unclear whether you obtained an opinion of counsel with respect to your conclusions regarding CSRC and CAC approval and that you do not need any additional permissions and approvals to operate your business. Please revise to clarify, and if you did not rely on an opinion of counsel, state as much and explain why such an opinion was not obtained. In addition, please update your proposed disclosure to disclose with specificity each permission or approval you, your subsidiaries, or the VIE are required to obtain. Lastly, the proposed disclosure here should not be qualified by materiality. Please make appropriate revisions to your disclosure.
RESPONSE: In response to the Staff’s comment, the Company intends to revise the proposed disclosures in the response to the Company’s response letter dated October 18, 2023 as follows (marked by underlines and strikethroughs), and undertakes to revise the relevant disclosure in its future Form 20-F filings as follows, subject to such updates and adjustments to be made in connection with any material developments of the subject matter being disclosed.
“INTRODUCTION
…
Permissions Required from the PRC Authorities for Our Securities Offerings and Operations
Our operations in China are governed by PRC laws and regulations. As advised by Based on the opinion of our PRC legal counsel, Beijing Zhongwen Law Firm, as of the date of this annual report, we, our PRC subsidiaries, the VIE and our affiliated entities in China have obtained all requisite permissions and approvals from the PRC government authorities that are material for our business operations in China, have not been denied such permissions and approvals and have not received any requirement to obtain any other permission or approval from any PRC government authority with respect to the operation of our business, nor have we been denied or dismissed by any government authority of any application of permissions or approvals that are necessary to the operations of our business, except for (1) Shaanxi Hengshi Tutorial School, and (2) Shaanxi Hengshui Experimental Middle School, which are still in the process of obtaining a private school operation permit and registering with the local market supervision and administration department or the local civil affairs bureau, and (3) Hengshizhong Education Tutorial School for which the private school operation permit has been cancelled and the school ceased operation since 2023. For such schools that conduct business before we can obtain a private school operation permit, we may be subject to order to cease our operation, refund the income we collected and a fine ranging from one to five times of the income the sponsor collected, which may materially and adversely affect our business and results of operations. For relevant risks, see “Item 3. Key Information—D. Risk Factors—Risks Related to Our Business and Industry—We may be unable to obtain all required approvals, licenses and make all required registrations for our education services and business operations, and may be subject to fines and penalties if the operations of our business do not comply with applicable PRC laws and regulation.” The relevant requisite permissions and approvals primarily include namely business licenses, private non-enterprise legal person unit registration certificates, and private school operation permits. We set forth below the details of all these licenses and permissions held by our PRC subsidiaries as of December 31, 2022.
Holding Entity License/Permission Issuing Authority
Yunnan Century Long-Spring Technology Co., Ltd. Business license State Administration for Market Regulation
Yunnan Long-Spring Logistics Service Co., Ltd. Business license State Administration for Market Regulation
Long-Spring Education Holding Group Limited Business license State Administration for Market Regulation
Kunming Xishan Long-Spring Experimental Secondary School
Private non-enterprise unit registration certificate; Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
Kunming Chenggong Long-Spring Experimental Secondary School
Private non-enterprise unit registration certificate;
Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
Yiliang Long-Spring Experimental Secondary School
Private non-enterprise unit registration certificate;
Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
Qujing Hengshui Experimental Secondary School
Private non-enterprise unit registration certificate;
Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
Yunnan Yuxi Hengshui Experimental High School
Private non-enterprise unit registration certificate;
Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
December 22, 2023
Page 5
Holding Entity License/Permission Issuing Authority
Yunnan Hengshui Experimental Secondary School—Xishan School
Private non-enterprise unit registration certificate;
Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
Yunnan Long-Spring Foreign Language Secondary School
Private non-enterprise unit registration certificate;
Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
Zhenxiong Long-Spring Advanced Secondary School
Private non-enterprise unit registration certificate;
Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
Qiubei Long-Spring Experimental Secondary School
Private non-enterprise unit registration certificate;
Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
Mengla Long-Spring Experimental Secondary School
Private non-enterprise unit registration certificate;
Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
Wenshan Long-Spring Experimental Secondary School
Private non-enterprise unit registration certificate;
Private school operating permit
Ministry of Civil Affairs of the PRC
Ministry of Education of the PRC
Xinping Long-Spring Advanced Secondary School Co., Ltd.
Business license;
Private school operating permit
State Administration for Market Regulation
Ministry of Education of the PRC
Xishuangbanna Long-Spring Experimental Secondary School Co., Ltd.
Business license;
Private school operating permit
State Administration for Market Regulation
Ministry of Education of the PRC
Yangling Hengshui Experimental Middle School Process of obtaining license and permit N/A
Kunming Wuhua District Zhuorui Cultural Training School Co., Ltd
Business license;
Private school operating permit
State Administration for Market Regulation
Ministry of Education of the PRC
Kunming Guandu Hengshizhong Education Training School Co., Ltd. Business license State Administration for Market Regulation
Zunyi Hengshi Education Technology Co., Ltd.
Business lic
Show Raw Text
CORRESP
1
filename1.htm
First High-School Education Group Co., Ltd.
No. 1-1, Tiyuan Road, Xishan District,
Kunming, Yunnan Province 650228,
People’s Republic of China
VIA EDGAR
December 22, 2023
Division of Corporation Finance
Office of Trade & Services
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
First High-School Education Group Co., Ltd. (the “Company”)
Responses to the Staff’s Comments
on
Form 20-F for the Fiscal Year Ended
December 31, 2022 Filed May 1, 2023
And Correspondence Filed October 18,
2023
File No. 001-40150
Ladies and Gentlemen,
This letter sets forth the Company’s responses
to the comment letter from the staff (the “Staff”) of the Securities and Exchange Commission dated December 8, 2023
relating to the above referenced filing in connection with the Form 20-F for the fiscal year ended December 31, 2022 filed on May 1, 2023
(the “2022 Form 20-F”).
The Staff’s comments are repeated below in
bold and are followed by the Company’s responses.
Correspondence Filed October 18, 2023
Introduction, page ii
1. We note your revised disclosure in response to comment 5. Please further revise to also include a
cross reference to the condensed consolidating schedules in your proposed disclosure in response to comment 11.
RESPONSE: In response to the
Staff’s comment, the Company intends to revise the proposed disclosures in the response to the Company’s response letter dated
October 18, 2023 as follows (marked by underlines and strikethroughs), and undertakes to revise the relevant disclosure in its future
Form 20-F filings as follows, subject to such updates and adjustments to be made in connection with any material developments of the subject
matter being disclosed.
“INTRODUCTION
…
Our Holding Company Structure and Contractual
Arrangements with the VIE
…
December 22, 2023
Page 2
Cash and Asset Flows through Our Organization
…
Our PRC subsidiaries received RMB282.4
million, RMB137.7 million and RMB122.9 million from the VIE in 2020, 2021 and 2022, respectively, which include cash advances and service
fees made by the VIE to our PRC subsidiaries for daily operations. The VIE received RMB43.0 million, RMB270.8 million and RMB139.6 million
from our PRC subsidiaries in 2020, 2021 and 2022, respectively, which include the repayment of aforementioned cash advances for daily
operations. For more information relating to cash and asset flows through our organization, see information disclosed in “—Financial
Information Related to the VIE.” For risks relating to our corporate structure, see “Item 3. Key Information—D.
Risk Factors—Risks Related to Our Corporate Structure—If the PRC government determines that the contractual arrangements constituting
part of the VIE structure do not comply with PRC regulations, or if these regulations change or are interpreted differently in the future,
we may be unable to assert our contractual rights over the assets of the VIE, and our ADSs or ordinary shares may decline in value or
become worthless.”
“ITEM 5. OPERATING AND FINANCIAL
REVIEW AND PROSPECTS
B. Liquidity and Capital Resources
…
In 2020, 2021 and 2022, First High-School
Education Group Co., Ltd. did not make any capital contribution or loans to our PRC subsidiaries or VIE except that First High-School
Education Group Co., Ltd. made loans of RMB63.2 million to Yunnan WFOE in 2021. Our PRC subsidiaries received RMB282.4 million, RMB137.7
million and RMB122.9 million from the VIE in 2020, 2021 and 2022, respectively, which include cash advances and service fees made by the
VIE to our PRC subsidiaries for daily operations. The VIE received RMB43.0 million, RMB270.8 million and RMB139.6 million from our PRC
subsidiaries in 2020, 2021 and 2022, respectively, which include the repayment of aforementioned cash advances for daily operations. For
more information relating to cash and asset flows through our organization, see information disclosed in “Introduction—Financial
Information Related to the VIE.”
2. We note your response to comment 8 and reissue in part. Provide a diagram of the company’s corporate structure, identifying
the person or entity that owns the equity in each depicted entity, such as the diagram included on page 69. Ensure that, with respect
to relationships with the VIE, the diagram uses dashed lines without arrows, and make conforming changes on page 69. In this regard, we
note your diagram on page 69 includes dashed lines with arrows.
RESPONSE:
* Shareholders of First High-School Education Group Co., Ltd.
include Visionsky Group Limited, Long-Spring Education Management Limited, Long-Spring Education International Limited, Minglin Wu, Brightenwit
Group Limited, others and public shareholders. See “Item 6. Directors, Senior Management and Employees—E. Share Ownership”
for more details.
December 22, 2023
Page 3
(1) Mr. Shaowei Zhang and Ms. Yu Wu hold 86.76% and 9.64% equity interests in Long-Spring Education, respectively. The remaining 3.6%
equity interests of Long-Spring Education are held by five limited partnerships established to hold interests for certain of our employees.
(2) The 10 schools comprise Kunming Xishan Long-Spring Experimental Secondary School, Kunming Chenggong Long-Spring Experimental Secondary
School, Yiliang Long-Spring Experimental Secondary School, Qujing Hengshui Experimental Secondary School, Yunnan Yuxi Hengshui Experimental
High School, Yunnan Hengshui Experimental Secondary School—Xishan School, Yunnan Long-Spring Foreign Language Secondary School,
Zhenxiong Long-Spring Advanced Secondary School, Qiubei Long-Spring Experimental Secondary School, and Mengla Long-Spring Experimental
Secondary School.
(3) We have registered Xinping Long-Spring Advanced Secondary School as Xinping Long-Spring Advanced Secondary School Co., Ltd., and Xishuangbanna
Long-Spring Experimental Secondary School as Xishuangbanna Long-Spring Experimental Secondary School Co., Ltd., all of which were registered
as for-profit private schools.
(4) As the private school operation permit for Hengshizhong Education Tutorial School has been cancelled, we diverted its Gaokao repeater
program and extra-curricular services related programs to Yunnan Long-Spring Education Holding Group Hengshui Experimental Middle School
Management Co., Ltd, Kunming Wuhua District Zhuorui Cultural Training School Co., Ltd., and Kunming Guandu Hengshizhong Education Training
School Co., Ltd. We have registered Guizhou Zunyi Tutorial School as Zunyi Hengshi Education Technology Co., Ltd. We have registered Shaanxi
Hengshi Tutorial School as Shaanxi Hengshi Hengzhong Education Technology Co., Ltd.
(5) The seven regional new vocational education companies comprise Guizhou New Vocational Education Technology Co., Ltd., Guangxi New
Vocational Education Technology Co., Ltd., New Vocational Education (Hebei) Education Technology Co., Ltd., New Vocational Education (Henan)
Education Technology Co., Ltd., New Vocational Education (Yunnan) Cultural Development Co., Ltd., New Vocational Education (Shandong)
Cultural Development Co., Ltd., and New Vocational Education (Chengdu) Cultural Development Co., Ltd.
December 22, 2023
Page 4
In response to the Staff’s
comment, the Company undertakes to revise the diagram of the Company’s corporate structure disclosed in “Item 4.
Information of the Company—C. Organizational Structure” of the 2022 Form 20-F to remove the arrows for dashed lines with
respect to relationships with the VIE, as illustrated in the diagram above (marked by underlines for the footnote newly added). The
Company undertakes to update and disclose the revised corporate structure together with its footnotes to the section headed
“Our Holding Company Structure and Contractual Arrangements with the VIE” in the beginning of the Introduction section
in its future Form 20-F filings.
3. We note your response to comment 10 and reissue in part. State affirmatively whether you have received
all requisite permissions or approvals and whether any permissions or approvals have been denied with respect to your ability to offer
securities to investors, as you have done with respect to your business operations. In addition, you disclose that you were “advised”
by counsel, but it is still unclear whether you obtained an opinion of counsel with respect to your conclusions regarding CSRC and CAC
approval and that you do not need any additional permissions and approvals to operate your business. Please revise to clarify, and if
you did not rely on an opinion of counsel, state as much and explain why such an opinion was not obtained. In addition, please update
your proposed disclosure to disclose with specificity each permission or approval you, your subsidiaries, or the VIE are required to obtain.
Lastly, the proposed disclosure here should not be qualified by materiality. Please make appropriate revisions to your disclosure.
RESPONSE: In response to the
Staff’s comment, the Company intends to revise the proposed disclosures in the response to the Company’s response letter dated
October 18, 2023 as follows (marked by underlines and strikethroughs), and undertakes to revise the relevant disclosure in its future
Form 20-F filings as follows, subject to such updates and adjustments to be made in connection with any material developments of the subject
matter being disclosed.
“INTRODUCTION
…
Permissions Required from the PRC Authorities
for Our Securities Offerings and Operations
Our operations in China are
governed by PRC laws and regulations. As advised by Based on the opinion of our PRC legal counsel, Beijing
Zhongwen Law Firm, as of the date of this annual report, we, our PRC subsidiaries, the VIE and our affiliated entities in
China have obtained all requisite permissions and approvals from the PRC government authorities that are material
for our business operations in China, have not been denied such permissions and approvals and have not received any requirement
to obtain any other permission or approval from any PRC government authority with respect to the operation of our business, nor have
we been denied or dismissed by any government authority of any application of permissions or approvals that are necessary to the
operations of our business, except for (1) Shaanxi Hengshi Tutorial School, and (2) Shaanxi Hengshui Experimental Middle School,
which are still in the process of obtaining a private school operation permit and registering with the local market supervision and
administration department or the local civil affairs bureau, and (3) Hengshizhong Education Tutorial School for which the private
school operation permit has been cancelled and the school ceased operation since 2023. For such schools that conduct business before
we can obtain a private school operation permit, we may be subject to order to cease our operation, refund the income we collected
and a fine ranging from one to five times of the income the sponsor collected, which may materially and adversely affect our
business and results of operations. For relevant risks, see “Item 3. Key Information—D. Risk Factors—Risks Related
to Our Business and Industry—We may be unable to obtain all required approvals, licenses and make all required registrations
for our education services and business operations, and may be subject to fines and penalties if the operations of our business do
not comply with applicable PRC laws and regulation.” The relevant requisite permissions and approvals primarily include namely
business licenses, private non-enterprise legal person unit registration
certificates, and private school operation permits. We set forth below the details of all these
licenses and permissions held by our PRC subsidiaries as of December 31, 2022.
Holding Entity
License/Permission
Issuing Authority
Yunnan Century Long-Spring Technology Co., Ltd.
Business license
State Administration for Market Regulation
Yunnan Long-Spring Logistics Service Co., Ltd.
Business license
State Administration for Market Regulation
Long-Spring Education Holding Group Limited
Business license
State Administration for Market Regulation
Kunming Xishan Long-Spring Experimental Secondary School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
Kunming Chenggong Long-Spring Experimental Secondary School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
Yiliang Long-Spring Experimental Secondary School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
Qujing Hengshui Experimental Secondary School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
Yunnan Yuxi Hengshui Experimental High School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
December 22, 2023
Page 5
Holding Entity
License/Permission
Issuing Authority
Yunnan Hengshui Experimental Secondary School—Xishan School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
Yunnan Long-Spring Foreign Language Secondary School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
Zhenxiong Long-Spring Advanced Secondary School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
Qiubei Long-Spring Experimental Secondary School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
Mengla Long-Spring Experimental Secondary School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
Wenshan Long-Spring Experimental Secondary School
Private non-enterprise unit registration
certificate;
Private school operating permit
Ministry of Civil Affairs of
the PRC
Ministry of Education of the
PRC
Xinping Long-Spring Advanced Secondary School Co., Ltd.
Business license;
Private school operating permit
State Administration for Market
Regulation
Ministry of Education of the
PRC
Xishuangbanna Long-Spring Experimental Secondary School Co., Ltd.
Business license;
Private school operating permit
State Administration for Market
Regulation
Ministry of Education of the
PRC
Yangling Hengshui Experimental Middle School
Process of obtaining license and permit
N/A
Kunming Wuhua District Zhuorui Cultural Training School Co., Ltd
Business license;
Private school operating permit
State Administration for Market
Regulation
Ministry of Education of the
PRC
Kunming Guandu Hengshizhong Education Training School Co., Ltd.
Business license
State Administration for Market Regulation
Zunyi Hengshi Education Technology Co., Ltd.
Business lic