China Communications Construction Company Limited (China Comm Cons) has proposed to amend and extend its existing undertakings designed to eliminate horizontal competition with its subsidiary, CCCC Design Consulting Group Co., Ltd. (CCCC Design). The revised commitment seeks an additional three-year window—beginning upon approval by CCCC Design’s shareholders—to resolve overlapping operations in road and municipal design, supervision, and related general contracting services.

Key elements of the proposed “Letter of Supplemental Undertakings II” include:

1. Consulting Corporation • The company cites weaker infrastructure investment and declining returns at China Highway Engineering Consulting Corporation (Consulting Corporation) as reasons the unit no longer meets injection criteria, which require any acquired assets to enhance earnings per share and strengthen CCCC Design’s financial position. • China Comm Cons plans to place Consulting Corporation’s core road and municipal design units and its supervision arm under entrusted management by CCCC Design during the extension period. • Equity transfer or other restructuring measures remain under consideration, with a potential acquisition to be pursued once the unit’s financial metrics satisfy the stipulated injection conditions.

2. Water Transportation Institutes • The five Water Transportation Institutes—each a subsidiary of China Comm Cons—currently exhibit lower returns on net assets than CCCC Design. High exposure to process-driven EPC projects and limited road/municipal design volumes have made divestment challenging. • China Comm Cons now commits to reduce and ultimately cease the institutes’ independent road and municipal design and supervision activities within the extended three-year period, rather than injecting them into CCCC Design.

3. General Contracting Business • Consulting Corporation will be required to wind down its general contracting operations “as soon as practicable,” reinforcing the separation of businesses.

Rationale and Compliance The board argues that immediate asset injections would not meet the prerequisites of improving CCCC Design’s asset quality or profitability, given current market headwinds and subdued performance at the affected subsidiaries. Under Article 13 of the China Securities Regulatory Commission’s Guideline No. 4, undertakings may be altered if performance has become impractical or detrimental to the listed company’s interests; China Comm Cons asserts the proposed changes fall squarely within this provision.

Next Steps The amendments are conditional upon approval at CCCC Design’s forthcoming shareholders’ meeting. The company will provide further disclosures in line with Hong Kong Listing Rules. Investors are advised to monitor subsequent announcements for final outcomes of the undertaking revisions.