CSRC Consultation on the Regulations on the Supervision and Administration of Listed Companies

We refer to China Securities Regulatory Commission's (CSRC) invitation to comment on draft Regulations on the Supervision and Administration of Listed Companies (the Regulations) and welcome the opportunity to provide feedback. We commend CSRC's initiative to consolidate and strengthen the regulatory framework for listed companies through this comprehensive administrative regulation.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with USD 1.94 trillion (CNY 13.9 trillion) as of 30 June 2025, of which approximately USD 48.7 billion (CNY 349.14 billion) was invested in the shares of 662 Chinese or China incorporated listed companies.

As an investor with around 70 percent of our holdings in listed equity, we depend on thriving public markets that foster long-term value creation. Robust minority shareholder protection is fundamental to well-functioning capital markets. Strong protections ensure fair treatment, facilitate information flows, and support an effective market for corporate control – all of which directly impact our long-term investment returns. The Regulations represent a significant advance in China's corporate governance framework, with investor protection as the foundational principle. We therefore welcome CSRC's efforts to strengthen these safeguards.

Please find our responses and recommended enhancements to selected articles in the annex, grounded in our Global Voting Guidelines. We shared some of these views during the CSRC consultation on the Corporate Governance Code. [1] We thank you for considering our perspective and remain at your disposal should you wish to discuss these matters further.

Yours sincerely

Carine Smith Ihenacho                                                                  
Chief Governance and Compliance Officer                    

Jeanne Stampe                 

Lead Policy Advisor

[1] Consultation on the Corporate Governance Code for Listed Companies (Revised Draft for Comments) | Norges Bank Investment Management