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Ossen Innovation Co., Ltd.

osn · NASDAQ Basic Materials
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Employees 51-200
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FY2018 Annual Report · Ossen Innovation Co., Ltd.
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

FORM 20-F

(cid:133) REGISTRATION STATEMENT PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934

(cid:95) ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

OR

For the fiscal year ended December 31, 2018

OR

(cid:133) TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from _________ to _____________.

OR

(cid:133) SHELL COMPANY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

Date of event requiring this shell company report:

Commission file number: 001-34999

Ossen Innovation Co., Ltd.
(Exact name of Registrant as Specified in its Charter)

British Virgin Islands
(Jurisdiction of Incorporation or Organization)

518 Shangcheng Road, Floor 17, Shanghai, 200120, People’s Republic of China
(Address of Principal Executive Offices)

Wei Hua
Tel: +86 (21) 6888-8886 Fax: +86 (21) 6888-8666
518 Shangcheng Road, Floor 17, Shanghai, 200120, People’s Republic of China
(Name, Telephone, E-mail and/or Facsimile Number and Address of Company Contact Person)

Securities registered or to be registered pursuant to Section 12(b) of the Act:

Title of Each Class
Ordinary shares, par value US$0.01 per share *

Trading symbol
OSN

Name of Each Exchange On Which Registered
NASDAQ Capital Market

* Ordinary shares are not traded in the United States; rather they are deposited with JP Morgan Chase Bank, N.A., as Depositary. Each American Depositary 
Share represents three (3) ordinary shares.

Securities registered or to be registered pursuant to Section 12(g) of the Act:

None
(Title of Class)

Securities for which there is a reporting obligation pursuant to Section 15(d) of the Act:

None
(Title of Class)

The number of outstanding shares of each of the issuer’s classes of capital or common stock as of December 31, 2018 was: 19,791,110 ordinary shares, par 
value $0.01 per share.

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.

If this report is an annual or transition report, indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or 15(d) of the 
Securities Exchange Act of 1934.

Yes (cid:133) No (cid:95)

Yes (cid:133) No (cid:95)

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 
during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing 
requirements for the past 90 days.

Yes (cid:95) No (cid:133)

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of 
Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).

Yes (cid:95) No (cid:133)

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, or an emerging growth company. See 
definition of “large accelerated filer,” “accelerated filer” and “emerging growth company” in Rule 12b-2 of the Exchange Act. (Check one):

Large accelerated filer (cid:133) Accelerated filer (cid:133) Non-accelerated filer (cid:95)
Emerging growth company (cid:133)

If an emerging growth company that prepares its financial statements in accordance with U.S. GAAP, indicate by check mark if the registrant has elected not 
to use the extended transition period for complying with any new or revised financial accounting standards† provided pursuant to Section 13(a) of the 
Exchange Act. (cid:133)

† The term “new or revised financial accounting standard” refers to any update issued by the Financial Accounting Standards Board to its Accounting 
Standards Codification after April 5, 2012.

Indicate by check mark which basis of accounting the registrant has used to prepare the financial statements included in this filing:

(cid:95) U.S. GAAP (cid:133) International Financial Reporting Standards as issued by the International Accounting
Standards Board (cid:133) Other (cid:133)

If “Other” has been checked in response to the previous question, indicate by check mark which financial statement item the registrant has elected to follow: 
Item 17 (cid:133) Item 18 (cid:133)

If this is an annual report, indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes (cid:133) No (cid:95)

OSSEN INNOVATION CO., LTD.
FORM 20-F ANNUAL REPORT

TABLE OF CONTENTS

PART I

Item 1.
Item 2.
Item 3.
Item 4.
Item 4A.
Item 5.
Item 6.
Item 7.
Item 8.
Item 9.
Item 10.
Item 11.
Item 12.

Item 13.
Item 14.
Item 15.
Item 16.
Item 16A.
Item 16B.
Item 16C.
Item 16D.
Item 16E.
Item 16F.
Item 16G.
Item 16H.

Identity of Directors, Senior Management and Advisers
Offer Statistics and Expected Timetable
Key Information
Information On The Company
Unresolved Staff Comments
Operating And Financial Review And Prospects
Directors, Senior Management And Employees
Major Shareholders And Related Party Transactions
Financial Information
The Offer And Listing
Additional Information
Quantitative And Qualitative Disclosures About Market Risk
Description Of Securities Other Than Equity Securities

PART II

Defaults, Dividend Arrearages And Delinquencies
Material Modifications To The Rights Of Security Holders And Use Of Proceeds
Controls And Procedures
[Reserved]
Audit Committee Financial Expert
Code Of Ethics
Principal Accountant Fees and Services
Exemptions From The Listing Standards For Audit Committees
Purchases Of Equity Securities By The Issuer And Affiliated Purchasers
Change In Registrant’s Certifying Accountant
Corporate Governance
Mine Safety Disclosure

PART III

Item 17.
Item 18.
Item 19.

Financial Statements
Financial Statements
Exhibits

Page

1
1
2
18
38
38
56
60
61
61
62
72
73

75
75
75
77
77
77
78
78
78
78
78
78

79
79
79

PART I

CERTAIN INFORMATION

In this annual report on Form 20-F, unless otherwise indicated, “we,” “us,” “our,” the “Company” and “Ossen” refer to Ossen Innovation Co., Ltd., a 

company organized in the British Virgin Islands, its predecessor entities and its subsidiaries.

Unless the context indicates otherwise, all references to “China” and the “PRC” refer to the People’s Republic of China, all references to “Renminbi” 
or “RMB” are to the legal currency of the People’s Republic of China, all references to “U.S. dollars,” “dollars” and “$” are to the legal currency of the United 
States  and  all  references  to  “ADSs”  refer  to  our  American  Depositary  Shares,  each  of  which  represents  one  ordinary  share.  This  annual  report  contains 
translations of Renminbi amounts into U.S. dollars at specified rates solely for the convenience of the reader. We make no representation that the Renminbi or 
U.S. dollar amounts referred to in this report could have been or could be converted into U.S. dollars or Renminbi, as the case may be, at any particular rate or 
at all. On April 1, 2019, the cash buying rate announced by the People’s Bank of China was RMB 6.73 to $1.00.

FORWARD-LOOKING STATEMENTS

This report contains “forward-looking statements” for purposes of the safe harbor provisions of the Private Securities Litigation Reform Act of 1995 
that  represent  our  beliefs,  projections  and  predictions  about  future  events.  All  statements  other  than  statements  of  historical  fact  are  “forward-looking 
statements,” including any projections of earnings, revenue or other financial items, any statements of the plans, strategies and objectives of management for 
future  operations,  any  statements  concerning  proposed  new  projects  or  other  developments,  any  statements  regarding  future  economic  conditions  or 
performance, any statements of management’s beliefs, goals, strategies, intentions and objectives, and any statements of assumptions underlying any of the 
foregoing.  Words  such  as  “may”,  “will”,  “should”,  “could”,  “would”,  “predicts”,  “potential”,  “continue”,  “expects”,  “anticipates”,  “future”,  “intends”, 
“plans”, “believes”, “estimates” and similar expressions, as well as statements in the future tense, identify forward-looking statements.

These  statements  are  necessarily  subjective  and  involve  known  and  unknown  risks,  uncertainties  and  other  important  factors  that  could  cause  our 
actual  results,  performance  or  achievements,  or  industry  results,  to  differ  materially  from  any  future  results,  performance  or  achievements  described  in  or 
implied by such statements. Actual results may differ materially from expected results described in our forward-looking statements, including with respect to 
correct measurement and identification of factors affecting our business or the extent of their likely impact, and the accuracy and completeness of the publicly 
available information with respect to the factors upon which our business strategy is based or the success of our business.

Forward-looking statements should not be read as a guarantee of future performance or results, and will not necessarily be accurate indications of 
whether, or the times by which, our performance or results may be achieved. Forward-looking statements are based on information available at the time those 
statements are made and management’s belief as of that time with respect to future events, and are subject to risks and uncertainties that could cause actual 
performance or results to differ materially from those expressed in or suggested by the forward-looking statements. Important factors that could cause such 
differences include, but are not limited to, those factors discussed under the headings “Risk Factors”, “Operating and Financial Review and Prospects,” and 
elsewhere in this report.

ITEM 1.

IDENTITY OF DIRECTORS, SENIOR MANAGEMENT AND ADVISERS

Not Applicable.

ITEM 2.

OFFER STATISTICS AND EXPECTED TIMETABLE

Not Applicable.

1

ITEM 3.

KEY INFORMATION

3.A. Selected Financial Data

The following selected financial information should be read in connection with, and is qualified by reference to, our consolidated financial statements 
and their related notes and the section entitled “Operating and Financial Review and Prospects” included elsewhere in this annual report. The consolidated 
statements of income data for the fiscal years ended December 31, 2016, 2017 and 2018 and the balance sheet data as of December 31, 2017 and 2018 are 
derived  from  audited  consolidated  financial  statements  included  elsewhere  in  this  annual  report.  The  consolidated  statements  of  income  data  for  the  fiscal 
years ended December 31, 2014 and 2015 and the balance sheet data as of December 31, 2014, 2015 and 2016 are not included in this annual report. Our 
historical results for any prior period are not necessarily indicative of results to be expected in any future period.

Selected Consolidated Statement of
Income Data

Revenues
Cost of goods sold
Gross profit
Selling and distribution expenses
General and administrative expenses
Total Operating Expenses
Income from operations

$

2018
(Audited)

136,104,867
115,585,803
20,519,064
327,365
5,263,914
5,591,279
14,927,785

$

2017
(Audited)

132,375,915
117,721,799
14,654,116
598,832
6,002,121
6,600,953
8,053,163

$

2016
(Audited)

117,029,154
100,932,528
16,096,626
734,159
6,376,383
7,110,542
8,986,084

$

2015
(Audited)

117,908,416
102,197,994
15,710,422
986,378
4,478,413
5,464,791
10,245,631

$

2014
(Audited)

123,571,455
110,250,876
13,320,579
772,383
6,340,584
7,112,967
6,207,612

Financial expenses, net
Other income, net
Income before income taxes
Income taxes
Net income
Less: Net Income attributable to non-controlling 
interest

Net income attributable to controlling interest
Other comprehensive income
Foreign currency translation gain (loss)

(1,621,486)
208,071
13,514,370
(2,129,387)
11,384,983

(1,610,337)
147,108
6,589,934
(691,556)
5,898,378

(2,827,138)
90,584
6,249,530
(926,048)
5,323,482

(2,823,952)
371,894
7,793,573
(1,180,167)
6,613,406

(2,401,268)
907,941
4,714,285
(578,727)
4,135,558

1,005,530

553,067

499,509

716,602

276,682

10,379,453

5,345,311

4,823,973

5,896,804

3,858,876

(6,272,303)

6,606,207

(6,975,100)

(5,829,470)

779,135

Total other comprehensive income (loss)
Comprehensive Income (loss)

(6,272,303)
4,107,150

6,606,207
11,951,518

(6,975,100)
(2,151,127)

(5,829,470)
67,334

779,135
4,638,011

Weighted average shares outstanding

19,791,110

19,791,110

19,804,164

19,862,537

19,901,959

Earnings per share*

0.52

0.27

0.24

0.30

0.19

* Calculation is based on net income attributable to controlling interest and the weighted average shares outstanding, excluding foreign currency translation 
gain (loss).

2

$
$

2018
(Audited)

2017
(Audited)

$
$

3,444,421
4,070,655
155,293,023
6,952,888
162,245,911

42,182,852
120,063,059
162,245,911

950,225
7,192,928
144,640,849
7,878,057
152,518,906

37,568,527
114,950,379
152,518,906

$
$

December 31,
2016
(Audited)

217,631
6,7036242
132,259,554
8,184,198
140,443,752

37,997,958
102,445,794
140,443,752

$
$

2015
(Audited)

2014
(Audited)

$
$

812,277
8,780,443
144,772,273
9,468,260
154,240,533

50,106,311
104,134,222
154,240,533

684,592
17,572,732
159,358,503
11,405,994
170,764,497

67,355,476
103,409,021
170,764,497

Selected Balance Sheets Data

Cash and cash equivalents
Restricted cash
Total current assets
Total long-term assets
Total assets

Total liabilities
Total shareholders’ equity
Total liabilities and shareholders’ equity

3.B. Capitalization and Indebtedness

Not Applicable.

3.C. Reasons For The Offer And Use Of Proceeds

Not Applicable.

3.D. Risk Factors 

An investment in our ADSs involves a high degree of risk. You should carefully consider the risks and uncertainties described below together with all 
other information contained in this annual report, including the matters discussed under the headings “Forward-Looking Statements” and “Operating and 
Financial Review and Prospects” before you decide to invest in our ADSs. We are a holding company with substantial operations in China and are subject to 
a legal and regulatory environment that in many respects differs from the United States. If any of the following risks, or any other risks and uncertainties that 
are not presently foreseeable to us, actually occur, our business, financial condition, results of operations, liquidity and our future growth prospects could be 
materially and adversely affected.

Risks Related to Our Business and Our Industry

The proposed sale of our existing business and proposed acquisition of a new business in the medical technology industry have not been consummated, 
and such transaction will not be consummated.

On July 19, 2017, we entered into a Share Exchange Agreement (the "SEA") with the shareholders (the “Selling Shareholders”) of America-Asia 
Diabetes  Research  Foundation  (the  "Foundation"),  a  California  corporation  that  owns  90.27%  of  the  equity  interests  of  San  MediTech  (Huzhou)  Co.  Ltd. 
("San MediTech"), a China-based medical device company engaged in the research, development and marketing of glucose control products. Pursuant to the 
SEA,  we  agreed  to  acquire  all  of  the  issued  and  outstanding  equity  interests  of  the  Foundation  in  exchange  for  81,243,000  of  our  ordinary  shares  (the 
"Acquisition").  Upon  completion  of  the  Acquisition,  we  would  indirectly  own  90.27%  of  San  MediTech.  San  MediTech's  proprietary  Dynamic  Glucose 
Monitoring System ("DGMS") provides continuous, real-time monitoring of glucose level in diabetes patients, with two patents granted in China and several 
patents pending both in China and the U.S. DGMS has been approved by the China Food and Drug Administration and has entered into clinical trials in the 
U.S. for DGMS.

In  connection  with  the  Acquisition,  we  agreed  to  sell  our  existing  pre-stressed  steel  manufacturing  business,  including  all  existing  liabilities, 
immediately following the completion of the Acquisition. An entity affiliated with Dr. Liang Tang, our Chairman, agreed to acquire all of the equity of our 
wholly-owned subsidiary, which indirectly owns all of our existing operating subsidiaries, in exchange for the forfeiture and cancellation of all 11,850,000 
ordinary shares held by Dr. Tang at that time (the “Sale Transaction”).

3

The Selling Shareholders breached the SEA and as a result, the SEA and the Sale Transaction have been terminated. We may consider a transaction 
similar to the Sale Transaction along with the acquisition of another business in the future, although no such plans currently exist and there is no guarantee 
that  we  will  be  successful  in  consummating  any  such  transaction.  Any  such  transaction  would  be subject  to  the  satisfaction  of  various  closing  conditions, 
including  shareholder  approval.  Furthermore,  in  the  event  that  such  transactions  are  consummated,  the  interests  of  our  existing  shareholders  may  be 
substantially diluted.

Our  chairman  controls  a  large  percentage  of  our  outstanding  stock  through  an  entity  that  has  applied  for  listing  on  a  foreign  exchange  and  could 
significantly influence the outcome of our corporate matters.

Acme  Innovation  Limited,  an  affiliate  of  Dr.  Tang,  owns  approximately  65.9%  of  our  outstanding  ordinary  shares,  reflecting  a  majority  equity 
interest in our company. The parent entity of Acme Innovation Limited has applied for listing of its shares on a foreign exchange. See Item 4C below. As the 
controlling person of our majority shareholder, Dr. Tang is able to elect our board of directors, and determine the outcome of all matters requiring the approval 
of the holders of a majority of our outstanding shares, including the sale of our assets or an acquisition of assets. This concentration of ownership in our shares 
controlled by Dr. Tang limits your ability to influence corporate matters and may have the effect of delaying or preventing a third party from acquiring control 
over us. In addition, sales of significant amounts of ordinary shares controlled by Dr. Tang, or the prospect of these sales, could adversely affect the market 
price of our ordinary shares. Furthermore, the potential listing of our parent entity on a foreign exchange could negatively impact on the market price of our 
ordinary shares.

Our operations are cash intensive, and our business could be adversely affected if we fail to maintain sufficient levels of liquidity and working capital.

As of December 31, 2018, we had approximately $3.4 million of cash and cash equivalents and $4.1 million of restricted cash. Historically, we have 
spent a significant amount of cash on our operational activities, principally to procure raw materials for our products. Our short-term loans are from Chinese 
banks and are generally secured by a portion of our fixed assets, land use right, receivables and/or guarantees by related parties. The term of almost all such 
short-term loans is one year or less. Historically, we have rolled over such loans on an annual basis. However, we may not have sufficient funds available to 
pay  all  of  our  borrowings  upon  maturity  in  the  future.  Failure  to  roll  over  our  short-term  borrowings  at  maturity  or  to  service  our  debt  could  result  in  the 
imposition of penalties, including increases in interest rates, legal actions against us by our creditors, or even insolvency.

Although we have been able to maintain adequate working capital primarily through cash from operations and short-term borrowings, any failure by 
our  customers  to  settle  outstanding  accounts  receivable,  or  our  inability  to  borrow  sufficient  capital  from  local  banks,  in  the  future  could  materially  and 
adversely affect our cash flow, financial condition and results of operations. 

If existing sources of capital are insufficient to support our business, we may issue debt and equity securities that are senior to our ordinary shares as to 
distributions and in liquidation, which could negatively affect the value of our ordinary shares, or we may not be able to raise additional financing at all.

If available liquidity is not sufficient to meet our operating and loan obligations as they come due, our plans include considering pursuing alternative 
financing  arrangements,  reducing  expenditures  as  necessary,  or  limiting  our  plans  for  expansion  to  meet  our  cash  requirements.  However,  there  is  no 
assurance that, if required, we will be able to raise additional capital, reduce discretionary spending or efficiently limit our expansion to provide the required 
liquidity.  Currently,  the  capital  markets  for  small  capitalization  companies  are  difficult  and  banking  institutions  have  become  stringent  in  their  lending 
requirements. Accordingly, we cannot ensure the availability or terms of any third party financing. If we are unable to raise additional financing, we may be 
unable to procure the raw materials we need, implement our long-term business plan, develop or enhance our products, take advantage of future opportunities 
or respond to competitive pressures on a timely basis.

4

Alternatively,  if  we  raise  capital  by  issuing  equity  or  convertible  debt  securities,  such  issuances  could  result  in  substantial  dilution  to  our 
shareholders. In addition, we may issue senior notes, subordinated notes or preferred shares that have preference over our common equity. In the event of our 
liquidation,  any  such  lenders  and  holders  of  our  debt  or  preferred  securities  would  receive  a  distribution  of  our  available  assets  before  distributions  to  the 
holders of our ADSs. Our decision to incur debt and issue securities in future offerings will depend on market conditions and other factors beyond our control. 
We cannot predict or estimate the amount, timing or nature of future offerings and debt financings. Future offerings could reduce the value of shares of our 
ADSs or dilute your investment.

We face intense competition, and if we are unable to compete effectively we may not be able to maintain profitability.

We compete with many other companies located in the PRC and internationally that manufacture materials similar to ours. Many of our competitors 
are  larger companies with greater  financial resources than us. Intense competition in  a  challenging  economic environment in the PRC has, in  the past, put 
pressure on our margins and may adversely affect our future financial performance. Moreover, intense competition may result in potential or actual litigation 
between us and our competitors relating to such activities as competitive sales practices, relationships with key suppliers and customers or other matters.

In 2017 and 2018, we generated revenue of approximately $112.4 million and $103.4 million, respectively, or 84.9% and 76.0%, respectively, of our 
total revenue, from sales of our rare earth coated PC wires and PC strands. We believe that our rare earth coating capabilities provide us with a competitive 
advantage  among  our  competitors,  however,  it  is  likely  that  our  competitors  may  develop  similar  competing  products.  We  intend  to  continue  to  expand 
research and development efforts to advance our rare earth coating applications even further, including improving the products’ corrosion-resistant level and 
increasing  the  products’  strength  and  life  span.  Meanwhile,  we  will  also  continue  to  invest  in  research  and  development  of  higher  strength  and  higher 
corrosion-resistant level of other types of prestressed products. However, there can be no assurance that our initial competitive advantage will be retained and 
that one or more competitors will not develop products that are equal or superior to ours in quality and are better priced than our rare earth coated products.

Our  revenues  are  highly  dependent  on  a  limited  number  of  customers  and  the  loss  of  any  one  of  our  major  customers  could  materially  and  adversely 
affect our growth and our revenues.

During the years ended December 31, 2018 and 2017, our six largest customers contributed 68.3% and 74.8% of our total sales, respectively. As a 
result of our reliance on a limited number of customers, we may face pricing and other competitive pressures, which may have a material adverse effect on our 
profits and our revenues. The volume of products sold for specific customers varies from year to year, especially since we are not the exclusive provider for 
any customers. In addition, there are a number of factors, other than our performance, that could cause the loss of a customer or a substantial reduction in the 
products that we provide to any customer and that may not be predictable. For example, our customers may decide to reduce spending on our products or a 
customer may no longer need our products following the completion of a project. The loss of any one of our major customers, a decrease in the volume of 
sales to these customers or a decrease in the price at which we sell our products to them could materially adversely affect our profits and our revenues.

In addition, this customer concentration may subject us to perceived or actual leverage that our customers may have in negotiations with us, given 
their  relative  size  and importance to  us.  If our  customers  seek to  negotiate  their agreements  on  terms less favorable  to  us and  we accept  such  unfavorable 
terms, such unfavorable terms may have a material adverse effect on our business, financial condition and results of operations. Accordingly, unless and until 
we diversify and expand our customer base, our future success will significantly depend upon the timing and volume of business from our largest customers 
and the financial and operational success of these customers.

As  we  expand  our  operations,  we  may  need  to  establish  a  more  diverse  supplier  network  for  our  raw  materials.  The  failure  to  secure  a  more  diverse 
supplier network could have an adverse effect on our financial condition.

We  currently  purchase  almost  all  of  our  raw  materials  from  a  small  number  of  suppliers.  Purchases  from  our  five  largest  suppliers  accounted  for 
99.8%  and 99.7%  of our raw  material purchases in the  years  ended December 31, 2018 and 2017, respectively. In  the event that  we need to diversify  our 
supplier network, we may not be able to procure a sufficient supply of raw materials at a competitive price, which could have an adverse effect on our results 
of operations, financial condition and cash flows.

5

Furthermore, despite our efforts to control our supply of raw materials and maintain good relationships with our existing suppliers, we could lose one 
or more of our existing suppliers at any time. The loss of one or more key suppliers could increase our reliance on higher cost or lower quality supplies, which 
could negatively affect our profitability. Any interruptions to, or decline in, the amount or quality of our raw materials supply could materially disrupt our 
production and adversely affect our business, financial condition and financial prospects.

Volatile steel prices can cause significant fluctuations in our operating results. Our revenues and operating income could decrease if steel prices decline 
or if we are unable to pass price increases on to our customers.

Our principal raw material is high carbon steel wire rods that we typically purchase from multiple primary steel producers. The steel industry as a 
whole is cyclical and, at times, pricing and availability of steel can be volatile due to numerous factors beyond our control, including general domestic and 
international economic conditions, labor costs, sales levels, competition, levels of inventory held by us and other steel service centers, consolidation of steel 
producers,  higher  raw  material  costs  for  steel  producers,  import  duties  and  tariffs  and  currency  exchange  rates.  This  volatility  can  significantly  affect  the 
availability and cost of raw materials for us.

We,  like  many  other  steel  product  manufacturers,  maintain  substantial  inventories  of  steel  to  accommodate  the  short  lead  times  and  just-in-time 
delivery requirements of our customers. Accordingly, we purchase steel in an effort to maintain our inventory at levels that we believe to be appropriate to 
satisfy  the  anticipated  needs  of  our  customers  based  upon  historic  buying  practices,  supply  agreements  with  customers  and  market  conditions.  Our 
commitments to purchase steel are generally at prevailing market prices in effect at the time we place our orders. We have no long-term, fixed-price steel 
purchase contracts. When steel prices increase, competitive conditions will influence how much of the price increase we can pass on to our customers. To the 
extent we are unable to pass on future price increases in our raw materials to our customers, the revenues and profitability of our business could be adversely 
affected.

When  steel  prices  decline,  customer  demands  for  lower  prices  and  our  competitors'  responses  to  those  demands  could  result  in  lower  sale  prices, 
lower margins and inventory valued at the lower of cost or market adjustments as we use existing steel inventory. Significant or rapid declines in steel prices 
or  reductions  in  sales  volumes  could  result  in  us  incurring  inventory  or  goodwill  impairment  charges.  Therefore,  changing  steel  prices  could  significantly 
impact our revenues, gross margins, operating income and net income.

In  2018,  China  continued  focusing  on  addressing  the  overcapacity  in  the  steel  industry  and  strengthening  supply-side  structural  reform  to  drive 
sustained growth. As of December 2018, China has lowered steel production by approximately 150 million tons, according to reports issued by the Chinese 
government.  As  a  result,  the  average  price  of  steel  products,  including  our  products  and  principal  raw  materials,  increased  in 2018.  According  to  industry 
consultant Frost & Sullivan, the Chinese central government will focus on strictly controlling steel capacity increases in 2019, however, due to the slowdown 
of economic growth, local governments in Northern China, the most important steel production base in China, could increase allowable production levels of 
steel products, including our products and principal raw materials. As a result, we expect the average price of our principal raw materials to decrease in 2019. 
This could adversely impact our results of operations due to lower sale prices of our coated and plain surface products in the market.  

Sales to customers outside China and international developments expose us to risks inherent in international sales and increased competition.

We  generated  approximately  3.3%  and  4.1%,  respectively,  of  our  revenue  during  the  years  ended  December  31,  2018  and  2017  from  sales  to 
customers in international markets. As a result, we are subject to risks and challenges that we would otherwise not face if we conducted our business only in 
China. In the first quarter of 2018, the United States government announced stiff tariffs on imports of steel and aluminum from certain countries, including 
China. In June 2018, the United States government announced the imposition of an additional duty of 25% on approximately $34 billion worth of Chinese 
imports. In September 2018, the United States government announced the imposition of an additional duty of 10% on approximately $200 billion worth of 
Chinese  imports.  Although  we  have  not  generated  any  sales  from  the  United  States  since  the  anti-dumping  duties  were  imposed  in  2010,  these  measures 
imposed in 2018 may also have a negative impact on our business and results of operations because Chinese-based steel product exporters may now focus 
their marketing efforts on the Chinese domestic market.

6

We are subject to various risks and uncertainties that might affect our ability to procure quality raw materials.

Our  performance  depends  on  our  ability  to  procure  low  cost,  high  quality  raw  materials  on  a  timely  basis  from  our  suppliers.  Our  suppliers  are 
subject  to  certain  risks,  including  availability  of  raw  materials,  labor  disputes,  inclement  weather,  natural  disasters,  and  general  economic  and  political 
conditions, which might limit the ability of our suppliers to provide us with low cost, high quality merchandise on a timely basis. Furthermore, for these or 
other reasons, one or more of our suppliers might not adhere to our quality control standards, and we might not identify the deficiency. Our suppliers’ failure 
to supply quality materials at a reasonable cost on a timely basis could reduce our net sales or profits, damage our reputation and have an adverse effect on our 
financial condition.

We  may  lose  our  competitive  advantage,  and  our  operations  may  suffer,  if  we  fail  to  prevent  the  loss  or  misappropriation  of,  or  disputes  over,  our 
intellectual property.

We rely on a combination of patents, trademarks, trade secrets and confidentiality agreements to protect our intellectual property rights. While we are 
not  currently  aware  of  any  infringement  on  our  intellectual  property  rights,  our  ability  to  compete  successfully  and  to  achieve  future  revenue  growth  will 
depend, in significant part, on our ability to protect our proprietary technology. Despite many laws and regulations promulgated, as well as other efforts made, 
by China over the past several years in an attempt to protect intellectual property rights, intellectual property rights are not as certain in China as they would 
be in many Western countries, including the United States. Furthermore, enforcement of such laws and regulations in China has not been fully developed. 
Neither  the  administrative  agencies  nor  the  court  systems  in  China  are  as  equipped  as  their  counterparts  in  developed  countries  to  deal  with  violations  or 
handle the nuances and complexities between compliant technological innovation and non-compliant infringement.

Our  rare  earth  coating  technology  is  protected  through  a  combination  of  patents,  trade  secrets,  confidentiality  agreements  and  other  methods. 
However,  our  competitors  may  independently  develop  proprietary  methodologies  similar  to  ours  or  duplicate  our  products,  or  develop  alternatives,  which 
could  have  a  material  adverse  effect  on  our  business,  results  of  operations  and  financial  condition.  The  misappropriation  or  duplication  of  our  intellectual 
property could disrupt our ongoing business, distract our management and employees, reduce our revenues and increase our expenses. We may need to litigate 
to  enforce  our  intellectual  property  rights.  Any  such  litigation  could  be  time  consuming  and  costly  and  the  outcome  of  any  such  litigation  cannot  be 
guaranteed.

Our  revenues,  expenses  and  profits  are  difficult  to  predict  and  vary  significantly  from  quarter  to  quarter.  This  could  cause  the  trading  price  of  our 
ordinary shares to decline.

Our operating results vary significantly from quarter to quarter. Therefore, we believe that period-to-period comparisons of our results of operations 
are not necessarily meaningful and should not be relied upon as an indication of our future performance. It is possible that in the future some of our quarterly 
results of operations may be below the expectations of market analysts and our investors, which could lead to a significant decline in the trading price of our 
ordinary shares. Factors which affect the fluctuation of our revenues, expenses and profits include:

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delays  or  cancellations  of  infrastructure  projects  in  China  due  to  unexpected  accidents  or  to  financial  or  other  issues  confronting  the  Ministry  of 
Transport, China National Railway Co., or other PRC governmental agencies overseeing these industries;
changes in prices of our raw materials, with higher prices leading to reduced operating income;
variations, expected or unexpected, in the duration, size, timing and scope of purchase orders;
changes in our pricing policies or those of our competitors;
changes in compensation, which may reduce our gross profit for the quarter in which they are effected;
our inability to manage costs, including those related to our raw materials, personnel, infrastructure and facilities;
exchange rate fluctuations; and
general economic conditions.

7

A portion of our expenses, particularly those related to personnel and facilities are generally fixed in advance of any particular quarter. As a result, 
unanticipated  variations  in  the  number  and  timing  of  our  purchase  orders  or  prices  of  our  raw  materials  may  cause  significant  variations  in  our  operating 
results in any particular quarter.

Our success depends in large part upon our senior management and key personnel. Our inability to attract and retain these individuals could materially 
and adversely affect our business, results of operations and financial condition.

We are highly dependent on our senior management and other key employees, including our Chairman, Dr. Tang and our Chief Executive Officer 
and Chief Financial Officer, Mr. Hua. Our future performance will be dependent upon the continued service of members of our senior management and key 
employees.  We  do  not  maintain  key  man  life  insurance  for  any  of  the  members  of  our  management  team  or  other  key  personnel.  Competition  for  senior 
management  in  our  industry  is  intense,  and  we  may  not  be  able  to  retain  our  senior  management  and  key  personnel  or  attract  and  retain  new  senior 
management and key personnel in the future, which could materially and adversely affect our business, results of operations and financial condition.

We have limited insurance coverage and may incur losses resulting from product liability claims, business interruption or natural disasters.

We  are  exposed  to  risks  associated  with  product  liability  claims  in  the  event  that  the  use  of  our  products  results  in  property  damage  or  personal 
injury. Since our products are ultimately incorporated into bridges, buildings, railways and other large structures, it is possible that users of these structures or 
people installing our products could be injured or killed by such structures, whether as a result of defects, improper installation or other causes. Because we 
continue to expand our customer base and because our products are used for long periods of time, we are unable to predict whether product liability claims 
will be brought against us in the future or to predict the impact of any resulting adverse publicity on our business. The successful assertion of product liability 
claims  against  us  could  result  in  potentially  significant  monetary  damages  and  require  us  to  make  significant  payments.  We  do  not  carry  product  liability 
insurance and may not have adequate resources to satisfy a judgment in the event of a successful claim against us. As the insurance industry in China is still in 
its early stages of development, even the insurance that we currently carry offers limited coverage compared with that offered in many other countries. Any 
business  interruption  or  natural  disaster  could  result  in  substantial  losses  and  diversion  of  our  resources  and  materially  and  adversely  affect  our  business, 
financial condition and results of operations. 

If we are unable to maintain appropriate internal financial reporting controls and procedures, it could cause us to fail to meet our reporting obligations, 
result in the restatement of our financial statements, harm our operating results, subject us to regulatory scrutiny and sanction, and cause investors to 
lose confidence in our reported financial information.

Effective  internal  controls  are  necessary  for  us  to  provide  reliable  financial  reports  and  effectively  prevent  fraud.  As  a  public  company,  we  have 
significant requirements for enhanced financial reporting and internal controls. We are required to document and test our internal control procedures in order 
to  satisfy  the  requirements  of  Section  404 of  the  Sarbanes-Oxley Act  of  2002,  which requires  annual  management  assessments  of  the  effectiveness  of  our 
internal  controls  over  financial  reporting  and,  for  many  companies,  a  report  by  the  independent  registered  public  accounting  firm  addressing  these 
assessments. The process of designing and implementing effective internal controls is a continuous effort that requires us to anticipate and react to changes in 
our business and the economic and regulatory environments and to expend significant resources to maintain a system of internal controls that is adequate to 
satisfy our reporting obligations as a public company.

We cannot assure you that we will not in the future identify areas requiring improvement in our internal control over financial reporting. In addition, 
we cannot assure you that the measures we will take to remediate any areas in need of improvement will be successful or that we will implement and maintain 
adequate  controls  over  our  financial  processes  and  reporting  in  the  future  as  we  continue  our  growth.  If  we  are  unable  to  establish  appropriate  internal 
financial  reporting  controls  and  procedures,  it  could  cause  us  to  fail  to  comply  with  Sarbanes-Oxley  and  meet  our  reporting  obligations,  result  in  the 
restatement of our financial statements, harm our operating results, subject us to regulatory scrutiny and sanction, and cause investors to lose confidence in our 
reported financial information.

8

A failure of our information technology systems would harm our business.

The nature of our business requires the development and implementation of certain functioning information technology systems. Such systems are 
vulnerable to a variety of potential risks, including damage or interruption resulting from natural disasters and telecommunication failures and human error or 
intentional  acts  of  sabotage,  vandalism,  break-ins  and  similar  acts.  The  occurrence  of  any  of  these  events  could  result  in  costly  interruptions  or  failures 
adversely affecting our business and the results of our operations.

We rely on information technology to support our operations and reporting environments. A security failure of that technology could impact our ability to 
operate our businesses effectively, adversely affect our reported financial results, impact our reputation and expose us to potential liability or litigation.

In the ordinary course of our business, we store sensitive data, including intellectual property, our proprietary business information and that of our 
customers,  suppliers  and  business  partners,  and  information  of  our  customers  and  employees,  on  our  networks.  The  secure  processing,  maintenance  and 
transmission  of  this  information  is  critical  to  our  operations  and  business  strategy.  Despite  our  security  measures,  our  information  technology  and 
infrastructure  may  be  vulnerable  to  attacks  by  hackers  or  breached  due  to  a  cyber  incident,  natural  disaster,  hardware  or  software  failure  or  error, 
telecommunications system failure, service provider or vendor error or failure, intentional or unintentional personnel actions, employee error, malfeasance or 
other disruptions. Any such breach could compromise our networks and the information stored there could be accessed, publicly disclosed, altered, damaged, 
held  ransom,  lost  or  stolen.  In  any  such  event,  we  could  suffer  significant  loss  or  incur  significant  liability,  including:  damage  to  our  reputation;  loss  of 
customer  confidence  or  goodwill;  and  significant  expenditures  of  time  and  money  to  address  and  remediate  resulting  damages  to  affected  individuals  or 
business  partners.  Furthermore,  such  data  breach  could  result  in  legal  claims  or  proceedings,  liability  under  laws  that  protect  the  privacy  of  personal 
information, and regulatory penalties, disrupt our operations, and damage our reputation, which could adversely affect our business, revenues and competitive 
position.

Risks Related to Doing Business in China

Fluctuations in the value of the RMB may have an adverse effect on our shareholders’ investment.

Our reporting currency is the U.S. dollar. However, substantially all of our revenues are denominated in RMB. Any significant revaluation of the 
Renminbi may have a material adverse effect on the U.S. dollar equivalent amount of our revenues and financial condition as well as on the value of, and any 
dividends payable on, our ordinary shares in foreign currency terms. For instance, a decrease in the value of Renminbi against the U.S. dollar could reduce the 
U.S. dollar equivalent amounts of our financial results, the value of your investment in our ordinary shares and the dividends we may pay in the future, if any, 
all of which may have a material adverse effect on the prices of our ADSs. For 2017 and 2018, we had foreign currency translation gain of $6.6 million and 
foreign  currency  translation  loss  of  $6.3  million,  respectively,  primarily  due  to  the  strengthening  of  the  RMB  against  the  U.S.  dollar  in  2017  and  the 
weakening of the RMB against the U.S. dollar in 2018.

The value of the RMB against the U.S. dollar and other currencies is affected by, among other things, changes in China’s political and economic 
conditions and China’s foreign exchange policies. The conversion of RMB into foreign currencies, including U.S. dollars, has been based on exchange rates 
set by the People’s Bank of China. On July 21, 2005, the PRC government changed its decade-old policy of pegging the value of the RMB solely to the U.S. 
dollar,  and  the  RMB  appreciated  more  than  20%  against  the  U.S.  dollar  over  the  following  three  years.  Between  July  2008  and  June  2010,  however,  this 
appreciation  halted  and  the  RMB  was  traded  within  a  narrow  range  against  the  U.S.  dollar.  Between  July  2010  and  November  2015,  the  RMB  fluctuated 
against the U.S. dollar, at times significantly and unpredictably. On November 30, 2015, the Executive Board of IMF completed the regular five-year review 
of the basket of currencies that make up the Special Drawing Right, or the SDR, and decided that with effect from October 1, 2016, RMB is determined to be 
a freely usable currency and will be included in the SDR basket as a fifth currency, along with the U.S. dollar, the Euro, the Japanese yen and the British 
pound. In the fourth quarter of 2016, the RMB depreciated significantly in the backdrop of a surging U.S. dollar and persistent capital outflows of China. This 
depreciation halted in 2017, and the RMB appreciated approximately 7% against the U.S. dollar during this one-year period. In 2018, the RMB depreciated 
4.8%  against  the  U.S.  dollar.  With  the  development  of  the  foreign  exchange  market  and  progress  towards  interest  rate  liberalization  and  RMB 
internationalization, the PRC government may in the future announce further changes to the exchange rate system, and we cannot assure you that the RMB 
will  not  appreciate  or  depreciate  significantly  in  value  against  the  U.S.  dollar  in  the  future.  It  is  difficult  to  predict  how  market  forces  or  PRC  or  U.S. 
government policy may impact the exchange rate between the RMB and the U.S. dollar in the future.

9

The Renminbi may be revalued further against the U.S. dollar or other currencies, or may be permitted to enter into a full or limited free float, which 
may  result  in  an  appreciation  or  depreciation  in  the  value  of  the  Renminbi  against  the  U.S.  dollar  or  other  currencies.  In  addition,  there  are  very  limited 
hedging transactions available in China to reduce our exposure to exchange rate fluctuations. While we may decide to enter into hedging transactions in the 
future, the availability and effectiveness of these hedges may be limited and we may not be able to successfully hedge our exposure, if at all. In addition, our 
currency exchange losses may be magnified by PRC exchange control regulations that restrict our ability to convert RMB into U.S. dollars.

Changes in China’s political or economic situation could harm us and our operating results.

Economic reforms adopted by the Chinese government have had a positive effect on the economic development of the country, but the government 
could change these economic reforms or any of the legal systems at any time. This could either benefit or damage our operations and profitability. Some of 
factors that could have this effect include:

·

·

·

·

·

·

Level of government involvement in the economy;

Control of foreign exchange;

Methods of allocating resources;

Balance of payments position;

International trade restrictions; and

International conflict.

The Chinese economy differs from most countries belonging to the Organization for Economic Cooperation and Development, or OECD, in many 
ways. For example, state-owned enterprises still constitute a large portion of the Chinese economy, and weak corporate governance and the lack of a flexible 
currency exchange policy still prevail in China. As a result of these differences, we may not develop in the same way or at the same rate as might be expected 
if the Chinese economy were similar to those of the OECD member countries.

The  PRC  government  exerts  substantial  influence  over  the  infrastructure  and  steel  sectors  and  the  manner  in  which  we  must  conduct  our  business 
activities.

The  PRC  government  has  exercised,  and  continues  to  exercise,  substantial  control  over  virtually  every  sector  of  the  Chinese  economy  through 
regulation and state ownership, including the infrastructure and steel sectors where we have been doing our business. Any government decisions or actions to 
postpone, change or halt the construction of certain types of infrastructure projects for any reason, such as the high speed railway accident in July 2011 in 
South China and the reduction of 150 million tons of steel production announced between 2016 and 2018, or any decisions the government might make to cut 
spending, could adversely impact our business and results of operations. 

10

In addition, our ability to operate in China may be harmed by changes in its laws and regulations, including those relating to taxation, import and 
export tariffs, environmental regulations, land use rights, property, and other matters. We believe that our operations in China are in material compliance with 
all applicable legal and regulatory requirements. However, the central or local governments of the jurisdictions in which we operate may impose new, stricter 
regulations or interpretations of existing  regulations that would require additional expenditures and  efforts on our part to ensure our compliance with such 
regulations or interpretations. Accordingly, government actions in the future, including any decision not to continue to support recent economic reforms and to 
return  to  a  more  centrally  planned  economy  or  regional  or  local  variations  in  the  implementation  of  economic  policies,  could  have  a  significant  effect  on 
economic conditions in China or particular regions thereof.

You may have difficulty enforcing judgments against us.

Our  assets  are  located,  and  our  operations  are  conducted,  in  the PRC.  In  addition,  substantially all  of  our  directors  and  officers  are  nationals  and 
residents of the PRC and a substantial portion of their assets is located outside the United States. As a result, it may be difficult to effect service of process 
within the United States upon these persons. In addition, there is uncertainty as to whether the courts of the PRC would recognize or enforce judgments of 
U.S. courts because China does not have any treaties or other arrangements that provide for the reciprocal recognition and enforcement of foreign judgments 
with  the  United  States.  In  addition,  according  to  the  PRC  Civil  Procedures  Law,  courts  in  the  PRC  will  not  enforce  a  foreign  judgment  against  us  or  our 
directors and officers if they decide that the judgment violates basic principles of PRC law or national sovereignty, security, or the public interest.

Most of our revenues are denominated in Renminbi, which is not freely convertible for capital account transactions and may be subject to exchange rate 
volatility.

We  are  exposed  to  the  risks  associated  with  foreign  exchange  controls  and  restrictions  in  China,  as  our  revenues  are  primarily  denominated  in 
Renminbi,  which  is  currently  not  freely  exchangeable.  The  PRC  government  imposes  control  over  the  convertibility  between  Renminbi  and  foreign 
currencies. Under the PRC foreign exchange regulations, payments for “current account” transactions, including remittance of foreign currencies for payment 
of dividends, profit distributions, interest and operation-related expenditures, may be made without prior approval but are subject to procedural requirements. 
Strict  foreign  exchange  control  continues  to  apply  to  “capital  account”  transactions,  such  as  direct  foreign  investment  and  foreign  currency  loans.  These 
capital  account  transactions  must  be  approved  by,  or  registered  with,  the  PRC  State  Administration  of  Foreign  Exchange,  or  SAFE.  Further,  capital 
contribution  by  an  offshore shareholder  to  its  PRC  subsidiaries may  require approval by  the Ministry  of Commerce in  China  or its local counterparts. We 
cannot assure you that we are able to meet all of our foreign currency obligations to remit profits out of China, to pay dividends, or to fund operations in 
China.

On  August  29,  2008,  SAFE  promulgated  the  Circular  on  the  Relevant  Operating  Issues  concerning  the  Improvement  of  the  Administration  of 
Payment  and  Settlement  of  Foreign  Currency  Capital  of  Foreign-Invested  Enterprises,  or  Circular  142,  to  regulate  the  conversion  by  foreign  invested 
enterprises,  or  FIEs,  of  foreign  currency  into  Renminbi  by  restricting  how  the  converted  Renminbi  may  be  used.  Circular  142  requires  that  Renminbi 
converted  from  the  foreign  currency-dominated  capital  of  a  FIE  may  be  used  only  for  purposes  within  the  business  scope  approved  by  the  applicable 
government authority and may not be used for equity investments within the PRC unless specifically provided. In addition, SAFE strengthened its oversight 
over the flow and use of Renminbi funds converted from the foreign currency-dominated capital of a FIE. The use of such Renminbi may not be changed 
without approval from SAFE, and may not be used to repay Renminbi loans if the proceeds of such loans have not yet been used. Compliance with Circular 
142 may delay or inhibit our ability to complete such transactions, which could affect our ability to expand our business.

In light of  the flood  of capital outflows of  China  in 2016 due to  the weakening RMB,  the PRC government  has  imposed more  restrictive foreign 
exchange policies and stepped up scrutiny of major outbound capital movement including overseas direct investment. More restrictions and substantial vetting 
process are put in place by SAFE to regulate cross-border transactions falling under the capital account. If any of our shareholders regulated by such policies 
fails to satisfy the applicable overseas direct investment filing or approval requirement timely or at all, it may be subject to penalties from the relevant PRC 
authorities. The PRC government may at its discretion further restrict access in the future to foreign currencies for current account transactions. If the foreign 
exchange control system prevents us from obtaining sufficient foreign currencies, we may not be able to satisfy our foreign currency demands.

11

China’s legal system is different from those in some other countries.

China  is  a  civil  law  jurisdiction.  Under  the  civil  law  system,  prior  court  decisions  may  be  cited  as  persuasive  authority  but  do  not  have  binding 
precedential  effect.  Although  progress  has  been  made  in  the  promulgation  of  laws  and  regulations  dealing  with  economic  matters,  such  as  corporate 
organization and governance, foreign investment, commerce, taxation and trade, China’s legal system remains less developed than the legal systems in many 
other countries. Furthermore, because many laws, regulations and legal requirements have been recently adopted, their interpretation and enforcement by the 
courts and administrative agencies may involve uncertainties. Sometimes, different government departments may have different interpretations. Licenses and 
permits issued or granted by one government authority may be revoked by a higher government authority at a later time. Government authorities may decline 
to take action against unlicensed operators which may work to the disadvantage of licensed operators, including us. The PRC legal system is based in part on 
government policies and internal rules that may have a retroactive effect. We may not be aware of our violation of these policies and rules until sometime after 
the  violation.  Changes  in  China’s  legal  and  regulatory  framework,  the  promulgation  of  new  laws  and  possible  conflicts  between  national  and  provincial 
regulations  could  adversely  affect  our  financial  condition  and  results  of  operations.  In  addition,  any  litigation  in  China  may  result  in  substantial  costs  and 
diversion of resources and management attention. 

Our business and financial performance may be materially adversely affected if the PRC regulatory authorities determine that our acquisition of Ossen 
Materials constitutes a round-trip investment without MOFCOM approval.

On  August  8,  2006,  six  PRC  regulatory  agencies  promulgated  the  Regulation  on  Mergers  and  Acquisitions  of  Domestic  Companies  by  Foreign 
Investors, or the 2006 M&A Rule, which became effective on September 8, 2006. According to the 2006 M&A Rule which was amended by the Ministry of 
Commerce on June 22, 2009, a “round-trip investment” is defined as having taken place when a PRC business that is owned by PRC individuals is sold to a 
non-PRC entity that is established or controlled, directly or indirectly, by those same PRC individuals. Under the 2006 M&A Rules which was amended by 
the  Ministry  of  Commerce  on  June  22,  2009,  any  round-trip  investment  must  be  approved  by  MOFCOM,  and  any  indirect  arrangement  or  series  of 
arrangements which achieves the same end result without the approval of MOFCOM is a violation of PRC law.

However, the PRC regulatory authorities may take the view that the acquisition of shares in our PRC operating subsidiaries and the share exchange 
between our predecessor, Ultra Glory, and our subsidiary, Ossen Materials Group, are part of an overall series of arrangements which constitute a round-trip 
investment. If the PRC regulatory authorities take this view, we cannot assure you we may be able to obtain the approval required from MOFCOM. It is also 
possible that the PRC regulatory authorities could invalidate our acquisition and ownership of our Chinese subsidiaries, and that these transactions require the 
prior approval of the China Securities Regulatory Commission, or CSRC, before MOFCOM approval is obtained.

If these regulatory actions occur, we cannot assure you that we will be able to re-establish control of our Chinese subsidiaries’ business operations, 
that any such contractual arrangements will be protected by PRC law, or that we would receive as complete or effective an economic benefit and control of 
our Chinese subsidiaries’ business as if we had direct ownership of our Chinese subsidiaries.

12

PRC  regulations  relating  to  investments  in  offshore  companies  by  PRC  residents  may  subject  our  future  PRC-resident  beneficial  owners  or  our  PRC 
subsidiaries  to  liability  or  penalties,  limit  our  ability  to  inject  capital  into  our  PRC  subsidiaries  or  limit  our  PRC  subsidiaries’  ability  to  increase  their 
registered capital or distribute profits.

SAFE  promulgated  the  Circular  on  Relevant  Issues  Concerning  Foreign  Exchange  Control  on  Domestic  Residents’  Offshore  Investment  and 
Financing and Roundtrip Investment through Special Purpose Vehicles, or SAFE Circular 37, on July 4, 2014, which replaced the former circular commonly 
known as “SAFE Circular 75” promulgated by SAFE on October 21, 2005. SAFE Circular 37 requires PRC residents to register with local branches of SAFE 
in connection with their direct establishment or indirect control of an offshore entity, for the purpose of overseas investment and financing, with such PRC 
residents’ legally owned assets or equity interests in domestic enterprises or offshore assets or interests, referred to in SAFE Circular 37 as a “special purpose 
vehicle.” SAFE Circular 37 further requires amendment to the registration in the event of any significant changes with respect to the special purpose vehicle, 
such as increase or decrease of capital contributed by PRC individuals, share transfer or exchange, merger, division or other material event. In the event that a 
PRC  shareholder  holding  interests  in  a  special  purpose  vehicle  fails  to  fulfill  the  required  SAFE  registration,  the  PRC  subsidiaries  of  that  special  purpose 
vehicle may be prohibited from making profit distributions to the offshore parent and from carrying out subsequent cross-border foreign exchange activities, 
and the special purpose vehicle may be restricted in its ability to contribute additional capital into its PRC subsidiary. Moreover, failure to comply with the 
various SAFE registration requirements described above could result in liability under PRC law for evasion of foreign exchange controls.

We believe that some of our shareholders are PRC residents under SAFE Circular 37. We do not have control over the these shareholders and our 
other beneficial owners and cannot assure you that all of our PRC-resident beneficial owners have complied with, and will in the future comply with, SAFE 
Circular  37  and  subsequent  implementation  rules.  The  failure  of  PRC-resident  beneficial  owners  to  register  or  amend  their  SAFE registrations  in  a  timely 
manner pursuant to SAFE Circular 37 and subsequent implementation rules, or the failure of future PRC-resident beneficial owners of our company to comply 
with  the  registration  procedures  set  forth  in  SAFE  Circular  37  and  subsequent  implementation  rules,  may  subject  such  beneficial  owners  or  our  PRC 
subsidiaries  to  fines  and  legal  sanctions.  Furthermore,  SAFE  Circular  37  is  unclear  how  this  regulation,  and  any  future  regulation  concerning  offshore  or 
cross-border  transactions,  will  be  interpreted,  amended  and  implemented  by  the  relevant  PRC  government  authorities,  and  we  cannot  predict  how  these 
regulations  will  affect  our  business  operations  or  future  strategy.  Failure  to  register  or  comply  with  relevant  requirements  may  also  limit  our  ability  to 
contribute additional capital to our PRC subsidiaries and limit our PRC subsidiaries’ ability to distribute dividends to us. These risks could in the future have a 
material adverse effect on our business, financial condition and results of operations.

All  employee  participants  in  our  share  incentive  plans  who  are  PRC  citizens  may  be  required  to  register  with  the  SAFE.  We  may  also  face  regulatory 
uncertainties that could restrict our ability to adopt additional option plans for our directors and employees under PRC law.

In  December  2006,  the  People’s  Bank  of  China  promulgated  the  Administrative  Measures  for  Individual  Foreign  Exchange,  which  set  forth  the 
respective requirements for foreign exchange transactions by PRC individuals under either current account or the capital account. In January 2007, the SAFE 
issued  the  Implementation  Rules  of  the  Administrative  Measures  for  Individual  Foreign  Exchange,  which,  among  other  things,  specified  approval 
requirements for certain capital account transactions such as a PRC citizen’s participation in the employee stock ownership plans or stock option plans of an 
overseas publicly-listed company. On March 28, 2007, the SAFE promulgated the Processing Guidance on Foreign Exchange Administration for Domestic 
Individuals  Participating  in  Employee  Stock  Ownership  Plans  or  Stock  Option  Plans  of  Overseas-Listed  Companies,  or  the  Stock  Option  Rule.  Under  the 
Stock Option Rule, PRC citizens who are granted stock options by an overseas publicly-listed company are required, through a qualified PRC domestic agent 
or PRC subsidiary of such overseas publicly-listed company, to register with the SAFE and complete certain other procedures. In February 2012, the SAFE 
promulgated  the  Notice  on  Issues  Concerning  the  Foreign  Exchange  Administration  for  Domestic  Individuals  Participating  in  Stock  Incentive  Plan  of 
Overseas  Publicly  Listed  Company,  according  to  which,  employees,  directors,  supervisors  and  other  management  members  participating  in  any  share 
incentive plan of an overseas publicly listed company who are PRC citizens or who are non-PRC citizens residing in China for a continuous period of not less 
than one year, subject to limited exceptions, are required to register with SAFE through a domestic qualified agent, which could be a PRC subsidiary of such 
overseas listed company, and complete certain other procedures. Failure to complete the SAFE registrations may subject them to fines and legal sanctions and 
may also limit our ability to make payments under our equity incentive plans or receive dividends or sales proceeds related thereto, or our ability to contribute 
additional capital into our subsidiaries in China and limit our subsidiaries’ ability to distribute dividends to us. We also face regulatory uncertainties that could 
restrict our ability to adopt additional equity incentive plans for our directors and employees under PRC law.

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In  addition,  the  PRC  State  Administration  of  Taxation  has  issued  circulars  concerning  employee  share  options  or  restricted  shares.  Under  these 
circulars, employees working in the PRC who exercise share options, or whose restricted shares vest, will be subject to PRC individual income tax. The PRC 
subsidiaries  of  an  overseas  listed  company  have  obligations  to  file  documents  related  to  employee  share  options  or  restricted  shares  with  relevant  tax 
authorities and to withhold individual income taxes of those employees related to their share options or restricted shares. If the employees fail to pay, or the 
PRC subsidiaries fail to withhold applicable income taxes, the PRC subsidiaries may face sanctions imposed by the tax authorities or other PRC government 
authorities.

Under the New Enterprise Income Tax Law, we may be classified as a “resident enterprise” of China. Such classification will likely result in unfavorable 
tax consequences to us and our non-PRC shareholders.

China passed a New Enterprise Income Tax Law, or the New EIT Law, which became effective on January 1, 2008. Under the New EIT Law, an 
enterprise established outside of China with de facto management bodies within China is considered a resident enterprise, meaning that it can be treated in a 
manner  similar  to  a  Chinese  enterprise  for  enterprise  income  tax  purposes.  The  implementing  rules  of  the  New  EIT  Law  define  de  facto  management  as 
“substantial and overall management and control over the production and operations, personnel, accounting, and properties” of the enterprise. In addition, a 
circular issued by the State Administration of Taxation on April 22, 2009 clarified that dividends and other income paid by such resident enterprises will be 
considered to be PRC source income, subject to PRC withholding tax, currently at a rate of 10%, when recognized by non-PRC enterprise shareholders. This 
recent circular also subjects such resident enterprises to various reporting requirements with the PRC tax authorities. 

Although substantially all of our management is currently located in the PRC, it remains unclear whether the PRC tax authorities would require or 
permit our overseas registered entities to be treated as PRC resident enterprises. We do not currently consider our company to be a PRC resident enterprise. 
However, if the PRC tax authorities determine that we are a resident enterprise for PRC enterprise income tax purposes, a number of unfavorable PRC tax 
consequences could follow. First, we may be subject to the enterprise income tax at a rate of 25% on our worldwide taxable income as well as PRC enterprise 
income  tax  reporting  obligations.  In  our  case,  this  would  mean  that  income  such  as  interest  on  offering  proceeds  and  non-China  source  income  would  be 
subject to PRC enterprise income tax at a rate of 25%. Second, although under the New EIT Law and its implementing rules dividends paid to us from our 
PRC subsidiaries would qualify as tax-exempt income, we cannot guarantee that such dividends will not be subject to a 10% withholding tax, as the PRC 
foreign exchange control authorities, which enforce the withholding tax, have not yet issued guidance with respect to the processing of outbound remittances 
to entities that are treated as resident enterprises for PRC enterprise income tax purposes. Finally, it is possible that future guidance issued with respect to the 
new resident enterprise classification could result in a situation in which a 10% withholding tax is imposed on dividends we pay to our non-PRC shareholders 
and with respect to gains derived by our non-PRC shareholders from transferring our shares.

Restrictions  under  PRC  law  on  our  PRC  subsidiaries'  ability  to  pay  dividends  and  make  other  distributions  could  materially  and  adversely  affect  our 
ability to grow, make investments or acquisitions that could benefit our business, pay dividends to you, and otherwise fund and conduct our business.

Our  revenues  are  generated  by  our  PRC  subsidiaries.  However,  PRC  regulations  restrict  the  ability  of  our  PRC  subsidiaries  to  pay  dividends  and 
make  other  payments  to  their  offshore  parent  company.  PRC  legal  restrictions  permit  payments  of  dividends  by  our  PRC  subsidiaries  only  out  of  their 
accumulated after-tax profits, if any, determined in accordance with PRC accounting standards and regulations. Our PRC subsidiaries are also required under 
PRC laws and regulations to allocate at least 10% of their annual after-tax profits determined in accordance with PRC GAAP to a statutory general reserve 
fund until the amounts in said fund reaches 50% of their registered capital. Allocations to these statutory reserve funds can be used only for specific purposes 
and are not transferable to us in the form of loans, advances, or cash dividends. Any limitations on the ability of our PRC subsidiaries to transfer funds to us 
could  materially  and  adversely  limit  our  ability  to  grow,  make  investments  or  acquisitions  that  could  be  beneficial  to  our  business,  pay  dividends  and 
otherwise fund and conduct our business.

Any failure to comply with PRC environmental laws may require us to incur significant costs.

We carry on our business in an industry that is subject to PRC environmental protection laws and regulations. These laws and regulations require 
enterprises engaged in manufacturing and construction that may cause environmental waste to adopt effective measures to control such waste. In addition, 
such enterprises are required to pay fines, or to cease operations entirely under extreme circumstances, should they discharge waste substances. The Chinese 
government  may also  change the existing laws or  regulations  or impose  additional  or stricter laws or  regulations, compliance  with  which  may cause us to 
incur significant capital expenditures, which we may be unable to pass on to our customers through higher prices for our products.

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We must comply with the Foreign Corrupt Practices Act.

We are required to comply with the United States Foreign Corrupt Practices Act, which prohibits U.S. companies from making prohibited payments 
to foreign officials for the purpose of obtaining or retaining business. Corruption, extortion, bribery, pay-offs, theft and other fraudulent practices occur from 
time to time in mainland China. If any of our non-U.S. listed competitors that are not subject to the Foreign Corrupt Practices Act engage in these practices, 
they may receive preferential treatment and secure business from government officials in a way that is unavailable to us. Furthermore, although we inform our 
personnel that such practices are illegal, we cannot assure you that our employees or other agents will not engage in illegal conduct for which we might be 
held responsible under U.S. law. If our employees or other agents are found to have engaged in such practices, we could suffer severe penalties. 

Because  our  funds  are  held  in  banks  that  do  not  provide  insurance,  the  failure  of  any  bank  in  which  we  deposit  our  funds  could  affect  our  ability  to 
continue our business operations.

Banks and other financial institutions in the PRC do not provide insurance for funds held on deposit. The Chinese government implemented the bank 
deposit insurance program on May 1, 2015. Financial institutions are required to pay insurance premiums into a fund that is managed by an agency appointed 
by the State Council. The program is designed to return bank clients' deposits if their bank suffers insolvency or bankruptcy. The reimbursement is drawn 
from the new fund in the case of the deposit being RMB 500,000 (approximately $72,852 as of December 31, 2018) or less. However, the implementation and 
impact of this program are uncertain. As a result, in the event of a bank failure, we may not have access to funds on deposit. Depending upon the amount of 
money we maintain in a bank that fails, our inability to have access to our cash could impair our operations, and, if we are not able to access funds to pay our 
suppliers, employees and other creditors, we may be unable to continue our business operations.

If relations between the United States and China worsen, investors may be unwilling to hold or buy our ordinary shares and our share price may decrease.

At various times during recent years, the United States and China have had significant disagreements over political and economic issues, which may 
result  in  or  intensify  potential  conflicts  in  relation  to  territorial,  regional  security  and  trade  disputes.  In  2018,  the  United  States  implemented  certain  trade 
policies,  tariffs,  other  trade  actions  against  China  relating  to  the  import  and  export  of  certain  products,  and  negotiations  with  respect  thereto,  may  have  a 
negative effect on our business, financial condition, and results of operations in China. China has imposed, or threatened to impose, tariffs on U.S. imports or 
to take other actions in retaliation to actions taken by the United States. These developments may have a material adverse effect on the economy, financial 
markets, and currency exchange rates in China and the United States. Any continuing or worsening trade relations between the United States and China could 
significantly reduce domestic growth in China and therefore adversely affect our business, financial condition and results of operations.

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If we become directly subject to the scrutiny, criticism and negative publicity that historically related to U.S.-listed Chinese companies, we may have to 
expend significant resources to investigate and resolve the matter which could harm our business operations, stock price and reputation and could result 
in a loss of your investment in our stock, especially if such matter cannot be addressed and resolved favorably.

In  past  years,  U.S.  public  companies  that  have  substantially  all  of  their  operations  in  China,  particularly  companies  that  have  completed  reverse 
merger transactions, have been the subject of intense scrutiny, criticism and negative publicity by investors, financial commentators and regulatory agencies, 
such  as  the  United  States  Securities  and  Exchange  Commission.  Much  of  the  scrutiny,  criticism  and  negative  publicity  has  centered  around  financial  and 
accounting irregularities and mistakes, a lack of effective internal controls over financial accounting, inadequate corporate governance policies or a lack of 
adherence thereto and, in many cases, allegations of fraud. As a result of the scrutiny, criticism and negative publicity, the publicly traded stock of many U.S. 
listed Chinese companies has sharply decreased in value and, in some cases, has become virtually worthless. Many of these companies are now, or were in the 
recent  past,  subject  to  shareholder  lawsuits,  SEC  enforcement  actions  and  are  conducting  internal  and  external  investigations  into  the  allegations.  If  we 
become the subject of any unfavorable allegations, whether such allegations are proven to be true or untrue, we will have to expend significant resources to 
investigate such allegations and/or defend our Company. This situation will be costly and time consuming and distract our management from growing our 
Company. If such allegations are not proven to be groundless, our Company and business operations will be severely impacted and your investment in our 
stock could be rendered worthless.

The  disclosures  in  our  reports  and  other  filings  with  the  SEC  and  our  other  public  pronouncements  are  not  subject  to  the  scrutiny  of  any  regulatory 
bodies in the PRC. Accordingly, our public disclosure should be reviewed in light of the fact that no governmental agency that is located in China where 
substantially  all  of  our  operations  and  business  are  located  have  conducted  any  due  diligence  on  our  operations  or  reviewed  or  cleared  any  of  our 
disclosures.

We are regulated by the SEC and our reports and other filings with the SEC are subject to SEC review in accordance with the rules and regulations 
promulgated by the SEC under the Securities Act and the Exchange Act. Unlike public reporting companies whose operations are located primarily in the 
United States, however, substantially all of our operations are located in China. Since substantially all of our operations and business take place in China, it 
may be more difficult for the Staff of the SEC to overcome the geographic and cultural obstacles that are present when reviewing our disclosures. These same 
obstacles  are  not  present  for  similar  companies  whose  operations  or  business  take  place  entirely  or  primarily  in  the  United  States.  Furthermore,  our  SEC 
reports and other disclosures and public pronouncements are not subject to the review or scrutiny of any PRC regulatory authority. For example, the disclosure 
in our SEC reports and other filings are not subject to the review of China Securities Regulatory Commission, a PRC regulator that is tasked with oversight of 
the capital markets in China. Accordingly, you should review our SEC reports, filings and our other public pronouncements with the understanding that no 
local regulator has done any due diligence on our Company and with the understanding that none of our SEC reports, other filings or any of our other public 
pronouncements has been reviewed or otherwise been scrutinized by any local regulator. 

The audit report included in this annual report is prepared by auditors who are not inspected fully by the Public Company Accounting Oversight 

Board, or the PCAOB, and, as such, our shareholders are deprived of the benefits of such inspection.

As an auditor of companies that are publicly traded in the United States and a firm registered with the PCAOB, BDO China Shu Lun Pan Certified 
Public Accountants LLP is required under the laws of the United States to undergo regular inspections by the PCAOB. However, because we have substantial 
operations  within  the  PRC,  a  jurisdiction  where  the  PCAOB  is  currently  unable  to  conduct  inspections  without  the  approval  of  the  Chinese  government 
authorities, our auditor and its audit work is not currently inspected fully by the PCAOB.

Inspections of other auditors conducted by the PCAOB outside China have at times identified deficiencies in those auditors' audit procedures and 
quality control procedures, which may be addressed as part of the inspection process to improve future audit quality. The lack of PCAOB inspections of audit 
work undertaken in China prevents the PCAOB from regularly evaluating our auditor's audits and its quality control procedures. As a result, shareholders may 
be  deprived  of  the  benefits  of  PCAOB  inspections,  and  may  lose  confidence  in  our  reported  financial  information  and  procedures  and  the  quality  of  our 
financial statements.

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Risks Related to Our ADSs

The market price for our ADSs may be volatile.

The market price for our ADSs is highly volatile and subject to wide fluctuations in response to various factors, including the following:

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actual or anticipated fluctuations in our quarterly operating results and revisions to our expected results;
changes in financial estimates by securities research analysts;
conditions in the markets for our products;
changes in the economic performance or market valuations of companies specializing in our industry or our customers or their industries;
changes in market valuations of U.S. listed companies headquartered in China, and in particular small capitalization companies;
announcements by us or our competitors of new products, acquisitions, strategic relationships, joint ventures or capital commitments;
addition or departure of our senior management and key personnel;
fluctuations of exchange rates between the Renminbi and the U.S. dollar;
litigation related to our intellectual property;
release or expiry of transfer restrictions on our outstanding ordinary shares; and
sales or perceived potential sales of our ADSs.

In addition, the securities market has from time to time, and to an even greater degree over the past several years, experienced significant price and 
volume fluctuations that are not related to the operating performance of particular companies. These market fluctuations may also have a material adverse 
effect on the market price of our ADSs. In the event that market price of our ADSs is below $1 for more than 30 consecutive business days we will fail to 
meet the requirements of NASDAQ listing rules. Furthermore, in the past, following periods of volatility in the market price of a public company’s securities, 
shareholders  have  frequently  instituted  securities  class  action litigation  against  that  company.  Litigation  of  this  kind  could result  in  substantial  costs  and  a 
diversion of our management’s attention and resources.

We may be precluded from paying any dividends on our ADSs.

Under British Virgin Islands law, we may pay dividends if the directors declare that the company is able to satisfy the provisions of Section 57 of the 
BVI Act. Pursuant to this provision, the company, immediately after the distribution, must satisfy the solvency test, in so far as its assets exceeds its liabilities, 
and the company must be able to pay its debts as they become due. Our ability to pay dividends will therefore depend on our ability to generate sufficient 
profits. Even if we are able to pay dividends, we cannot give any assurance that we will declare dividends of any amounts, at any rate or at all in the future. 
We  have  not  paid  any  dividends  in  the  past.  Future  dividends,  if  any,  will  be  at  the  discretion  of  our  board  of  directors,  subject  to  the  approval  of  our 
shareholders, and will depend upon our results of operations, our cash flows, our financial condition, the payment of our subsidiaries of cash dividends to us, 
our capital needs, future prospects and other factors that our directors may deem appropriate. We currently intend to retain most, if not all, of our available 
funds and any future earnings to operate and expand our business.

You may not have the same voting rights as the holders of our ordinary shares and may not receive voting materials in time to be able to exercise your 
right to vote.

Holders of our ADSs may not be able to exercise voting rights attaching to the shares represented by our ADSs on an individual basis. Holders of our 
ADSs appoint the depositary or its nominee as their representative to exercise the voting rights attached to the ordinary shares represented by the ADSs. You 
may not receive voting materials in time to instruct the depositary to vote, and it is possible that you, or persons who hold their ADSs through brokers, dealers 
or other third parties, will not have the opportunity to exercise your right to vote.

Your right to participate in any rights offering may be limited, which may cause dilution to your holdings, and you may not receive cash dividends if it is 
impractical to make them available to you.

We may from time to time distribute rights to our shareholders, including rights to acquire our securities. However, we cannot make rights available 
to you in the United States unless we register the rights, and the securities to which the rights relate, under the Securities Act, or unless an exemption from 
registration is available. Under the deposit agreement, the depositary will not make rights available to you unless both the rights and the underlying securities 
to be distributed to ADS holders are either registered under the Securities Act or exempt from registration. We are under no obligation to file a registration 
statement with respect to any such rights or securities or to endeavor to cause such a registration statement to be declared effective and we may not be able to 
establish  a  necessary  exemption from registration  under  the Securities Act.  Accordingly,  you  may be unable to  participate in  our  rights  offerings  and  may 
experience dilution in your holdings as a result.

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The depositary of our ADSs has agreed to pay to you the cash dividends or other distributions it or the custodian receives on our ordinary shares or 
other deposited securities after deducting its fees and expenses. You will receive these distributions in proportion to the number of ordinary shares your ADSs 
represent. However, the depositary may, at its discretion, decide that it is inequitable or impractical to make a distribution available to holders of ADSs. For 
example, the depositary may determine that it is not practicable to distribute certain property through the mail, or that the value of certain distributions may be 
less than the cost of mailing them. In these cases, the depositary may decide not to distribute such property to you.

You may be subject to limitations on transfer of your ADSs.

Your ADSs are transferable on the books of the depositary. However, the depositary may close its transfer books at any time or from time to time 
when it deems expedient in connection with the performance of its duties. In addition, the depositary may refuse to deliver, transfer or register transfers of 
ADSs generally when our books or the books of the depositary are closed, or at any time if we or the depositary deems it advisable to do so because of any 
requirement of law or of any government or governmental body, or under any provision of the deposit agreement, or for any other reason.

If we are classified as a passive foreign investment company, our U.S. shareholders may suffer adverse tax consequences. 

Generally, if for any taxable year, after applying certain look-through rules, 75% or more of our gross income is passive income, or at least 50% of 
our  assets  (generally  based  on  average  value  determined  on  a  quarterly  basis)  are  held  for  the  production  of,  or  produce,  passive  income,  we  may  be 
characterized as a passive foreign investment company, or PFIC, for U.S. federal income tax purposes. This characterization could result in adverse U.S. tax 
consequences to our U.S. shareholders, including gain realized on the disposition of our ADSs or ordinary shares being treated as ordinary income rather than 
capital gain and in punitive interest charges being applied to such sales proceeds. Rules similar to those applicable to dispositions apply to amounts treated as 
“excess distributions.”

We do not believe that we were a PFIC for our previous taxable year. However, because the determination of our PFIC status is based on such factual 
matters as the composition of our income and assets, the valuation of our assets, and our market capitalization, there is no assurance that the United Stated 
Internal Revenue Service (“IRS”) will agree with our position. In addition, there can be no assurance that we will not become a PFIC for current taxable year 
or in future taxable years. U.S. shareholders should consult with their own U.S. tax advisors with respect to the U.S. tax consequences of investing in our 
ADSs or ordinary shares if we were to become a PFIC. See “Taxation — United States Federal Income Taxation — Tax Consequences if We Are a Passive 
Foreign Investment Company.”

If equity research analysts do not publish research or reports about our company or if they issue unfavorable commentary or downgrade our ADSs, the 
price of our ADSs could decline.

The trading market for our ADSs relies in part on the research and reports that equity research analysts publish about us and our company. We do not 
control these analysts. The price of our ADSs could decline if one or more equity analysts downgrade our ordinary shares or if they issue other unfavorable 
commentary, or cease publishing reports, about us or our company.

ITEM 4.

INFORMATION ON THE COMPANY

4A. History and Development of the Company

We were incorporated under the laws of the British Virgin Islands as Ultra Glory International Ltd., or Ultra Glory, in 2010. We operate under the 
BVI  Business Companies  Act, 2004,  or the  BVI Act.  Our registered office is located  at Akara  Bldg., 24  De Castro Street,  Wickhams  Cay 1, Road  Town, 
Tortola,  British  Virgin  Islands.  The  telephone  number  of  the  registered  office  is  +86  (21)  51192951.  Our  World  Wide  Web  address  is 
http://www.osseninnovation.com. Information contained on our website does not constitute a part of this annual report.

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Our agent for service of process in the United States is CT Corporation System, 111 Eighth Avenue, New York, New York 10011. The telephone 

number of our agent for service is (212) 894-8940.

Business Combination

On July 7, 2010, Ultra Glory and its sole shareholder entered into a share exchange agreement with Ossen Innovation Group, a British Virgin Islands 
limited liability company organized on April 30, 2011 under the BVI Act and the shareholders of Ossen Innovation Group. Pursuant to the share exchange 
agreement, Ultra Glory acquired from the shareholders of Ossen Innovation Group all of the issued and outstanding shares of Ossen Innovation Group, in 
exchange for an aggregate of 10,000,000 newly issued ordinary shares issued by Ultra Glory to the shareholders of Ossen Innovation Group. In addition, the 
sole shareholder of Ultra Glory sold all of the 5,000,000 ordinary shares of Ultra Glory that were issued and outstanding prior to the business combination, to 
the  shareholders  of  Ossen  Innovation  Group  for  cash,  at  a  price  of  $0.03  per  share.  As  a  result,  the  individuals  and  entities  that  owned  shares  of  Ossen 
Innovation  Group  prior  to  the  business  combination  acquired  100%  of  the  equity  of  Ultra  Glory,  and  Ultra  Glory  acquired  100%  of  the  equity  of  Ossen 
Innovation Group. Ossen Innovation Group is now a wholly owned subsidiary of Ultra Glory. In conjunction with the business combination, Ultra Glory filed 
an amended charter, pursuant to which Ultra Glory changed its name to Ossen Innovation Co., Ltd., changed its fiscal year end to December 31, changed the 
par value of its ordinary shares to $0.01 per share and increased its authorized shares to 100,000,000. Upon the consummation of the business combination, 
we ceased to be a shell company.

Capital Expenditures

We incurred capital expenditures of approximately $72,305 and $37,848 for the years ended December 31, 2018 and 2017, respectively, primarily in 
connection  with  maintenance  and  repair  of  current  production  lines.  These  capital  expenditures  were  financed  by  proceeds  from  bank  financing  and  cash 
provided by operating activities.

We expect to incur further capital expenditures in fiscal year 2019 in connection with our production lines.

4B. Business Overview

Overview

We manufacture and sell an array of plain surface prestressed steel materials and rare earth coated and zinc coated prestressed steel materials, which 
we  believe  is  the  most  comprehensive  array  among  our  competitors  in  China.  Our  materials  are  used  in  the  construction  of  bridges,  highways  and  other 
infrastructure projects in the PRC and internationally. Our facilities are located in Maanshan City, Anhui Province and in Jiujiang City, Jiangxi Province, in 
the People’s Republic of China. Based on our extensive experience in the industry, we believe that Ossen is one of the leading enterprises in the PRC in the 
design,  engineering,  manufacture and  sale  of  customized  prestressed  steel  materials  used in the construction  of  bridges,  highways, and  other infrastructure 
projects in China.

During the year ended December 31, 2018, we generated revenue of approximately $103.4 million, or 76.0% of our total revenue (as compared to 

$112.4 million, or 84.9% of our total revenue, in 2017), from sales of our rare earth coated PC wires and PC strands.

While we believe that our rare earth coating capabilities provide us with a competitive advantage among our competitors due to higher strength and 
higher quality, however, it is likely that our competitors may develop similar competing products. We intend to continue to expand research and development 
efforts  to  advance  our  rare  earth  coating  applications  even  further  including  improving  the  product’s  corrosion-resistant  level  and  increasing  the  product’s 
strength and life span However, there can be no assurance that our initial competitive advantage will be retained and that one or more competitors will not 
develop products that are equal or superior to ours in quality or are better priced than our rare earth coated products.

19

The primary characteristics of coated prestressed products, which are used in infrastructure projects, most notably, the construction of new bridges 

and the renovation of older bridges in need of repair, are as follows:

·

·

·

·

·

Superior corrosion resistance;

Superior toughness and plasticity;

Endurance against extreme heat;

Smooth and appealing coating; and

Easily coated.

Our products are marketed under the “Ossen” brand name both domestically and internationally. We handle all aspects of market research, product 
design, engineering, manufacturing, sales and marketing.  We conduct our manufacturing operations in our ISO 9001 manufacturing facilities in Maanshan 
City and Jiujiang City, in the PRC.

In 2013, the Chinese market began to adopt zinc-aluminum alloy coated PC wires and PC strands, which have more corrosion-resistance and stronger 
protective effect than zinc coated PC wires and PC strands. Our research and development department is currently developing a method to apply rare earth 
materials  to  the  zinc-aluminum  alloy  coating  process.  We  have  made  progress  in  developing  such  product  so  far  and  we  will  continue  our  research  and 
development efforts in 2019. We anticipate that additional time will be necessary for such products to pass government inspection and to gain acceptance in 
the market.

Ossen  Materials,  our  operating  subsidiary,  was  founded  in  2004.  In  2005,  we  expanded  our  manufacturing  capabilities  by  acquiring  a  facility  in 
Jiujiang City in the PRC and forming Ossen Jiujiang. The senior management team of Ossen were among the first in China to introduce and promote the use 
of  prestressed  steel  materials  in  construction  projects.  They  have  been  involved  in  producing  prestressed  materials  since  1994  and  each  has  accumulated 
nearly 25 years of experience in the prestressed materials industry.

Competitive Advantages

Our management believes that the following competitive strengths differentiate us from other domestic and international competitors and are the key 

factors to our success:

We are taking advantage of industry trends in the bridge infrastructure sectors in the PRC and other international markets

We  believe  that  the  Chinese  central  government  will  continue  to  maintain  economic  growth  rate  at  approximately  6.0%  in  the  next  few  years  by 
optimizing economic structure and reforming the supply-side and funding infrastructure investment to maintain stable GDP growth. While we do not believe 
that  the  Chinese  government  will  initiate  another  large  scale,  comprehensive  capital  injection,  we  believe  that  infrastructure  spending  will  be  selectively 
targeted at developing regions in Central or Western China. Furthermore, through the “One Belt, One Road” initiatives, announced in late 2013, and the Asian 
Infrastructure Investment Bank launched in December 2015, investments are expected to be made during the next decade to construct new bridges and new 
railroads.  In  addition,  the  safety  and  technical  requirements  for  building  construction  are  higher,  resulting  in  an  increase  in  the  demand  of  prestressed 
materials.  We  believe  that  these  developments  should  create  opportunities  for  us  and  we  expect  the  market  will  continue  to  grow  gradually  in  2019  and 
beyond.

20

Leading provider of customized prestressed steel materials

Based on  our  extensive experience  in  the  industry,  we  believe  that  Ossen  is one  of  the leading  enterprises in the  PRC  in  the design, engineering, 
manufacture and sale of customized prestressed steel materials used in the construction of bridges, highways, and other infrastructure projects in China. We 
manufacture and sell an array of plain surface prestressed steel materials and rare earth coated and zinc coated prestressed steel materials, which we believe is 
the most comprehensive array among our competitors in China and which are used in the construction of bridges, highways and other infrastructure projects in 
the PRC and internationally. Our facilities are located in Maanshan City, Anhui Province and in Jiujiang City, Jiangxi Province, in the People’s Republic of 
China.

Strong in-house research and development capabilities

Our research and development team consists of members recognized as industry experts in China, and each member of our senior management team 
has extensive experience in prestressed materials industry. We have built a recognized brand name in the industry by introducing innovative solutions to the 
prestressed  materials  industry,  and  particularly  coated  prestressed  materials,  in  China  and  internationally.  Our  engineering  team  works  closely  with  our 
customers  in  order  to  understand  their  requirements.  We  have  been  able  to  introduce  new  equipment  to  enhance  cost  saving  and  time  reduction  in  the 
construction of bridges, highways, railways and buildings, as well as numerous other projects.

Efficient proprietary production technology

We continually pursue technological improvements to our manufacturing processes via our strong in-house development teams. We own forty-two 
patents granted by the State Intellectual Property Office of the PRC, including seven invention patents and thirty-five utility model patents as of April 1, 2019. 
These  patents  and  patent  applications  are  intended  to  protect our  technologies,  including  production  processes  of  various  wire ropes,  pickling  methods  for 
steel  wire  materials,  the  quality  control  methods  for  certain  steel  wire  products  and  devices  designed  for  the  production  of  steel  wire.  Our  research  and 
development  efforts  have  generated  technological  improvements  that  have  been  instrumental  in  controlling  our  production  costs  and  increasing  our 
operational efficiency, most notably with respect to the development of our rare earth coated materials.

Strong recognition from domestic and international customers for supplying materials for infrastructure projects

The solid reputation that our management team has developed over the past nearly 25 years in the prestressed material industry in China and in other 
countries  such  as  Canada,  the  United  States,  Japan,  South  Korea,  Bangladesh,  South  Africa,  Italy  and  Spain,  including  an  established  track  record  for 
consistently providing quality products at competitive prices, has enabled us to develop a strong customer base and to be involved in major building projects.

We  generated  approximately  3.3%  and  4.1%,  respectively,  of  our  revenue  during  the  years  ended  December  31,  2018  and  2017  from  sales  to 
customers in international markets including primarily Vietnam, South Korea, Japan, New Zealand, Australia, Bangladesh, Brunei, Costa Rica, South Africa, 
Egypt, and Amman, primarily for use in the construction of bridges. Due to the anti-dumping measures imposed by the United States and European Union in 
2008 and 2009 and recent stiff trade measures imposed by the United States government in 2018, we do not intend to reestablish a presence in the United 
States or the European Union at the levels we experienced in 2008 in the near future. However, if opportunities arise in the U.S. or EU markets or in other 
international markets for us to win bids on projects or to reengage with former customers or establish relationships with new customers, we would pursue such 
opportunities. Although we have not generated any sales from the United States since the anti-dumping duties were imposed in 2010, these measures imposed 
in  2018  may  also  have  a  negative  impact  on  our  business  and  results  of  operations  because  Chinese-based  steel  product  exporters  may  now  focus  their 
marketing efforts on the Chinese domestic market.

21

Rigorous quality control standards

Consistent with our continuing commitment to quality, we impose rigorous quality control standards at various stages of our production process. We 
strictly  comply  with  various  national  and  international  quality  standards  with  respect  to  the  manufacture  of  prestressed  materials.  Our  certifications  and 
accreditations include the Japanese Industrial Standards (JIS) certification, United Kingdom Accreditation Service (UKAS), the Korean Standards Association 
(KS) certification from South Korea and an ISO 9001 certification. We believe that these certifications, together with the numerous national awards that we 
have been awarded demonstrate our commitment to producing high-quality products as well as providing us with a competitive advantage over some of our 
competitors in certain international markets and in China.

Experienced management and operational teams with domestic PRC international market knowledge

Our senior management team and key operating personnel have extensive management skills, relevant operating experience and industry knowledge. 
In particular, Dr. Tang, our Chairman, is a Doctor of Economics, Senior Engineer and Professor of Finance and Statistics at the School of East China Normal 
University, and has extensive experience managing and operating companies in the prestressed steel industry. We believe our management team’s experience 
and in depth knowledge of the market in China and internationally will enable us to continue to successfully execute our expansion strategies. In addition, we 
believe our management team’s strong track record will enable us to continue to take advantage of market opportunities that may arise.

Our Products 

Our prestressed steel materials are categorized as plain surface products and coated products.

Plain Surface Products

Our plain surface products, which term refers to our uncoated plain surfaced and stabilized products, are characterized as follows:

·

Plain surface prestressed concrete, or PC, strands. These products consist of PC wires that are twisted into a bundle and used in precast concrete 
plates on the riding surface of bridges. These products are categorized based on size, strength and structure. Sizes range from 9.3mm to 17.8mm. 
Strength level ranges from 1570MPa (megapascal) to 2000MPa. The number of strands in the products varies between 3 and 7.

·

·

Unbonded plain surface PC strands. These products consist of plain surface PC strands that are coated with grease and extruded with high-
density polyethylene. These products are used primarily in the construction of bridges and buildings.

PC wires, also referred to as stabilized materials. These products are further divided among the following three categories:

§

§

Plain surface PC wires. This product consists of an individual round wire used in the construction of buildings.

Indented PC wires. This product consists of an individual round wire that contains an indentation used in the construction of buildings.

§ Helical (spiral) rib PC wires. This product consists of an individual round wire whose surface is pulled out into a helical rib pattern used 

in the construction of railway ties, or sleepers, and buildings.

PC wires are categorized based on size, strength and structure. Sizes range from 4.0mm to 9.0mm. Strength level ranges from 1570MPa to 2000MPa. 

The number of strands in the products varies between 3 and 7.

22

Coated Prestressed Products 

Our coated prestressed products included zinc coated PC products and rare earth coated PC products. Rare earth coated prestressed products are plain 
surface materials that are coated with a rare earth or rare earth alloy protective layer so as to produce materials that are more corrosion-resistant and long-
lasting. The purpose of coating is to generate a surface layer to protect the materials from erosion, abrasion and oxidization, without changing the elements of 
the basic materials or weakening the basic material’s strength or other functionality through any techniques that utilize physical chemistry or electrochemistry. 
The coating process can cause loss of strength in regular steel materials, but the loss of strength in rare earth coated prestressed products is reduced.

For  steel  wires  and  strands,  coating  can  provide  a  protective  layer  to  improve  the  product’s  corrosion-resistant  level  and  increase  its  life  span. 
Traditional technology uses zinc as the coating material and such products are called zinc coated PC wires and PC strands. The introduction of rare earth in 
the coating process adds more benefits to the final products. When rare earth is added into the coating material and form a new alloy with zinc, it increases 
further the life span of the product. More importantly, it reduces the loss of strength compared to traditional zinc coating process.

The  coating  process  happens  in  an  environment  with  very  high  temperature.  Because  of  the  high  temperature,  there  will  be  some  loss  of  product 
strength during the coating process. For example, if the steel wires to be used as raw material have a strength level of 2000 MPa (mega pascal), its strength 
level will lose about 300 MPa after going through the traditional coating process. When zinc forms a new alloy with rare earth and is used as a coating layer, 
the requirement of high temperature for processing could be lowered. Processing with lower temperature results in less loss of product strength during the 
coating process. Therefore, the same raw material, if using rare earth coating, could deliver higher strength final product. Compared with better corrosion-
resistant level, longer life span, higher strength level may be the most important benefit rare earth coated products bring to customers, as compared to zinc 
coated products. Higher strength means less steel is needed to build the bridge. The bridge cables could be slimmer, quantity of steel required for construction 
could be less and overall construction cost could be reduced.

Applications of zinc coated PC wires and PC strands are primarily in the construction of bridges.

Customers  that  purchase  our  prestressed  materials  also  purchase  other  supporting  products,  such  as  anchorage  devices  and  ripple  tubes,  to 

complement our materials. These supplementary products are produced by anchorage manufacturing factories that are unaffiliated with us.

Competition

China  is  one  of  the  world’s  largest  producers  and  markets  for  prestressed  steel  materials.  In  2017  and  2018,  our  sales  were  predominantly  to 

customers located in the PRC, and as a result, our primary competitors were PRC domestic companies.

We believe that being located in China provides us with a number of competitive factors within our industry, including the following:

Pricing. Flexibility to control pricing of products and the ability to use economies of scale to secure competitive pricing advantages;

Technology. Ability to manufacture products efficiently, utilize low-cost raw materials, and to achieve better production quality; and

Barriers to entry. Technical knowledge, access to raw materials, local market knowledge and established relationships with suppliers and customers 
to support the development of commercially viable production facilities and products.

·

·

·

Competition among manufacturers of plain surface steel products in China can be characterized as fragmented, with many large and small companies 

competing with each other. Our primary competitors for these products are Guizhou Steel Wire Co., Ltd. and Silvery Dragon Co., Ltd.

23

Competition among PRC manufacturers of zinc coated prestressed products in China is limited to only several companies. Our main competitors for 
these products are Baosteel Group Nantong Wire Products Co., Ltd., Shuangyou Eaststeel and Jiangyin Walsin Steel Cable Co. Ltd. Furthermore, While we 
believe that our rare earth coating capabilities provide us with a competitive advantage among our competitors, however, it is likely that our competitors may 
develop  similar  competing  products.  We  intend  to  continue  to  expand  research  and  development  efforts  to  advance  our  coating  applications  even  further, 
including improving the products’ corrosion-resistant level and increasing the products’ strength and life span However, there can be no assurance that our 
initial competitive advantage will be retained and that one or more competitors will not develop products that are equal or superior to ours in quality or are 
better priced than our rare earth coated products.

We  believe  that  we  differentiate ourselves  because we have  built a  recognized brand  name  in  the  industry  and  because we offer  superior  product 

quality, timely delivery and high value. We believe that we have the following advantages over many of our competitors:

·
·
·
·
·

·

the performance and cost effectiveness of our products;
our ability to manufacture and deliver products in required volumes, on a timely basis, and at competitive prices;
superior quality and reliability of our products;
our after-sale support capabilities, from both an engineering and an operational perspective;
effectiveness  of  customer  service  and  our  ability  to  send  experienced  operators  and  engineers  as  well  as  a  seasoned  sales  force  to  assist  our 
customers; and
overall management capability.

Seasonality 

Demand for our products is slightly affected by seasonality and is usually low during the first quarter of every year, as February is the Chinese New 

Year holiday and the winter weather in Northern China is cold, which results in a slowdown of construction.

Our Raw Materials and Supply

Raw Materials

High carbon steel wire rods are the primary raw material required to manufacture prestressed steel materials. The quality and cost of the rods we 
purchase differ between our plain surface products and our rare earth and zinc coated products. Rare earth and zinc coated products require higher-priced rods 
that are higher in purity and durability. The price for certain rods needed for coated products is higher than rods needed for plain surface products.  

Our Supply Sources 

We select our suppliers by assessing criteria such as the quality of materials supplied, the duration of the supplier’s business relationship with us, 
pricing,  delivery  reliability  and  response  time  to  orders  placed  by  us.  To  minimize  purchasing  costs,  we  use  a  limited  number  of  suppliers.  Because  we 
purchase  substantial  quantities  from  these  suppliers,  we  are  often  able  to  procure  these  products  at  competitive  prices.  We  usually  enter  into  a  one-year 
purchase agreement with each supplier and then order on a spot basis for each delivery. We negotiate pricing with our suppliers on an arm’s length basis prior 
to the delivery of these supplies to us, based upon the prevailing market prices at such time.

The suppliers that supplied us with a significant percentage of our raw materials for the past three years were Jiangsu Shagang Group Co., Ltd., 

Shanghai Chemical Industry Supply and Marketing Co., Ltd., Jiangxi Yigeer Technology Co., Ltd., and Baosteel Group Nantong Wire Products Co., Ltd. and 
all are based in China.

Purchases from our five largest suppliers accounted for 99.8% and 99.7% of our raw material purchases in 2018 and 2017, respectively.

24

We are not dependent on any one of our suppliers, as we are able to source raw materials from alternative vendors should the need arise. We have not 

experienced significant production disruptions due to a supply shortage from our suppliers, nor have we had any major dispute with a material supplier.

Volatility of Price of Raw Materials 

We have no long-term, fixed-price steel purchase contracts. When steel prices increase competitive conditions will influence how much of the price 
increase we can pass on to our customers. To the extent we are unable to pass on future price increases in our raw materials to our customers, the revenues and 
profitability of our business could be adversely affected. When steel prices decline, customer demands for lower prices and our competitors' responses to those 
demands could result in lower sale prices, lower margins and inventory valued at the lower of cost or market adjustments as we use existing steel inventory. 
Significant or rapid declines in steel prices or reductions in sales volumes could result in us incurring inventory or goodwill impairment charges. Therefore, 
changing steel prices could significantly impact our revenues, gross margins, operating income and net income. In 2018, the Chinese government continued to 
focus on addressing the overcapacity in the steel industry and strengthening supply-side structural reform to drive sustained growth. As of December 2018, 
China has lowered steel production by about 150 million tons, according to reports issued by the Chinese government. As a result, the average price of steel 
products,  including  our  products  and  principal  raw  materials,  increased  in  2018.  According  to  industry  consultant  Frost  &  Sullivan,  the  Chinese  central 
government  will  focus  on  strictly  controlling  steel  capacity  increases  in  2019.  However,  due  to  the  slowdown  of  economic  growth,  local  governments  in 
Northern China, the most important steel production base, could increase allowable production levels of steel products, including our products and principal 
raw  materials.  As  a  result,  we  expect  the  average  price  of  our  principal  raw  materials  will  decrease  in  2019.  This  could  adversely  impact  our  results  of 
operations due to lower sale prices of our coated and plain surface products in the market.

Manufacturing Process 

Equipment

Our production facilities use innovative equipment and machinery imported from France and Italy and, we believe, is of the highest quality in metal 
wire  drawing,  wire  stranding,  zinc plating  and  finishing.  Our production  lines  produce prestressed  steel  materials  that  meet  quality standards mandated  by 
numerous countries, including Japan, the United Kingdom and South Korea.

We own cutting edge technologies in over 20 high-tech fields, including oil-immersion preservation technology, new coating production technology, 
skin  pass  coating  technology,  coating  stabilization  technology,  zinc  rare  earth  alloy  plating  technology,  new  high-temperature  phosphorization  heating 
technology,  new material traction technology, rare earth alloy technology, new fixed scoring technology,  new high-temperature low-speed thread stripping 
technology, and double coating stabilization, among others. We believe that we are the leading company in our industry with respect to the implementation of 
innovative technologies in the manufacture of prestressed steel materials.

Production Process

The production of our products involves various steps, including inspection, pickling, washing, rinsing, phosphatizing, boronizing, surface treatment, 
plating, baking, coating, cooling, polishing, inspection and packaging. The technology and procedures used in the above processes vary among the different 
products that we manufacture and depend upon the product specifications prescribed by a particular customer.

Generally, the manufacturing process involves the following:

· Cleaning steel wire rods or other similar raw materials by chemical pickling, mechanical de-scaling or a similar process. The materials are then cold 
drawn and reduced until the desired diameter and resistance characteristics are achieved. This process is what provides the material with its strength.
In the production of strands, the individual wires (either 3 or 7 wires) are braided together to form a strand.

·
· The  final  step  is  to  subject  the  steel  material  to  a  thermo-chemical  process  which  endows  the  material  with  mechanical  properties,  such  as  low 

relaxation, which enable the material to last over time.

25

Processing Lines

We currently have 18 processing lines, consisting of the following:

· Two surface treatment lines, one located in our Maanshan facility and one in our Jiujiang facility, each composed of an acid pickling bath, rinsing bath, 

high pressure water rinsing bath, phosphating bath, saponification (boronizing) bath and cleaning bath.

· Seven  wire  drawing  production  lines,  four  located  in  our  Maanshan  facility  and  three  in  our  Jiujiang  facility,  each  composed  of  a  pay-off  machine, 

drawn can and take-up machine. Each of our half-finished products is processed on a wire drawing production line.

· Three  PC  strand  stabilization  treatment  lines,  two  located  in  our  Maanshan  facility  and  one  in  our  Jiujiang  facility,  each  composed  of  stranding 
machines, straightening wheels, jockey wheels, medium frequency furnace, cooling tank, take-up and pay-off machines, a wire arraying machine and a 
layer winding machine. The PC strand stabilization product lines in our Jiujiang facility produce plain surface PC strands and zinc coated PC strands of 
various specifications.

· One zinc galvanization line, located in our Jiujiang facility, composed of a pay-off machine, degreasing furnace, acid rinsing pickling tank, assistant 
plating tank, drying furnace, galvanizing furnace, drawing tower and take-up machine. Half-finished products needed for different series of zinc coated 
PC wires and strands are produced on this line.

· Two  surface  finishing  lines,  both  located  in  our  Jiujiang  facility,  each  composed  of  a  pay-off  machine,  a  finishing  machine  and  a  take-up  machine. 

These production lines are used to produce half-finished products of zinc coated PC wires and strands.

· Two  PC  wire  stabilization  treatment  lines,  both  located  in  our  Jiujiang  facility,  each  composed  of  a  pay-off  machine,  jockey  wheel,  straightening 
machine, indent marking machine, medium frequency furnace, cooling tank, towing machine, shearing machine and take-up machine. Zinc coated PC 
wires, round PC wires, indented PC wires and helical rib PC wires are produced on these production lines.

· One  unbonded  PC  strand  line,  located  in  our  Jiujiang  facility,  composed  of  a  pay-off  machine,  oiling  machine,  high-density  polyethylene  plastic 
injection machine, water tank, towing machine and take-up machine. This line is used to produce different series of unbonded plain surface PC strands 
and unbonded zinc coated PC strands.

Quality Control

Consistent with our continuing commitment to quality, we impose rigorous quality control standards at various stages in the production process. In 
addition, our facilities are equipped with first-class testing equipment, such as a tensile strength tester and a relaxation tester, which guarantee the high quality 
and safety of our products.

We  strictly  comply  with  various  national  and  international  quality  standards  with  respect  to  the  manufacture  of  pre-stressed  materials.  Our 
certifications  and  accreditations  include  the  Japanese  Industrial  Standards  (JIS)  certification,  United  Kingdom  Accreditation  Service  (UKAS),  the  Korean 
Standards Association (KS) certification from South Korea and an ISO 9001 certification.

Our  procedure  when  discovering  any  product  quality  problem  in  the  production  process  includes  immediate  shut  down  for  inspection.  Once  the 
problem  is  solved,  we  continue  with  production.  If  a  problem  occurs  with  a  product,  the  product  inspector  stamps  a  nonconformity  seal  and  hangs  a 
nonconformity label on the problematical product. The nonconforming product is moved to a separate area and is not transferred to the next procedure. We do 
not deliver nonconforming products to users.

26

Sales, Marketing and Distribution

Sales and Marketing

We have been successful to date in maintaining long-term relationships with numerous customers by satisfying their commercial needs. In addition, 
our marketing team monitors the market and responds accordingly in order to increase our customer base. We have a dedicated marketing and sales team of 
six employees that proactively follows up on new sales leads.

Our marketing team develops strategies for the short-term and long-term by obtaining first-hand information about our products’ market positioning, 
monitoring national macro-economic policies, inquiring about current and future market needs, following the progress of existing projects and the satisfaction 
of existing customers. In addition, our technicians and marketing specialists regularly visit governmental departments, construction development companies, 
design institutes, supervision institutions, national construction quality inspection institutions and builders to promote new products. We have also joined the 
PRC national bridge exhibition for marketing purposes.

Distribution

Both  of  our  manufacturing  plants  are  equipped  with  facilities  for  cargo  lifting,  shipment  and  distribution.  Products  for  domestic  customers  are 
distributed to the destination designated by our customers. Products for international customers are delivered either to carriers at various ports of exit in China 
or delivered to a designated destination overseas.

Technical After-Sales Services

Our team of experienced engineers and technicians provides after-sales services to our customers. After the delivery of our materials, our engineers 
train our customers to install and identify and address safety and maintenance concerns. After a sale of our product, we introduce and advertise the company 
brand position, distribute a guide application method process, issue regulation manuals, and explain and solve general and difficult problems. All technical 
after-sales services are provided to our customers free of charge.

Our Customers 

We  sell  the  vast  majority  of  our  products  domestically  in  China.  Since  our  inception,  we  have  also  exported  our  products  to  foreign  countries, 
including the United States, Canada, Spain, Japan, South Korea, Taiwan, Australia, South Africa and Saudi Arabia, among others. Our customers are diverse 
in nature, as we sell our products directly to end users, to other manufacturers and to distributors, in each case depending on the nature of the product and the 
utilization of the product.

While  we  value  our  relationship  with  each  of  our  customers,  we  believe  that  generally  the  loss  of  any  particular  customer,  including  our  largest 
customers, would not materially impact our business in the long-term. Many of our customer contracts relate to designated infrastructure projects which are 
performed during a defined period of time, and are not necessarily long-term in nature. Accordingly, if any of our customers were to discontinue purchasing 
our products, we would actively seek new customers, which we have been successful doing in the past.

In 2017 and 2018, sales to our six largest customers, in the aggregate, accounted for approximately 68.3% and 74.8% of our total sales, respectively. 
The following table provides the name of each customer that contributed to more than 10% of our revenues in each of 2017 and 2018 and the percentage of 
our revenues generated from such customers during these periods.

27

Name of Customer

Zhangjiagang Shajing Iron and Steel Trading Co., Ltd.

Jiangsu Jinrun Steel Cable Co., Ltd.

Zhangjiagang OVM Machinery Co., Ltd.

Shanghai Hanghe Metal Products Co., Ltd.

Zhejiang Kexin Engineering Material Co., Ltd.

Liuzhou OVM Machinery Co., Ltd.

* Less than 10% of our annual revenues.

2018 Revenues
(%)

2017
Revenues
(%)

*

13.6

14.1

*

14.6

10.2

30.4

10.4

*

*

10.9

*

 The following table describes the breakdown of our sales in 2018 and 2017 between our domestic and international customers.

Domestic Sales

International Sales

Total Sales

Research and Development 

For the Year Ended December 31,

2018
131,642,673 $

2017

126,930,386

4,462,194 $

5,445,529

136,104,867 $

132,375,915

$

$

$

Our research and development efforts are focused on three objectives:

·

·

·

Superior product safety and quality;

Reduction of operating costs; and

Sustaining growth through the development of new products.

We have a research and development team at each of our facilities. In total, sixteen employees are dedicated to research and development. We spent 
$3.3 million and $4.3 million in 2018 and 2017, respectively, on our research and development activities to customize products for new or existing customers 
and  develop  new  products.  The  nature  of  our  research  and  development  activities  needed  for  our  product  development  is  generally  not  cash  intensive.  In 
addition, a portion of the work is conducted by organizations and universities with which we have a collaborative relationship.

We  regularly  train  the  members  of  our  research  and  development  department  in  order  to  consistently  enhance  our  research  and  development 
capabilities  in  the  field  of  coating  technology.  We  have  developed  a  business  model  that  involves  a  very  close  interrelationship  between  our  research  and 
development department and our product development and marketing departments. As a result, we focus our research and development activities on projects 
that  would  enable  us  to  branch  out  our  products  into  new  desired  markets.  In  addition,  we  conduct  research  and  development  activities  that  enable  us  to 
increase  our  market  share  in  existing  markets  in  the  PRC  and  internationally.  We  also  focus  certain  of  our  research  and  development  activities  on  higher 
margin products that can be sold to customers in international markets.

28

Specifically, we have entered into cooperation agreements with Jiujiang Institute pursuant to which the institute assists us in our efforts to improve 
the  comprehensive  function  and  manufacturing  technique  of  our  high  strength,  anti-erosion  zinc  coated  prestressed  strands.  These  high  strength  products, 
which have high endurance against erosion, are sold domestically and internationally. Pursuant to a two-year research cooperation agreement with Jiujiang 
Institute in 2017, Ossen Jiujiang agreed to provide its research and development resources such as the research and development team and testing laboratories 
for facilitating students of Jiujiang Institute to develop new technology know-how on certain galvanised prestressed technology with a view to reducing unit 
costs, improving production efficiency, upgrading product quality. In addition, we are cooperating with other steel manufacturers in research efforts regarding 
zinc coated PC wires, which serve as raw materials for our zinc coated PC strands, indented PC wires and helical rib PC wires with high performance and are 
designed for our international customers.

In addition, our Jiujiang facility received the recognition of Jiujiang Municipal Enterprise Technology Center by Jiujiang Municipal Government in 
2012 and our Maanshan facility received Maanshan Municipal Projects Technology Research Center by Maanshan Municipal Science and Technology Bureau 
in 2014.

We believe that our research and development activities and production technology for rare-earth zinc coated materials have enhanced our market 
position. By using rare earth-alloy-plating technology, we are able to lower the temperature for the stabilizing treatment during the production process and 
thereby minimize the loss of strength during the stabilizing process. As a result, this technology reduces the level of strength required of our raw materials 
under circumstances of unvaried finished product strength requirement and enables us to produce materials with greater strength under circumstances in which 
the strength of raw materials remains firm. We can produce zinc rare earth alloy coated pre-stressing materials of 1,860 mega pascal (“mPa”) strength level 
and 15.20 mm diameter, as a result of our rare earth alloy-plating technology. We will continue our research and development efforts to improve the strength 
and stability of such product.

We plan to continue our research and development efforts to strengthen our leading position in our industry. In 2014, we developed 12.7 mm 2060 
mPa ultra high strength and low relaxation prestressed strands. Our research and development team also upgraded the heating method of acid pickling process, 
the circulating  cooling water  system  of  steel  wire  stabilization  production  line,  and  the  winding  system  of  coated steel  wire  We also own  or  lease various 
technologies that improve the quality of our products and reduce our operating costs, including coating polished technology, stabilizing treatment technology 
for dual tension gear zinc coated prestressing material, warning technology for missing plating of coating production line, stranded wire greasing technology, 
water cut-off technology by strander infrared temperature detection and other core technologies.

Intellectual Property

We  rely  on  a  combination  of  patents,  trademarks,  domain  names  and  confidentiality  agreements  to  protect  our  intellectual  property.  Our 

manufacturing processes are based on technology developed primarily in-house by our research and development and engineering personnel.

With respect to proprietary know-how that is not patentable and processes for which patents are difficult to enforce, we rely on, among other things, 
trade  secret  protection  and  confidentiality  agreements  to  safeguard  our  interests.  All  of  our  research  and  development  personnel  have  entered  into 
confidentiality and proprietary information agreements with us. These agreements address intellectual property protection issues and require our associates to 
assign  to  us  all  of  the  inventions,  designs  and  technologies  they  develop  during  the  course  of  employment  with  us.  We  are  not  aware  of  any  material 
infringement of our intellectual property rights.

Patents

As of April 1, 2019, we have forty-two patents registered with the State Intellectual Property Office of the PRC, including seven invention patents 

and thirty-five utility model patents.

Between  January  1,  2018  to  April  1,  2019,  five  previously-pending  utility  model  patents  and  three  previously-pending  invention  patents  were 

approved by the State Intellectual Property Office.

29

Actual examination times for patent applications in China vary, but examinations of similar patent applications have taken approximately one year. 
These patents and patent applications are intended to protect the production processes of various wire ropes, pickling methods of materials of steel wire, the 
quality control methods for certain steel wire products and devices designed for the steel wire production. The term of all of the utility model patents is ten 
years from the filing of the application and the term of all of the invention patents is twenty years from the filing of the application. We currently do not have 
any patents registered or pending in any jurisdiction outside of the PRC.

The following table provides the name, the application number or patent number, the name of the applicant or patent holder and the status of our 

registered invention patents and each of our invention patent applications, and the expiration date of our registered invention patent:

Name

Stabilizing Process of Indented Wire
Method to Change the Length of Waste of Stranded Wire Joint
Production Process of Zinc Coated Steel Wire
Re-processing Technology of Galvanized Steel Wire
Prestressed Galvanized Steel Wire Joint Stabilizing Processing 
Production Method
High-strength prestressed steel wire drawing and matching 
method
Prestressed steel strand aeration pickling tank and pickling 
method

Application No.
/Patent No.

Applicant
/Patent
Holder

ZL200710157149.0
ZL200910144241.2
ZL201010105179.9
ZL201310137387.0

Ossen Jiujiang
Ossen Materials
Ossen Jiujiang
Ossen Jiujiang

Status

Registered
Registered
Registered
Registered

Expiration
Date

11/22/2027
7/26/2029
2/2/2030
4/18/2033

ZL201610567857.0

Ossen Jiujiang

Registered

7/18/2036

ZL201610567616.6

Ossen Jiujiang

Registered

7/18/2036

ZL201510161287.0

Ossen Materials

Registered

4/6/2035

The following table provides the name, the application number or patent number, the name of the applicant or patent holder and the status of each of 

our registered utility model patents and utility model patent applications, and the expiration dates of our registered utility model patents:

Name

Device Designed to Control Water Temperature When 
Phosphatizing the PC Strand

Application No.
/Patent No.

Applicant
/Patent
Holder

Status

Expiration
Date

ZL200920233724.5

Ossen Materials

Registered

07/29/2019

Device for Testing Center Steel Wire Broken for Stranded Wire

ZL200920233725.x

Ossen Materials

Registered

07/29/2019

Device Designed to Test Temperature of Steel Wire When 
Drawing the Stranded Wire

ZL200920233726.4

Ossen Materials

Registered

07/29/2019

Steel Wire Joint Machine with Pressure Detecting Function

ZL200920233728.3

Ossen Materials

Registered

07/29/2019

Automatic Paper Rolling Device of Asphalt Paper

ZL200920233729.8

Ossen Materials

Registered

07/29/2019

Aerial Overhaul Platform for Forklift

ZL200920233730.0

Ossen Materials

Registered

07/29/2019

Skid Used When Packing PC Strand

ZL200920233731.5

Ossen Materials

Registered

07/29/2019

Inductive Water Saving Device

ZL201220218155.4

Ossen Materials

Registered

06/25/2021

Anti-Impact Gear

ZL201220217756.3

Ossen Materials

Registered

06/23/2021

Lock Device for PC Strand Production Wheel

ZL201220218156.9

Ossen Materials

Registered

06/25/2021

New Dies for Wire Drawing

ZL201320723167.7

Ossen Materials

Registered

12/24/2022

Energy-saving Device for Acid Mist Drainage

ZL201320722838.8

Ossen Materials

Registered

12/24/2022

Cold Assembly Mould

Prestressed Strand Spreader

ZL201420023335.0

Ossen Materials

Registered

1/14/2024

ZL201420023447.6

Ossen Materials

Registered

1/14/2024

30

Name

Application No.
/Patent No.

Applicant
/Patent
Holder

Status

Expiration
Date

Pickling Pool Electric Heating Control System

ZL201620087931.4

Ossen Materials

Registered

1/26/2026

Air Compressor Motor Protection System

ZL201620087953.0

Ossen Materials

Registered

1/26/2026

Prestressed Steel Wire Ultrasonic Vibration Pickling Pool

ZL201621197903.4

Ossen Materials

Registered

11/6/2026

Prestressed Strand Online Water Removal Device

ZL201720979882.X

Ossen Materials

Registered

8/6/2027

Prestressed Steel Strand Production Spiral Air Cylinder

ZL201621197904.9 

Ossen Materials

Registered

11/6/2026

Closed Soot Filter System for Strand Production

ZL201721178282.X

Ossen Materials

Registered

9/13/2027

Strand Take-up Machine

ZL201721177583.0

Ossen Materials

Registered

9/13/2027

Steel Wire On-line Oil Coating Device

ZL201721178741.4

Ossen Materials

Registered

9/13/2027

Prestressed Steel Strand Packaging Structure

ZL201720976708.X

Ossen Materials

Registered

8/6/2027

Furnace for Zinc Coating Process

ZL201320200197.4

Ossen Jiujiang

Registered

4/18/2023

Actinomycetes Machine Discharge Line Protection Devices

ZL201320200077.4

Ossen Jiujiang

Registered

4/18/2023

Strand Actinomycetes Devices

ZL201320200171.X

Ossen Jiujiang

Registered

4/18/2023

Cooling Device with Distilled Water for Medium Frequency 
Furnace

ZL201320199776.1

Registered

4/18/2023

Ossen Jiujiang

U-shape Hot Galvanizing Furnace

ZL201420532006.9

Ossen Jiujiang

Registered

9/16/2024

Plastic Particle Drying Mixer

ZL201420798062.7

Ossen Jiujiang

Registered

12/16/2024

Multi-functional Line Traction Machine for Steel Wire 
Stabilization Processing Production Line

ZL201420798307.6

Registered

12/16/2024

Ossen Jiujiang

Dust Removing Device for Surface Treatment for Drawing Steel 
Wire

ZL201420798232.1

Ossen Jiujiang

Registered

12/16/2024

An Oil Weight Control Device for Unbonded Steel Strand

ZL201620720468.2

Ossen Jiujiang

Registered

7/10/2026

A Dedusting and Dedusting Device for A Prestressed Steel Strand 
Joint Machine

ZL201620720466.3

Ossen Jiujiang

Registered

7/10/2026

A Galvanized Steel Wire Fixture for Tensile Testing Machine

ZL201620720452.1

Ossen Jiujiang

Registered

7/10/2026

A Trapezoid Mold for Wire Rod Drawing of Carbon Steel

ZL201620720451.7

Ossen Jiujiang

Registered

7/10/2026

31

Trademarks

We have been granted a total of five trademarks, three of which are registered trademarks in the PRC and two of which are registered with the World 
Intellectual  Property  Organization  (WIPO)  in  accordance  with  Madrid  Agreement.  The  five  trademarks  which  are  described  in  the  table  below  were 
transferred by Shanghai Ossen Investment Co., Ltd. to Ossen Materials in 2008 and 2009.

Name of Trademark

Application No.
/Trademark No.

A Figurative Trademark (Registered under Madrid Agreement )

0973552

“OSSEN” (Registered under Madrid Agreement )

A Figurative Trademark (PRC Domestic Registered)

“OSSEN” (PRC Domestic Registered)

“

” (PRC Domestic Registered)

0945308

4396898

4396895

4396896

32

Applicant
/Trademark
Holder

Ossen Innovation 
Materials

Ossen Innovation 
Materials

Ossen Innovation 
Materials

Ossen Innovation 
Materials

Ossen Innovation 
Materials

Status

Registered

Registered

Registered

Registered

Registered

Environmental Matters

The Environmental Protection Law, promulgated by the National People’s Congress on December 26, 1989, is the primary law for environmental 
protection in China. The law establishes basic principles for coordinated advancement of economic growth, social progress and environmental protection, and 
defines the rights and duties of governments at all levels. Local environmental protection bureaus may set stricter local standards than the national standards 
and enterprises are required to comply with the stricter of the two sets of standards. Due to the nature of our business, we produce certain amounts of waste 
water, gas and solid waste materials during the course of our production. We believe that we are in compliance in all material respects with applicable PRC 
laws and regulations. All of our products meet the relevant environmental requirements under PRC laws and during the three years ended December 31, 2018 
and 2017, we were not subject to any fines or legal action involving non-compliance with any relevant environmental regulation, nor are we aware of any 
threatened or pending action, including by any environmental regulatory authority.

Governmental Regulations

Business license

Any company that conducts business in the PRC must have a business license that covers a particular type of work. Our business license covers our 
present business of manufacturing, processing, procuring and selling metallic materials, metallic products, new alloy materials, rare earth application products, 
building materials, general machinery and related products. Prior to expanding our business beyond that of our business license, we are required to apply and 
receive approval from the PRC government.

Employment laws

We are subject to laws and regulations governing our relationship with our employees, including: wage and hour requirements, working and safety 
conditions,  citizenship  requirements,  work  permits  and  travel  restrictions.  These  include  local  labor  laws  and  regulations,  which  may  require  substantial 
resources for compliance. China’s National Labor Law, which became effective on January 1, 1995, and China’s National Labor Contract Law, which became 
effective on January 1, 2008, permit workers in both state and private enterprises in China to bargain collectively. The National Labor Law and the National 
Labor Contract Law provide for collective contracts to be developed through collaboration between the labor union (or worker representatives in the absence 
of a union) and management that specify such matters as working conditions, wage scales, and hours of work. The laws also permit workers and employers in 
all types of enterprises to sign individual contracts, which are to be drawn up in accordance with the collective contract.

Patent protection in China

The PRC has domestic laws for the protection of copyrights, patents, trademarks and trade secrets. The PRC is also signatory to some of the world’s 

major intellectual property conventions, including:

· Convention establishing the World Intellectual Property Organization (WIPO Convention) (June 4, 1980);
· Paris Convention for the Protection of Industrial Property (March 19, 1985);
· Patent Cooperation Treaty (January 1, 1994); and
· The Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPs) (November 11, 2001).

33

Patents  in  the  PRC  are  governed  by  the  China  Patent  Law  and  its  Implementing  Regulations,  each  of  which  went  into  effect  in  1985.  Amended 

versions of the China Patent Law and its Implementing Regulations came into effect in 2001 and 2003, respectively.

The PRC is signatory to the Paris Convention for the Protection of Industrial Property, in accordance with which any person who has duly filed an 
application for a patent in one signatory country shall enjoy, for the purposes of filing in the other countries, a right of priority during the period fixed in the 
convention (12 months for inventions and utility models, and 6 months for industrial designs).

The Patent Law covers three kinds of patents - patents for inventions, utility models and designs. The Chinese patent system adopts the principle of 
first to file, which means that a patent may be granted only to the person who first files an application. Consistent with international practice, the PRC allows 
the  patenting  of  inventions  or  utility  models  that  possess  the  characteristics  of  novelty,  inventiveness  and  practical  applicability  only.  For  a  design  to  be 
patentable it cannot be identical with, or similar to, any design which, before the date of filing, has been publicly disclosed in publications in the country or 
abroad or has been publicly used in the country, and should not be in conflict with any prior right of another.

Value added tax

Pursuant to the Provisional Regulation of China on Value Added Tax and their implementing rules, all entities and individuals that are engaged in the 
sale of goods, the provision of repairs and replacement services and the importation of goods in China are generally required to pay VAT at a rate of 16.0% or 
17.0% of the gross sales proceeds received, less any deductible VAT already paid or borne by the taxpayer. Since May 1, 2018, the VAT rate is 16% which 
applies to the manufacturing sector in China. Furthermore, when exporting goods, the exporter is entitled to a portion, or in some instances all, of the VAT 
refund that the exporter previously paid.

Foreign currency exchange

Under  the  PRC  foreign  currency  exchange  regulations  applicable  to  us,  the  Renminbi  is  convertible  for  current  account  items,  including  the 
distribution of dividends, interest payments, and trade and service-related foreign exchange transactions. Conversion of Renminbi for capital account items, 
such as direct investment, loan, security investment and repatriation of investment, however, is still subject to the approval of the PRC State Administration of 
Foreign  Exchange,  or  SAFE.  Foreign-invested  enterprises  may  buy, sell  and/or  remit  foreign  currencies  only  at  those  banks  authorized  to  conduct  foreign 
exchange business, after providing valid commercial documents and, in the case of capital account item transactions, obtaining approval from SAFE. Capital 
investments by foreign-invested enterprises outside of China are also subject to limitations, which include approvals by the Ministry of Commerce, SAFE and 
the State Reform and Development Commission.

Mandatory statutory reserve and dividend distributions

Under  applicable  PRC  regulations,  foreign-invested  enterprises  in  China  may  pay  dividends  out  of  their  accumulated  profits  only,  if  any,  as 
determined in accordance with PRC accounting standards and regulations. In addition, a foreign-invested enterprise in China is required to set aside at least 
10% of its after-tax profit based on PRC accounting standards each year for its general reserve until the cumulative amount of such reserve reaches 50% of its 
registered capital. These reserves are not distributable as cash dividends. The board of directors of a foreign-invested enterprise has the discretion to allocate a 
portion of its after-tax profits to staff welfare and bonus funds, which may not be distributed to equity owners except in the event of liquidation.

Employees

As of December 31, 2018 and 2017, we had 184 and 190 full-time employees. As of April 1, 2019, we had 184 full-time employees.

34

The following table shows the breakdown in numbers and percentages of employees by department as of December 31, 2018:

Functions

Manufacturing
Research & Development
Quality Control
General Administration, Purchasing, Sales and Marketing
Total

Number of
employees

% of total

102
16
6
60
184

55%
9%
3%
33%
100%

We have not experienced any significant labor disputes and consider our relationship with our employees to be good. Our employees are not covered 

by any collective bargaining agreement.

We  have  established  an  employee  welfare  plan  in  accordance  with  the  relevant  PRC  laws  and  regulations.  Our  total  expenses  for  this  plan  were 

approximately $265,491 and $249,491 in 2018 and 2017, respectively.

As  we  continue  to  expand  our  business,  we  believe  it  is  critical  to  hire  and  retain  top  talent,  especially  in  the  areas  of  marketing,  metal  surface 
treatment, materials science, and technology engineering. We believe we have the ability to attract and retain high quality engineering talent in China based on 
our competitive salaries, annual performance-based bonus system, and equity incentive program for senior employees and executives. In addition, we have a 
training program for entry-level engineers that allows them to work closely with an experienced mentor to gain valuable hands-on experience and provide 
other professional development opportunities, including seminars where experienced engineers give lectures on specific engineering topics and new methods 
that can be applied to various projects.

4C. Organizational Structure

Our Majority Shareholders

Pursuant to securities purchase agreements dated August 7, 2018, on August 8, 2018 and August 14, 2018, Effectual Strength Enterprises Limited 

(“Effectual”), a British Virgin Islands company controlled by Liang Tang, purchased:

(cid:120)

(cid:120)

600,000 shares from Fascinating Acme Development Limited, an entity controlled by the spouse of Wei Hua, our Chief Executive Officer, at a price 
of $2.582 per ADS, each ADS representing three Ordinary Shares; and

600,000 shares from Gross Inspiration Development Limited, an entity controlled by the spouse of Xufeng Zhou, our senior manager, at a price of 
$2.582 per ADS. 

On October 2, 2018, Acme Innovation Limited, a British Virgin Islands company (“Acme”) wholly owned by Pujiang International Group Limited, a 
Cayman Islands company (“Pujiang”) controlled by Dr. Liang Tang, purchased 13,050,000 of our ordinary shares from Effectual, in exchange for the issuance 
of  54,404  shares  of  Pujiang  to  Elegant  Kindness  Limited  (“Elegant”),  a  British  Virgin  Islands  company  wholly  owned  by  Dr.  Liang  Tang.  Consequently, 
Acme now holds 13,050,000 of our ordinary shares.

On  December  11,  2018,  Pujiang,  the  parent  entity  of  Acme,  submitted  an  application  to  the  Hong  Kong  Stock  Exchange  (the  “HK  Exchange”), 
seeking  approval  of  a  potential  listing  of  Pujiang’s  shares  on  the  HK  Exchange  following  a  proposed  initial  public  offering  of  Pujiang’s  shares.  Such 
application is subject to the review of the HK Exchange. The terms of such offering have not yet been set. Furthermore, the timing of the consummation of 
such potential offering and listing is unknown, and there is no guarantee that such listing and offering will be consummated at all. This filing shall not be 
deemed an offering of the securities of Pujiang or the Company.

35

Our Subsidiaries

British Virgin Islands Companies

Ossen  Innovation  Group,  our  wholly  owned  subsidiary,  is  the  sole  shareholder  of  two  holding  companies  organized  in  the  British Virgin  Islands: 
Ossen Group (Asia) Co., Ltd., or Ossen Asia, and Topchina Development Group Ltd., or Topchina. All of the equity of Ossen Asia and Topchina had been 
held  by Dr.  Tang,  our Chairman,  since inception.  In May 2010,  Dr. Tang  transferred  these  shares to  Ossen  Innovation  Group in anticipation of  the public 
listing of our company’s shares in the United States.

Ossen Asia is a British Virgin Islands limited liability company organized on February 7, 2002. Ossen Asia has one direct operating subsidiary in 

China, Ossen Innovation Materials Co. Ltd., or Ossen Materials. Ossen Asia owns 81% of the equity of Ossen Materials.

Topchina  is  a  British  Virgin  Islands  limited  liability  company  organized  on  November  3,  2004.  Ossen  Materials  and  Topchina  directly  own  an 
operating subsidiary in China, Ossen (Jiujiang) Innovation Materials Co., Ltd., or Ossen Jiujiang. As of December 31, 2016, Ossen Materials owns 20.5% of 
the equity of Ossen Jiujiang and Topchina owns 79.5%.

Ossen Materials

Ossen  Materials  was  formed  in  China  on  October  27,  2004  as  a  Sino-foreign  joint  venture  limited  liability  company  under  the  name  Ossen 
(Maanshan) Steel Wire and Cable Co., Ltd. On May 8, 2008, Ossen Materials was restructured from a Sino-foreign joint venture limited liability company to a 
corporation. The name of the entity was changed at that time to Ossen Innovation Materials Co., Ltd.

Ossen Asia owns 81% of the equity of Ossen Materials. The remaining 19% is held in the aggregate by three third-party Chinese entities, two of 
which are controlled by Chinese governmental entities, one of which is controlled by Zhonglu Co. Ltd., a company whose shares are listed on the Shanghai 
Stock Exchange, and Ossen Group PRC, which is ultimately controlled by Chinese citizens.

Through Ossen Materials, we have manufactured and sold plain surface PC strands, rare earth coated PC steel wires and PC wires in our Maanshan 
City  facility  since  2004.  The  primary  markets  for  the  products  manufactured  at  our  Maanshan  facility  are  Anhui  Province,  Jiangsu  Province,  Zhejiang 
Province and Shanghai City, each in the PRC.

Ossen Jiujiang

On April 6, 2005, Shanghai Ossen Investment Holdings (Group) Co., Ltd., or Ossen Shanghai, acquired a portion of the bankruptcy assets of Jiujiang 
Steel & Iron Company, including equipment, land use rights and inventory, for approximately RMB 20,000,000 (approximately $2.9 million). Ossen Jiujiang 
was formed by Ossen Shanghai in the PRC as a Sino-foreign joint venture limited liability company on April 13, 2005. Ossen Shanghai then transferred the 
newly acquired assets to Ossen Jiujiang. At its inception, Ossen Jiujiang was owned by two entities: 33.3% of its equity was held by Ossen Asia and 66.7% by 
Ossen Shanghai. In June 2005, Ossen Shanghai transferred its entire interest in Ossen Jiujiang to Topchina in exchange for approximately $2.9 million. In 
October 2007, Topchina transferred 41.7% of the equity in Ossen Jiujiang to Ossen Asia for no consideration. On December 17, 2007, Ossen Asia transferred 
all of its shares in Ossen Jiujiang to Ossen Materials.

On  November  19,  2010,  the  Department  of  Commerce  of  Jiujiang  City  approved  an  increase  in  the  registered  capital  of  Ossen  Jiujiang  by 
approximately $29.2 million, which capital must be paid in full by November 2013. On November 5, 2012, the Department of Commerce of Jiujiang City 
approved a decrease in the registered capital of Ossen Jiujiang by approximately $9.2 million. As of December 31, 2014, Topchina paid approximately $20 
million of the increased registered capital to Ossen Jiujiang. As a result, 79.5% of Ossen Jiujiang is currently held by Topchina and 20.5% by Ossen Materials. 
On April 9, 2014, Ossen (Jiujiang) Steel Wire & Cable Co., Ltd. changed its name to Ossen (Jiujiang) Innovation Materials Co., Ltd.

36

Through Ossen Jiujiang, we manufacture zinc or rare earth coated PC wires and strands, plain surface PC strands, unbonded PC strands, helical rib 
PC wires, sleeper PC wires and indented PC wires. The primary markets for the PC strands manufactured in our Jiujiang facility are Jiangxi Province, Hubei 
Province, Hunan Province, Fujian Province and Sichuan Province, each in the PRC.

Organizational Structure Chart

The following chart reflects our organizational structure:

4D. Property, Plants and Equipment

Under PRC law, land is owned by the state. “Land use rights” are granted to an individual or entity after payment of a land use right fee is made to 

the applicable state or rural collective economic organization. Land use rights allow the holder the right to use the land for a specified long-term period.

37

We have land-use rights for facilities at two locations in the PRC, one in Maanshan City, Anhui Province and one in Jiujiang City, Jiangxi Province, 
which are utilized for production, research and development and employee living quarters. We have paid all amounts relating to these properties. The land-use 
rights for our Maanshan facility expires in 2058 and the rights for our Jiujiang facilities expire at different intervals, ranging from 2055 to 2057. Our facilities 
cover an aggregate of approximately 106,136 square meters.

As of December 31, 2018, our production facility and office in Maanshan City had a total gross floor area of approximately 14,668 square meters and 
we  employed  49  production  personnel  at  that  facility.  Our  Maanshan  facility  contained  seven  processing  lines.  As  of  December  31,  2018,  our  production 
facility  and  office  in  Jiujiang  City  had  a  total  gross  floor  area  of  approximately  20,810  square  meters  and  we  employed  53  production  personnel  at  that 
facility.  Our  Jiujiang  facility  contained eleven  processing lines.  The  production volume  of  our Maanshan facility  and Jiujiang facility was 193,174  tons in 
2018.  Historically,  we  did  not  experience  any  form  of  disruption  in  our  production  facilities.  However,  from  July  2018  to  December  2018,  due  to  a  local 
government's construction accident affecting a high-voltage transmission line near Ossen Jiujiang production facility, the power supply to some of our zinc 
coating  processing  lines  was  interrupted,  resulting  in  the  inoperability  of  several  equipment.  We  were  able  to  overcome  this  temporary  interruption  by 
purchasing semi-finished zinc coated products to produce finished zinc coated products. The total annual production of our two facilities decreased in 2018 
compared to 2017 due to less demand of our rare earth coated products and the interrupted power supply in Jiujiang facility, partially offset by the increase in 
demand of our zinc coated products in 2018.

We believe that our current property rights are sufficient for our current operations.

ITEM 4A. UNRESOLVED STAFF COMMENTS

Not Applicable

ITEM 5.

OPERATING AND FINANCIAL REVIEW AND PROSPECTS

The  following  discussion  and  analysis  should  be  read  in  conjunction  with  our  consolidated  financial  statements,  the  notes  to  those  financial 
statements  and  other  financial  data  that  appear  elsewhere  in  this  annual  report.  In  addition  to  historical  information,  the  following  discussion  contains 
forward-looking  statements  based  on  current  expectations  that  involve  risks  and  uncertainties.  Actual  results  and  the  timing  of  certain  events  may  differ 
significantly from those projected in such forward-looking statements due to a number of factors, including those set forth in “Risk Factors” and elsewhere in 
this report. Our consolidated financial statements are prepared in conformity with U.S. GAAP.

5A. Operating Results 

Overview

General

We manufacture and sell an array of plain surface prestressed steel materials and rare earth coated and zinc coated prestressed steel materials, which 
we  believe  is  the  most  comprehensive  array  among  our  competitors  in  China.  Our  materials  are  used  in  the  construction  of  bridges,  highways  and  other 
infrastructure projects in the PRC and internationally. Our facilities are located in Maanshan City, Anhui Province and in Jiujiang City, Jiangxi Province, in 
the People’s Republic of China. Based on our extensive experience in the industry, we believe that Ossen is one of the leading enterprises in the PRC in the 
design,  engineering,  manufacture and  sale  of  customized  prestressed  steel  materials  used in the construction  of  bridges,  highways, and  other infrastructure 
projects in China.

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Important Factors Affecting our Results of Operations and Existing Trends

Migration of Our Business to the Domestic PRC Market

Our results of operations depend in part on the proportion of international sales to domestic sales that we attain during a particular financial reporting 
period. We have historically collected a significant percentage of revenues generated by international sales by letter of credit, which enables us to convert 
accounts receivable into cash more quickly. Between 2013 and 2015, the Chinese government followed a prudent monetary policy and was conservative in 
lending to certain industries, including steel industry and our domestic customers. In 2018, the Chinese government’s policy in lending is more conservative 
compared to 2016 and 2017. As a result, our domestic customers had to pay our accounts receivables slower than 2016 and 2017, and our average Days Sales 
Outstanding was approximately 150, 123 and 126 days in 2018, 2017 and 2016, respectively.

Our  current  business  model  is  to  continue  focusing  on  the  domestic  PRC  market,  while  selectively  pursuing  international  opportunities  when 
appropriate.  Under  existing  PRC  governmental  policies,  especially  the  “One  Belt,  One  Road”  initiatives,  significant  investments  are  expected  to  be  made 
during the next decade to construct many new bridges and new railroads.

We  generated  approximately  3.3%  and  4.1%,  respectively,  of  our  revenue  during  the  years  ended  December  31,  2018  and  2017  from  sales  to 
customers in international markets including primarily Vietnam, South Korea, Japan, New Zealand, Australia, Bangladesh, Brunei, Costa Rica, South Africa, 
Egypt, Costa Rica and Amman , primarily for use in the construction of bridges. In 2018, we increased our efforts to develop new customers in Africa, South 
America and the Middle East, while at the same time maintaining relationships with existing foreign customers. Due to the anti-dumping measures imposed 
by  the United States and European  Union in 2008  and  2009  and  recent stiff trade  measures imposed  by the  United  States government  in 2018,  we do not 
intend to reestablish a presence in the United States or the European Union at the levels we experienced in 2008 in the near future. However, if opportunities 
arise in the U.S. or EU markets or in other international markets for us to win bids on projects or to reengage with former customers or establish relationships 
with new customers, we would pursue such opportunities. Although we have not generated any sales from the United States since the anti-dumping duties 
were imposed in 2010, these measures imposed in 2018 may also have a negative impact on our business and results of operations because Chinese-based 
steel product exporters may now focus their marketing efforts on the Chinese domestic market.

Product Mix and Industry Trends

Our results of operations also depend in part on the product mix that we attain during a particular financial reporting period. We produce and sell 

products according to customer orders. As an overall percentage of sales, sales of our coated products increased from 94.0% in 2017 to 95.7% in 2018.

Overall gross margin of our products were 13.8%, 11.1% and 15.1% respectively in 2016, 2017 and 2018. The decrease of gross margin in 2017 
compared to 2016 was primarily due to the increase of the price of raw materials and because the orders for plain surface products were mainly wholesale 
orders, which normally have lower gross profit margin than the retail orders we had in 2016. The increase of gross margin in 2018 was primarily due to the 
increase of the prices of our steel products.

As an overall percentage of sales, sales of our coated products increased from 94.0% in 2017 to 95.7% in 2018 and 79.4% and 90.4%, respectively, 
of our coated product sales in the years ended December 31, 2018 and December 31, 2017 were sales of rare earth coated products and the remaining 20.6% 
and 9.6%, respectively, were zinc coated products.

Favorable price and terms for supply of principal raw materials

Our principal raw material is high carbon steel wire rods that we typically purchase from multiple primary steel producers. The steel industry as a 
whole is cyclical and, at times, pricing and availability of steel can be volatile due to numerous factors beyond our control, including general domestic and 
international economic conditions, labor costs, sales levels, competition, levels of inventory held by us and other steel service centers, consolidation of steel 
producers,  higher  raw  material  costs  for  steel  producers,  import  duties  and  tariffs  and  currency  exchange  rates.  This  volatility  can  significantly  affect  the 
availability and cost of raw materials for us.

39

We,  like  many  other  steel  product  manufacturers,  maintain  substantial  inventories  of  steel  to  accommodate  the  short  lead  times  and  just-in-time 
delivery requirements of our customers. Accordingly, we purchase steel in an effort to maintain our inventory at levels that we believe to be appropriate to 
satisfy  the  anticipated  needs  of  our  customers  based  upon  historic  buying  practices,  supply  agreements  with  customers  and  market  conditions.  Our  key 
suppliers  usually  dedicate  portions  of  their  inventories  as  reserves  to  meet  our  manufacturing  requirements.  These  key  suppliers  are  generally  provided  a 
prepayment and in return, they give us discounts compared to prevailing market prices.

We have no long-term, fixed-price steel purchase contracts. When steel prices increase, competitive conditions will influence how much of the price 
increase we can pass on to our customers. To the extent we are unable to pass on future price increases in our raw materials to our customers, the net sales and 
profitability of our business could be adversely affected.

When steel prices decline, customer demands for lower prices and our competitors' responses to those demands could result in lower sale prices and, 
consequently,  lower  margins. Significant or  rapid declines  in steel prices  or reductions  in sales  volumes could result in us incurring inventory or  goodwill 
impairment charges. Changing steel prices therefore could significantly impact our net sales, gross margins, operating income and net income. In 2014 and 
2015,  steel  supply  outpaced  demand  as  China’s  economic  growth  slowed  and  growth  in  steel  demand  in  China  remained  weak.  The  price  of  all  of  our 
principal raw materials decreased in 2014 and 2015 due to the market condition of steel industry in China. However, since raw materials purchased for our 
rare earth and zinc coated products are produced by only a select few steel manufacturers, the average price of these raw materials was not as volatile as other 
steel products, and the decline is not as much as those that are mass produced such as raw materials for plain surface products in 2014 and 2015. In 2016, 2017 
and 2018, Chinese Government continued its policy to cut excessive industrial capacity and reform the supply-side of its economy, while strictly controlling 
steel capacity increases. As a result, the average price of steel products, including our products and principal raw materials, increased in 2016, 2017 and 2018. 
We expect that the Chinese central government will focus on strictly controlling steel capacity increases in 2019. However, due to the slowdown of economic 
growth, local governments in Northern China, the most important steel production base, are expected to increase allowable production levels of steel products, 
including  our  principal  raw  materials.  As  a  result,  according  to  industry  consultant  Frost  &  Sullivan,  the  average  price  of  our  principal  raw  materials  is 
expected to decrease in 2019. 

We currently purchase almost all of our new materials from a very small number of suppliers. Purchases from our five largest suppliers amounted to 
99.8%, 99.7% and 99.1% of our total raw material purchases in 2018, 2017 and 2016, respectively. To date, we have been able to obtain favorable pricing and 
delivery terms from these suppliers. However, if we were to increase the scale of our production, we may need to further diversify our supplier network and, 
as a result, may not be able to obtain favorable pricing and delivery terms from new suppliers.

Slow Growth of the Chinese Economy

We  operate  our  manufacturing  facilities  in  China  and  derive  the  majority  of  our  revenues  from  sales  to  customers  in  China.  As  such,  economic 
conditions in China affect virtually all aspects of our operations, including the demand for our products, the availability and prices of our raw materials and 
our other expenses. Although the economy in China has grown significantly in the past decades, any slow-down of economic growth in China could reduce 
expenditures for infrastructure, which in turn may adversely affect our operating results and financial condition. For example, the weakness in the economy 
could  reduce  the  investment  in  infrastructure,  which,  in  turn,  could  result  in  demand  for  our  products  and  our  revenues  may  decline.  Furthermore,  any 
financial turmoil affecting the financial markets and banking system may significantly restrict our ability to obtain financing in the capital markets or from 
financial institutions on commercially reasonable terms, or at all.

40

Level of income tax and preferential tax treatment

Our net income is affected by the income tax that we pay and any preferential tax treatment that we are able to receive. Our operating subsidiaries are 
subject to the PRC enterprise income tax, or EIT. According to the relevant laws and regulations in the PRC, foreign invested enterprises established prior to 
January 1, 2008 are entitled to full exemption from income tax for two years beginning with the first year in which such enterprise is profitable and a 50% 
income tax reduction for the subsequent three years. Ossen Materials was entitled to an EIT exemption during the two years ended December 31, 2006 and 
was subject to a 50% income tax reduction during the three years ended December 31, 2009. Ossen Jiujiang was entitled to the EIT exemption during the two 
years ended December 31, 2008, and a 50% income tax reduction during the three years ended December 31, 2012.

Ossen Materials was subject to a 15% tax rate through 2012 as the result of its being designated a high-tech enterprise. In 2012, Ossen Materials 
renewed  its  status of high-tech  enterprise,  and  would  be  subject  to  a  15%  tax  rate  through  2015.  In  2015,  Ossen  Materials  renewed  its  status  of high-tech 
enterprise again, and was subject to a 15% tax rate through 2018. In 2018, Ossen Materials renewed its status of high-tech enterprise again and will be subject 
to a 15% tax rate through 2020. Ossen Jiujiang was subject to a 15% tax rate through 2011 as the result of its being designated a high-tech enterprise. Since 
January 1, 2012, Ossen Jiujiang has enjoyed a tax rate of 15% as it is considered as a high-tech enterprise. In 2015, Ossen Jiujiang successfully renewed its 
status of high-tech enterprise, and was subject to a 15% tax rate through 2018. In 2018, Ossen Jiujiang renewed its status of high-tech enterprise again and will 
be subject to a 15% tax rate through 2021. In the event that our income tax obligations increase over time, our net income will be affected.

Foreign currency translation

Our financial statements are expressed in U.S. dollars but the functional currency of our operating subsidiaries is RMB. Our results of operations are 
translated at average exchange rates during the relevant financial reporting periods, assets and liabilities are translated at the unified exchange rate at the end 
of  these  periods  and  equity  is  translated  at  historical  exchange  rates.  Adjustments  resulting  from  the  process  of  translating  the  local  currency  financial 
statements into U.S. dollars are included in determining comprehensive income.

Description of Selected Income Statement Items

Revenues. We generate revenue from sales of our prestressed steel products, including plain surface products and rare earth coated products. We also 
derive  an insignificant  amount  of revenue  from  providing services to  select  customers.  Service revenues account for  less  than 2% of total revenues for  all 
periods presented and is recognized upon delivery and acceptance of the finished products by the customer, or when pick up occurs.

Cost of goods sold. Cost of goods sold includes direct and indirect production costs, as well as freight and handling costs for products sold.

Selling expenses. Selling expenses consist of sales commissions, payroll, traveling expenses, transportation expenses and advertising expenses. For 
example, we typically pay our international distribution customers a commission ranging from 0.5% to 5% of invoiced amounts (including VAT) actually paid 
to us.

General and administrative expenses. General and administrative expenses consist primarily of research and development expense, management and 
office salaries and employee benefits, deprecation for office facility and office equipment, travel and entertainment, legal and accounting, consulting fees and 
other office expenses.

Financial expenses. Financial expenses consist of interest expense on bank loans, interest income.

Other Income. Our other income consisted of government grants and revenue from sales of scrap materials.

Income Taxes. Ossen Materials and Ossen Jiujiang have been recognized by their respective local government agencies as high-tech enterprises. As a 

result, both subsidiaries were subject to an income tax rate of 15% under relevant PRC income tax laws in 2016, 2017 and 2018.

41

Results of Operations

The following table sets forth the key components of our results of operations for the periods indicated, in dollars and as a percentage of revenue.

Revenues
Cost of Goods Sold
Gross profit
Selling expenses
General and administrative expenses
Total operating expenses
Income from operation
Financial expenses, net
Other income, net
Income before income taxes
Income Taxes
Net Income

Less: net income attributable to non-controlling 
interest
Net income attributable to controlling interest
Other comprehensive income- Foreign currency 
translation gain (loss)
Total other comprehensive income (loss)
Comprehensive Income

2018
136,104,867
115,585,803
20,519,064
327,365
5,263,914
5,591,279
14,927,785
(1,621,486)
208,071
13,514,370
(2,129,387)
11,384,983

1,005,530
10,379,453

(6,272,303)
(6,272,303)
4,107,150

% of Revenue

2017

% of Revenue

2016

% of Revenue

For the Year Ended December 31,

100.0% 132,375,915
84.9% 117,721,799
15.1% 14,654,116
598,832
0.2%
3.9%
6,002,121
4.1%
6,600,953
8,053,163
11.0%
(1,610,337)
-1.2%
0.2%
147,108
6,589,934
9.9%
(691,556)
-1.6%
5,898,378
 8.64%

0.7%
7.6%

553,067
5,345,311

-4.6%
6,606,207
-4.6%
6,606,207
3.0% 11,951,518

100.0% 117,029,154
88.9% 100,932,528
11.1% 16,096,626
734,159
6,376,383
7,110,542
8,986,084
(2,827,138)
90,584
6,249,530
(926,048)
5,323,482

0.5%
4.5%
5.0%
6.1%
-1.2%
0.1%
5.0%
-0.5%
4.5%

0.4%
4.0%

5.0%
5.0%
9.0%

499,509
4,823,973

(6,975,100)
(6,975,100)
(2,151,127)

100.0%
86.2%
13.8%
0.6%
5.4%
6.1%
7.7%
-2.4%
0.1%
5.3%
-0.8%
4.5%

0.4%
4.1%

-6.0%
-6.0%
-1.8%

Year Ended December 31, 2018 Compared to Year Ended December 31, 2017

Revenues. During the year ended December 31, 2018, we had revenues of approximately $136.1 million as compared to revenues of approximately 
$132.4 million during year ended December 31, 2017, an increase of approximately $3.7 million, or 2.8%. The increase in our revenues during the year ended 
December 31, 2018 was mainly attributable to a 124.0% increase in sales of zinc coated PC wires and PC strands, partially offset by an 8.1% decrease in rare 
earth coated products, a 20.3% decrease in plain surface products and a 43.4% decrease in other products.

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The following table provides a breakdown of our revenues during the years ended December 31, 2018 and 2017, respectively:

Products:
Plain surface PC strands
Zinc coated PC wires and PC strands
Rare earth coated PC wires and PC strands
Others
Total

Year ended December 31,

2018

2017

Revenue ($) % of Total Revenue Revenue ($) % of Total Revenue Difference

4,812,541
26,834,870
103,368,148
1,089,308
136,104,867

3.5%
6,037,207
19.7% 11,978,159
76.0% 112,437,410
0.8%
1,923,138
100% 132,375,915

4.6%
9.0%
84.9%
1.5%
100%

-20.3%
124.0%
-8.1%
-43.4%
2.8%

The market demand for our rare earth coated PC wires and PC strands decreased in 2018, which motivated us to focus on the production and sale of 
zinc coated products. As a result, the sales of rare earth coated PC wires and PC strands decreased by $9.1 million, or 8.1%, to $103.4 million for the year of 
2018.

The sales of zinc coated PC wires and PC strands were $26.8 million during the year ended December 31, 2018, an increase of 124.0%, compared to 
the  year  ended  December  31,  2017.  The  increase  of  sales  generated  by  zinc  coated  products  in  2018  was  primarily  due  to  our  efforts  to  focus  on  the 
production and sale of zinc coated products and increased market demand for such products in 2018.

The  sales  of  plain  surface  PC  strands  and  PC  wires  were  $4.8  million  during  the  year  ended  December  31,  2018,  a  decrease  of  $1.2  million,  or 
20.3%,  compared  to  the  year  ended  December  31,  2017.  This  decrease  of  sales  generated  by  plain  surface  PC  strands  and  PC  wires  was  primarily  due  to 
decreased market demand during the period.

Other sales were $1.1 million during the year ended December 31, 2018, a decrease of $0.8 million, or 43.4%, compared to the year ended December 

31, 2017. This decrease was primarily due to fewer scrap materials sold in 2018 compared to 2017 and the decrease of service revenue.

Cost of Goods Sold. Cost of goods sold was approximately $115.6 million during the year ended December 31, 2018, as compared to approximately 
$117.7  million  during  the  year  ended  December  31,  2017,  representing  a  decrease  of  1.8%,  or  approximately  $2.1  million.  This  decrease  occurred  mainly 
because the total sales volume deceased in 2018 and the average price of raw materials did not increase as much as the average sale price of our products. As a 
percentage of revenues, cost of goods sold decreased from 88.9% to 84.9% during the year ended December 31, 2018.

Gross  Profit  and  Gross  Margin. Our  gross  profit  is  equal  to  the  difference  between  our  revenues  and  our  cost  of  goods  sold.  Our  gross  profit 
increased 40.0% to approximately $20.5 million during the year ended December 31, 2018, from approximately $14.7 million for the same period in 2017. 
For the years ended December 31, 2018 and 2017, our gross margin was 15.1% and 11.1%, respectively. The increase of gross margin was primarily due to 
the increase of the prices of our steel products.

Selling  Expenses.  Selling  expenses  totaled  $0.3  million  for  the  year  ended  December  31,  2018,  as  compared  to  $0.6  million  for  the  year  ended 
December 31, 2017, a decrease of 45.3%. This decrease was primarily due to lower freight and sales commission for export sales and lower transportation cost 
for domestic sales as more projects were in closer proximity in 2018.

General and Administrative Expenses. General and administrative expenses totaled $5.3 million for the year ended December 31, 2018, as compared 
to $6.0 million for the year ended December 31, 2017, a decrease of 12.3%. The decrease in 2018 was primarily due to lower research and development cost 
for customized products in 2018.

43

Operating  Income. As  a  result  of  the  foregoing,  operating  income  for  the  year  ended  December  31,  2018  was  approximately  $14.9  million,  an 
increase of 85.4% as compared to approximately $8.1 million for the same period in 2017. As a percentage of net sales, operating income increased from 6.1% 
to 11.0% during the year ended December 31, 2018. This increase was primarily due to higher gross profit and lower operating expenses.

Income  Taxes .  We  incurred  income  tax  expenses  of  $2.1  million  and  $0.7  million  in  the  fiscal  years  ended  December  31,  2018  and  2017, 

respectively. Ossen Materials and Ossen Jiujiang were subject to a 15% tax rate as the result of being designated as high-tech enterprises through 2018.

Net Income . As a result of the foregoing, our net income totaled approximately $11.4 million for the year ended December 31, 2018, as compared to 

approximately $5.9 million for the year ended December 31, 2017, an increase of 93.0%.

Net  Income  Attributable  to  Non-controlling  Interest. We  own  81%  of  Ossen  Materials  and  96.1%  of  Ossen  Jiujiang  in  the  aggregate.  Net  income 
attributable  to  non-controlling  interest  represents  the  net  income  attributable  to  the  holders  of  the  remaining  shares.  Our  net  income  attributable  to  non-
controlling interest totaled approximately $1.0 million for the year ended December 31, 2018, as compared to approximately $0.6 million for the year ended 
December 31, 2017.

Foreign  Currency  Income  (Loss). For  the  year  ended  December  31,  2018,  foreign  currency  exchange  loss  was  $6.3  million,  compared  to  foreign 
currency exchange gain of $6.6 million, for the year ended December 31, 2017. The loss was due to the weakening of the exchange rate of the RMB versus 
the US dollar in 2018.

Year Ended December 31, 2017 Compared to Year Ended December 31, 2016

Revenues. During the year ended December 31, 2017, we had revenues of approximately $132.4 million as compared to revenues of approximately 
$117.0 million during year ended December 31, 2016, an increase of approximately $15.4 million, or 13.1%. The increase in our revenues during the year 
ended December 31, 2017 was mainly attributable to a 10.9% increase in sales of rare earth coated PC wires and PC strands, a 46.1% increase in zinc coated 
PC wires and PC strands, and a 14.9% increase in plain surface PC strands, partially offset by a 13.2% decrease in other products.

The following table provides a breakdown of our revenues during the years ended December 31, 2017 and 2016, respectively:

Products:
Plain surface PC strands
Zinc coated PC wires and PC strands
Rare earth coated PC wires and PC strands
Others
Total

Year ended December 31,

2017

2016

Revenue ($) % of Total Revenue Revenue ($) % of Total Revenue Difference

6,037,207
11,978,159
112,437,410
1,923,138
132,375,915

5,256,109
4.6%
9.0%
8,195,801
84.9% 101,361,992
1.5%
2,215,252
100% 117,029,154

4.5%
7.0%
86.6%
1.9%
100%

14.9%
46.1%
10.9%
-13.2%
13.1%

The  demand  for  our  rare  earth  coated  PC  wires  and  PC  strands  continue  to  improve  in  2017.  However,  the  demand  for  lower  strength  coated 
materials  was  greater  than  demand  for  higher  strength  coated  materials.  We  used  lower  grade  raw  materials  for  some  of  our  rare  earth  coated  products  to 
improve margins without sacrificing product strength or quality. As a result, the sales of rare earth coated PC wires and PC strands increased by $11.1 million, 
or 10.9%, to $112.4 million for the year of 2017.

44

The sales of zinc coated PC wires and PC strands were $12.0 million during the year ended December 31, 2017, an increase of 46.1%, compared to 
the year ended December 31, 2016. The increase of sales generated by zinc coated products in 2017 was primarily due to our efforts to take advantage of the 
improved market condition and customer demand and promoting the products in 2017.

The  sales  of  plain  surface  PC  strands  and  PC  wires  were  $6.0  million  during  the  year  ended  December  31,  2017,  an  increase  of  $0.8  million,  or 
13.9%,  compared  to  the  year  ended  December  31,  2016.  This  increase  of  sales  generated  by  plain  surface  PC  strands  and  PC  wires  was  primarily  due  to 
favorable wholesale market demand during the period.

Other sales were $1.9 million during the year ended December 31, 2017, a decrease of $0.3 million, or 13.2%, compared to the year ended December 

31, 2016. This decrease was primarily due to fewer spare raw materials sold in 2017 compared to 2016 and the decrease of service revenue.

Cost of Goods Sold. Cost of goods sold was approximately $117.7 million during the year ended December 31, 2017, as compared to approximately 
$100.9 million during the year ended December 31, 2016, representing an increase of 16.6%, or approximately $16.8 million. This increase mainly resulted 
from the increase of revenues and the increase of raw material costs. As a percentage of revenues, cost of goods sold increased from 86.2% to 88.9% during 
the year ended December 31, 2017.

Gross  Profit  and  Gross  Margin. Our  gross  profit  is  equal  to  the  difference  between  our  revenues  and  our  cost  of  goods  sold.  Our  gross  profit 
decreased 9.0% to approximately $14.7 million during the year ended December 31, 2017, from approximately $16.1 million for the same period in 2016. For 
the years ended December 31, 2017 and 2016, our gross margin was 11.1% and 13.8%, respectively. The decrease of gross margin was primarily due to the 
increase of the price of raw materials and because the orders for plain surface products were mainly wholesale orders, which normally have lower gross profit 
margin than the retail orders we had in 2016.

Selling  Expenses.  Selling  expenses  totaled  $0.6  million  for  the  year  ended  December  31,  2017,  as  compared  to  $0.7  million  for  the  year  ended 

December 31, 2016, a decrease of 18.4%. This decrease was primarily due to lower sales commission and lower transportation cost in 2017.

General and Administrative Expenses. General and administrative expenses totaled $6.0 million for the year ended December 31, 2017, as compared 
to $6.4 million for  the year  ended December  31, 2016,  a  decrease of 5.9%. The  decrease in 2017  was primarily due to lower bad-debt provision, partially 
offset by higher research and development cost in 2017.

Operating Income. As a result of the foregoing, operating income for the year ended December 31, 2017 was approximately $8.1 million, a decrease 
of 10.4% as compared to approximately $9.0 million for the same period in 2016. As a percentage of net sales, operating income decreased from 7.7% to 6.1% 
during the year ended December 31, 2017.This decrease was primarily due to lower gross profit partially offset by lower operating expenses.

Income  Taxes .  We  incurred  income  tax  expenses  of  $0.7  million  and  $0.9  million  in  the  fiscal  years  ended  December  31,  2017  and  2016, 

respectively. Ossen Materials and Ossen Jiujiang were subject to a 15% tax rate as the result of being designated as high-tech enterprises through 2018.

Net Income . As a result of the foregoing, our net income totaled approximately $5.9 million for the year ended December 31, 2017, as compared to 

approximately $5.3 million for the year ended December 31, 2016, an increase of 10.8%.

Net  Income  Attributable  to  Non-controlling  Interest. We  own  81%  of  Ossen  Materials  and  96.1%  of  Ossen  Jiujiang  in  the  aggregate.  Net  income 
attributable  to  non-controlling  interest  represents  the  net  income  attributable  to  the  holders  of  the  remaining  shares.  Our  net  income  attributable  to  non-
controlling interest totaled approximately $0.6 million for the year ended December 31, 2017, as compared to approximately $0.5 million for the year ended 
December 31, 2016.

45

Foreign  Currency  Income  (Loss). For  the  year  ended  December  31,  2017,  foreign  currency exchange  gain  was  $6.6  million,  compared  to  foreign 
currency exchange loss of $6.9 million, for the year ended December 31, 2016. The gain was due to the strengthening of the exchange rate of the RMB versus 
the US dollar in 2017.

Critical Accounting Policies and Estimates

Our consolidated financial statements, which have been prepared in accordance with U.S. GAAP. Our financial statements reflect the selection and 
application  of  accounting  policies,  which  require  management  to  make  significant  estimates  and  judgments.  See  Note  2  to  our  consolidated  financial 
statements  for  “Summary  of  Significant  Accounting  Policies.”  We  believe  that  the  following  paragraphs  reflect  the  most  critical  accounting  policies  that 
currently affect our financial condition and results of operations.

Use of Estimates

The  preparation  of  the  consolidated  and  combined  financial  statements  in  conformity  with  generally  accepted  accounting  principles  in  the  United 
States  of  America  requires  management  to  make  estimates  and  assumptions  that  affect  the  reported  amounts  of  assets  and  liabilities  and  disclosure  of 
contingent assets and liabilities at the date of the consolidated financial statements and the reported amounts of revenues and expenses during the reporting 
periods. Management makes these estimates using the best information available at the time the estimates are made. Actual results could differ from those 
estimates.

Revenue Recognition

In  accordance  with  the  ASC  Topic  606,  “Revenue  Recognition”,  the  Company  recognizes  revenue  when  persuasive  evidence  of  an  arrangement 

exists, delivery has occurred or services have been rendered, the seller’s price to the buyer is fixed or determinable, and collectability is reasonable assured.

The Company derives revenues from the processing, distribution and sale of own products. The Company recognizes its revenues net of value-added 
taxes (“VAT”). The Company was subject to VAT which was levied on the rate of 17% on the invoiced value of sales before May 1, 2018. After May 1, 2018, 
the Company’s VAT rate is 16% which applies to the manufacturing sector in China. Output VAT is borne by customers in addition to the invoiced value of 
sales and input VAT is borne by the Company in addition to the invoiced value of purchases to the extent not refunded for export sales.

The  Company  will  recognize  revenue  for  domestic  sales  based  on  the  terms  defined  in  the  contract  as  long  as  risk  of  loss  has  transferred  to  the 
customers and each of the criteria under ASC 606 have been met. Contracts terms may require the Company to deliver the finished goods to the customers’ 
location  or  the  customer  may  pick  up  the  finished  goods  at  the  Company’s  factory.  International  sales  are  recognized  when  shipment  clears  customs  and 
leaves the port.

Contracts with distributors do not offer any chargeback or price protection. The Company experienced no product returns and recorded no reserve for 

sales returns for the years ended December 31, 2018, 2017 and 2016.

Research and Development

Research  and  development  costs  are  expensed  as  incurred  and  totaled  approximately  $3,345,097,  $4,269,512  and  $3,869,277  for  the  years  ended 
December 31, 2018, 2017 and 2016, respectively. Research and development costs are included in general and administrative expenses in the accompanying 
statements of operations. Research and development costs are incurred on a project specific basis.

46

Income Taxes

The Company accounts for income taxes following the liability method pursuant to FASB ASC 740 “Income Taxes”. Under this method, deferred tax 
assets and liabilities are determined based on the difference between the financial reporting and tax bases of assets and liabilities using enacted tax rates that 
will be in effect in the period in which the differences are expected to reverse. The Company records a valuation allowance to offset deferred tax assets if, 
based on the weight of available evidence, it is more-likely-than-not that some portion, or all, of the deferred tax assets will not be realized. The effect on 
deferred taxes of a change in tax rate is recognized in income in the period that includes the enactment date.

The Company also follows FASB ASC 740, which addresses the determination of whether tax benefits claimed or expected to be claimed on a tax 
return should be recorded in the financial statements. The Company may recognize the tax benefit from an uncertain tax position only if it is more likely than 
not that the tax position will be sustained on examination by the taxing authorities, based on the technical merits of the position. The tax benefits recognized in 
the financial statements from such a position should be measured based on the largest benefit that has a greater than fifty percent likelihood of being realized 
upon ultimate settlement. ASC 740 also provides guidance on recognition, classification, interest and penalties on income taxes, accounting in interim periods 
and requires increased disclosures. As of December 31, 2016, the Company did not have a liability for unrecognized tax benefits. It is unlikely that the amount 
of  liability  for  unrecognized  tax  benefits  will  significantly  change  over  the  next  12  months.  It  is  the  Company’s  policy  to  include  penalties  and  interest 
expense  related  to  income  taxes  as  a  component  of  other  expense  and  interest  expense,  respectively,  as  necessary.  The  Company’s historical  tax  years 
will always remain open for examination by the local authorities. 

The Company has not provided for income taxes on accumulated earnings amounting $68,673,561 that are subject to the PRC dividend withholding 

tax as of December 31, 2018, since these earnings are intended to be permanently reinvested.

Fair Value of Financial Instruments

The  Company  applies  the  provisions  of  ASC  820, Fair  Value  Measurements  and  Disclosures,  to  the  financial  instruments  that  are  required  to  be 
carried  at  fair  value.  Fair  value  is  the  price  that  would  be  received  to  sell  an  asset  or  paid  to  transfer  a  liability  (an  exit  price)  in  the  principal  or  most 
advantageous market for the asset or liability in an orderly transaction between market participants at the measurement date. The Company uses a three-tier 
fair value hierarchy based upon observable and non-observable inputs that prioritizes the information used to develop our assumptions regarding fair value. 
Fair value measurements are separately disclosed by level within the fair value hierarchy. FASB ASC 820 (formerly SFAS No. 157 Fair Value Measurements) 
establishes  a  three-tier  fair  value  hierarchy,  which  prioritizes the  inputs  used  in  measuring  fair  value.  The  hierarchy  prioritizes  the  inputs  into  three  levels 
based on the extent to which inputs used in measuring fair value are observable in the market

These tiers include:

Level 1—defined as observable inputs such as quoted prices in active markets for identical assets or liabilities;

Level 2—defined as inputs other than quoted prices in active markets that are either directly or indirectly observable; and

Level 3—defined as unobservable inputs in which little or no market data exists, therefore requiring an entity to develop its own assumptions.

(cid:120)

(cid:120)

(cid:120)

The company’s financial instruments primarily consist of cash and cash equivalents, restricted cash, accounts receivable, notes receivable, accounts 

payable, other payables and accrued liabilities, short-term bank loans, and bond payable.

The  carrying  value  of  cash  and  cash  equivalents,  restricted  cash,  accounts  receivable,  accounts  payable,  and  other  current  assets  and  liabilities 
approximate fair value because of the short term nature of these items. The estimated fair values of short-term bank loans were not materially different from 
their carrying value as presented due to the short maturities and that the interest rates on the borrowing approximate those that would have been available for 
loans  of  similar  remaining  maturity  and  risk  profile.  As  the  carrying  amounts  are  reasonable  estimates  of  the  fair  value,  these  financial  instruments  are 
classified within Level 1 of the fair value hierarchy.

47

Accounts Receivable

Accounts receivable  are carried at  net realizable value. The Company reviews its accounts  receivables on a  periodic basis and makes  general  and 
specific allowances when there is doubt as to the collectability of individual balances. In evaluating the collectability of individual receivable balances, the 
Company considers many factors, including the age of the balance, customer’s historical payment history, its current credit-worthiness and current economic 
trends. Accounts are written off after exhaustive efforts at collection. If accounts receivable are to be provided for, or written off, they would be recognized in 
the consolidated statement of operations within operating expenses. Balance of allowance of doubtful accounts was $939,535 and $868,973 at December 31, 
2018 and 2017, respectively. The increase was mainly due to the increase of accounts receivable as of December 31, 2018.

Inventories

Inventories  are  stated  at  the  lower  of  cost  or net  realizable value, which is based  on  estimated  selling  prices  less any  further  costs  expected  to  be 
incurred for completion and disposal. Cost of raw materials is calculated using the weighted average method and is based on purchase cost. Work-in-progress 
and  finished  goods  costs  are  determined  using  the  weighted  average  method  and  comprise  direct  materials,  direct  labor  and  an  appropriate  proportion  of 
overhead.  The  Company  considers  a  provision  for  excess,  obsolete,  or  slow-moving  inventory  based  on  changes  in  customer  demand,  technology 
developments or other economic factors. At December 31, 2018 and 2017, the Company has $121,370 and $127,766 reserve for inventories, respectively.

Advance to Suppliers

Advance to Suppliers represents interest-free cash paid in advance to suppliers for purchases of raw materials. The balance of advance to suppliers 
was $69,986,656 and $71,280,903 at December 31, 2018 and 2017, respectively. Among the balance of $69,986,656, the aging of $36,913,322 was within 60 
days,  $25,541,361  was  between  60-180  days  and  $7,531,973  was  over  180  days.  High  carbon  steel  wire  rods  are  the  primary  raw  material  required  to 
manufacture prestressed steel materials. Most suppliers of high carbon steel wire rods require advance payment. Advance to suppliers at December 31, 2018 
decreased from 2017 due to the strengthening of the U.S. dollar at the end of 2018 as compared to the end of 2017. Advance to suppliers in RMB at December 
31,  2018  increased  slightly  from  2017  in  order  to  secure  favorable  treatment  in  terms  of  supply  of  raw  materials.  No  allowance  was  provided  for  the 
prepayments balance at December 31, 2018.

In 2018, the PRC steel industry completed the process of reducing overcapacity which resulted in the increase of the average steel price. However, 
we were able to receive raw materials delivered by our suppliers in 2018 at a discounted price, locked in by prepayments. We expect to continue using the 
advance  payment  to  suppliers  to  lock  a  discounted  price  of  raw materials  and  the  balance  of  advance  to  suppliers  may  fluctuate depending  on  the  market 
development.

Property, Plant, and Equipment

Property, plant, and equipment are stated at cost less accumulated depreciation, and include expenditure that substantially increases the useful lives of 

existing assets.

Depreciation is provided over their estimated useful lives, using the straight-line method. Estimated useful lives are as follows:

Plant, buildings and improvements

Machinery and equipment

Motor vehicles

Office Equipment

5 ~ 20 years

5 ~ 20 years

5 years

5 ~ 10 years

48

When assets are sold or retired, their costs and accumulated depreciation are eliminated from the consolidated financial statements and any gain or 
loss resulting from their disposal is recognized in the period of disposition as an element of other income. The cost of maintenance and repairs is charged to 
income as incurred, whereas significant renewals and betterments are capitalized.

Land Use Rights

According to the PRC laws, the government owns all the land in the PRC. Companies or individuals are authorized to possess and use the land only 
through land use rights granted by the Chinese government. The land use rights granted to the Company are being amortized using the straight-line method 
over the lease term of fifty years.

Impairment of Long-Lived Assets

Long-lived assets are evaluated for impairment periodically whenever events or changes in circumstances indicate that their related carrying amounts 

may not be recoverable in accordance with FASB ASC 360, “Property, Plant and Equipment”.

In evaluating long-lived assets for recoverability, the Company uses its best estimate of future cash flows expected to result from the use of the asset 
and eventual disposition in accordance with FASB ASC 360-10-15. To the extent that estimated future, undiscounted cash inflows attributable to the asset, 
less estimated future, undiscounted cash outflows, are less than the carrying amount, an impairment loss is recognized in an amount equal to the difference 
between the carrying value of such asset and its fair value. Assets to be disposed of and for which there is a committed plan of disposal, whether through sale 
or abandonment, are reported at the lower of carrying value or fair value less costs to sell. 

No  impairment  loss  is  subsequently  reversed  even  if  facts  and  circumstances  indicate  recovery.  There  was  no  impairment  loss  recognized  for  the 

years ended December 31, 2018, 2017 and 2016.

Related Party

In general, related parties exist when there is a relationship that offers the potential for transactions at less than arm’s-length, favorable treatment, or 
the ability to influence the outcome of events different from that which might result in the absence of that relationship. A related party may be any of the 
followings: a) affiliate, a party that directly or indirectly controls, is controlled by, or is under common control with another party; b) principle owner, the 
owner of record or known beneficial owner of more than 10% of the voting interest of an entity; c) management, persons having responsibility for achieving 
objectives  of  the  entity  and  requisite  authority  to  make  decision;  d)  immediate  family  of  management  or  principal  owners;  e)  a  parent  company  and  its 
subsidiaries; d) other parties that has ability to significant influence the management or operating policies of the entity.

FASB issued authoritative guidance that clarifies considerations relating to the consolidation of certain entities. The guidance requires identification 
of the Company’s participation in variable interest entities (“VIE”), which are defined as entities with a level of invested equity that is not sufficient to fund 
future activities to permit them to operation on a standalone basis, or whose equity holders lack certain characteristics of a controlling financial interest. That, 
for entities identified as a VIE, the guidance sets forth a model to evaluate potential consolidation based on an assessment of which party to a VIE, if any, 
bears  a  majority  of  the  exposure  to  expected  losses,  or  stand  to  gain  from  majority  of  its  expected  returns.  The  guidance  also sets  forth  certain  disclosure 
regarding interests in a VIE that are deemed significant even if consolidation is not required. This item is discussed in further detail in Note 10 – Related Party 
Transactions.

49

Recently adopted Accounting Pronouncements

In  May  2014,  the  FASB  issued  a  new  standard  on  revenue  recognition  related  to  contracts  with  customers.  This  standard  supersedes  nearly  all 
existing revenue recognition guidance and involves a five-step principles-based approach to recognizing revenue. The new model requires revenue recognition 
to depict the transfer of promised goods or services to customers in an amount that reflects the consideration a company expects to receive. The new standard 
also  require  additional  qualitative  and  quantitative  about  the  nature,  amount,  timing  and  uncertainty  of  revenue  and  cash  flows  arising  from  customer 
contracts,  including  significant judgments  made in applying  the revenue guidance,  and  assets  recognized  from  the  costs to obtain  or fulfill  a contract. The 
Company adopted this standard in the first quarter of 2018 using the modified retrospective approach. The impact of adoption on its Consolidated Financial 
Statements for any period presented is not material.

In  November  2015,  the  FASB  issued  ASU  2015-17,  “Balance  Sheet  Classification  of  Deferred  Taxes.”  This  ASU  amends  existing  guidance  to 
require  that  deferred  income  tax  assets  and  liabilities  be  classified  as  non-current  in  a  classified  balance  sheet,  and  eliminates  the  prior  guidance  which 
required an entity to separate deferred tax assets and liabilities into a current amount and a non-current amount in a classified balance sheet. The Company 
adopted this standard prospectively in the first quarter of 2018. The impact of adoption on its Consolidated Financial Statements for any period presented is 
not material.

In October 2016, the FASB issued ASU 2016-16, Income Taxes (Topic 740): Intra-Entity Transfers Other than Inventory, which requires companies 
to recognize the income-tax consequences of an intra-entity transfer of an asset other than inventory when the transfer occurs, rather than when the asset has 
been  sold  to  an  outside  party.  The  Company  adopted  this  standard  prospectively  in  the  first  quarter  of  2018.  The  impact  of  adoption  on  its  Consolidated 
Financial Statements for any period presented is not material.

In November 2016, the FASB issued ASU 2016-18, “Statement of Cash Flows (Topic 230) - Restricted Cash,” (“ASU 2016-18”). This ASU requires 
a statement of cash flows to explain the change during the period in the total of cash, cash equivalents, and amounts generally described as restricted cash or 
restricted cash equivalents. Amounts generally described as restricted cash and restricted cash equivalents should be included with cash and cash equivalents 
when reconciling the beginning-of-period and end-of-period total amounts shown on the statement of cash flows. The Company adopted this standard in the 
first quarter of 2018. The impact of adoption on its Consolidated Financial Statements for any period presented is not material.

In  January  2017,  the  FASB  issued  ASU  2017-01,  Business  Combinations  (Topic  805):  Clarifying  the  Definition  of  a  Business,  which  revises  the 
definition  of  a  business  and  provides  new  guidance  in  evaluating  when  a  set  of  transferred  assets  and  activities  is  a  business.  The  Company  adopted  this 
standard prospectively in the first quarter of 2018. The impact of adoption on its Consolidated Financial Statements for any period presented is not material.

Recently Issued Accounting Pronouncements 

In  February  2016,  the  FASB  issued  ASU  No.  2016-02  - Leases (Topic  842).  Under  the  new  guidance,  a  lessee  is  required  to  recognize  lease 
liabilities and corresponding right-of-use assets, initially measured at the present value of lease payments, on the balance sheet for operating leases with terms 
greater than one year.  Lessor accounting remains largely unchanged from existing lease accounting.  For leases with a term of 12 months or less, a lessee is 
permitted to make an accounting policy election not to recognize lease assets and lease liabilities.  If the lessee makes the election, the lessee would recognize 
lease  expense  on  a  straight-line  basis  over  the  lease  term.  This  ASU  is  effective  in  annual  reporting  periods  beginning  after  December  15,  2018  and  the 
interim  periods  within  that  fiscal  year.  The  Company  is  still  evaluating  the  potential  impacts  that  the  implementation  of  ASU  2016-02  may  have  on  its 
financial position, operational results, or cash flows 

In  June  2016,  the  FASB  issued  ASU  2016-13,”  Measurement  of  Credit  Losses  on  Financial  Instruments”,  to  require  financial  assets  carried  at 
amortized cost to be presented at the net amount expected to be collected based on historical experience, current conditions and forecasts. Subsequently, the 
FASB issued ASU No. 2018-19, Codification Improvements to Topic 326, to clarify that receivables arising from operating leases are within the scope of 
lease  accounting  standards.  The  ASUs  are  effective  for  interim  and  annual  periods  beginning  after  December  15,  2019,  with  early  adoption  permitted. 
Adoption of the ASUs is modified retrospective. We are currently obtaining an understanding of the ASUs and plan to adopt them on January 1, 2020.

50

In January 2017, the FASB issued ASU No. 2017-04 (Topic 350) Intangibles—Goodwill and Other: Simplifying the Test for Goodwill Impairment, 
which  removes  Step  2  of  the  goodwill  impairment  test,  which  requires  a  hypothetical  purchase  price  allocation.  Under  the  amended  guidance,  a  goodwill 
impairment charge will now be recognized for the amount by which the carrying value of a reporting unit exceeds its fair value, not to exceed the carrying 
amount of goodwill. This ASU will be applied on a prospective basis and is effective for interim and annual periods beginning after December 15, 2019, with 
early adoption permitted for any impairment tests performed after January 1, 2017. The Company does not expect the adoption to have a material impact on 
the Consolidated Financial Statements.

In February 2018, the FASB released ASU 2018-2, “Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income.” This 
standard  update  addresses  a  specific  consequence  of  the  Tax  Cuts  and  Jobs  Act  (“U.S.  tax  reform”)  and  allows  a  reclassification  from  accumulated  other 
comprehensive income to retained earnings for the stranded tax effects resulting from U.S. tax reform. Consequently, the update eliminates the stranded tax 
effects that were created as a result of the historical U.S. federal corporate income tax rate to the newly enacted U.S. federal corporate income tax rate. The 
Company is required to adopt this standard in the first quarter of fiscal year 2020, with early adoption permitted. The amendments in this update should be 
applied either in the period of adoption or retrospectively to each period in which the effect of the change in the U.S. federal corporate income tax rate in the 
Tax Cuts and Jobs Act is recognized. The Company has finished the evaluation and determined there is no impact of on its Consolidated Financial Statements.

In  June  2018,  the  FASB  issued  ASU  No.  2018-07  – Compensation  –  Stock  Compensation (Topic  718).  The  ASU  was  issued  as  part  of  its 
Simplification  Initiative  to  reduce  costs  and  complexities  of  financial  reporting.  ASU  No.  2018-07  simplifies  the  accounting  for  share-based  payments 
granted  to  nonemployees  for  goods  and  services.  Under  the  ASU,  most  of  the  guidance  on  such  payments  to  nonemployees  would  be  aligned  with  the 
requirements for share-based payments granted to employees.  Currently, share-based payments transactions to nonemployees are measured at fair value and 
remeasured  at  each  reporting  date  through  the  date  of  final  vesting.  This  ASU  changes  the  guidance  related  to  the  determination  of  the  measurement 
date.  Under the new guidance, equity-classified awards would be measured at the grant date.  This ASU is effective for fiscal years beginning after December 
15, 2018 including interim periods within those fiscal years.  Early adoption is permitted if financial statements have not yet been issued. The Company is 
currently evaluating the impact of adoption on the Consolidated Financial Statements.

In  August  2018,  the  FASB  issued  ASU  2018-13 Disclosure  Framework  —  Changes  to  the  Disclosure  Requirements  for  Fair  Value 
Measurement, which eliminates, adds, and modifies certain disclosure requirements for fair value measurements under ASC 820. This ASU is to be applied on 
a prospective basis for certain modified or new disclosure requirements, and all other amendments in the standard are to be applied on a retrospective basis. 
The new standard is effective for interim and annual periods beginning after December 15, 2019, with early adoption permitted. The Company is currently 
evaluating the impact of adoption on the Consolidated Financial Statements.

5B. Liquidity and Capital Resources 

  We  have  historically  met  our  working  capital  and  capital  expenditure  requirements  by  using  both  net  cash  flow  from  operations  and  by  bank 
borrowings, including loans from banks and bank acceptance notes. We expect to finance our operations and working capital needs in the near future from 
cash generated from operations and short-term borrowings, including lines of credit from local banks, which can be utilized to fund our short term operation 
and fulfill liabilities.

51

Our cash and cash equivalents, and restricted cash which are denominated in RMB, were approximately $3.4 million and $4.1 million at December 
31, 2018, as compared to $1.0 million and $7.2 million at December 31, 2017. The increase in cash and cash equivalents and the decrease in restricted cash 
were  mainly  because  the  decrease  in  bank  acceptance  notes.  For the  years  ended  December  31,  2017  and  2018,  we  used  a  significant  portion  of  our  cash 
reserve to purchase raw materials to satisfy our production needs and to maintain satisfactory levels of inventory. In 2016, 2017 and 2018, Chinese central 
bank,  the  People’s  Bank  of  China,  maintained  a  prudent  and  neutral  monetary  policy  and  local  banks  have  generally  maintained  tight  lending  policies,  in 
addition  to  the  Chinese  government’s  policy  to  reduce  the  country’s  steel  capacity  which  resulted  in  further  tightened  lending to  steel  companies,  thereby 
limiting our ability to borrow funds for working capital purpose. In 2016, we were able to generate net profits and positive cash flow from operating activities. 
In  2017,  we  had  net  profits,  but  net  cash used  in  operating  activities  was  $3.0  million.  In  2018,  we  had  net  profits  and  positive  cash  flow  from  operating 
activities. We believe that our cash reserves, together with expected cash flow from operations and short-term loans, are sufficient to allow us to continue to 
operate for the next 12 months. For details of our bank loans and notes payables please see “Bank Loans and Bank Acceptance Notes” below.

We had $5.0 million of accounts receivable aged over 180 days as of December 31, 2017. We had $5.8 million of accounts receivable aged over 180 
days as of December 31, 2018. As of April 1, 2019, we have collected approximately $29.4 million of the $60.6 million of accounts receivable outstanding as 
of  December  31,  2018.  The  remaining  approximately  $31.2  million  of  uncollected  accounts  receivable  are  mainly  from  construction  companies  that  have 
long-term business relationship with us. Based on our historical experience, most of these projects are government sponsored programs and we are confident 
that we will be able to collect the balance when the projects are completed.

We believe that current cash balances, future cash provided by operations, and amounts available under our line of credit or bank borrowings will be 
sufficient  to  cover  our  operating  and  capital  needs  in  the  ordinary  course  of  business  for  the  foreseeable  future.  If  we  experience  an  adverse  operating 
environment or unanticipated and unusual capital expenditure requirements, additional financing may be required. No assurance can be given, however, that 
additional financing, if required, would be available at all or on favorable terms. We might also require or seek additional financing for the purpose of bidding 
new  projects  growing  our  existing  markets,  or  for  other  reasons.  Such  financing  may  include  the  use  of  additional  debt  or  the  sale  of  additional  equity 
securities. Any financing which involves the sale of equity securities or instruments that are convertible into equity securities could result in immediate and 
possibly significant dilution to our existing shareholders.

Accounts Receivable

In  2016,  2017  and  2018,  the  accounts  receivable  collection  period  of  our  domestic  customers  was  approximately  126,  123  and  150  days  after 
receiving the materials at their construction site, respectively. As of December 31, 2018, our accounts receivable increased to $60.6 million from $51.7 million 
at December 31, 2017 as a result of slower collection of accounts receivable in 2018.

The average Days Sales Outstanding (“DSO”) of 2016, 2017 and 2018 were 126, 123 days and 150 days, respectively. The DSO as of December 31, 
2016, 2017 and 2018 were 116, 142 and 162 days, respectively. The increase in DSO as of December 31, 2018 was primarily due to the slower payments from 
our customers during 2018.

The following table describes the aging of our accounts receivable during 2016, 2017 and 2018:

As of Date

December 31, 2018
December 31, 2017
December 31, 2016

Account Receivables
Balance (in US
Dollars)

60,586,869
51,699,930
37,298,465

<60 days
40,328,956
37,801,468
24,914,390

60-90 days
7,571,838
0
8,698,708

90-180 days
6,900,964
8,854,564
951,302

>180 days

5,785,111
5,043,898
2,734,065

As of April 1, 2019, we have collected approximately $29.4 million or 48.5% of the $60.6 million of accounts receivable outstanding as of December 

31, 2018 in cash. See Note 2 to our audited financial statements for a schedule of our valuation account.

52

Major Customers

During  the  years  ended  December  31,  2018,  2017  and  2016,  our  six  largest  customers  contributed  68.3%,  74.8%  and  81.4%  of  our  total  sales, 
respectively. See “Business—Our Customers” above. As a result of our reliance on a limited number of customers, we may face pricing and other competitive 
pressures, which may have a material adverse effect on our profits and our revenues. The volume of products sold for specific customers varies from year to 
year, especially since we are not the exclusive supplier for any customers. In addition, there are a number of factors, other than our performance, that could 
cause an unpredictable loss of a customer or substantial reduction in the business. For example, our customers may decide to reduce spending on our products 
due to insufficient funding or delay of the project, or a customer may no longer need our products following the completion of a project. The loss of any one 
of our major customers, a decrease in the volume of sales to these customers or a decrease in the price at which we sell our products to them could materially 
adversely affect our profits and our revenues.

In addition, this customer concentration may subject us to perceived or actual leverage that our customers may have in negotiations with us, given 
their  relative  size  and importance to  us.  If our  customers  seek to  negotiate  their agreements  on  terms less favorable  to  us and  we accept  such  unfavorable 
terms, such unfavorable terms may have a material adverse effect on our business, financial condition and results of operations. Accordingly, unless and until 
we diversify and expand our customer base, our future success will significantly depend upon the timing and volume of business from our largest customers 
and the financial and operational success of these customers.

Bank Loans and Bank Acceptance Notes

At  December  31,  2018,  we  had  approximately  $13.6  million  of  short-term  bank  loans  and  $8.7  million  of  bank  acceptance  notes  outstanding,  as 
compared to approximately $13.9 million of short-term bank loans and $10.3 million of bank acceptance notes outstanding at December 31, 2017 and $16.9 
million and $9.6 million at December 31, 2016, respectively. In 2018, Chinese government and Chinese banks were still conservative in lending to certain 
industries including steel industry and our domestic customers. 

Our notes payable of $9.6 million at December 31, 2016, $10.3 million at December 31, 2017 and $8.7 million at December 31, 2018 represented the 
amount of bank acceptance notes our suppliers received from us for our purchases of raw materials. These notes were issued by financial institutions, typically 
by banks, that entitle our suppliers to receive the full face amount from the bank or financial institution at maturity. Our notes payable are interest-free and 
range from six months to one year from the date of issuance. These notes are subject to bank charges of 0.05% of the principal amount as commission on each 
issuance  and  in  total  were  secured  by  $6.7  million,  $7.2  million  and  $4.1  of  restricted  cash  as  of  December  31,  2016,  2017  and  2018,  respectively.  Bank 
acceptance notes are commonly used in domestic China due to their enhanced credibility and the liquidity it provides to the bearer. The bearer always has the 
option to cash the bank acceptance notes before maturity at its issuing bank and receive a discounted amount in cash. We expect that bank acceptance notes 
will continue to account for a material portion of our total receivables and payables in the near future.

Short-term bank loans were obtained from local banks in China. All short-term bank loans are repayable within one year and are secured by a portion 
of  our  property,  plant  and  equipment  and  land  use  rights,  or  guaranteed  by  related  parties.  None  of  our  short-term  bank  loans  have  financial  covenants. 
However, each loan contains a covenant that restricting our use of the funds to either purchases of raw materials or working capital.

The  weighted  average  annual  interest  rate  of  our  short-term  bank  loans  was  5.71%,  6.41%  and  6.11%  as  of  December  31,  2018,  2017  and  2016, 

respectively. Interest expense was $0.9 million, $0.9 million and $1.1 million for the years ended December 31, 2018, 2017 and 2016, respectively.

Due to the Chinese government’s policy to reduce the country’s steel capacity, Chinese banks further tightened lending to steel companies. We were 
also affected by this policy and we had to repay a portion of our short term bank loans in 2017 without being able to roll-over such loans into new short-term 
loans. However, we did not experience difficulties in the rollover of the remaining short-term bank loans that we use to fund our daily operations in 2017. In 
2018, we were able to rollover substantially all short-term bank loans and we anticipate rollovers of substantially all current facilities that are set to mature in 
2019. We also anticipate a slight reduction in the availability of short-term bank loans in 2019 but we do not anticipate any difficulties to fund our operations. 
In the  past,  our affiliates, namely  Ossen Material  Research (formerly Shanghai ZFX),  Shanghai Ossen, and Ossen Shanghai, have provided guarantees for 
certain of our short-term bank loans for no consideration. There can be no assurance that they will be willing or able to continue to provide similar guarantees 
on this basis with respect to future borrowings. We usually maintain lines of credit with several local banks, which will be utilized to fund our short term 
operation and fulfill liabilities.

53

Working Capital 

Our  working  capital  was  approximately  $113.1  million  at  December  31,  2018,  as  compared  to  $114.7  million  at  December  31,  2017  and  $101.6 

million at December 31, 2016.

The working capital decrease of $1.6 million in 2018 as compared with 2017 was due primarily to the increase of the current portion of long-term 
bank  loans and customer deposits,  partially offset by  the increase  in  accounts  receivable  and  inventories. The working  capital increase  of $13.1  million in 
2017  as  compared  with  2016  was  due  primarily  to  the  increase  of  accounts  receivable  and  advance  to  suppliers,  partially  offset  by  the  decrease  in  note 
receivable and inventories.

Inventories

We,  like  many  other  steel  product  manufacturers,  maintain  substantial  inventories  of  steel  to  accommodate  the  short  lead  times  and  just-in-time 
delivery requirements of our customers. Accordingly, we purchase steel in an effort to maintain our inventory at levels that we believe to be appropriate to 
satisfy the anticipated needs of our customers based upon historic buying practices, supply agreements with customers and market conditions.

Cash Flows

In 2017, our cash flow from operations was negative primarily due to the increase in advance to suppliers and accounts receivable. In 2018, our cash 
flow from operations was positive primarily due to the increases in net income and customer deposits, and a decrease in advance to suppliers, partially offset 
by the increases in accounts receivable and inventories.

Years Ended December 31, 2018 and 2017

The following table sets forth a summary of our net cash flow information for the periods indicated:

Year Ended December 31,
2017
2018

Net cash provided by (used in) operating activities

$

7,619,314

$

(3,019,725)

Net cash used in investing activities

Net cash used in financing activities

Operating Activities

(72,305)

(37,848)

(700,151)

(3,808,613)

Net cash provided in operating activities was approximately $7.6 million in 2018, as compared to $3.0 million of net cash used in operating activities 
in 2017. This was the result of a $5.5 million increase in net income due to higher revenue, a $1.3 million decrease in advance to suppliers due to the stronger 
U.S.  dollar,  a  $4.8  million  increase  in  customer  deposits  and  a  $1.3  million  increase  in  due  to  shareholder,  partially  offset  by  a  $8.9  million  increase  in 
accounts receivable due to slower payment from our customers and a $3.7 million increase in inventories due to lower consumption of raw materials at the end 
of 2018.

54

Investing Activities

Net cash used in investing activities was $72,305 in 2018, as compared to $37,848 of net cash used in investing activities in 2017 as the result of 

more spending in maintenance and repair of production lines in 2018.

Financing Activities

Net  cash  used  in  financing  activities  in  2018  was  approximately  $0.7  million,  as  compared  to  approximately  $3.8  million  of  net  cash  used  in 
financing activities in 2017. The decrease in cash used in financing activities was the result of an increase in proceeds from short-term bank loans, a decrease 
in repayment of notes payable, partially offset by a decrease in proceeds from notes payable.

5C. Research and Development, Patents and Licenses, etc.

See the discussion under the headings “Research and Development”, “Intellectual Property” and “Patents” in Item 4 above.

5D. Trend Information

See discussion in Parts A and B of this item.

5.E. Off-Balance Sheet Arrangements 

As of December 31, 2018 we guaranteed $74.1 million short-term debt and $2.9 million of notes payable for Shanghai Pujiang. We do not have any 
other  off-balance  sheet  arrangements  that  have,  or  are  reasonably  likely  to  have,  a  current  or  future  effect  on  our  financial  condition,  changes  in  financial 
condition, revenues or expenses, results of operations, liquidity, capital expenditures or capital resources that is material to our investors.

5.F. Tabular Disclosure of Contractual Obligations 

Our  contractual  obligations  consist  of  short-term  and  long-term  debt  obligations.  The  following  table  sets  forth  a  breakdown  of  our  contractual 

obligations as of December 31, 2018:

CONTRACTUAL OBLIGATIONS

Short-term debt obligations (1)
Interest Commitments – Short-term bank loans
Long-term debt obligations (2)
Interest Commitments – Long-term bank loans
Total

Total

22,315,912
448,746
7,269,027
404,196
30,437,881

Less than
1 year

22,315,912
448,746
7,269,027
404,196
30,437,881

Payments due by period

1-3 years

3-5 years

More than
5 years

-
-
-
-
-

-
-
-
-
-

-
-
-
-
-

(1) Attributable to short-term bank loans and bank acceptance notes.
(2) Attributable to long-term bank loans. Less than 1 year is the current portion of long-term bank loans.

55

ITEM 6.

DIRECTORS, SENIOR MANAGEMENT AND EMPLOYEES

6.A. Directors, Executive Officers and Key Employees

The following table sets forth the name, age, positions and a brief description of the business experience of each of our directors, executive officers 

and key employees as of the date hereof.

Name

Liang Tang

Wei Hua

Junhong Li

Xiaobing Liu

Yingli Pan

Zhongcai Wu

Position(s)

Chairman of the Board

Chief Executive Officer, Chief Financial Officer 
and Director

Director

Director

Director

Director

Age

51

57

53

60

63

70

There are no family relationships among our directors and officers. There are no arrangements or understandings with major shareholders, customers, 
suppliers or others, pursuant to which any person referred to above was selected as a director or member of senior management, except as disclosed in Note 10 
in the “accompanying consolidated financial statements”. The address of each of our directors and executive officers is c/o Ossen Innovation Co., Ltd., 518 
Shangcheng Road, Floor 17, Shanghai, 200120, People’s Republic of China.

Executive Officers and Directors

Dr.  Liang  Tang was  appointed  as  our  Chairman  following  our  business  combination.  Dr.  Tang  has  been  the  Chairman  and  President  of  Ossen 
Materials, our subsidiary, since 2008. Dr. Tang has also been President of Shanghai Ossen Investment Holding (Group) Co., Ltd. since 2001. He has more 
than 20 years of experience in the steel industry. Prior to joining our Company in 2004, Dr. Tang first worked as an officer of the enterprise management 
office at Baosteel Group Shanghai Ergang Co., Ltd. from July 1988 to March 1993 and then promoted and worked as the deputy director of the enterprise 
management  office  from  March  1993  to  November  1994.  He  then  served  as  the  deputy  head  of  the  enterprise  administrative  division  of  the  Shanghai 
Municipal  Metallurgical  Industry  Bureau  from  November  1994  to  May  1998.  From  May  1998  to  May  2001,  Dr.  Tang  served  as  an  officer  of  the  China 
Association  of  Social  Workers,  previously  known  as  China  Union  of  Social  Workers.  Thereafter,  Dr.  Tang  served  as  the  general  manager  of  Innovation 
Material  Research  Institute  from  May  2001  to  April  2004.  Dr.  Tang  graduated  from  Shanghai  University  in  the  PRC,  previously  Shanghai  University  of 
Technology,  with  a  Bachelor’s  degree  in  Metallurgy  and  Materials  Engineering  (Metal  Pressure  Processing  Discipline)  in  July  1988.  He  then  obtained  a 
Master of Business Administration degree jointly organized by Peking University in the PRC and Fordham University in the USA in May 2002, and obtained 
a Doctoral degree in World Economics from East China Normal University in the PRC in July 2007.

Mr. Wei Hua was appointed as our CEO and a director of ours following our business combination. In January 1, 2017, Mr. Hua was appointed as 
our CFO. Mr. Hua has served as Chairman of the Board of Directors of Ossen Jiujiang since 2007. Since 2000, he has been the Assistant Chief Executive 
Officer  for  the  Steel  Department  of  Ossen  Group.  Before  joining  Ossen  Group  in  2000,  from  1988  until  2000,  Mr.  Hua  was  a  vice  supervisor  of  the 
department of technology and quality supervision at Baosteel Group Shanghai Ergang Co., Ltd. From 1985 until 1988, Mr. Hua worked at Shanghai No. 5 
steel factory. He graduated from Shanghai University with a degree in Business Management.

56

Mr.  Junhong  Li has  been  one  of  our  directors  since  July  2010.  Mr.  Li  has  been  the  Senior  Partner  and  Deputy  Chief  Accountant  at  Continental 
Certified Public Accountants since 2008. Prior to joining Continental Certified Public Accountants in 2008, from 2007 until 2008, Mr. Li was the Executive 
Director  and  Chief  Financial  Officer  of  ZMAY  Holdings  Limited.  From  2004  until  2007,  Mr.  Li  was  Chief  Financial  Officer  of  Zhongmin  On  Line 
Technology Co. Ltd. Mr. Li has more than 20 years of experience in mergers and acquisitions, reorganizations and management consulting. Mr. Li received a 
bachelor’s degree from Central University of Finance and Economics and he is qualified as a certified public accountant.

Mr. Xiaobing Liu has been one of our directors since July 2010. Mr. Liu has served as Chairman of the Board of Huachen Trust since 2009. From 
2005 until 2009, Mr. Liu was Chairman of the Board of Directors of Shanghai Dingfeng Technology Co., Ltd. Since 2002, he has also been an independent 
director of Southern Building Material Co., Ltd. Mr. Liu graduated from the University of Shanghai for Science and Technology with a bachelor’s degree in 
optical instruments.

Ms. Yingli Pan has been one of our directors since July 2010. Professor Pan has been a professor in the Department of Finance at Antai College of 
Economics & Management of Shanghai since 2005. Prior to being appointed professor at Antai College of Economics & Management of Shanghai in 2005, 
from 1994 until 2005, Professor Pan was a professor in the Finance Department at East China Normal University. Professor Pan received a bachelor’s degree 
in economics from East China Normal University, a master’s degree in economics from Shanghai University of Finance and Economics and a doctoral degree 
in economics from East China Normal University.

Mr. Zhongcai Wu has been one of our directors since July 2010. Mr. Wu has been Chief Engineer in the Communications Department of Yunnan 

Province since 2002. Mr. Wu received a bachelor’s degree in road and bridge engineering from Hunan University.

Each of our directors will serve as a director until our next annual general meeting and until their successors are duly elected and qualified.

6.B. Compensation

For  the  year  ended  December  31,  2018,  the  aggregate  cash  compensation  that  we  paid  to  our  executive  officers  and  directors  was  approximately 
$86,300.  For the  year  ended  December 31,  2017,  the aggregate cash compensation  that  we paid  to our executive  officers  and  directors  was approximately 
$86,300. There are no service contracts between us and any of our directors, except for those directors who are also our executive officers. Pursuant to PRC 
law, 25% of our executive officers’ salaries have been set aside for pension and retirement.

Employment Agreements 

We have entered into an employment agreement with Dr. Liang Tang. Dr. Tang is employed as Chairman of the Board of our Company. The term of 
his agreement is set to expire on December 31, 2021.   We may terminate the employment agreement for cause as specified in the agreement. Dr. Tang may 
terminate the employment agreement with thirty days written notice. The employment agreement may be renewed upon the mutual agreement of the parties.

Each executive officer has agreed to hold in confidence any confidential information that he has obtained about the Company.

6.C. Board Practices

Terms of Directors and Officers

Expiration of Term of Directors

Pursuant to our memorandum and articles of association, the business of our company is managed by our board of directors. Commencing with the 
first annual meeting of the shareholders, directors are elected for a term of office to expire at the next succeeding annual meeting of the shareholders after their 
election. Each director will hold office until the expiration of his or her term of office and until his or her successor has been elected and qualified, or until his 
or her earlier death, resignation or removal by the shareholders or a resolution passed by the majority of the remaining directors. 

57

In the interim between annual meetings of shareholders, or special meetings of shareholders called for the election of directors, any vacancy on the 
board of directors may be filled by the vote of a majority of the remaining directors then in office, although less than a quorum, or by the sole remaining 
director.  A  director  elected  to  fill  a  vacancy  resulting  from  death,  resignation  or  removal  of  a  director  will  serve  for  the  remainder  of  the  full  term  of  the 
director whose death, resignation or removal will have caused such vacancy and until his successor will have been elected and qualified.

Director Remuneration Upon Termination

The directors may receive such remuneration as our board of directors may determine from time to time. The compensation committee will assist the 
directors in reviewing and approving the compensation structure for the directors. Currently, our directors are not entitled to receive any remuneration upon 
termination of employment.

Audit Committee

Our audit committee consists of Junhong Li, Yingli Pan and Xiaobing Liu, each of whom satisfies the independence requirements of Rule 10A-3 
under the Securities Exchange Act of 1934, as amended, which we refer to as the Exchange Act, and Rule 5605 of the NASDAQ rules. The audit committee 
oversees  our  accounting  and  financial  reporting  processes  and  audits  of  the  financial  statements  of  our  company.  The  audit  committee  is  responsible  for, 
among other things:

selecting our independent auditors and pre-approving all audit and non-audit services permitted to be performed by our independent auditors;
reviewing with our independent auditors any audit problems or difficulties and management’s response;
reviewing and approving all proposed related party transactions, as defined in Item 404 of Regulation S-K;
discussing our annual audited financial statements with management and our independent auditors;
reviewing major issues as to the adequacy of our internal controls and any special audit steps adopted in light of material control deficiencies; and

·
·
·
·
·
· meeting separately and periodically with management and our independent auditors.

Compensation Committee

Our compensation committee consists of Xiaobing Liu, Yingli Pan and Junhong Li, each of whom satisfies the independence requirements of Rule 
5605 of the NASDAQ rules. The compensation committee assists the Board in reviewing and approving the compensation structure, including all forms of 
compensation relating to our directors and executive officers. Our Chief Executive Officer may not be present at any committee meeting during which his 
compensation is deliberated. The compensation committee is responsible for, among other things:

·
·

reviewing and approving the total compensation package for our senior executives; and
reviewing  periodically,  and  approving,  any  long-term  incentive  compensation  or  equity  plans,  programs  or  similar  arrangements,  annual  bonuses, 
employee pension and welfare benefit plans.

Corporate Governance and Nominating Committee

Our  corporate  governance  and  nominating  committee  consists  of  Yingli  Pan,  Zhongcai  Wu  and  Xiaobing  Liu,  each  of  whom  satisfies  the 
independence  requirements  of  Rule  5605  of  the  NASDAQ  rules.  The  corporate  governance  and  nominating  committee  assists  the  board  in  selecting 
individuals qualified to become members of our board and in determining the composition of the board and its committees. The corporate governance and 
nominating committee is responsible for, among other things:

·

identifying  and  recommending  to  the  board  qualified  candidates  to  be  nominated  for  the  election  or  re-election  to  the  board  of  directors  and 
committees of the board of directors, or for appointment to fill any vacancy;

58

·

·

reviewing annually with the board of directors the current composition of the board of directors with regards to characteristics such as independence, 
age, skills, experience and availability of service to us; and
advising the board of directors periodically with regard to significant developments in the law and practice of corporate governance as well as our 
compliance with these laws and practices, and making recommendations to the board of directors on all matters of corporate governance and on any 
remedial actions to be taken, if needed.

6.D. Employees

See the section entitled “Employees” in Item 4.B above.

6.E. Share Ownership 

As of April 1, 2019, 19,791,110 of our ordinary shares were outstanding. Holders of our ordinary shares are entitled to vote together as a single class 
on all matters submitted to shareholders for approval. No holder of ordinary shares has different voting rights from any other holders of ordinary shares. We 
are  not  aware  of  any  arrangement  that  may, at  a  subsequent  date,  result  in  a  change  of  control  of  our  company.  Approximately  6,741,110  of  our  ordinary 
shares represented by American Depositary Receipts are held by an aggregate of 1 record holder in the United States.

Beneficial ownership  is determined in  accordance with the  rules and  regulations  of the  SEC. The  percentages  of shares  beneficially  owned in the 

table below are based on 19,791,110 ordinary shares outstanding as of April 1, 2019.

The following table sets forth information with respect to the beneficial ownership of our common shares as of April 1, 2019 by:

·
·

each of our directors and executive officers; and
each person known to us to beneficially own more than 5% of our outstanding ordinary shares.

Unless otherwise noted below,  the address for each listed shareholder, director or executive officer is 518  Shangcheng Road, Floor 17, Shanghai, 

200120, People’s Republic of China.

Name

Directors, Executive Officers and 5% Shareholders (1) :

Liang Tang (2)

Wei Hua

Junhong Li

Xiaobing Liu

Yingli Pan

Zhongcai Wu

Number of
Shares

Percentage

13,050,000

65.9%

-

-

-

-

-

-

-

-

-

-

(1) Beneficial ownership is determined in accordance with the rules and regulations of the SEC. Percentage of beneficial ownership of each listed person 
is based on ordinary shares outstanding as of the date of this filing, including ordinary shares convertible from all outstanding preferred shares, and 
the ordinary shares underlying any options and warrants exercisable by such person within 60 days of the date of this filing. Percentage of beneficial 
ownership  of  each  listed  person  is  based  on  ordinary  shares  outstanding  as  of  April  1,  2019  and  the  ordinary  shares  underlying  any  options  and 
warrants exercisable by such person within 60 days of the date of this filing.

(2) Acme holds such shares. Pujiang is the parent entity of Acme and is controlled by Dr. Tang. See Item 4C above.

59

ITEM 7. MAJOR SHAREHOLDERS AND RELATED PARTY TRANSACTIONS

7.A. Major Shareholders

See Item 6.E., “Share Ownership,” for a description of our major shareholders.

7.B. Related Party Transactions

Transfers of Shares Between Related Parties

Several of our subsidiaries and affiliates which are, or at one time were, controlled by our chairman, transferred shares with other entities controlled 

by Dr. Tang. See the discussion under Item 4.C above for a description of these transactions.

Purchases from a Related Party

Historically, we purchased a significant percentage of our raw materials from an affiliated entity, Ossen Material Research (formerly Shanghai ZFX), 
an  agent  that  supplies  steel  wire  rods  to  prestressed  concrete  manufacturers  in  China  such  as  our  company.  Ossen  Material  Research  is  controlled  by  our 
chairman, Dr. Tang. We have not procured any steel wire rods from Ossen Materials Research since 2014.

Sales to a Related Party 

In 2018, we sold $2.8 million of our products to Shanghai Pujiang Cable Co., Ltd., a subsidiary Shanghai Ossen acquired in September 2010. We 
sold  $2.9  million  of  our  products  to  Zhejiang  Pujiang  Cable  Co.,  Ltd.,  a  subsidiary  of  Shanghai  Pujiang  in  2018.  In  2018  and  2017,  we  generated 
approximately 4.2% and 0% of our revenue from sales to Shanghai Pujiang and Zhejiang Pujiang.

Guarantees 

During  the  years  ended  December  31,  2018,  2017  and  2016,  Ossen  Material  Research  (formerly  Shanghai  ZFX),  an  affiliate  of  ours,  and  Ossen 
Shanghai, an affiliate of ours, and Shanghai Pujiang, an affiliate of ours, provided guarantees for certain of our short-term and long-term bank loans. The term 
of each of the short-term loans is within one year. The term of the long-term loans is within three years. The purpose of these loans is to fund our working 
capital needs. Local banks have required guaranties pursuant to their standard regulations.

Ossen Material Research guaranteed loans in the amount of $0, $3.7 million and $1.3 million in 2018, 2017 and 2016, respectively. Ossen Shanghai 
guaranteed loans in the amount of $0.6 million in 2018, $0 in 2017 and $0 in 2016. Shanghai Pujiang guaranteed loans in the amount of $9.4 million in 2018, 
$3.7 million in 2017 and $0 in 2016. These guarantees in 2018, 2017 and 2016 were provided for no consideration. In addition, in 2018, 2017 and 2016, we 
guaranteed loans in  the amount of $74.1 million, $5.4 million and  $59.8  million and notes payable  in the amount of $2.9 million, $0 and $7.2 million for 
Shanghai Pujiang, we guaranteed loans in the amount of $0, $18.8 million and $70.6 million for Ossen Material Research, we guaranteed loans in the amount 
of $0, $0 and $28.5 million and notes payable in the amount of $0, $0 and $2.2 million for Ossen Shanghai, and we guaranteed loans in the amount of $0, 
$25.4 million and $0 for Zhejiang Pujiang.

60

There can be no assurance that Ossen Material Research, Shanghai Pujiang and Ossen Shanghai will be willing or able to continue to provide similar 

guarantees on this basis with respect to future borrowings. The loans that have come due have been repaid by us in full.

The terms of the loan guarantees between the guarantor and the bank provide for the following: if the borrower does not repay its loan, the bank may 
seek the principal and interest of the loan from the guarantor; the guarantee period is typically one or two years from the date the guaranteed loan is due, as 
determined by the lending bank; the bank may change the terms of the loan with the borrower without receiving the consent of the guarantor; the guarantor 
indemnifies the bank for actual damage or loss because of any fraudulent misrepresentations made by the guarantor and if the guarantor causes the contract to 
become invalid, the guarantor indemnifies the bank for damages and losses.

7.C. Interests of Experts and Counsel

Not applicable.

ITEM 8.

FINANCIAL INFORMATION

Consolidated Statements and Other Financial Information

The financial statements required by this item may be found at the end of this report on 20-F, beginning on page F-1.

Legal Proceedings

We are not currently, and have not recently been, a party to any material legal or administrative proceedings. We are not aware of any material legal 
or administrative proceedings threatened against us. From time to time, we are subject to various legal or administrative proceedings arising in the ordinary 
course of our business.

Dividends

We have never declared or paid any dividend on our ordinary shares and we do not anticipate paying any dividends on our ordinary shares in the 

future. We currently intend to retain all future earnings to finance our operations and to expand our business.

No Significant Changes

No significant changes to our financial condition have occurred since the date of the annual financial statements contained herein.

ITEM 9.

THE OFFER AND LISTING

9.A. Offer and Listing Details

 Our ADS’s are listed for trading on the NASDAQ Capital Market under the symbol “OSN.” The shares began trading on December 21, 2010 on the 
NASDAQ Global Market. The listing of our ADS’s was transferred to the NASDAQ Capital Market on July 30, 2013. The closing price for the ADSs was 
$1.75 on April 1, 2019.

On  December  11,  2018,  Pujiang,  the  parent  entity  of  Acme,  our  controlling  shareholder,  submitted  an  application  to  the  HK  Exchange,  seeking 
approval of a potential listing of Pujiang’s shares on the HK Exchange following a proposed initial public offering of Pujiang’s shares. Such application is 
subject to the review of the HK Exchange. The terms of such offering have not yet been set. Furthermore, the timing of the consummation of such potential 
offering and listing is unknown, and there is no guarantee that such listing and offering will be consummated at all. This filing shall not be deemed an offering 
of the securities of Pujiang or the Company.

61

9.B. Plan of Distribution

Not Applicable.

9.C. Markets

Our ADS’s are currently traded on the NASDAQ Capital Market.

9.D. Selling Shareholders

Not Applicable.

9.E. Dilution

Not Applicable.

9.F. Expenses of the Issuer

Not Applicable.

ITEM 10. ADDITIONAL INFORMATION

10.A. Share Capital

Not Applicable.

10.B. Memorandum and Articles of Association

We are a British Virgin Islands exempted company with limited liability and our affairs are governed by our memorandum and articles of association 
and the BVI Business Companies Act, 2004 (as amended from time to time) which is referred to as the BVI Act below. The following description of certain 
provisions of our memorandum and articles of association does not propose to be complete and is qualified in its entirety by our memorandum and articles of 
association.

Ordinary Shares

Certificates representing our ordinary shares are issued in registered form. Our shareholders who are nonresidents of the British Virgin Islands may 

freely hold and vote their shares. We are currently authorized to issue 100,000,000 ordinary shares. We do not have the power to issue bearer shares.

Charter

Our charter documents consist of our amended and restated memorandum of association and our amended and restated articles of association, or the 

memorandum and articles of association. We may amend our memorandum and articles of association generally by a special resolution of our shareholders.

Corporate Powers

Ultra Glory was incorporated under the BVI Act on January 21, 2010. Pursuant to our memorandum of association, the objects for which we were 
established are unrestricted and we have full power and authority to carry out any objects not prohibited by the BVI Act, as the same may be revised from 
time to time, or any other law of the British Virgin Islands, except that we have no power to carry on banking or trust business, business as an insurance or 
reinsurance  company,  insurance  agent  or  insurance  broker,  the  business  of  company  management,  the  business  of  providing  the  registered  office  or  the 
registered  agent  for  companies  incorporated  in  the  British  Virgin  Islands,  or  business  as  a  mutual  fund,  mutual  fund  management  or  mutual  fund 
administrator, unless we obtain certain licenses under the laws of the British Virgin Islands.

62

Board Composition

Pursuant to our memorandum and articles of association, the business of our company is managed by our board of directors. Commencing with the 
first annual meeting of the shareholders, directors are elected for a term of office to expire at the next succeeding annual meeting of the shareholders after their 
election. Each director will hold office until the expiration of his or her term of office and until his or her successor has been elected and qualified, or until his 
or her earlier death, resignation or removal by the shareholders or a resolution passed by the majority of the remaining directors.

In the interim between annual meetings of shareholders, or special meetings of shareholders called for the election of directors, any vacancy on the 
board of directors may be filled by the vote of a majority of the remaining directors then in office, although less than a quorum, or by the sole remaining 
director.  A  director  elected  to  fill  a  vacancy  resulting  from  death,  resignation  or  removal  of  a  director  will  serve  for  the  remainder  of  the  full  term  of  the 
director whose death, resignation or removal will have caused such vacancy and until his successor will have been elected and qualified.

There is  no  cumulative voting  by  shareholders for the  election of directors. We  do not have any age-based  retirement requirement  and we  do not 

require our directors to own any number of shares to qualify as a director.

Board Meetings

Board meetings may be held at the discretion of the directors at such times and in such manner as the directors may determine upon not less than 
three days notice having been given to all directors. Decisions made by the directors at meetings shall be made by a majority of the directors. There must be at 
least a majority of the directors (with a minimum of two) at each meeting.

Directors Interested in a Transaction

A director must, immediately after becoming aware of the fact that he is interested in a transaction entered into or to be entered into by us, disclose 
such interest to the board of directors. A director who is interested in a transaction entered into, or to be entered into, by the company, may vote on a matter 
related to the transaction, attend a meeting of directors at which a matter relating to the transaction arises and be included among the directors present at the 
meeting for the purposes of a quorum and sign a document on behalf of the company, or do any other thin in his capacity as a director, that relates to the 
transaction. A director is not required to disclose his interest in a transaction or a proposed transaction to our board of directors if the transaction or proposed 
transaction is between the director and us, or the transaction or proposed transaction is or is to be entered into the ordinary course of our business and on usual 
terms and conditions.

The  directors  may  exercise  all  powers  of  our  company  to  borrow  money,  mortgage  or  charge  our  undertakings  and  property,  issue  debentures, 

debenture shares and other securities whenever money is borrowed or as security for any debt, liability or obligation of the company or of any third party.

Our directors may, by resolution, fix the compensation of directors in respect of services rendered or to be rendered in any capacity to us.

A director may attend and speak at any meeting of the shareholders and at any separate meeting of the holders of any class of our shares.

Rights of Shares

We are currently authorized to issue 100,000,000 ordinary shares. The shares are made up of one class and one series, namely ordinary shares with a 
par value of $0.01 per share. The ordinary shares have one vote each and have the same rights with regard to dividends paid by the company and distributions 
of the surplus assets of the company.

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We may purchase, redeem or acquire our shares, provided that we obtain the consent of the member whose shares are being purchased, redeemed or 

otherwise acquired.

Issuance of Shares; Variation of Rights of Shares

Our articles of association provide that directors may, without limiting or affecting any right of holders of existing shares, offer, allot, grant options 
over or otherwise dispose of our unissued shares to such persons at such times and for such consideration and upon such terms and conditions as the directors 
may determine.

Without prejudice to any special rights previously conferred on the holders of any existing shares or class of shares, we may issue shares, with such 
preferred,  deferred  or  other  special  rights  or  such  restrictions,  whether  in  regard  to  dividend,  voting  or  otherwise,  as  the  directors  from  time  to  time  may 
determine.

If  we  issue  shares  of  more  than  one  class,  we  will  further  amend  and  restate  our  Memorandum  and  Articles  of  Association  to  reflect  the  rights 
attached to any class (unless otherwise provided by the terms of issue of the shares of that class) as may be varied with the consent in writing of the holders of 
not less than three-fourths of the issued shares of that class and the holders of not less than three-fourths of the issued shares of any other class of shares which 
may  be  affected  by  such  variation.  The  rights  conferred  upon  the  holders  of  the  shares  of  any  class  issued  with  preferred  or  other  rights  will  not,  unless 
otherwise expressly provided by the terms of issue of the shares of that class, be deemed to be varied by the creation or issue of further shares ranking pari 
passu therewith.

Shareholders Meetings

Under  our  memorandum  and  articles  of  association,  we  are  required  to  hold  an  annual  meeting  of  shareholders  each  year  at  such  date  and  time 
determined by our directors. Meetings of shareholders may be called pursuant to board resolution or the written request of shareholders holding more than 
30% of the votes of our outstanding voting shares. Written notice of meetings of shareholders must be given to each shareholder entitled to vote at a meeting 
not  fewer  than  10  days  prior  to  the  date  of  the  meeting,  with  certain  limited  exceptions.  The  written  notice  will  state  the  place,  time  and  business  to  be 
conducted at the meeting. The shareholders listed in our share register on the date prior to the date the notice is given shall be entitled to vote at the meeting, 
unless the notice provides a different date for determining the shareholders who are entitled to vote.

A meeting of shareholders held without proper notice will be valid if shareholders holding 90% majority of the total number of shares entitled to vote 
on all matters to be considered at the meeting, or 90% of the votes of each class or series of shares where shareholders are entitled to vote thereon as a class or 
series, together with an absolute majority of the remaining votes, have waived notice of the meeting and, for this purpose, presence of a shareholder at the 
meeting is deemed to constitute a waiver. The inadvertent failure of the directors to give notice of a meeting to a shareholder, or the fact that a shareholder has 
not received notice, will not invalidate a meeting.

Shareholders may vote in person or by proxy. No business may be transacted at any meeting unless a quorum of shareholders is present. A quorum 
consists of the presence in person or by proxy of holders entitled to exercise at least 50% of the voting rights of the shares of each class or series of shares 
entitled to vote as a class or series thereon and the same proportion of the votes of the remaining shares entitled to vote thereon.

Changes in the Maximum Number of Shares the Company is Authorized to Issue

Subject to the provisions of the BVI Act, we may, by a resolution of shareholders, amend our memorandum and articles of association to increase or 
decrease the number of shares authorized to be issued. Our directors may, by resolution, authorize a distribution by us at a time, of an amount, and to any 
shareholders they think fit if they are satisfied, on reasonable grounds, that we will, immediately after the distribution, satisfy the solvency test as set forth in 
the BVI Act, which requires that the value of a company’s assets exceeds its liabilities, and the company is able to pay its debts as they fall due.

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Indemnification

Subject  to  the  provisions  of  the  BVI  Act,  we  may  indemnify  any  person  who  (a)  is  or  was  a  party  or  is  threatened  to  be  made  a  party  to  any 
threatened, pending or completed proceedings, whether civil, criminal, administrative or investigative, by reason of the fact that the person is or was a director 
of our company; or (b) is or was, at our request, serving as a director of, or in any other capacity is or was acting for, another company or a partnership, joint 
venture, trust or other enterprise, against all expenses, including legal fees, and against all judgments, fines and amounts paid in settlement and reasonably 
incurred in connection with legal, administrative or investigative proceedings.

Material Differences between U.S. Corporate Law and British Virgin Islands Corporate Law

The  BVI  Act  differs  from  laws  applicable  to  U.S.  corporations  and  their  shareholders.  Set  forth  below  is  a  summary  of  the  material  differences 

between the provisions of the BVI Act applicable to us and the laws applicable to companies incorporated in the United States and their shareholders.

Differences in Corporate Law

We were incorporated under, and are governed by, the laws of the British Virgin Islands. The corporate statutes of the State of Delaware and the 
British  Virgin  Islands  are  similar,  and  the  flexibility  available  under  British  Virgin  Islands  law  has  enabled  us  to  adopt  memorandum  of  association  and 
articles of association that will provide shareholders with rights that do not vary in any material respect from those they would enjoy if we were incorporated 
under the Delaware General Corporation Law, or Delaware corporate law. Set forth below is a summary of some of the differences between provisions of the 
BVI Act applicable to us and the laws applicable to companies incorporated in Delaware and their shareholders.

Director’s Fiduciary Duties

Under Delaware corporate law, a director of a Delaware corporation has a fiduciary duty to the corporation and its stockholders. This duty has two 
components: the duty of care and the duty of loyalty. The duty of care requires that a director act in good faith, with the care that an ordinarily prudent person 
would  exercise  under  similar  circumstances.  Under  this  duty,  a  director  must  inform  himself  of,  and  disclose  to  stockholders,  all  material  information 
reasonably available regarding a significant transaction. The duty of loyalty requires that a director act in a manner he reasonably believes to be in the best 
interests of the corporation. He must not use his corporate position for personal gain or advantage. This duty prohibits self-dealing by a director and mandates 
that the best interest of the corporation and its stockholders take precedence over any interest possessed by a director, officer or controlling stockholder and 
not shared  by  the  stockholders  generally.  In general,  actions  of  a  director are  presumed  to  have  been  made  on  an informed  basis,  in  good  faith and  in the 
honest belief that the action taken was in the best interests of the corporation. However, this presumption may be rebutted by evidence of a breach of one of 
the fiduciary duties. Should such evidence be presented concerning a transaction by a director, a director must prove the procedural fairness of the transaction, 
and that the transaction was of fair value to the corporation.

British Virgin Islands law provides that every director of a British Virgin Islands company, in exercising his powers or performing his duties, shall 
act honestly and in good faith and in what the director believes to be in the best interests of the company. Additionally, the director shall exercise the care, 
diligence, and skill that a reasonable director would exercise in the same circumstances taking into account, but without limitation, the nature of the company, 
the nature of the decision, the position of the director and the nature of his responsibilities. In addition, British Virgin Islands law provides that a director shall 
exercise his powers as a director for a proper purpose and shall not act, or agree to the company acting, in a manner that contravenes British Virgin Islands law 
or the memorandum association or articles of association of the company.

Amendment of Governing Documents

Under Delaware corporate law, with very limited exceptions, a vote of the stockholders is required to amend the certificate of incorporation. Under 
British  Virgin  Islands  law,  no  article  or  regulation  shall  be  amended,  rescinded  or  altered,  and  no  new  article  shall  be  made,  without  the  approval  of  the 
members pursuant to a special resolution, unless the memorandum of association and articles of association provide otherwise.

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Written Consent of Directors

Under  Delaware  corporate  law,  directors  may  act  by  written  consent  only  on  the  basis  of  a  unanimous  vote.  Under  British  Virgin  Islands  law, 

directors’ consents need only a majority of directors signing to take effect.

Written Consent of Shareholders

Under Delaware corporate law, unless otherwise provided in the certificate of incorporation, any action to be taken at any annual or special meeting 
of stockholders of a corporation, may be taken by written consent of the holders of outstanding stock having not less than the minimum number of votes that 
would be necessary to take such action at a meeting. As permitted by British Virgin Islands law, shareholders’ consents need only a majority of shareholders 
signing to take effect. Our memorandum of association and articles of association provide that, other than changes to our memorandum of association and 
articles  of  association,  shareholders  may  approve  corporate  matters  by  way  of  a  resolution  consented  to  at  a  meeting  of  shareholders  or  in  writing  by  a 
majority of shareholders entitled to vote thereon. Changes to our memorandum of association and articles of association require the approval of 66 2/3% of the 
votes of shareholders.

Shareholder Proposals

Under Delaware corporate law, a shareholder has the right to put any proposal before the annual meeting of shareholders, provided it complies with 
the notice provisions in the governing documents. A special meeting may be called by the board of directors or any other person authorized to do so in the 
governing documents, but shareholders may be precluded from calling special meetings. British Virgin Islands law and our memorandum of association and 
articles of association provide that our directors shall call a meeting of the shareholders if requested in writing to do so by shareholders entitled to exercise at 
least 30% of the voting rights in respect of the matter for which the meeting is requested.

Sale of Assets

Under Delaware corporate law, a vote of the stockholders is required to approve the sale of assets only when all or substantially all assets are being 

sold. In the British Virgin Islands, shareholder approval is required when more than 50% of the company’s total assets by value are being disposed of or sold.

Dissolution; Winding Up

Under Delaware corporate law, unless the board of directors approves the proposal to dissolve, dissolution must be approved by shareholders holding 
100% of the total voting power of the corporation. Only if the dissolution is initiated by the board of directors may it be approved by a simple majority of the 
corporation’s outstanding shares. Delaware corporate law allows a Delaware corporation to include in its certificate of incorporation a supermajority voting 
requirement in connection with dissolutions initiated by the board. As permitted by British Virgin Islands law and our memorandum of association and articles 
of  association,  we  may  be  voluntarily  liquidated  under  Part  XII  of  the  BVI  Act  by  resolution  of  directors  and  resolution  of  shareholders  if  we  have  no 
liabilities and we are able to pay our debts as they fall due.

Redemption of Shares

Under Delaware corporate law, any stock may be made subject to redemption by the corporation at its option or at the option of the holders of such 
stock provided there remains outstanding shares with full voting power. Such stock may be made redeemable for cash, property or rights, as specified in the 
certificate of incorporation or in the resolution of the board of directors providing for the issue of such stock. As permitted by British Virgin Islands law, and 
our memorandum of association and articles of association, shares may be repurchased, redeemed or otherwise acquired by us. Our directors must determine 
that immediately following the redemption or repurchase we will be able to satisfy our debts as they fall due and the value of our assets exceeds our liabilities.

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Variation of Rights of Shares

Under Delaware corporate law, a corporation may vary the rights of a class of shares with the approval of a majority of the outstanding shares of such 
class, unless the certificate of incorporation provides otherwise. As permitted by British Virgin Islands law, and our memorandum of association and articles 
of association, if our share capital is divided into more than one class of shares, we may vary the rights attached to any class only with the consent in writing 
of holders of not less than three-fourths of the issued shares of that class and holders of not less than three-fourths of the issued shares of any other class of 
shares which may be affected by the variation.

Removal of Directors

Under Delaware corporate law, a director of a corporation with a classified board may be removed only for cause with the approval of a majority of 
the  outstanding  shares  entitled  to  vote,  unless  the  certificate  provides  otherwise.  As  permitted  by  British  Virgin  Islands  law  and  our  memorandum  of 
association and articles of association, directors may be removed by resolution of directors or resolution of shareholders, with or without cause.

Mergers

Under the BVI Act, two or more companies may merge or consolidate in accordance with the statutory provisions. A merger means the merging of 
two or more constituent companies into one of the constituent companies, and a consolidation means the uniting of two or more constituent companies into a 
new company. In order to merge or consolidate, the directors of each constituent company must approve a written plan of merger or consolidation which must 
be authorized by a resolution of shareholders.

Shareholders not otherwise entitled to vote on the merger or consolidation may still acquire the right to vote if the plan of merger or consolidation 
contains any provision which, if proposed as an amendment to the memorandum association or articles of association, would entitle them to vote as a class or 
series on the proposed amendment. In any event, all shareholders must be given a copy of the plan of merger or consolidation irrespective of whether they are 
entitled to vote at the meeting or consent to the written resolution to approve the plan of merger or consolidation.

Inspection of Books and Records

Under  Delaware  corporate  law,  any  shareholder  of  a  corporation  may  for  any  proper  purpose  inspect  or  make  copies  of  the  corporation’s  stock 
ledger, list of shareholders and other books and records. Under the BVI Act, members, upon giving written notice to us, are entitled to inspect the register of 
members, the register of directors and minutes of resolutions of members, and to make copies of these documents and records.

Conflict of Interest

The BVI Act provides that a director shall forthwith, after becoming aware that he is interested in a transaction entered into or to be entered into by 
the company, disclose that interest to the board of directors of the company. The failure of a director to disclose that interest does not affect the validity of a 
transaction entered into by the director or the company. A transaction entered into by us, in respect of which a director is interested, is voidable by us unless 
the director’s interest was disclosed to the board prior to the company’s entry into the transaction or was not required to be disclosed. A transaction is not 
voidable if the material facts of the director’s interest are known by the members entitled to vote or if the transaction is approved or ratified by a resolution of 
members.  As  permitted  by  British  Virgin  Islands  law  and  our  memorandum  of  association  and  articles  of  association,  a  director  interested  in  a  particular 
transaction may vote on it, attend meetings at which it is considered, and sign documents on our behalf which relate to the transaction.

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Transactions with Interested Shareholders

Delaware  corporate  law  contains  a  business  combination  statute  applicable  to  Delaware  public  corporations  whereby,  unless  the  corporation  has 
specifically  elected  not  to  be  governed  by such  statute  by  amendment  to  its  certificate  of  incorporation,  it  is  prohibited  from  engaging  in  certain  business 
combinations  with  an  “interested  shareholder”  for  three  years  following  the  date  that  such  person  becomes  an  interested  shareholder.  An  interested 
shareholder generally is a person or group who or that owns or owned 15% or more of the target’s outstanding voting stock within the past three years. This 
has the effect of limiting the ability of a potential acquirer to make a two-tiered bid for the target in which all shareholders would not be treated equally. The 
statute does not apply if, among other things, prior to the date on which such shareholder becomes an interested shareholder, the board of directors approves 
either the business combination or the transaction that resulted in the person becoming an interested shareholder. This encourages any potential acquirer of a 
Delaware public corporation to negotiate the terms of any acquisition transaction with the target’s board of directors.

British Virgin Islands law has no comparable provision.

Independent Directors

There are no provisions under Delaware corporate law or under the BVI Act that require a majority of our directors to be independent.

Cumulative Voting

Under  Delaware  corporate  law,  cumulative  voting  for  elections  of  directors  is  not  permitted  unless  the  company’s  certificate  of  incorporation 
specifically provides for it. Cumulative voting potentially facilitates the representation of minority shareholders on a board of directors since it permits the 
minority shareholder to cast all the votes to which the shareholder is entitled on a single director, which increases the shareholder’s voting power with respect 
to electing such director. There are no prohibitions to cumulative voting under the laws of the British Virgin Islands, but our memorandum of association and 
articles of association do not provide for cumulative voting. 

Anti-takeover Provisions in Our Memorandum of Association and Articles of Association

Some provisions of our memorandum of association and articles of association may discourage, delay or prevent a change in control of our company 
or management that shareholders may consider favorable, including provisions that authorize our board of directors to issue preference shares in one or more 
series and to designate the price, rights, preferences, privileges and restrictions of such preference shares.

10.C. Material Contracts

We have not entered into any material contracts other than in the ordinary course of business and other than those described in this annual report.

10.D. Exchange Controls

British Virgin Islands

There are currently no exchange control regulations in the British Virgin Islands applicable to us or our shareholders.

The PRC

China regulates foreign currency exchanges primarily through the following rules and regulations:

·

·

Foreign Currency Administration Rules of 1996, as amended; and

Administrative Rules of the Settlement, Sale and Payment of Foreign Exchange of 1996.

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As we disclosed in the risk factors above, Renminbi is not a freely convertible currency at present. Under the current PRC regulations, conversion of 
Renminbi is permitted in China for routine current-account foreign exchange transactions, including trade and service related foreign exchange transactions, 
payment of dividends and service of foreign debts. Conversion of Renminbi for most capital-account items, such as direct investments, investments in PRC 
securities markets and repatriation of investments, however, is still subject to the approval of SAFE.

Pursuant to the above-mentioned administrative rules, foreign-invested enterprises may buy, sell and/or remit foreign currencies for current account 
transactions at banks in China with authority to conduct foreign exchange business by complying with certain procedural requirements, such as presentment of 
valid commercial documents. For capital-account transactions involving foreign direct investment, foreign debts and outbound investment in securities and 
derivatives,  approval  from  SAFE  is  a  pre-condition.  Capital  investments  by  foreign-invested  enterprises  outside  China  are  subject  to  limitations  and 
requirements in China, such as prior approvals from the PRC Ministry of Commerce or SAFE.

10.E. Taxation

The following summary of the material British Virgin Islands, PRC and U.S. tax consequences of an investment in our ADSs or ordinary shares is 
based upon laws and relevant interpretations thereof in effect as of the date hereof, all of which are subject to change, possibly with retroactive effect. This 
summary is not intended to be, nor should it be construed as, legal or tax advice and is not exhaustive of all possible tax considerations. This summary also 
does not deal with all possible tax consequences relating to an investment in our ADSs or ordinary shares, such as the tax consequences under state, local, 
non-U.S.,  non-PRC,  and  non-British  Virgin  Islands  tax  laws.  Investors  should  consult  their  own  tax  advisors  with  respect  to  the  tax  consequences  of  the 
acquisition, ownership and disposition of our ADSs or ordinary shares. 

British Virgin Islands Taxation

All  dividends,  interests,  rents,  royalties,  compensations  and  other  amounts  paid  by  us  are  exempt  from  all  forms  of  taxation  in  the  British  Virgin 
Islands  and  any  capital  gains  realized  with  respect  to  any  of our  shares,  debt  obligations,  or  other  securities  are  not  subject  to  any  form  of  taxation  in  the 
British Virgin Islands. No estate, inheritance, succession or gift tax, rate, duty, levy or other charge is payable under BVI law by persons who are not persons 
resident  in  the  British  Virgin  Islands  with  respect  to  any  of  our  shares,  debt  obligation  or  other  securities.  There  are  currently  no  withholding  taxes  or 
exchange  control  regulations  in  the  British  Virgin  Islands  applicable  to  us  or  our  shareholders.  Currently,  there  is  no  income  tax  treaty,  convention  or 
reciprocal tax treaty regarding withholdings currently in effect between the United States and the British Virgin Islands. We will only be liable to pay payroll 
tax with respect to employees employed and working in the British Virgin Islands. We do not currently have, and do not intend to have in the near future, any 
employees in the British Virgin Islands.

People’s Republic of China Taxation

Under  the  former  Income  Tax  Law  for  Enterprises  with  Foreign  Investment  and  Foreign  Enterprises,  any  dividends  payable  by  foreign-invested 
enterprises  to  non-PRC  investors  were  exempt  from  PRC  withholding  tax.  In  addition,  any  dividends  payable,  or  distributions  made,  by  us  to  holders  or 
beneficial owners of our shares would not be subject to any PRC tax, provided that such holders or beneficial owners, including individuals and enterprises, 
were not deemed to be PRC residents under the PRC tax law and were not otherwise subject to PRC tax.

On March 16, 2007, the PRC National People’s Congress approved and promulgated a new PRC Enterprise Income Tax Law, which took effect as of 
January 1, 2008. Under the new tax law, enterprises established under the laws of non-PRC jurisdictions but whose “de facto management body” are located 
in China are considered “resident enterprises” for PRC tax purposes. Under the implementation regulations issued by the State Council relating to the new tax 
law,  “de  facto  management  body”  is  defined  as  the  body  that  has  material  and  overall  management  control  over  the  business,  personnel,  accounts  and 
properties of an enterprise. In April 2009, the PRC State Administration of Taxation promulgated a circular to clarify the definition of “de facto management 
body”  for  enterprises  incorporated  overseas  with  controlling  shareholders  being  PRC  enterprises.  It  remains  unclear  how  the  tax  authorities  will  treat  an 
overseas  enterprise  invested  or  controlled  by  another  overseas  enterprise  and  ultimately  controlled  by  PRC  individual  residents  as  is  in  our  case.  We  are 
currently not treated as a PRC resident enterprise by the relevant tax authorities. Since substantially all of our management is currently based in China and 
may remain in China in the future, we may be treated as a “resident enterprise” for the PRC tax purposes, in which case, we will be subject to PRC income tax 
as  to our worldwide income at a uniform income  tax rate of  25%. In addition, the new tax law provides that dividend income between  qualified “resident 
enterprises” is exempt from income tax.

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Moreover, the new tax law provides that an income tax rate of 10% is normally applicable to dividends payable for earnings derived since January 1, 
2008 to non-PRC investors who are “non-resident enterprises,” to the extent such dividends are derived from sources within China. We are a British Virgin 
Islands holding company and substantially all of our income is derived from dividends, if any, we receive from our operating subsidiaries located in China. 
Thus, dividends payable to us by our subsidiaries in China may be subject to the 10% withholding tax if we are considered as a “non-resident enterprise” 
under the new tax law.

Moreover, non-resident individual investors may be required to pay PRC individual income tax at a rate of 20% on interests or dividends payable to 
the investors or any capital gains realized from the transfer of ADSs or ordinary shares if such gains are deemed income derived from sources within the PRC. 
Under the Individual Income Tax Law or the IIT Law, non-resident individual refers to an individual who has no domicile in China and does not stay in the 
territory  of  China  or  who  has  no  domicile  in  China  and  has  stayed  in  the  territory  of  China  for  less  than  one  year.  Pursuant  to  the  IIT  Law  and  its 
implementation rules, for purposes of the PRC capital gains tax, the taxable income will be the balance of the total income obtained from the transfer of the 
ADSs  or  ordinary  shares  minus  all  the  costs  and  expenses  that  are  permitted  under  PRC  tax  laws  to  be  deducted  from  the  income.  Therefore,  if  we  are 
considered as a PRC "resident enterprise" and dividends we pay with respect to our ADSs or ordinary shares and the gains realized from the transfer of our 
ADSs or ordinary shares are considered income derived from sources within the PRC by relevant competent PRC tax authorities, such gains earned by non-
resident individuals may also be subject to PRC withholding tax at a rate of 20%.

Under the currently available guidance of the new tax law, dividends payable by us to our shareholders should not be deemed to be derived from 
sources within China and therefore should not be subject to withholding tax at 10%, or a lower rate if reduced by a tax treaty or agreement. However, what 
will constitute income derived from sources within China is currently unclear. In addition, gains on the disposition of our shares should not be subject to PRC 
withholding tax. However, these conclusions are not entirely free from doubt. In addition, it is possible that these rules may change in the future, possibly with 
retroactive effect.

United States Federal Income Taxation

The following is a discussion of the material U.S. federal income tax considerations that may apply to an investor with respect to the acquisition, 
ownership and disposition of our ADSs or ordinary shares. This discussion does not purport to address all of the tax consequences of owning our ADSs or 
ordinary shares with respect to all categories of investors that acquire our ADSs or ordinary shares, some of which (such as financial institutions, regulated 
investment companies, real estate investment trusts, tax-exempt organizations, insurance companies, persons holding our ADSs or ordinary shares as part of a 
hedging, integrated, conversion, straddle or constructive sale transaction, traders in securities that have elected the mark-to-market method of accounting for 
their securities, persons liable for alternative minimum tax, persons who are investors in pass-through entities, grantor trusts, persons who own, directly or 
indirectly under applicable constructive ownership rules, 10% or more (by voting power) of our ADSs or ordinary shares, persons who received our ADSs or 
ordinary  shares  pursuant  to  the  exercise  of  an  option  or  otherwise  as  compensation,  certain  former  citizens  and  long-term  residents  of  the  United  States, 
dealers in securities or currencies and investors whose functional currency is not the U.S. dollar) may be subject to special rules. This discussion addresses 
only holders who purchase our ADSs or ordinary shares and hold such ADSs or ordinary shares as a capital asset (i.e., generally for investment). Moreover, 
this discussion is based on the Internal Revenue Code of 1986, as amended (or the Code), existing and proposed Treasury regulations promulgated under the 
Code, published rulings, and administrative and judicial interpretations of the Code, all as currently in effect as of the date of hereof, all of which are subject 
to  change,  possibly  with  retroactive  effect.  Investors  should  consult  their  own  tax  advisors  regarding  the  tax  consequences  arising  in  their  own  particular 
situation under U.S. federal, state, local or foreign law or the United States – PRC income tax treaty with respect to the acquisition, ownership or disposition 
of our ADSs or ordinary shares.

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For purposes of this discussion, the term “U.S. Holder” means (except as described in the preceding paragraph) a beneficial owner of our ADSs or 
ordinary shares that is, for United States federal income tax purposes, (i) an individual U.S. citizen or resident, (ii) a corporation (or other entity taxable as a 
corporation) created or organized under the laws of the United States or any political subdivision thereof, or the District of Columbia, (iii) an estate the income 
of  which  is  subject  to  U.S.  federal  income  taxation  regardless  of  its  source  or  (iv)  a  trust  if  either  (x)  a  court  within  the  United  States  is  able  to  exercise 
primary jurisdiction over the administration of the trust and one or more U.S. persons have the authority to control all substantial decisions of the trust or (y) 
the trust has a valid election in effect under applicable Treasury Regulations to be treated as a U.S. person. A beneficial owner of our ADSs or ordinary shares 
(other  than  a  partnership  or  an  entity  treated  as  a  partnership  for  U.S.  federal  income  tax  purposes)  that  is  not  a  U.S.  Holder  is  referred  to  below  as  a 
“Non-U.S. Holder.”

If a partnership, or an entity treated for U.S. federal income tax purposes as a partnership, such as a limited liability company, holds our ADSs or 
ordinary shares, the tax treatment of a partner in such partnership will depend on the status of the partner and upon the activities of the partnership. A partner 
in such a partnership holding our ADSs or ordinary shares, you should consult its tax advisor.

U.S. Federal Income Taxation of Non-U.S. Holders

Except  as  described  in  “Backup  Withholding  and  Information  Reporting”  below,  non-U.S.  Holders  will  generally  not  be  subject  to  U.S.  federal 
income tax or withholding tax on the payment of dividends on, and the proceeds from the disposition of, our ADSs or ordinary shares unless, in the case of 
U.S.  federal  income  taxes,  the  income  is  effectively  connected  with  the  conduct  by  the  Non-U.S.  Holder  of  a  trade  or  business  in  the  United  States 
(“effectively connected income”) (and, if an income tax treaty applies, the income is attributable to a permanent establishment maintained by the Non-U.S. 
Holder in the United States or, in the case of an individual, the income is attributable to a fixed place of business).

Non-U.S. Holders will generally not be subject to U.S. federal income tax or withholding tax on any gain realized upon the sale, exchange or other 

disposition of our ADSs or ordinary shares, unless either:

·

·

the gain is effectively  connected income (or,  if  a treaty applies, the  gain is attributable  to  a  permanent establishment  maintained  by  the Non-U.S. 
Holder in the United States or, in the case of an individual, the income is attributable to a fixed place of business); or

the Non-U.S. Holder is an individual who is present in the United States for 183 days or more during the taxable year of disposition and certain other 
conditions are met.

Effectively connected income may be subject to regular U.S. federal income tax in the same manner as discussed in the section above relating to the 
taxation of U.S. Holders, unless exempt under an applicable income tax treaty. In addition, effectively connected income of a corporate Non-U.S. Holder may 
be subject to an additional branch profits tax at a rate of 30%, or at a lower rate as may be specified by an applicable income tax treaty.

Non-U.S. Holders may be subject to tax in jurisdictions other than the United States on dividends received from us on our ADSs or ordinary shares 
and on any gain realized upon the sale, exchange or other disposition of our ADSs or ordinary shares. Non-U.S. Holders should consult with their own tax 
advisors regarding such other jurisdictions.

Backup Withholding and Information Reporting

U.S. Holders (other than certain exempt recipients) may be subject to information reporting requirements with respect to the payment of dividends 
on,  or  proceeds  from  the  disposition  of,  our  ADSs  or  ordinary  shares.  In  addition,  a  U.S.  Holder  may  be  subject,  under  certain  circumstances,  to  backup 
withholding at a rate of up to 24% with respect to dividends paid on, or proceeds from the disposition of, our ADSs or ordinary shares unless the U.S. Holder 
provides  proof  of  an  applicable  exemption  or  correct  taxpayer  identification  number  and  otherwise  complies  with  applicable  requirements  of  the  backup 
withholding  rules.  A  U.S.  Holder  of  our  ADSs  or  ordinary  shares  who  provides  an  incorrect  taxpayer  identification  number  may  be  subject  to  penalties 
imposed by the IRS.

71

Non-U.S. Holders are generally not subject to information reporting or backup withholding with respect to dividends paid on, or proceeds from the 
disposition of, our ADSs or ordinary shares, provided that the Non-U.S. Holder provides its taxpayer identification number, certifies to its foreign status, or 
establishes another exemption to the information reporting or back-up withholding requirements.

10.F. Dividends and Paying Agents

Not Applicable.

10.G. Statement by Experts

Not Applicable.

10.H. Documents on Display

The Company  is subject to  the informational  requirements  of the  Securities  Exchange Act of  1934, as amended, and will file reports, registration 
statements and other information with the SEC. The Company’s reports, registration statements and other information can be inspected on the SEC’s website 
at www.sec.gov. You may also visit us on the World Wide Web at http://www.osseninnovation.com. However, information contained on our website does not 
constitute a part of this annual report.

10.I. Subsidiary Information

Not Applicable.

ITEM 11. QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

Financial instruments that expose us to concentrations of credit risk primarily consist of cash and accounts receivables. The maximum amount of loss 
due to credit risk in the event of other parties failing to perform their obligations is represented by the carrying amount of each financial asset as stated in our 
consolidated balance sheets.

As  of  December  31,  2018  and  2017,  substantially  all  of  our  cash  included  bank  deposits  in  accounts  maintained  within  the  PRC  where  there  is 
currently no rule or regulation in place for obligatory insurance to cover bank deposits in the event of bank failure. However, we have not experienced any 
losses in such accounts and we believe we are not exposed to any significant risks on our cash in bank accounts.

We are exposed to various types of market risks, including changes in foreign exchange rates, commodity prices and inflation in the normal course of 

business.

Interest rate risk

We are subject to risks resulting from fluctuations in interest rates on our bank balances. A substantial portion of our cash is held in China in interest 
bearing bank deposits and denominated in RMB. To the extent that we may need to raise debt financing in the future, upward fluctuations in interest rates 
would increase the cost of new debt. We do not currently use any derivative instruments to manage our interest rate risk.

Commodity price risk

Certain raw materials used by us are subject to price volatility caused by supply conditions, political and economic variables and other unpredictable 
factors.  The  primary  purpose  of  our  commodity  price  management  activities  is  to  manage  the  volatility  associated  with  purchases  of  commodities  in  the 
normal course of business. We do not speculate on commodity prices.

72

Foreign exchange risk

The RMB is not a freely convertible currency. The PRC government may take actions that could cause future exchange rates to vary significantly 

from current or historical exchange rates. Fluctuations in exchange rates may adversely affect the value of any dividends we declare.

Very limited hedging transactions are available in China to reduce our exposure to exchange rate fluctuations. To date, we have not entered into any 
hedging transactions in an effort to reduce our exposure to foreign currency exchange risk. While we may enter into hedging transactions in the future, the 
availability and effectiveness of these transactions may be limited, and we may not be able to successfully hedge our exposure at all. In addition, our foreign 
currency exchange losses may be magnified by PRC exchange control regulations that restrict our ability to convert RMB into foreign currencies.

Inflation risk

Inflationary  factors  such  as  increases  in  the  cost  of  our  products  and  overhead  costs  may  adversely  affect  our  operating  results.  A  high  rate  of 
inflation may have an adverse effect on our ability to maintain current levels of gross margin and selling, general and administrative expenses as a percentage 
of net revenues if the selling prices of our products do not increase proportionately with these increased costs.

ITEM 12. DESCRIPTION OF SECURITIES OTHER THAN EQUITY SECURITIES

The depositary may charge each person to whom ADSs are issued, including, without limitation, issuances against deposits of shares, issuances in 
respect of share distributions, rights and other distributions, issuances pursuant to a stock dividend or stock split declared by us or issuances pursuant to a 
merger, exchange of securities or any other transaction or event affecting the ADSs or deposited securities, and each person surrendering ADSs for withdrawal 
of deposited securities or whose ADRs are cancelled or reduced for any other reason, $5.00 for each 100 ADSs (or any portion thereof) issued, delivered, 
reduced, cancelled or surrendered, as the case may be. The depositary may sell (by public or private sale) sufficient securities and property received in respect 
of a share distribution, rights and/or other distribution prior to such deposit to pay such charge.

The following additional charges shall be incurred by the ADR holders, by any party depositing or withdrawing shares or by any party surrendering 
ADSs or to whom ADSs are issued (including, without limitation, issuance pursuant to a stock dividend or stock split declared by us or an exchange of stock 
regarding the ADRs or the deposited securities or a distribution of ADSs), whichever is applicable:

·
·
·

·

·
·
·

·

a fee of $1.50 per ADR or ADRs for transfers of certificated or direct registration ADRs;
a fee of up to $0.05 per ADS for any cash distribution made pursuant to the deposit agreement;
a fee of up to $0.05 per ADS per calendar year (or portion thereof) for services performed by the depositary in administering the ADRs (which fee 
may be charged on a periodic basis during each calendar year and shall be assessed against holders of ADRs as of the record date or record dates set 
by the depositary during each calendar year and shall be payable in the manner described in the next succeeding provision);
reimbursement  of  such  fees,  charges  and  expenses  as  are  incurred  by  the  depositary  and/or  any  of  the  depositary’s  agents  (including,  without 
limitation, the custodian and expenses incurred on behalf of holders in connection with compliance with foreign exchange control regulations or any 
law or regulation relating to foreign investment) in connection with the servicing of the shares or other deposited securities, the delivery of deposited 
securities or otherwise in connection with the depositary’s or its custodian’s compliance with applicable law, rule or regulation (which charge shall 
be assessed on a proportionate basis against holders as of the record date or dates set by the depositary and shall be payable at the sole discretion of 
the depositary by billing such holders or by deducting such charge from one or more cash dividends or other cash distributions);
stock transfer or other taxes and other governmental charges;
cable, telex and facsimile transmission and delivery charges incurred at your request in connection with the deposit or delivery of shares;
transfer  or  registration  fees  for  the  registration  of  transfer  of  deposited  securities  on  any  applicable  register  in  connection  with  the  deposit  or 
withdrawal of deposited securities; and
expenses of the depositary in connection with the conversion of foreign currency into U.S. dollars.

73

We will pay all other charges and expenses of the depositary and any agent of the depositary (except the custodian) pursuant to agreements from time 

to time between us and the depositary. The charges described above may be amended from time to time by agreement between us and the depositary.

Our  depositary  has  agreed  to  reimburse  us  for  certain  expenses  we  incur  that  are  related  to  establishment  and  maintenance  of  the  ADR  program, 
including investor relations expenses and exchange application and listing fees. Neither the depositary nor we can determine the exact amount to be made 
available  to  us  because  (i)  the  number  of  ADSs  that  will  be  issued  and  outstanding,  (ii)  the  level  of  fees  to  be  charged  to  holders  of  ADSs  and  (iii)  our 
reimbursable expenses related to the ADR program are not known at this time. The depositary collects its fees for issuance and cancellation of ADSs directly 
from investors depositing shares or surrendering ADSs for the purpose of withdrawal or from intermediaries acting for them. The depositary collects fees for 
making distributions to investors by deducting those fees from the amounts distributed or by selling a portion of distributable property to pay the fees. The 
depositary may collect its annual fee for depositary services by deduction from cash distributions, or by directly billing investors, or by charging the book-
entry system accounts of participants acting for them. The depositary will generally set off the amounts owing from distributions made to holders of ADSs. If, 
however,  no  distribution  exists  and  payment  owing  is  not  timely  received  by  the  depositary,  the  depositary  may  refuse  to  provide  any  further  services  to 
holders that have not paid those fees and expenses owing until such fees and expenses have been paid.

At the discretion of the depositary, all fees and charges owing under the deposit agreement are due in advance and/or when declared owing by the 

depositary.

74

ITEM 13. DEFAULTS, DIVIDEND ARREARAGES AND DELINQUENCIES

Not Applicable.

PART II

ITEM 14. MATERIAL MODIFICATIONS TO THE RIGHTS OF SECURITY HOLDERS AND USE OF PROCEEDS

Not Applicable.

ITEM 15. CONTROLS AND PROCEDURES

(a)

Disclosure Controls and Procedures

Under the supervision and with the participation of our management, including our principal executive officer and our principal financial officer, we 
conducted an evaluation of our disclosure controls and procedures, as such term is defined under Rule 13a-15(e) promulgated under the Securities Exchange 
Act of 1934, as amended.  Our principal executive officer and principal financial officer have concluded that our disclosure controls and procedures were not 
effective as of the end of the period covered by this annual report. This conclusion was based on the material weakness in our internal control over financial 
reporting further described below.

(b)

Management’s Report on Internal Control Over Financial Reporting

Our management is responsible for establishing and maintaining adequate internal control over financial reporting, as such item is defined in Rules 
13a-15(f)  and  15d-15(f)  under  the  Exchange  Act,  for  our  company.  Internal  control  over  financial  reporting  is  a  process  designed  to  provide  reasonable 
assurance regarding the reliability of financial reporting and the preparation of consolidated financial statements in accordance with U.S. GAAP and includes 
those  policies  and  procedures  that  (1)  pertain  to  the  maintenance  of  records  that,  in  reasonable  detail,  accurately  and  fairly  reflect  the  transactions  and 
dispositions of a company’s assets, (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of consolidated financial 
statements in accordance with generally accepted accounting principles, and that a company’s receipts and expenditures are being made only in accordance 
with authorizations of a company’s management and directors, and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized 
acquisition, use, or disposition of a company’s assets that could have a material effect on the consolidated financial statements.

Because of its inherent limitations, internal control over financial reporting is not intended to provide absolute assurance that a misstatement of our 
financial statements would be prevented or detected. Also, projections of any evaluation of effectiveness to future periods are subject to the risks that controls 
may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Our management has conducted an assessment, including testing of the design and the effectiveness of our internal control over financial reporting as 
of  December  31,  2018.  In  making  its  assessment,  management  used  the  criteria  in  Internal  Control  —  Integrated  Framework  issued  by  the  Committee  of 
Sponsoring Organizations of the Treadway Commission (COSO) in Internal Control — Integrated Framework (2013).

A  material  weakness  is  a  deficiency,  or  a  combination  of  deficiencies,  in  internal  control  over  financial  reporting,  such  that there  is  a  reasonable 
possibility that a material misstatement of our annual or interim consolidated financial statements will not be prevented or detected and corrected on a timely 
basis.

The Company identified deficiencies related to corporate governance, management’s application of disclosure requirements for SEC reporting and 

documentation of our financial statement reporting process. Such deficiencies are common for companies of our size. 

75

The Company identified deficiencies related to management’s application of disclosure requirements for SEC reporting and documentation of our 
financial statement reporting process. Although our accounting staff employees are professional and experienced in accounting requirements and procedures 
generally accepted in the PRC, management has determined that they require additional training and assistance in U.S. GAAP methods and SEC reporting. 
Our  management’s  assessment  of  the  control  deficiency  over  accounting  and  finance  personnel  as  of  December  31,  2018  considered  the  below  factors, 
including:

●       the number of adjustments proposed by our independent auditors during our quarterly review and annual audit processes;

●       how adequately we complied with U.S. GAAP on transactions; and

●       how accurately we prepared supporting information to provide to our independent auditors on a quarterly and annual basis.

Based on this assessment, management concluded that our internal controls over financial reporting were not effective as of December 31, 2018 due 
to  the  material  weakness  related  to  management’s  application  of  disclosure  requirements  for  SEC  reporting  and  documentation  of  our  financial  statement 
reporting process.

(c)

Attestation Report of Independent Registered Public Accounting Firm

We are a non-accelerated filer under the rules of the Securities and Exchange Commission. Accordingly, we are not required to include in this annual 

report an attestation report of our independent registered public accounting firm.

(d)

Changes in Internal Control over Financial Reporting

There were no changes in our internal controls over financial reporting during our fiscal year ended December 31, 2018 that have materially affected, 

or are reasonably likely to materially affect, our internal control over financial reporting.

(e)

Remediation Initiatives

For  2019,  we  have  prepared  a  preliminary  remediation  plan  to  address  the  underlying  causes  of  the  material  weakness  described  above.  The 

preliminary remediation plan includes:

(cid:120)

Reassessing the design and operation of internal controls over financial reporting, including interim and annual accruals cutoff procedures and review 
procedures related to information received from our outside consulting technical experts;

(cid:120) Hiring and training of permanent accounting personnel to further educate the staff on U.S. GAAP methods and SEC reporting matters;
(cid:120)

Increasing staffing levels and expertise to implement this remediation plan.

Our management, including our Chief Executive Officer and our Chief Financial Officer, does not expect that our disclosure controls and procedures 
or our internal controls will prevent or detect 100% of all errors and fraud that may occur. A control system, no matter how well conceived and operated, can 
provide only reasonable, not absolute, assurance that the objectives of the control system are met. Further, the design of a control system must reflect the fact 
that there are resource constraints and the benefits of controls must be considered relative to their costs. Due to the inherent limitations in all control systems, 
no evaluation of controls can provide absolute assurance that all control issues and instances of fraud, if any, within our company have been detected.

76

Material Weakness Previously Identified for the year ended December 31, 2017

As previously reported in our annual report on Form 20-F for the year ended December 31, 2017, management concluded that, as of such date, our 
disclosure  controls  and  procedures  were  not  effective  due  to  the  existence  of  deficiencies  in  the  design  and  operating  effectiveness  of  an  internal  control 
related  to  management’s  application  of  disclosure  requirements  for  SEC  reporting  and  documentation  of  our  financial  statement  reporting  process.  In 
connection with the audit of our financial statements as of and for the year ended December 31, 2017, we did not adequately and timely review the reporting 
and documentation. Management has concluded that there was a deficiency in the design of reporting and documentation controls and the management review 
controls were not designed with appropriate levels of precision and were not undertaken in a timely manner, which resulted in an extension to file our Annual 
Report on Form 20-F.

Remediation of Material Weakness for the year ended December 31, 2017

During  fiscal  2018,  management  implemented  a  number  of  actions  to  remediate  the  prior  deficiencies  and  strengthen  our  internal  control  and 

compliance environment, including the following:

(cid:120)

(cid:120)

(cid:120)

(cid:120)

(cid:120)
(cid:120)

reviewed documented policies, procedures and controls related to the key processes we use to identify material information, prepare regulatory filings and 
other public documents, and communicate information to external parties to ensure they are complete and effective;
reviewed  documented  controls  and  procedures  to  ensure  they  are  properly  implemented  and  effective  to  enhance  the  overall  completeness,  accuracy, 
consistency and timeliness of our disclosures;
identified and assessed key risks that may impact our ability to disclose material information and prepare regulatory filings that are complete, accurate, 
consistent and timely;
enhanced  open  and candid communication between  all parties involved  in  operations,  governance and financial  and  regulatory reporting,  and  a strong 
control and governance environment;
created positions and allocate sufficient resources to achieve an effective disclosure controls and procedures; and
established direct reporting procedures from the Chief Accounting Officer to the Chief Financial Officer to ensure a better overview of the Company’s 
financial reporting system by the CFO.

ITEM 16. RESERVED

ITEM 16A. AUDIT COMMITTEE FINANCIAL EXPERT

Our audit committee consists of Junhong Li, Yingli Pan and Xiaobing Liu. Our board of directors has determined that Junhong Li, Yingli Pan and 
Xiaobing Liu are “independent directors” within the meaning of NASDAQ Stock Market Rule 5605(a)(2) and meet the criteria for independence set forth in 
Rule 10A−3(b) of the Exchange Act. Junhong Li meets the criteria of an audit committee financial expert as set forth under the applicable rules of the SEC.

ITEM 16B. CODE OF ETHICS

Our  board  of  directors  has  adopted  a  code  of  business  conduct  and  ethics.  The  purpose  of  the  code  is  to  promote  ethical  conduct  and  deter 
wrongdoing. The policies outlined in the Code are designed to ensure that our directors, executive officers and employees act in accordance with not only the 
letter but also the spirit of the laws and regulations that apply to our business. We expect our directors, executive officers and employees to exercise good 
judgment, to uphold these standards in their day-to-day activities, and to comply with all applicable policies and procedures in the course of their relationship 
with  the  company.  Any  amendment  to  or  waivers  of  the  Code  for  members  of  our  board  of  directors  and  our  executive  officers  that  are  required  to  be 
disclosed by the rules of the SEC or NASDAQ will be disclosed on our website at http://www.osseninnovation.com within four business days following the 
amendment or waiver. During fiscal year 2016, no amendments to or waivers from the Code were made or given for any of our executive officers.

77

Our code of business conduct and ethics are publicly available on our website at http://www.osseninnovation.com.

ITEM 16C. PRINCIPAL ACCOUNTANT FEES AND SERVICES

Year Ended
December 31, 2017

Year Ended
December 31, 2018

Audit fees*

$

220,000 $

130,000

*Audit Fees – This category includes the audit of our annual financial statements, review of financial statements included in our quarterly reports and services 
that are normally provided by the independent registered public accounting firm in connection with engagements for those years and services that are normally 
provided by our independent registered public accounting firm in connection with statutory audits and Securities and Exchange Commission regulatory filings 
or engagements.

The policy of our audit committee and our board of directors is to pre-approve all audit and non-audit services provided by our principal auditors, including 
audit  services,  audit-related  services,  and  other  services  as  described  above,  other  than  those  for  de  minimis  services  which  are  approved  by  the  audit 
committee or our board of directors prior to the completion of the services.

ITEM 16D. EXEMPTIONS FROM THE LISTING STANDARDS FOR AUDIT COMMITTEES

Not Applicable.

ITEM 16E. PURCHASES OF EQUITY SECURITIES BY THE ISSUER AND AFFILIATED PURCHASERS

On May 6, 2015, we announced a share repurchase program for up to a total of 500,000 shares of our ADS’s through May 2016 in accordance with 
applicable requirements of Rule 10b5-1 and/or Rule 10b-18 under the U.S. Securities Exchange Act of 1934, as amended. On April 28, 2016, we announced 
that our Board of Directors authorized the extension of its repurchase plan of up to 166,667 shares of the Company's ADSs for an additional twelve months 
to May 2017. In the fiscal years ended December 31, 2017 and 2018, no shares of our ADS’s have been purchased under the repurchase program.

ITEM 16F. CHANGE IN REGISTRANT’S CERTIFYING ACCOUNTANT

None.

ITEM 16G. CORPORATE GOVERNANCE

Our  ADSs  are  listed  on  the  NASDAQ  Capital  Market,  or  NASDAQ.  As  such,  we  are  subject  to  corporate  governance  requirements  imposed  by 
NASDAQ. Under NASDAQ rules, listed non-US companies such as ourselves may, in general, follow their home country corporate governance practices in 
lieu  of  some  of  the  NASDAQ  corporate  governance  requirements.  A  NASDAQ  -listed  non-US  company  is  required  to  provide  a  general  summary  of  the 
significant differences to its US investors either on the company website or in its annual report distributed to its US investors. We are committed to a high 
standard of corporate governance. As such, we endeavor to comply with the NASDAQ corporate governance practices and there is no significant difference 
between our corporate governance practices and what the NASDAQ requires of domestic U.S. companies.

ITEM 16H. MINE SAFETY DISCLOSURE

Not applicable.

78

ITEM 17.

FINANCIAL STATEMENTS

Not applicable.

ITEM 18.

FINANCIAL STATEMENTS

PART III

The consolidated financial statements and related notes required by this item are contained on pages F-1 through F-44.

ITEM 19. EXHIBITS

Exhibit
Number

Description of Documents

1.1

1.2

2.1

2.2

2.3

4.1

4.2

8.1

12.1

13.1

101

Amended and Restated Memorandum of Association (1)

Amended and Restated Articles of Association (1)

Form of American Depositary Receipt (included in Exhibit 2.3)

Form of Amended and Restated Ordinary Share Certificate (1)

Form of Deposit Agreement (3)

Share  Exchange  Agreement  between  Ultra  Glory  International  Ltd.,  the  shareholder  of  Ultra  Glory  International  Ltd.,  Ossen  Innovation 
Materials Group Co., Ltd. and the Shareholders of Ossen Innovation Materials Group Co., Ltd., dated July 7, 2010 (2)

Employment Contract by and between Ossen Innovation Co., Ltd. and Liang Tang, dated January 1, 2014 (4)

Subsidiaries of the Registrant*

CEO and CFO Certification pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 *

CEO and CFO Certification pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 **

Interactive Data File (XBRL).*

*
Filed as an exhibit hereto.
** Furnished as an exhibit hereto.

(1) Incorporated by reference to our Registration Statement on Form F-1/A, filed on September 29, 2010.
(2) Incorporated by reference to our Shell Company Report on Form 20-F, filed on July 12, 2010.
(3) Incorporated by reference to Post-Effective Amendment No. 1 to our Registration Statement on Form F-6, filed on August 11, 2016.
(4) Incorporated by reference to our Annual Report on Form 20-F, filed on April 29, 2014.

79

The registrant hereby certifies that it meets all of the requirements for filing on Form 20-F and that it has duly caused and authorized the undersigned 

to sign this annual report on its behalf.

SIGNATURES

OSSEN INNOVATION CO., LTD.

/s/ Wei Hua

Name:   Wei Hua
Title: Chief Executive Officer and Chief Financial Officer

Date: May 14, 2019

80

OSSEN INNOVATION CO., LTD. 

AND SUBSIDIARIES

CONSOLIDATED FINANCIAL STATEMENTS

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES

CONTENTS

PAGE

F-1

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM FOR THE YEAR ENDED 
DECEMBER 31, 2018 AND 2017

PAGE

F-2-F-3

CONSOLIDATED BALANCE SHEETS AS OF DECEMBER 31, 2018 AND 2017

PAGE

PAGE

F-4

F-5

CONSOLIDATED STATEMENTS OF OPERATIONS AND COMPREHENSIVE INCOME FOR THE YEARS 
ENDED DECEMBER 31, 2018, 2017 AND 2016

CONSOLIDATED STATEMENTS OF CHANGES IN SHAREHOLDERS’ EQUITY FOR THE YEARS ENDED 
DECEMBER 31, 2018, 2017 AND 2016

PAGE

F-6-F-7

CONSOLIDATED STATEMENTS OF CASH FLOWS FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 
AND 2016

PAGE

F-8 –F- 41

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

PAGE

F-42 –F- 44

SCHEDULE I — CONDENSED PARENT COMPANY FINANCIAL INFORMATION FOR THE YEARS ENDED 
DECEMBER 31, 2018, 2017, AND 2016

REPORT OF INDEPENDENT REGISTERED PUBLIC ACOUNTING FIRM

Board of Directors and Shareholders
Ossen Innovation Co., Ltd.
Shanghai, China

We have audited the accompanying consolidated balance sheets of Ossen Innovation Co., Ltd. as of December 31, 2018 and 2017 and the related consolidated 
statements of operations and other comprehensive income, shareholders’ equity, and cash flows for each of the three years in the period ended December 31, 
2018.  In  connection  with  our  audits  of  the  financial  statements,  we  have  also  audited  the  financial  statement  schedules  listed  in  the  accompanying  index. 
These financial statements and schedules are the responsibility of the Company’s management. Our responsibility is to express an opinion on these financial 
statements based on our audit.

We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that 
we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. The Company is not 
required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. Our audit included consideration of internal control 
over financial reporting as a basis for designing audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on 
the effectiveness of the Company’s internal control over financial reporting. Accordingly, we express no such opinion. An audit also includes examining, on a 
test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made 
by management, as well as evaluating the overall financial statement presentation. We believe that our audits provide a reasonable basis for our opinion.

In our opinion, the consolidated financial statements referred to above present fairly, in all material respects, the financial position of Ossen Innovation Co., 
Ltd. as of December 31, 2018 and 2017 and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2018 
in conformity with accounting principles generally accepted in the United States of America.

Also, in our opinion, the financial statement schedules, when considered in relation to the basic consolidated financial statements taken as a whole, present 
fairly, in all material respects, the information set forth therein.

/s/ BDO China Shu Lun Pan Certified Public Accountants LLP

Shanghai, People’s Republic of China
We have served as the Company's auditor since 2015.

May 14, 2019

F-1

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
CONSOLIDATED BALANCE SHEETS AS OF DECEMBER 31, 2018 AND 2017

ASSETS
Current assets
Cash and cash equivalents
Restricted cash
Accounts receivable, net of allowance for doubtful accounts of $939,535 and $868,973 at December 31, 2018 and 
2017, respectively
Inventories
Advance to suppliers
Other current assets

Total current assets

Property, plant and equipment, net
Land use rights, net
Deferred tax assets
TOTAL ASSETS

December 31,

2018

2017

$

3,444,421
4,070,655

$

950,225
7,192,928

60,586,869
17,177,926
69,986,656
26,496
155,293,023
3,371,387
3,422,365
159,136
162,245,911

$

51,699,930
13,479,473
71,280,903
37,390
144,640,849
4,031,534
3,697,012
149,511
152,518,906

$

See accompanying notes to the consolidated financial statements

F-2

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
CONSOLIDATED BALANCE SHEETS AS OF DECEMBER 31, 2018 AND 2017 (Continued)

Current Liabilities
Notes payable-bank acceptance notes
Short-term bank loans
Accounts payables
Customer deposits
Taxes payable
Other payables and accrued liabilities
Customer deposits – related parties
Due to shareholder
Long-term bank loans – current portion

Total current liabilities

Long-term bank loans
TOTAL LIABILITIES

EQUITY
Shareholders' Equity
Ordinary shares, $0.01 par value: 100,000,000 shares authorized; 20,000,000 shares issued; 19,791,110 shares 
outstanding as both of December 31, 2018 and 2017
Additional paid-in capital
Statutory reserve
Retained earnings
Treasury stock, at cost: 208,890 shares as both of December 31, 2018 and 2017
Accumulated other comprehensive income/(loss)
TOTAL SHAREHOLDERS’ EQUITY
Non-controlling interest
TOTAL EQUITY

December 31,

2018

2017

$

$

8,722,832
13,593,080
289,954
283,869
1,547,882
3,980,565
4,800,384
1,695,259
7,269,027
42,182,852
-
42,182,852

10,253,742
13,947,385
359,927
316,394
450,711
4,236,823
-
351,499
-
29,916,481
7,652,046
37,568,527

200,000
33,971,455
7,764,813
68,673,562
(192,153)
(4,044,969)
106,372,708
13,690,351
120,063,059

200,000
33,971,455
6,672,254
59,386,668
(192,153)
2,227,334
102,265,558
12,684,821
114,950,379

TOTAL LIABILITIES AND SHAREHOLDERS’ EQUITY

$

162,245,911

$

152,518,906

See accompanying notes to the consolidated financial statements

F-3

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF OPERATIONS AND COMPREHENSIVE INCOME FOR THE YEARS ENDED DECEMBER 31, 2018, 
2017 AND 2016

REVEUNUES
COST OF GOODS SOLD
GROSS PROFIT
Selling expenses
General and administrative expenses

Total Operating Expenses

INCOME FROM OPERATIONS
Financial expenses, net
Other income, net
INCOME BEFORE INCOME TAX
INCOME TAX
NET INCOME
LESS: NET INCOME ATTRIBUTABLE TO NONCONTROLLING INTEREST
NET INCOME ATTRIBUTABLE TO OSSEN INNOVATION CO.,LTD 
AND SUBSIDIARIES

OTHER COMPREHENSIVE INCOME (LOSS)
Foreign currency translation gain (loss)
TOTAL OTHER COMPREHENSIVE INCOME (LOSS)
COMPREHENSIVE INCOME/(LOSS)

EARNINGS PER ORDINARY SHARE

Basic and diluted

WEIGHTED AVERAGE ORDINARY SHARES OUTSTANDING

Basic and diluted

Year Ended December 31,
2017

2016

2018

$

136,104,867
115,585,803
20,519,064
327,365
5,263,914
5,591,279

$

132,375,915
117,721,799
14,654,116
598,832
6,002,121
6,600,953

117,029,154
100,932,528
16,096,626
734,159
6,376,383
7,110,542

14,927,785
(1,621,486)
208,071
13,514,370
(2,129,387)
11,384,983
1,005,530

8,053,163
(1,610,337)
147,108
6,589,934
(691,556)
5,898,378
553,067

8,986,084
(2,827,138)
90,584
6,249,530
(926,048)
5,323,482
499,509

10,379,453

5,345,311

4,823,973

(6,272,303)
(6,272,303)
4,107,150

$

6,606,207
6,606,207
11,951,518

$

(6,975,100)
(6,975,100)
(2,151,127)

0.52

$

0.27

$

0.24

19,791,110

19,791,110

19,804,164

$

$

$

See accompanying notes to the consolidated financial statements

F-4

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF SHAREHOLDER’S EQUITY
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

Ordinary Shares
$0.01 Par Value

Shares
20,000,000
-
-
-

Amount
200,000
-
-
-

Additional 
Paid-in
Capital
33,971,455
-
-
-

-
20,000,000
-
-

-
$ 200,000
-
-

-
$ 33,971,455
-
-

-
20,000,000
-
-

-
$ 200,000
-
-

-
$ 33,971,455
-
-

-
20,000,000

-
$ 200,000

-
$ 33,971,455

Total Ossen Innovation Co., Ltd. Shareholders’ Equity

Treasury stock

Shares
(171,210)
-
-
(37,680)

Amount
(155,343)
-
-
(36,810)

Accumulated
Other
Comprehensive
Income/(loss)

2,596,227
-
-
-

Statutory
Reserve
5,631,373
-
491,649
-

Retained
 Earnings
50,258,265
4,823,973
(491,649)
-

Non 
Controlling
Interest
11,632,245
499,509

-

-

(208,890) $ (192,153) $

-
-

-

-
-

-

(208,890) $ (192,153) $

-
-

-

-
-

-

(208,890) $ (192,153) $

(6,975,100)
-
(4,378,873) $ 6,123,022
-
549,232

-
-

-
$ 54,590,589
5,345,311
(549,232)

$ 12,131,754
553,067

6,606,207
2,227,334
-
-

-
$ 6,672,254
-
1,092,559

-
$ 59,386,668
10,379,453
(1,092,559)

$ 12,684,821
1,005,530

(6,272,303)
-
(4,044,969) $ 7,764,813

-
$ 68,673,562

$ 13,690,351

 Total
104,134,222
5,323,482
-
(36,810)

(6,975,100)
$ 102,445,794
5,898,378
-

6,606,207
$ 114,950,379
11,384,983
-

(6,272,303)
$ 120,063,059

Balance at January 1, 2016
Net income
Transfer to statutory reserve
Common shares repurchase
Foreign currency translation 
adjustment
Balance at December 31, 2016
Net income
Transfer to statutory reserve
Foreign currency translation 
adjustment
Balance at December 31, 2017
Net income
Transfer to statutory reserve
Foreign currency translation 
adjustment
Balance at December 31, 2018

See accompanying notes to the consolidated financial statements

F-5

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF CASH FLOWS 
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

CASH FLOWS FROM OPERATING ACTIVITIES:
Net income

Adjustments to reconcile net income to net cash provided by operating activities:
Depreciation and amortization

Changes in operating assets and liabilities:
(Increase) Decrease In:
Accounts receivable
Inventories
Advance to suppliers
Other current assets

Deferred tax assets

Notes receivable - bank acceptance notes

Increase (Decrease) In:
Accounts payable
Customer deposits
Income tax payable
Other payables and accrued expenses

Customer deposits - RPT

Due to related party
Due to shareholder

Net cash provided by/ (used in) operating activities

CASH FLOWS FROM INVESTING ACTIVITIES:

Purchases of plant and equipment
Net cash used in investing activities

Year Ended December 31,
2017

2016

2018

$

11,384,983

$

5,898,378

$

5,323,482

641,647

796,566

883,755

(8,886,939)
(3,698,453)
1,294,247
10,894
(9,625)
-

(69,973)
(32,524)
1,097,171
(256,258)
4,800,384
-
1,343,760
7,619,314

(14,401,465)
12,519,709
(24,551,618)
(6,023)
16,440
15,280,381

(1,144,936)
180,490
(144,084)
2,496,349
-
(3,912)
44,000
(3,019,725)

5,949,508
1,277,040
9,000,804
745,284
(27,562)
(7,270,152)

(394,537)
(173,243)
180,545
70,804
-
(61,883)
25,000
15,528,845

(72,305)
(72,305)

(37,848)
(37,848)

(17,537)
(17,537)

See accompanying notes to the consolidated financial statements

F-6

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF CASH FLOWS 
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016 (Continued)

CASH FLOWS FROM FINANCING ACTIVITIES:

Proceeds from short-term bank loans
Repayments of short-term bank loans
Proceeds from long-term bank loans
Proceeds from notes payable-bank acceptance notes
Repayment of notes payable-bank acceptance notes
Repurchase of common share
Repayments of bond payable

Net cash used in financing activities

INCREASE (DECREASE) IN CASH, CASH EQUIVALENTS, AND RESTRICTED 
CASH

Effect of exchange rate changes on cash, cash equivalents, and restricted cash
Cash, cash equivalents and restricted cash at beginning of period

CASH, CASH EQUIVALENTS AND RESTRICTED CASH AT END OF PERIOD

SUPPLEMENTARY CASH FLOW INFORMATION
Cash paid during the periods:

Income taxes paid
Interest paid

Non-cash transactions:
Appropriation to statutory reserve

Year Ended December 31,
2017

2016

2018

17,900,302
(17,543,051)
-
9,063,444
(10,120,846)
-
-
(700,151)

6,846,858
(7,474,935)
8,143,153
7,515,076

1,019,270
1,388,283

1,092,559

$

$
$

$

13,497,882
(17,380,550)
-
14,662,757
(14,588,702)
-
-
(3,808,613)

(6,866,186)
8,088,466
6,920,873
8,143,153

840,670
1,397,635

549,232

$

$
$

$

20,422,885
(20,068,975)
7,530,007
17,846,117
(20,029,819)
(36,810)
(15,273,177)
(9,609,772)

5,901,536
(8,573,383)
9,592,720
6,920,873

740,873
2,311,039

491,649

$

$
$

$

See accompanying notes to the consolidated financial statements

F-7

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 1 – ORGANIZATION AND PRINCIPAL ACTIVITIES

Ossen Innovation Co., Ltd., (“Ossen Innovation” or the “Company”) formerly known as Ultra Glory International, Ltd., or Ultra Glory, is a British Virgin 
Islands  limited  liability  company organized  on  January  21,  2010  under  the  BVI  Business  Companies Act,  2004 (the “BVI  Act”).  Ultra  Glory  was  a  blank 
check company formed for the purpose of acquiring, through a share exchange, asset acquisition or other similar business combination, an operating business.

Business Combination

On July 7, 2010, Ultra Glory and its sole shareholder entered into a share exchange agreement with Ossen Innovation Materials Group, Co., Ltd, or Ossen 
Innovation Group, a British Virgin Islands limited liability company organized on April 30, 2010 under the BVI Act and the shareholders of Ossen Innovation 
Group. Pursuant to the share exchange agreement, Ultra Glory acquired from the shareholders of Ossen Innovation Group all of the issued and outstanding 
shares  of  Ossen  Innovation  Group,  in  exchange  for  an  aggregate  of  10,000,000  newly  issued  ordinary  shares  issued  by  Ultra  Glory  to  the  shareholders  of 
Ossen  Innovation  Group.  In  addition,  the  sole  shareholder  of  Ultra  Glory  sold  all  of  the  5,000,000  ordinary  shares  of  Ultra  Glory  that  were  issued  and 
outstanding  prior  to  the  business  combination,  to  the  shareholders  of  Ossen  Innovation  Group  for  cash,  at  a  price  of  $0.03  per  share.  As  a  result,  the 
individuals and entities that owned shares of Ossen Innovation Group prior to the business combination acquired 100% of the equity of Ultra Glory, and Ultra 
Glory acquired 100% of the equity of Ossen Innovation Group. Ossen Innovation Group is now a wholly owned subsidiary of Ultra Glory. In conjunction 
with the business combination, Ultra Glory filed an amended charter, pursuant to which Ultra Glory changed its name to Ossen Innovation Co., Ltd., changed 
its fiscal year end to December 31 and increased its authorized shares to 100,000,000. Upon the consummation of the business combination, the company 
ceased  to  be  a  shell  company.  Ossen  Innovation,  together  with  its  subsidiaries,  is  referred  to  as  the  “Company,”  unless  specific  reference  is  made  to  a 
company or entity.

The effect of the share exchange and the share sale is such that effectively a reorganization of the entities has occurred for accounting purposes and is deemed 
to be a reverse acquisition.

F-8

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 1 – ORGANIZATION AND PRINCIPAL ACTIVITIES (CONTINUED)

The share exchange acquisition is accounted  for as a  “reverse  acquisition” since, immediately following  completion of the transaction, the shareholders of 
Ossen Innovation Group have had effective control of Ultra Glory. For accounting purposes, Ossen Innovation Group is deemed to be the accounting acquirer 
in the transaction and, consequently, the transaction is treated as a recapitalization of Ultra Glory, i.e., a capital transaction involving the issuance of shares by 
Ultra Glory for the shares of Ossen Innovation Group. Accordingly, the combined assets, liabilities and results of operations of Ossen Innovation Group and 
its subsidiaries, became the historical financial statements of Ultra Glory at the closing of the share exchange, and Ultra Glory’s assets (primarily cash and 
cash equivalents), liabilities and results of operations is consolidated with those of Ossen Innovation Group beginning on the share exchange date. No step-up 
in basis or intangible assets or goodwill is recorded in this transaction. As this transaction is being accounted for as a reverse acquisition, all direct costs of the 
transaction is charged to additional paid-in capital. All professional fees and other costs associated with transaction were expensed. The 15,000,000 shares of 
Ultra Glory, subsequent to the July 7, 2010 share exchange, are presented as if they are outstanding for all periods presented, as these are held 100% by the 
equity owners of Ossen Innovation Group as of the share exchange and the share sale.

The Company’s Shareholders

Dr.  Tang,  our  chairman,  owns  100%  of  the  shares  of  Effectual  Strength  Enterprises  Ltd.,  a  British  Virgin  Islands  company,  which  currently  owns 
approximately 60.0% of our outstanding ordinary shares. The spouse of our chief executive officer, Wei Hua, owns 100% of the shares of Fascinating Acme 
Development Ltd., which owns approximately 3.0% of our outstanding ordinary shares. The spouse of the chief executive officer of Ossen Material Research 
(formerly  Shanghai  ZFX),  which  is  an  affiliated  company  of  ours  that  supplies  us  with  raw  materials,  owns  100%  of  the  shares  of  Gross  Inspiration 
Development Ltd., which owns approximately 3.0% of our outstanding ordinary shares. In December 2011, 5 million shares were issued in our initial public 
offering. Currently we have approximately 30.2% of our ordinary shares, or 5,988,290 shares, trading on NASDAQ in the form of ADS’s. The holders of the 
remaining approximately 3.8% of our shares are investors that are residents of the PRC and are unaffiliated with Ossen. In August 2018, Fascinating Acme 
Development  Ltd  and  Gross  Inspiration  Development  Ltd  transferred  its  shares  to  Effectual  Strength  Enterprises  Ltd.  In  October  2018,  Effectual  Strength 
Enterprises Ltd transferred its shares to Acme Innovation Ltd, which owned by Dr. Tang.

F-9

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 1 – ORGANIZATION AND PRINCIPAL ACTIVITIES (CONTINUED)

The Company’s Subsidiaries

British Virgin Islands Companies

Ossen Innovation Group, the Company’s wholly owned subsidiary, is the sole shareholder of two holding companies organized in the British Virgin Islands: 
Ossen Group (Asia) Co., Ltd., or Ossen Asia, and Topchina Development Group Ltd., or Topchina. All of the equity of Ossen Asia and Topchina had been 
held  by  Dr.  Tang  since  inception.  In  May  2010,  Dr.  Tang  transferred  these  shares  to  Ossen  Innovation  Group  in  anticipation  of  the  public  listing  of  our 
Company’s shares in the United States.

Ossen  Asia  is  a  British  Virgin  Islands  limited  liability  company  organized  on  February  7,  2002.  Ossen  Asia  has  one  direct  operating  subsidiary  in  China, 
Ossen Innovation Materials Co. Ltd., or Ossen Materials. Ossen Asia owns 81% of the equity of Ossen Materials.

Topchina  is  a  British  Virgin  Islands  limited  liability  company  organized  on  November  3,  2004.  Ossen  Materials  and  Topchina  directly  own  an  operating 
subsidiary  in  China,  Ossen  (Jiujiang)  Steel  Wire  &  Cable  Co.,  Ltd.,  or  Ossen  Jiujiang.  Ossen  Materials  owns  20.46%  of  the  equity  of  Ossen  Jiujiang  and 
Topchina owns 79.54%.

Ossen Materials

Ossen Materials was formed in China on October 27, 2004 as a Sino-foreign joint venture limited liability company under the name Ossen (Maanshan) Steel 
Wire and Cable Co., Ltd. On May 8, 2008, Ossen Materials was restructured from a Sino-foreign joint venture limited liability company to a corporation. The 
name of the entity was changed at that time to Ossen Innovation Materials Co., Ltd.

Ossen Asia owns 81% of the equity of Ossen Materials. The remaining 19% is held in the aggregate by four Chinese entities, two of which are controlled by 
Chinese governmental entities, one of which is controlled by Zhonglu Co. Ltd., a company whose shares are listed on the Shanghai Stock Exchange, and one 
of which is controlled by Chinese citizens.

Through  Ossen  Materials,  the  Company  has  manufactured  and  sold  plain  surface  PC  strands,  galvanized  PC  steel  wires  and  PC  wires  in  the  Company’s 
Maanshan  City,  PRC,  facility  since  2004.  The  primary  products  manufactured  in  this  facility  are  the  Company’s  plain  surface  PC  strands.  The  primary 
markets for the products manufactured at the Company’s Maanshan facility are Anhui Province, Jiangsu Province, Zhejiang Province and Shanghai City, each 
in the PRC.

F-10

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 1 – ORGANIZATION AND PRINCIPAL ACTIVITIES (CONTINUED)

Ossen Jiujiang

On  April  6,  2005,  Shanghai  Ossen  Investment  Holdings  (Group)  Co.,  Ltd.,  or  Ossen  Shanghai,  acquired  a  portion  of  the  bankruptcy  assets  of  Jiujiang 
Tianlong Galvanized Prestressing Steel Strand LLC, including equipment, land use rights and inventory for approximately $2.9 million. Ossen Jiujiang was 
formed by Ossen Shanghai in the PRC as a Sino-Foreign joint venture limited liability company on April 13, 2005. Ossen Shanghai then transferred the newly 
acquired assets to Ossen Jiujiang. At its inception, Ossen Jiujiang was owned by two entities: 33.3% of its equity was held by Ossen Asia and 66.7% by Ossen 
Shanghai. In June 2005, Ossen Shanghai transferred its entire interest in Ossen Jiujiang to Topchina in exchange for approximately $2.9 million. In October 
2007, Topchina transferred 41.7% of the equity in Ossen Jiujiang to Ossen Asia for no consideration. On December 17, 2007, Ossen Asia transferred all of its 
shares in Ossen Jiujiang to Ossen Materials for no consideration. On December 27, 2010, the paid-in capital of Ossen Jiujiang increased from approximately 
$6,048,509  (RMB  50,000,000)  to  approximately  $26,048,509  (RMB  183,271,074)  and  was  injected  by  cash  of  approximately  $20,000,000  (RMB 
133,271,074) from its shareholder Topchina. Since then, 20.46% of the equity interest of Ossen Jiujiang has been held by Ossen Materials and 79.54% by 
Topchina. On April 9, 2014, Ossen (Jiujiang) Steel Wire & Cable Co., Ltd. changed its name to Ossen (Jiujiang) New Materials Co., Ltd.

Through Ossen Jiujiang, the company manufactures galvanized PC wires, plain surface PC strands, galvanized PC strands, unbonded PC strands, helical rib 
PC wires, sleeper PC wires and indented PC wires. The primary products manufactured in this facility are the company’s galvanized PC wires. The primary 
markets  for  the  PC  strands  manufactured  in  the  company’s  Jiujiang  facility  are  Jiangxi  Province,  Wuhan  Province,  Hunan  Province,  Fujian  Province  and 
Sichuan Province, each in the PRC.

F-11

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 1 – ORGANIZATION AND PRINCIPAL ACTIVITIES (CONTINUED)

At December 31, 2018, the subsidiaries of Ossen Innovation Co., Ltd were as follows:

Name

Domicile and Date 
of Incorporation

Paid-in Capital

Percentage 
of 
Effective Ownership

Principal 
Activities

Ossen Innovation Materials Group, Co., Ltd. (“Ossen Innovation 
Group”)

BVI
April 30, 2010

Ossen Group (Asia) Co., Ltd. ("Ossen Asia")

Topchina Development Group Ltd. ("Topchina")

Ossen Innovation Materials Co., Ltd. ("Ossen Meterials")

BVI
February 7, 2002

BVI
November 3, 2004

The PRC
October 27, 2004

USD

USD

USD

-

-

-

100% Investments holdings

100% Investments holdings

100% Investments holdings

RMB

75,000,000

Design, engineering, manufacture and sale 
of customized prestressed steel materials

81%

Ossen (Jiujiang) New Materials Co., Ltd. (Formerly Ossen (Jiujiang) 
Steel Wire & Cable Co., Ltd.) ("Ossen Jiujiang")

The PRC
April 13, 2005

RMB

183,271,074

96.11%

Design, engineering, manufacture and sale 
of customized prestressed steel materials

F-12

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Principles of Consolidation

The consolidated financial statements include the accounts of Ossen Innovation Co., Ltd. and its subsidiaries and have been prepared in accordance with U.S. 
generally accepted accounting principles ("U.S. GAAP"). Intercompany accounts and transactions have been eliminated upon consolidation.

Use of Estimates

The preparation of the consolidated and combined financial statements in conformity with generally accepted accounting principles in the United States of 
America requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets 
and  liabilities  at  the  date  of  the  consolidated  financial  statements  and  the  reported  amounts  of  revenues  and  expenses  during  the  reporting  periods. 
Management makes these estimates using the best information available at the time the estimates are made. Actual results could differ from those estimates.

Non-controlling Interest

Non-controlling interests in the Company’s subsidiaries are recorded in accordance with the provisions of Financial Accounting Standards Board (“FASB”) 
Accounting Standards Codification 810 Consolidation (“ASC 810”) and are reported as a component of equity, separate from the parent’s equity. Purchase or 
sale  of  equity  interests  that  do  not  result  in  a  change  of  control  are  accounted  for  as  equity  transactions.  Results  of  operations  attributable  to  the  non-
controlling interest are included in our consolidated results of operations and, upon loss of control, the interest sold, as well as interest retained, if any, will be 
reported at fair value with any gain or loss recognized in earnings.

F-13

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Foreign Currency Translation

The  accompanying  consolidated  financial  statements  are  presented  in  United  States  dollars  (“US$”  or  “$”).  The  functional  currency  of  the  Company  is 
Renminbi  (“RMB”).  The  consolidated  financial  statements  are translated  into  United States dollars  from  RMB at year-end  exchange rates as  to  assets  and 
liabilities  and  average  exchange  rates  as  to  revenues  and  expenses.  Capital  accounts  are  translated  at  their  historical  exchange  rates  when  the  capital 
transactions  occurred.  The  resulting  transaction  adjustments  are  recorded  as  a  component  of  shareholders’  equity.  Gains  and  losses  from  foreign  currency 
transactions are included in net income.

Year end RMB: US$ exchange rate
Average yearly RMB: US$ exchange rate

2018

2017

2016

6.8785
6.6200

6.5342
6.7518

6.9370
6.6401

The  RMB  is  not  freely  convertible  into  foreign  currency  and  all  foreign  exchange  transactions  must  take  place  through  authorized  institutions.  No 
representation is made that the RMB amounts could have been, or could be, converted into US$ at the rates used in translation.

Revenue Recognition

The Company adopted ASC Topic 606 Revenue from Contracts with Customers with a date of the initial application of January 1, 2018 using the modified 
retrospective method. As a result, the Company has changed its accounting policy for revenue recognition. The impact of the adoption of ASC Topic 606 on 
the Company’s consolidated financial statements is not material.

The Company recognizes revenue when goods or services are transferred to customers in an amount that reflects the consideration which it expects to receive 
in  exchange  for  those  goods  or  services.  In  determining  when  and  how  revenue  is  recognized  from  contracts  with  customers,  the  Company  performs  the 
following five-step analysis: (i) identification of contract with customer; (ii) determination of performance obligations; (iii) measurement of the transaction 
price;  (iv)  allocation  of  the  transaction  price  to  the  performance  obligations;  and  (v)  recognition  of  revenue  when  (or  as)  the  Company  satisfies  each 
performance obligation.

The Company derives revenues from the processing, distribution and sale of own products. The revenue is recognized at a point in time once the Company has 
determined  that  the  customer  has  obtained  control  over  the  product.  Control  is  typically  deemed  to  have  been  transferred  to  the  customer  when  the 
performance obligation is fulfilled, usually at the time of delivery, at the net sales price (transaction price). Revenue is recognized net of any taxes collected 
from customers, which are subsequently remitted to governmental authorities. Shipping and handling costs for product shipments occur prior to the customer 
obtaining  control  of  the  goods  are  accounted  for  as  fulfillment  costs  rather  than  separate  performance  obligations  and  recorded  as  sales  and  marketing 
expenses.

F-14

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

The Company’s contracts are predominantly short-term in nature with a contract term of one year or less. For those contracts, the Company has utilized the 
practical expedient in ASC Topic 606 exempting the Company from disclosure of the transaction price allocated to remaining performance obligations if the 
performance obligation is part of a contract that has an original expected duration of one year or less.

Receivables are recorded when the Company has an unconditional right to consideration.

Cost of Sales

Cost of revenue includes direct and indirect production costs, as well as freight in and handling costs for products sold.

Selling Expenses

Selling expenses include operating expenses such as sales commissions, payroll, traveling expenses, transportation expenses and advertising expenses.

General and Administrative (“G&A”) Expenses

General  and  administrative  expenses  include  management  and  office  salaries  and  employee  benefits,  deprecation  for  office  facility  and  office  equipment, 
travel and entertainment, legal and accounting, consulting fees and other office expenses.

Research and Development

Research and development costs are expensed as incurred and totaled approximately $3,345,097, $4,269,512 and $3,869,277 for the years ended December 
31, 2018, 2017 and 2016, respectively. Research and development costs are included in G&A in the accompanying statements of operations. Research and 
development costs are incurred on a project specific basis.

Retirement Benefits

Retirement benefits in the form of contributions under defined contribution retirement plans to the relevant authorities are charged to operations as incurred. 
Retirement benefits of $164,495, $173,637 and $160,656 were charged to operations for the years ended December 31, 2018, 2017 and 2016, respectively.

F-15

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Income Taxes

The Company accounts for income taxes following the liability method pursuant to FASB ASC 740 “Income Taxes”. Under this method, deferred tax assets 
and liabilities are determined based on the difference between the financial reporting and tax bases of assets and liabilities using enacted tax rates that will be 
in effect in the period in which the differences are expected to reverse. The Company records a valuation allowance to offset deferred tax assets if, based on 
the weight of available evidence, it is more-likely-than-not that some portion, or all, of the deferred tax assets will not be realized. The effect on deferred taxes 
of a change in tax rate is recognized in income in the period that includes the enactment date.

The Company  also follows FASB ASC 740, which addresses the  determination of whether tax benefits claimed or expected to  be  claimed on  a  tax return 
should be recorded in the financial statements. The Company may recognize the tax benefit from an uncertain tax position only if it is more likely than not that 
the tax position will be sustained on examination by the taxing authorities, based on the technical merits of the position. The tax benefits recognized in the 
financial statements from such a position should be measured based on the largest benefit that has a greater than fifty percent likelihood of being realized upon 
ultimate settlement. ASC 740 also provides guidance on recognition, classification, interest and penalties on income taxes, accounting in interim periods and 
requires increased disclosures. As of December 31, 2018, the Company did not have a liability for unrecognized tax benefits.

The Company has not provided for income taxes on accumulated earnings amounting $ 68,673,561 that are subject to the PRC dividend withholding tax as of 
December 31, 2018, since these earnings are intended to be permanently reinvested.

Value-Added Tax (“VAT”)

Enterprises or individuals, who sell commodities, engage in repair and maintenance or import or export goods in the PRC are subject to a value added tax in 
accordance with Chinese Laws. The VAT standard rate is reduced from 17% to 16% after May 2018. The VAT standard rate is 16% of the gross sale price. A 
credit is available whereby VAT paid on the purchases of semi-finished products or raw materials used in the production of the Company’s finished products 
can be used to offset the VAT due on the sales of the finished products.

F-16

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Statutory Reserve

In accordance with the PRC Regulations on Enterprises with Foreign Investment, an enterprise established in the PRC with foreign investment is required to 
provide for certain statutory reserves, namely (i) General Reserve Fund, (ii) Enterprise Expansion Fund and (iii) Staff Welfare and Bonus Fund, which are 
appropriated from net profit as reported in the enterprise’s PRC statutory accounts. A wholly-owned foreign enterprise (“WOFE”) is required to allocate at 
least 10% of its annual after-tax profit to the General Reserve Fund until the balance of such fund has reached 50% of its respective registered capital. A non-
wholly-owned  foreign  invested  enterprise  is  permitted  to  provide  for  the  above  allocation  at  the  discretion  of  its  board  of  directors.  Appropriations  to  the 
Enterprise  Expansion  Fund  and  Staff  Welfare  and  Bonus  Fund  are  at  the  discretion  of  the  board  of  directors  for  all  foreign  invested  enterprises.  The 
aforementioned reserves can only be used for specific purposes and are not distributable as cash dividends.

As  a result, $1,092,559, $549,232  and  $491,649  have  been  appropriated  to  the  accumulated statutory  reserves  by the Company’s PRC  subsidiaries for the 
years ended December 31, 2018, 2017 and 2016 respectively.

Comprehensive Income

Comprehensive  income  is  defined  as  the  change  in  equity  during  the  year  from  transactions  and  other  events,  excluding  the  changes  resulting  from 
investments by owners and distributions  to owners,  and is not included in the computation of income tax expense or benefit. Accumulated comprehensive 
income consists of foreign currency translation. The Company presents comprehensive income (loss) in accordance with ASC Topic 220, “Comprehensive 
Income”. ASC Topic 220 states that all items that are required to be recognized under accounting standards as components of comprehensive income (loss) be 
reported in the consolidated financial statements.

Cash and Cash Equivalents

For  financial  reporting  purposes,  the  Company  considers  all  highly liquid  investments  purchased  with  original  maturity  of  three  months  or  less  to  be  cash 
equivalents. The Company maintains no bank account in the United States of America. The Company maintains its bank accounts in Mainland China and 
Hong Kong. Balances at financial institutions or state-owned banks within the Mainland China are not covered by insurance. However, the Company has not 
experienced any losses in such accounts and believes it is not exposed to any significant risks on its cash in bank accounts. According to the rules of Hong 
Kong Deposit Protection Board, in case a member bank of Deposit Protection Scheme (“DPS”) fails, the DPS will pay compensation up to a maximum of 
HK$500,000 to each depositor of the failed Scheme member.

F-17

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Restricted Cash

Restricted cash represents amounts held by a bank as security for bank acceptance notes and therefore is not available for the Company’s use until such time 
as the bank acceptance notes have been fulfilled or expired, normally within twelve month period.

The Company adopted ASU 2016-18, “Statement of Cash Flows (Topic 230) - Restricted Cash” in the first quarter of 2018. When cash, cash equivalents, 
restricted cash and restricted cash equivalents are presented in more than one line item on the balance sheet, the new guidance requires a reconciliation of the 
totals in the statement of cash flows to the related captions in the balance sheet. This reconciliation can be presented either on the face of the statement of cash 
flows or in the notes to the financial statements. The following represents a reconciliation of cash and cash equivalents in the condensed consolidated balance 
sheet to total cash, cash equivalents and restricted cash in the condensed consolidated statement of cash flows:

Cash and cash equivalents
Restricted cash
Total cash, cash equivalents and restricted cash in the statement of cash flows

December 31,
2018
3,444,421
4,070,655
7,515,076

December 31,
2017

950,225
7,192,928
8,143,153

Certain  amounts  included  in  the  2017  and  2016  consolidated  statement  of  cash  flows  have  been  reclassified  to  conform  to  the  2018  financial  statement 
presentation as follows:

The Company has included restricted cash of $6,703,242 and $7,192,928, respectively, with cash and cash equivalents when reconciling the beginning-of-
period and end-of-period total amounts shown on the statement of cash flows for the year ended December 31, 2017. As a result, the total amount of cash, 
cash equivalents, and restricted cash at the beginning of the period on the statement of cash flows for the year ended December 31, 2017 has changed from 
$217,631 to $6,920,873; the total amount of cash, cash equivalents, and restricted cash at the end of the period on the statement of cash flows for the year 
ended December 31, 2017 has changed from $950,225 to $8,143,153.

The Company has included restricted cash of $8,780,443 and $6,703,242, respectively, with cash and cash equivalents when reconciling the beginning-of-
period and end-of-period total amounts shown on the statement of cash flows for the year ended December 31, 2016. As a result, the total amount of cash, 
cash equivalents, and restricted cash at the beginning of the period on the statement of cash flows for the year ended December 31, 2016 has changed from 
$812,277 to $9,592,720; the total amount of cash, cash equivalents, and restricted cash at the end of the period on the statement of cash flows for the year 
ended December 31, 2016 has changed from $217,631 to $6,920,873.

The  Company  has  eliminated  the  line  item of  restricted  cash  of $489,686  from  the  financing  activities  section  on  the  statement of  cash  flows  for  the  year 
ended December 31, 2017. As a result, net cash used in financing activities of $4,298,299 on the statement of cash flows for the year ended December 31, 
2017  has  changed  to  net  cash  used  in  financing  activities  of  $3,808,613.  Net  decrease  in  cash,  cash  equivalents  and  restricted  cash  of  $7,355,872  on  the 
statement of cash flows for the year ended December 31, 2017 has changed to net decrease in cash, cash equivalents and restricted cash of $6,866,186.

The Company has eliminated the line item of restricted cash of $2,077,201 from the financing activities section on the statement of cash flows for the year 
ended December 31, 2016. As a result, net cash used in financing activities of $7,532,571 on the statement of cash flows for the year ended December 31, 
2016  has  changed  to  net  cash  used  in  financing  activities  of  $9,609,772.  Net  increase  in  cash,  cash  equivalents  and  restricted  cash  of  $7,978,737  on  the 
statement of cash flows for the year ended December 31, 2016 has changed to net increase in cash, cash equivalents and restricted cash of $5,901,536.

F-18

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Fair Value of Financial Instruments

The Company applies the provisions of ASC 820, Fair Value Measurements and Disclosures, to the financial instruments that are required to be carried at fair 
value. Fair value is the price that would be received to sell an asset or paid to transfer a liability (an exit price) in the principal or most advantageous market 
for the asset or liability in an orderly transaction between market participants at the measurement date. The Company uses a three-tier fair value hierarchy 
based  upon  observable  and  non-observable  inputs  that  prioritizes  the  information  used  to  develop  our  assumptions  regarding  fair  value.  Fair  value 
measurements are separately disclosed by level within the fair value hierarchy.

• Level 1—defined as observable inputs such as quoted prices in active markets for identical assets or liabilities;

• Level 2—defined as inputs other than quoted prices in active markets, that are either directly or indirectly observable; and

• Level 3—defined as unobservable inputs in which little or no market data exists, therefore requiring an entity to develop its own assumptions.

The company’s financial instruments primarily consist of cash and cash equivalents, restricted cash, accounts receivable, notes receivable, accounts payable, 
other payables and accrued liabilities, short-term bank loans, and bond payable.

The carrying value of cash and cash equivalents, restricted cash, accounts receivable, accounts payable, and other current assets and liabilities approximate 
fair value because of the short term nature of these items. The estimated fair values of short-term bank loans were not materially different from their carrying 
value as presented due to the short maturities and that the interest rates on the borrowing approximate those that would have been available for loans of similar 
remaining maturity and risk profile. As the carrying amounts are reasonable estimates of the fair value, these financial instruments are classified within Level 
1 of the fair value hierarchy.

Earnings per share

The Company calculates earnings per share in accordance with ASC Topic 260, “Earnings per Share.” Basic earnings per share is computed by dividing the 
net income by the weighted average number of common shares outstanding during the period. Diluted earnings per share is computed similar to basic earnings 
per  share  except  that  the  denominator  is  increased  to  include  the  number  of  additional  common  shares  that  would  have  been  outstanding  if  the  potential 
ordinary shares equivalents had been issued and if the additional common shares were dilutive.

F-19

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Accounts Receivable

Accounts  receivable  are  carried  at  net  realizable  value.  The Company  reviews  its  accounts  receivables  on  a  periodic  basis  and  makes  general and  specific 
allowances when there is doubt as to the collectability of individual balances. In evaluating the collectability of individual receivable balances, the Company 
considers  many  factors,  including  the  age  of  the  balance,  customer’s  historical  payment  history,  its  current  credit-worthiness and  current  economic  trends. 
Accounts are written off after exhaustive efforts at collection. If accounts receivable are to be provided for, or written off, they would be recognized in the 
consolidated statement of operations within operating expenses. Balance of allowance of doubtful accounts was $939,535 and $868,973 at December 31, 2018 
and 2017, respectively.

Inventories

Inventories are stated at the lower of cost or net realizable value, which is based on estimated selling prices less any further costs expected to be incurred for 
completion and disposal. Cost of raw materials is calculated using the weighted average method and is based on purchase cost. Work-in-progress and finished 
goods  costs  are  determined  using  the  weighted  average  method  and  comprise  direct  materials,  direct  labor  and  an  appropriate  proportion  of  overhead.  At 
December 31, 2018 and 2017, the Company has $121,370 and $127,766 reserve for inventories, respectively.

Advance to Suppliers

Advance  to  Suppliers  represents  interest-free  cash  paid  in  advance  to  suppliers  for  purchases  of  raw  materials.  The  balance  of  advance  to  suppliers  was 
$69,986,656  and  $71,280,903  at  December  31,  2018  and  2017,  respectively.  Among  the  balance  of  $69,986,656,  the  aging  of  $36,913,322  was  within  60 
days, $25,541,361 was between 60-180 days and $7,531,973 was over 180 days. No allowance was provided for the prepayments balance at December 31, 
2018.

Customer Deposits and Customer Deposits – related parties

Customer  deposits  consist  of  amounts  paid  to  the  Company  in  advance  for  the  sale  of  products  in  the  PRC.  The  Company  receives  these  amounts  and 
recognizes them as a current liability until the revenue can be recognized when the goods are delivered. The balance of customer deposits was $ 283,869 and 
$316,394 at December 31, 2018 and 2017, respectively.

Customer deposits – related parties consist of amounts paid to the Company in advance for the sale of products in the PRC from related parties. The Company 
receives these amounts and recognizes them as a current liability until the revenue can be recognized when the goods are delivered. The balance of customer 
deposits – related parties was $ 4,800,384 and nil at December 31, 2018 and 2017, respectively.

F-20

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Property, Plant, and Equipment

Property, plant, and equipment are stated at cost less accumulated depreciation, and include expenditure that substantially increases the useful lives of existing 
assets.

Depreciation is provided over their estimated useful lives, using the straight-line method. Estimated useful lives are as follows:

Plant, buildings and improvements
Machinery and equipment
Motor vehicles
Office Equipment

5 ~ 20 years
5 ~ 20 years
5 years
5 ~ 10 years

When  assets  are  sold  or  retired,  their  costs  and  accumulated  depreciation  are  eliminated  from  the  consolidated  financial  statements  and  any  gain  or  loss 
resulting  from  their  disposal  is  recognized  in  the  period  of  disposition  as  an  element  of  other  income.  The  cost  of  maintenance  and  repairs  is  charged  to 
income as incurred, whereas significant renewals and betterments are capitalized.

Land Use Rights

According to the PRC laws, the government owns all the land in the PRC. Companies or individuals are authorized to possess and use the land only through 
land use rights granted by the Chinese government. The land use rights granted to the Company are being amortized using the straight-line method over the 
lease term of fifty years.

Impairment of Long-Lived Assets

Long-lived assets are evaluated for impairment periodically whenever events or changes in circumstances indicate that their related carrying amounts may not 
be recoverable in accordance with FASB ASC 360, “Property, Plant and Equipment”.

In evaluating  long-lived  assets  for  recoverability,  the Company  uses its  best  estimate  of  future  cash  flows expected to result from  the use  of the  asset  and 
eventual disposition in accordance with FASB ASC 360-10-15. To the extent that estimated future, undiscounted cash inflows attributable to the asset, less 
estimated  future,  undiscounted  cash  outflows,  are  less  than  the  carrying  amount,  an  impairment  loss  is  recognized  in  an  amount  equal  to  the  difference 
between the carrying value of such asset and its fair value. Assets to be disposed of and for which there is a committed plan of disposal, whether through sale 
or abandonment, are reported at the lower of carrying value or fair value less costs to sell.

No impairment loss is subsequently reversed even if facts and circumstances indicate recovery. There was no impairment loss recognized for the years ended 
December 31, 2018, 2017 and 2016.

F-21

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Segments and Related Information

ASC 280-10-50, “Operating Segments”, define the characteristics of an operating segment as a) being engaged in business activity from which it may earn 
revenue and incur expenses, b) being reviewed by the company's chief operating decision maker (CODM) for decisions about resources to be allocated and 
assess  its  performance  and  c)  having  discrete  financial  information.  Although  we  indeed  look  at  our  product  to  analyze  the  nature  of  our  revenue,  other 
financial  information,  such  as  certain  costs  and  expenses  and  net  income  are  not  captured  or  analyzed  by  these  categories.  Therefore  discrete  financial 
information is not available by product line and we have no CODM to make resource allocation decisions or assess the performance of the business based on 
these categories, but rather in the aggregate. Based on this, Management believes that it operates in one business segment.

In the analysis of product lines as potential operating segments, management also considered ASC 280-10-50-11, “Aggregation Criteria”, which allows for the 
aggregation of operating segments if the segments have similar economic characteristics and if the segments are similar in each of the following areas:

•The nature of the products and services;

•The nature of the production processes;

•The type or class of customer for their products and services;

•The methods used to distribute their products or provide their services; and

•The nature of the regulatory environment, if applicable.

We are engaged in the business of manufacturing and selling steel materials. Our manufacturing process is essentially the same for the entire Company and is 
performed in house at our facilities in China. Our customers primarily consist of entities in the steel industry. The distribution of our products is consistent 
across the entire Company. In addition, the economic characteristics of each customer arrangement are similar in that we maintain policies at the corporate 
level.

F-22

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Related Party

In general, related parties exist when there is a relationship that offers the potential for transactions at less than arm’s-length, favorable treatment, or the ability 
to influence the outcome of events different from that which might result in the absence of that relationship. A related party may be any of the followings: a) 
affiliate, a party that directly or indirectly controls, is controlled by, or is under common control with another party; b) principle owner, the owner of record or 
known beneficial owner of more than 10% of the voting interest of an entity; c) management, persons having responsibility for achieving objectives of the 
entity and requisite authority to make decision; d) immediate family of management or principal owners; e) a parent company and its subsidiaries; d) other 
parties that has ability to significant influence the management or operating policies of the entity.

FASB issued authoritative guidance that clarifies considerations relating to the consolidation of certain entities. The guidance requires identification of the 
Company’s participation in variable interest entities (“VIE”), which are defined as entities with a level of invested equity that is not sufficient to fund future 
activities to permit them to operation on a standalone basis, or whose equity holders lack certain characteristics of a controlling financial interest. That, for 
entities identified as a VIE, the guidance sets forth a model to evaluate potential consolidation based on a assessment of which party to a VIE, if any, bears a 
majority of the exposure to expected losses, or stand to gain from majority of its expected returns. The guidance also sets forth certain disclosure regarding 
interests  in  a  VIE  that  are  deemed  significant  even  if  consolidation  is  not  required.  This  item  is  discussed  in  further  detail  in  Note  9  –  Related  Party 
Transactions.

Economic and Political Risks

The Company’s operations are conducted in the PRC. Accordingly, the Company’s business, financial condition and results of operations may be influenced 
by the political, economic and legal environment in the PRC, and by the general state of the PRC economy.

The Company’s operations in the PRC are subject to special considerations and significant risks not typically associated with companies in North America and 
Western  Europe.  These  include  risks  associated  with,  among  others,  the  political,  economic  and  legal  environment  and  foreign  currency  exchange.  The 
Company’s  results  may  be  adversely  affected  by  changes  in  the  political  and  social  conditions  in  the  PRC,  and  by  changes  in  governmental  policies  with 
respect to laws and regulations, anti-inflationary measures, currency conversion, remittances abroad, and rates and methods of taxation, among other things.

Exchange Risk

The  Company  cannot  guarantee  that  the  current  exchange  rate  will  remain  steady,  therefore  there  is  a  possibility  that  the  Company  could  post  the  same 
amount of profit for two comparable periods and because of a fluctuating exchange rate actually post higher or lower profit depending on exchange rate of 
PRC  Renminbi  (RMB)  converted  to  U.S.  dollars  on  the  date.  The  exchange  rate  could  fluctuate  depending  on  changes  in  the  political  and  economic 
environments without notice.

F-23

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Recently adopted Accounting Pronouncements

In  May  2014,  the  FASB  issued  a  new  standard  on  revenue  recognition  related  to  contracts  with  customers.  This  standard  supersedes  nearly  all  existing 
revenue  recognition  guidance  and  involves  a  five-step  principles-based  approach  to  recognizing  revenue.  The  new  model  requires  revenue  recognition  to 
depict the transfer of promised goods or services to customers in an amount that reflects the consideration a company expects to receive. The new standard 
also  requires  additional  qualitative  and  quantitative  about  the  nature,  amount,  timing  and  uncertainty  of  revenue  and  cash  flows  arising  from  customer 
contracts,  including  significant judgments  made in applying  the revenue guidance,  and  assets  recognized  from  the  costs to obtain  or fulfill  a contract. The 
Company adopted this standard in the first quarter of 2018 using the modified retrospective approach. The impact of adoption on its Consolidated Financial 
Statements for any period presented is not material.

In November 2015, the FASB issued ASU 2015-17, “Balance Sheet Classification of Deferred Taxes.” This ASU amends existing guidance to require that 
deferred income tax assets and liabilities be classified as non-current in a classified balance sheet, and eliminates the prior guidance which required an entity 
to separate deferred tax assets and liabilities into a current amount and a non-current amount in a classified balance sheet. The Company adopted this standard 
prospectively in the first quarter of 2018. The impact of adoption on its Consolidated Financial Statements for any period presented is not material.

In  October  2016,  the  FASB  issued  ASU  2016-16,  Income  Taxes  (Topic  740):  Intra-Entity  Transfers  Other  than  Inventory,  which  requires  companies  to 
recognize the income-tax consequences of an intra-entity transfer of an asset other than inventory when the transfer occurs, rather than when the asset has 
been  sold  to  an  outside  party.  The  Company  adopted  this  standard  prospectively  in  the  first  quarter  of  2018.  The  impact  of  adoption  on  its  Consolidated 
Financial Statements for any period presented is not material.

In  November  2016,  the  FASB  issued  ASU  2016-18,  “Statement  of  Cash  Flows  (Topic  230)  -  Restricted  Cash,”  (“ASU  2016-18”).  This  ASU  requires  a 
statement of cash flows to explain the change during the period in the total of cash, cash equivalents, and amounts generally described as restricted cash or 
restricted cash equivalents. Amounts generally described as restricted cash and restricted cash equivalents should be included with cash and cash equivalents 
when reconciling the beginning-of-period and end-of-period total amounts shown on the statement of cash flows. The Company adopted this standard in the 
first quarter of 2018. The impact of adoption on its Consolidated Financial Statements for any period presented is not material.

In January 2017, the FASB issued ASU 2017-01, Business Combinations (Topic 805): Clarifying the Definition of a Business, which revises the definition of 
a  business  and  provides  new  guidance  in  evaluating  when  a  set  of  transferred  assets  and  activities  is  a  business.  The  Company  adopted  this  standard 
prospectively in the first quarter of 2018. The impact of adoption on its Consolidated Financial Statements for any period presented is not material.

Recently issued Accounting Pronouncements

In February 2016, the FASB issued ASU No. 2016-02 - Leases (Topic 842).  Under the new guidance, a lessee is required to recognize lease liabilities and 
corresponding right-of-use assets, initially measured at the present value of lease payments, on the balance sheet for operating leases with terms greater than 
one year.  Lessor accounting remains largely unchanged from existing lease accounting.  For leases with a term of 12 months or less, a lessee is permitted to 
make an accounting policy election not to recognize lease assets and lease liabilities.  If the lessee makes the election, the lessee would recognize lease 
expense on a straight-line basis over the lease term.  This ASU is effective in annual reporting periods beginning after December 15, 2018 and the interim 
periods within that fiscal year.  The Company is still evaluating the potential impacts that the implementation of ASU 2016-02 may have on its financial 
position, operational results, or cash flows 

In June 2016, the FASB issued ASU 2016-13,” Measurement of Credit Losses on Financial Instruments”, to require financial assets carried at amortized cost 
to be presented at the net amount expected to be collected based on historical experience, current conditions and forecasts. Subsequently, the FASB issued 
ASU No. 2018-19, Codification Improvements to Topic 326, to clarify that receivables arising from operating leases are within the scope of lease accounting 
standards. The ASUs are effective for interim and annual periods beginning after December 15, 2019, with early adoption permitted. Adoption of the ASUs is 
modified retrospective. We are currently obtaining an understanding of the ASUs and plan to adopt them on January 1, 2020.

F-24

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

In January 2017, the FASB  issued ASU No. 2017-04 (Topic 350) Intangibles—Goodwill  and Other: Simplifying the Test for Goodwill Impairment, which 
removes Step 2 of the goodwill impairment test, which requires a hypothetical purchase price allocation. Under the amended guidance, a goodwill impairment 
charge will now be recognized for the amount by which the carrying value of a reporting unit exceeds its fair value, not to exceed the carrying amount of 
goodwill.  This  ASU  will  be  applied  on  a  prospective  basis  and  is  effective  for  interim  and  annual  periods  beginning  after  December  15,  2019,  with  early 
adoption permitted for any impairment tests performed after January 1, 2017. The Company does not expect the adoption to have a material impact on the 
Consolidated Financial Statements.

In February 2018, the FASB released ASU 2018-2, “Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income.” This standard 
update  addresses  a  specific  consequence  of  the  Tax  Cuts  and  Jobs  Act  (“U.S.  tax  reform”)  and  allows  a  reclassification  from  accumulated  other 
comprehensive income to retained earnings for the stranded tax effects resulting from U.S. tax reform. Consequently, the update eliminates the stranded tax 
effects that were created as a result of the historical U.S. federal corporate income tax rate to the newly enacted U.S. federal corporate income tax rate. The 
Company is required to adopt this standard in the first quarter of fiscal year 2020, with early adoption permitted. The amendments in this update should be 
applied either in the period of adoption or retrospectively to each period in which the effect of the change in the U.S. federal corporate income tax rate in the 
Tax Cuts and Jobs Act is recognized. The Company has finished the evaluation and determined there is no impact of on its Consolidated Financial Statements.

F-25

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

In  June  2018,  the  FASB  issued  ASU  No.  2018-07  – Compensation  –  Stock  Compensation (Topic  718).  The  ASU  was  issued  as  part  of  its  Simplification 
Initiative  to  reduce  costs  and  complexities  of  financial  reporting.  ASU  No.  2018-07  simplifies  the  accounting  for  share-based  payments  granted  to 
nonemployees for goods and services.  Under the ASU, most of the guidance on such payments to nonemployees would be aligned with the requirements for 
share-based  payments  granted  to  employees.  Currently,  share-based  payments  transactions  to  nonemployees  are  measured  at  fair  value  and  remeasured  at 
each reporting date through the date of final vesting.  This ASU changes the guidance related to the determination of the measurement date.  Under the new 
guidance, equity-classified awards would be measured at the grant date.  This ASU is effective for fiscal years beginning after December 15, 2018 including 
interim periods within those fiscal years.  Early adoption is permitted if financial statements have not yet been issued. The Company is currently evaluating 
the impact of adoption on the Consolidated Financial Statements.

In  August  2018,  the  FASB  issued  ASU  2018-13 Disclosure  Framework  —  Changes  to  the  Disclosure  Requirements  for  Fair  Value  Measurement, which 
eliminates, adds, and modifies certain disclosure requirements for fair value measurements under ASC 820. This ASU is to be applied on a prospective basis 
for certain modified or new disclosure requirements, and all other amendments in the standard are to be applied on a retrospective basis. The new standard is 
effective for interim and annual periods beginning after December 15, 2019, with early adoption permitted. The Company is currently evaluating the impact of 
adoption on the Consolidated Financial Statements.

F-26

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 3 – CONCENTRATION

Concentration of major customers and suppliers:

Major customers with revenues of more than 10% of the 

Company’s sales

Company A (3rd Party)
Company B (3rd Party)
Company C (3rd Party)
Company D (3rd Party)
Company E (3rd Party)
Company F (3rd Party)
Company G (3rd Party)
Total Revenues

2018

Year ended December 31,
2017

2016

$

-
-
18,566,897

19,131,793
19,845,886
13,832,333
$71,376,909

-
-

$40,312,341
-
14% 13,822,962
-
14%
-
15% 14,511,302
10%
-
53% $68,646,605

-
10%
-
-
11%
-

30% $51,033,356
11,802,981
-
11,962,597
-
-
-
51% $74,798,934

2018

2017

2016

Year ended December 31,

Major suppliers with purchases of more than 10% of the 
Company’s purchases

Company X (3rd Party)
Company Y (3rd Party)
Total Purchase

$ 93,832,471
30,583,589
$124,416,060

75% $ 82,189,241
24%
24,907,251
99% $107,096,492

76% 61,496,533
23% 31,553,260
99% $93,049,793

44%
10%
-
10%
-
-
-
64%

61%
31%
92%

Accounts  receivable  related  to  the  Company’s  major  customers  comprised  43%  and  37%  of  all  accounts  receivable  as  of  December  31,  2018  and  2017, 
respectively.

Accounts payable related to the Company’s major suppliers comprised nil and 4% of all accounts payable as of December 31, 2018 and 2017, respectively.

F-27

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 4 – ACCOUNTS RECEIVABLE

Accounts receivable is net of allowance for doubtful accounts.

Accounts receivable
Less: allowance for doubtful accounts
Accounts receivable, net

Changes in the allowance for doubtful accounts are as follows:

Beginning balance
Provision/(Reverse) for doubtful accounts
Ending balance

NOTE 5 – INVENTORIES

Raw materials
Work-in-progress
Finished goods
Less: reserve for inventories.
Inventories, net

F-28

December 31,

2018

2017

61,526,404
(939,535)
60,586,869

$

$

52,568,903
(868,973)
51,699,930

December 31,

2018

2017

868,973
70,562
939,535

$

$

985,990
(117,017)
868,973

December 31,

2018

2017

12,084,766
188,794
5,025,736
(121,370)
17,177,926

$

$

12,354,591
229,327
1,023,321
(127,766)
13,479,473

$

$

$

$

$

$

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 6 – OTHER CURRENT ASSETS

Other current assets consist of the following:

 Other receivables

NOTE 7 – PROPERTY, PLANT AND EQUIPMENT

Property, plant and equipment consist of the following:

At Cost:

Plant and buildings
Machinery and equipment
Motor vehicles
Office equipment

Less: Accumulated depreciation

Plant and buildings
Machinery and equipment
Motor vehicles
Office equipment

Construction- in-progress
Property, plant and equipment, net

December 31,

2018

2017

26,496
26,496

$
$

37,390
37,390

December 31,

2018

2017

3,885,849
14,047,271
344,226
120,678
18,398,024

(2,765,332)
(11,216,276)
(292,464)
(759,186)
(15,033,258)
6,621
3,371,387

$

$

4,090,603
14,743,997
340,271
126,298
19,301,169

(2,781,302)
(12,080,380)
(298,219)
(109,734)
(15,269,635)
-
4,031,534

$
$

$

$

Unrealized  foreign  exchange  translation  gain/(loss)  for  the  year  ended  December  31,  2018,  2017  and  2016  was  ($183,640),  $251,912  and  ($323,040), 
respectively, which has been included in other comprehensive income/(loss). Depreciation expense for the years ended December 31, 2018, 2017 and 2016 
was $548,553, $705,289 and $793,844, respectively. As of December 31, 2018 and 2017, a net book value of nil and $340,140, respectively, were used as 
collateral for the Company’s short-term bank loans.

F-29

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 8 – LAND USE RIGHTS

Land use rights consist of the following:

Cost of land use rights
Less: Accumulated amortization
Land use rights, net

December 31,

2018

2017

$

$

4,479,896
(1,057,531)
3,422,365

$

$

4,715,951
(1,018,939)
3,697,012

Unrealized  foreign  exchange  translation  gain/(loss)  for  the  year  ended  December  31,  2018,  2017  and  2016  was  ($181,553),  $217,105  and  ($247,088), 
respectively, which has been included in other comprehensive income/(loss). Amortization expense for the years ended December 31, 2018, 2017 and 2016 
was  $93,094,  $91,277  and  $89,911,  respectively.  As  of  December  31,  2018  and  2017,  a  net  book  value  of  nil  and  $2,357,834,  respectively,  were  used  as 
collateral for the Company’s long-term bank loans.

Amortization expense for the next five years and thereafter is as follows:

2019
2020
2021
2022
2023
Thereafter
Total

$

$

89,598
89,598
89,598
89,598
89,598
2,974,375
3,422,365

F-30

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 9 – RELATED PARTY TRANSACTIONS

(a) Names and Relationship of Related Parties:

Dr. Tang 
Shanghai Ossen Material Research Insititute Co., Ltd. (Formerly 
Shanghai Zhengfangxing Steel Co., Ltd.) (“Ossen Material Research”)
Shanghai Ossen Investment Co., Ltd. (“SOI”)
Shanghai Ossen Investment Holdings (Group) Co., Ltd. (“Ossen 
Shanghai) 
Shanghai Pujiang Cable Co., Ltd. (“Shanghai Pujiang”) 
Zhejiang Pujiang Cable Co., Ltd. (“Zhejiang Pujiang”)

(b) Summary of Balances with Related Parties:

Customer deposits – related parties
Shanghai Pujiang
Zhejiang Pujiang

Existing Relationship with the Company

Chairman and controlling shareholder of the Company
Under common control of Dr. Tang

Under common control of Dr. Tang
Under common control of Dr. Tang and Dr. Tang is the President

Subsidiary of Ossen Shanghai since September 2010
Subsidiary of Shanghai Pujiang since December 2010

December 31,

2018

2017

$
$
$

2,604,604
2,195,780
4,800,384

$
$
$

-
-
-

The balance of Customer deposits-related parties consist of amounts paid to the Company in advance from Shanghai Pujiang and Zhejiang Pujiang for the sale 
of products.

Due to shareholder:
Dr. Tang

December 31,

2018

2017

$
$

1,695,259
1,695,259

$
$

351,499
351,499

Dr. Tang is the chairman and controlling interest shareholder of the Company. From time to time, Dr. Tang paid operating expenses on behalf of the Company 
to assist with the Company’s cash needs for business purposes.

F-31

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 9 – RELATED PARTY TRANSACTIONS (CONTINUED)

(c) Summary of Related Party Transactions:

Ossen
Material
Research

Ossen
Shanghai

Shanghai
Pujiang 

Ossen Material Research provided guarantee together with Dr. Tang for the short-
term bank loans borrowed by the Company

$

$

$

Ossen Material Research provided guarantee together with Shanghai Pujiang and 
Dr. Tang for the short-term bank loans borrowed by the Company
Ossen Material Research provided guarantee together with Dr. Tang for the notes 
payable issued by the Company
The Company provided guarantee for the short-term bank loans borrowed by 
Ossen Material Research
Ossen Shanghai provided guarantee together with Dr. Tang for the short-term 
bank loans borrowed by the Company
The Company provided guarantee for the short-term bank loans borrowed by 
$
Ossen Shanghai
The Company provided guarantee for the notes payable issued by Ossen Shanghai $
Shanghai Pujiang provided guarantee and together with Dr. Tang for the short-
term bank loans borrowed by the Company
The Company provided guarantee for the short-term bank loans borrowed by 
Shanghai Pujiang
The Company provided guarantee for the notes payable issued by Shanghai 
Pujiang
The Company sold products to Shanghai Pujiang

$
$

$

$

$

F-32

2018

December 31,
2017

-

-

-

581,522

-
-

9,377,044

74,114,996

2,907,611
2,810,147

$

$

$

$

$

$
$

$

$
$

-

3,749,502

4,897,310

18,824,034

-

-
-

-

5,356,432

-
-

$

$

$

$

$

$
$

$

$
$

2016

1,297,391

-

-

70,635,721

-

28,542,598
2,162,318

-

59,824,131

7,207,727
-

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 9 – RELATED PARTY TRANSACTIONS (CONTINUED)

(c) Summary of Related Party Transactions (Continued):

Zhejiang
Pujiang

The Company provided guarantee for the notes payable issued by Zhejiang 
Pujiang

The Company sold products to Zhejiang Pujiang

2018

December 31,
2017

2016

$

$

-

2,945,584

$

$

25,426,525

-

$

$

-

-

In accordance with ASC 810-10, “Consolidation”, the Company first evaluated that none of the related parties met the scope exceptions as outlined in the 
guidance. The Company then had to determine if it hold any variable interest in the related parties. The Company determined to have a variable interest in 
Shanghai  Pujiang  because  the  Company  guarantees  $74,114,996  of  the  outstanding  short  term  debt.  Next,  the  Company  evaluated  if  Shanghai  Pujiang  is 
variable interest entities. Using both qualitative and quantitative analysis, the Company does not have the power to direct Shanghai Pujiang’s activities that 
significantly  impact  its  economic  performance  and  does  not  have  the  obligation  to  absorb  losses  or  the  right  to  receive  benefits  from  the  entity.  Thus,  the 
Company is not the primary beneficiary of Shanghai Pujiang. As a result, the Company determined Shanghai Pujiang was not variable interest entities that 
require consolidation as defined in ASC 810. The Company determined Dr. Tang to be the primary beneficiary of Shanghai Pujiang because Dr. Tang is most 
closely associated with the Shanghai Pujiang. Dr. Tang had the power to direct the activities of Shanghai Pujiang that most significantly impact its economic 
performance and has the obligation to absorb losses of Shanghai Pujiang that could potentially be significant or the right to receive benefits from the related 
parties that could potentially be significant.

The Company also evaluated the remaining related parties and affiliated entities under ASC 810 and because the Company does not guarantee the debt, the 
holders  of  the  equity  were  at  risk  and  therefore  determined  to  be  the  primary  beneficiary  and  these  entities  are  not  variable  interest  entities  that  require 
consolidation.

NOTE 10 – OTHER PAYABLES AND ACCRUED EXPENSES

Other payables and accrued expenses consist of the following:

Other taxes payable
Accrued payroll & welfare
Accrued expense & liability
Interest payable
Others

F-33

December 31,

2018
3,548,227
13,805
365,304
4,148
49,081
3,980,565

$

$

2017
2,845,393
33,977
1,283,660
15,747
58,046
4,236,823

$

$

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 11 – NOTES PAYABLE

Bank acceptance notes:

Due September 28, 2019
Due September 28, 2019
Due August 28, 2019
Due August 28, 2019
Due March 7, 2019, subsequently repaid on due date
Due March 6, 2019, subsequently repaid on due date
Due February 7,2019, subsequently repaid on due date
Due February 6,2019, subsequently repaid on due date
Due December 19, 2018, subsequently repaid on due date
Due October 13, 2018, subsequently repaid on due date
Due August 22, 2018, subsequently repaid on due date
Due August 22, 2018, subsequently repaid on due date
Due August 14, 2018, subsequently repaid on due date
Due June 27, 2018, subsequently repaid on due date
Total

December 31,

2018

2017

726,903
726,903
2,326,088
2,326,088
828,669
334,375
726,903
726,903
-
-
-
-
-
-
8,722,832

$

$

-
-
-

-
-
-
-
1,530,409
1,530,409
2,448,655
2,448,655
765,205
1,530,409
10,253,742

$

$

The interest-free notes payable, ranging from six months to one year from the date of issuance, are secured by $4,653,631 and $7,192,928 restricted cash, as of 
December 31, 2018 and 2017, respectively.

All the notes payable are subject to bank charges of 0.05% of the principal amount as commission on each loan transaction.

NOTE 12 – CONTRACT BALANCES

Contract liabilities primarily represent the Company’s obligation to transfer additional goods or services to a customer for which the Company has received 
consideration. The consideration received remains a contract liability until goods or services have been provided to the customer.

The following table provides information about contract liabilities from contracts with customers:

Customer deposits
Customer deposits – related parties

F-34

December 31,

2018

2017

$

$

283,869
4,800,384
5,084,253

$

$

316,394
-
316,394

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 13 – SHORT TERM BANK LOANS

Short-term loans are summarized as follows:

Due on December 18, 2019, guaranteed by Shanghai Pujiang

Due on October 9, 2019, guaranteed by Ma An Shan Pubang 

Financing guarantee co., Ltd, a 3rd party

Due on July 25, 2019, guaranteed by Ma An Shan Pubang 

Financing guarantee co., Ltd, a 3rd party

Due on July 23, 2019, guaranteed by Ma An Shan Pubang 

Financing guarantee co., Ltd, a 3rd party

Due on June 27, 2019, guaranteed by Shanghai Pujiang and Dr. 

Tang

Due on June 26, 2019, guaranteed by Shanghai Pujiang and Dr. 

Tang

Due on May 21, 2019, guaranteed by Shanghai Pujiang and Dr. 

Bank Name

Interest Rate
per Annum

December 31,

2018

2017

Agricultural Bank of China
(“ABC”) Jiu Long Branch
Anhui Commercial Bank
(“ACB”) Fei Cui Branch

5.8725% $

3,198,372

$

6.50%

581,521

ACB Fei Cui Branch

5.655%

1,090,354

ACB Fei Cui Branch

Bank SinoPac (China)

Bank SinoPac (China)

6.00%

1,235,735

5.22%

2,907,611

5.22%

2,907,611

Tang

ABC Jiu Long Branch

5.6971%

363,451

Due on March 6, 2019, guaranteed by Ossen Shanghai, Dr. Tang 
and Ma An Shan Pubang Financing guarantee co., Ltd, a 3rd 
party, subsequently repaid on due date

Due on January 27, 2019, guaranteed by Ma An Shan Pubang 
Financing guarantee co., Ltd, a 3rd party subsequently repaid 
on due date

Due on December 26, 2018, guaranteed by Ma An Shan Pubang 
Financing guarantee co., Ltd, a 3rd party, subsequently repaid 
on due date

Due on December 7, 2018, guaranteed by Dr. Tang, 

subsequently repaid on due date

Industrial Bank Ma An Shan Branch

5.22%

581,522

ACB Fei Cui Branch

6.00%

726,903

Postal Savings Bank of China
Ma An Shan Branch
China Construction Bank
(“CCB”) Jiu Jiang Branch

F-35

6.09%

5.4375%

-

-

1,224,327

2,448,655

-

-

-

-

-

-

-

-

-

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 13 – SHORT TERM BANK LOANS (CONTINUED)

Bank Name

Interest Rate
per Annum

December 31,

2018

2017

Due on December 6, 2018, guaranteed by Dr. Tang, 

subsequently repaid on due date

Due on December 5, 2018, guaranteed by Ossen Material 
Research and Dr. Tang, subsequently repaid on due date
Due on October 9, 2018, guaranteed by Ma An Shan Pubang 

Financing guarantee co., Ltd, a 3rd party, subsequently repaid 
on due date

Due on July 14, 2018, guaranteed by Ma An Shan Pubang 

Financing guarantee co., Ltd, a 3rd party, subsequently repaid 
on due date

Due on July 14, 2018, guaranteed by Ma An Shan Pubang 

Financing guarantee co., Ltd, a 3rd party, subsequently repaid 
on due date

Due on May 11, 2018, Collateral by Fixed assets subsequently 

repaid on due date

CCB Jiu Jiang Branch

ABC Jiu Long Branch

ACB Fei Cui Branch

ACB Fei Cui Branch

ACB Fei Cui Branch
Anhui Rural Commercial Bank
(“ARCB”) Ma An Shan Branch

Due on May 8, 2018, guaranteed by Ossen Material Research 

and Dr. Tang, subsequently repaid on due date

ABC Jiu Long Branch

Due on April 18, 2018, Collateral by Fixed assets subsequently 

repaid on due date

Due on March 3, 2018, Collateral by Fixed assets subsequently 

repaid on due date

Due on February 10, 2018, Collateral by Fixed assets 

subsequently repaid on due date

ARCB Ma An Shan Branch

ARCB Ma An Shan Branch

ARCB Ma An Shan Branch

F-36

5.4375%

5.8725%

6.00%

6.00%

6.00%

6.276%

5.65%

6.276%

6.276%

6.276%

-

-

-

-

-

-

-

-

-

-

765,205

3,366,900

612,164

1,530,409

918,246

250,222

382,602

156,102

374,950

127,024

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 13 – SHORT TERM BANK LOANS (CONTINUED)

Bank Name

Interest Rate
per Annum

December 31,

2018

2017

Due on January 7,2018, guaranteed by Ma An Shan Pubang 

Financing guarantee co., Ltd, a 3rd party, subsequently repaid 
on due date

Due on January 5, 2018, Collateral by Fixed assets subsequently 

repaid on due date

Total

ACB Hu Nan Road Branch

ARCB Ma An Shan Branch

All short term bank loans are obtained from local banks in China and are repayable within one year.

6.00%

6.276%

-

1,530,409

-
$ 13,593,080

260,170
$ 13,947,385

The  average  annual  interest  rate  of  the  short-term  bank  loans  was  5.71%  and  6.41%  as  of  December  31,  2018  and  2017,  respectively.  Interest  expense, 
included in the financial expenses in the statement of operations, was $897,840 $932,596 and $1,070,192 for the years ended December 31, 2018, 2017 and 
2016, respectively. The Company was in compliance of their financial covenants at December 31, 2018 and 2017, respectively.

NOTE 14 – LONG TERM BANK LOANS

Due on August 30, 2019, 
collateral by the Company’s LUR 
Less: current portion
Long term bank loans, net

Bank Name

Interest
Rate
per Annum

December 31,

2018

2017

Anhui Commercial Bank (“ACB”) Hui 
Tong Branch

8.00% $

$

7,269,027
7,269,027
-

$

$

7,652,046
-
7,652,046

Interest expense, included in the financial expenses in the statement of operations, was $612,622, $600,663 and $225,900 for the years ended December 31, 
2018, 2017 and 2016, respectively.

F-37

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 15 – EARNINGS PER SHARES

Basic  earnings  per  share  are  computed  by  dividing  income  attributable  to  holders  of  ordinary  shares  by  the  weighted  average  number  of  ordinary  shares 
outstanding during the period.

Diluted earnings per ordinary share reflects the potential dilution that could occur if securities or other contracts to issue ordinary shares were exercised or 
converted into ordinary shares.

The following table sets forth the computation of basic and diluted earnings per share for the periods indicated:

Net income attribute to the Company

Weighted average ordinary shares outstanding - basic and diluted

Basic and diluted earnings per share

NOTE 16 – INCOME TAX

BVI

2018

December 31,
2017

2016

$

$

10,379,453

$

5,345,311

$

4,823,973

19,791,110

19,791,110

19,804,164

0.52

$

0.27

$

0.24

Ossen Innovation Co., Ltd, Ossen Innovation Group, Ossen Asia and Topchina are registered in the British Virgin Island and are exempt from income tax.

The PRC

According to the relevant laws and regulations in the PRC, foreign invested enterprises established prior to January 1, 2008 are entitled to full exemption from 
income tax for two years beginning with the first year in which such enterprise is profitable and a 50% income tax reduction for the subsequent three years. 
Ossen Materials was entitled to an exemption during the two years ended December 31, 2006 and was subject to a 50% income tax reduction during the three 
years ended December 31, 2009. Starting from January 1, 2010, Ossen Materials enjoys a tax rate of 15% as it is considered as a High and New Technology 
Enterprise by the PRC government. Ossen Jiujiang was entitled to the CIT exemption during the two years ended December 31, 2008, was subject to a 50% 
income  tax  reduction  during  the  three  years  ended  December  31,  2011.  Starting  from  January  1,  2012,  Ossen  Jiujiang  enjoys  a  tax  rate  of  15%  as  it  is 
considered as a High and New Technology Enterprise by the PRC government.

F-38

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 16 – INCOME TAX-(CONTINUED)

Enterprises  established  under  the  laws  of  foreign  countries  or  regions  and  whose  “place  of  effective  management”  is  located  within  the  PRC  territory  are 
considered  PRC  resident  enterprises  and  subject  to  the  PRC  income  tax  at  the  rate  of  25%  on  worldwide  income.  The  definition  of  “place  of  effective 
management" refers to an establishment that exercises, in substance, overall management and control over the production and business, personnel, accounting, 
properties, etc. of an enterprise. As of December 31, 2018, no detailed interpretation or guidance has been issued to define “place of effective management”. 
Furthermore, as of December 31, 2018, the administrative practice associated with interpreting and applying the concept of “place of effective management” 
is  unclear.  If  the  Company’s  non-PRC  incorporated  entities  are  deemed  PRC  tax  residents,  such  entities  would  be  subject  to  PRC  tax  The  Company  has 
analyzed the applicability of this law, as of December 31, 2018, and the Company has not accrued for PRC tax on such basis. The Company will continue to 
monitor changes in the interpretation or guidance of this law.

PRC tax law also imposes a 10% withholding income tax, subject to reduction based on tax treaty where applicable, for dividends distributed by a foreign 
invested enterprise to its immediate holding company outside China. Such dividends were exempted from PRC tax under the previous income tax law and 
regulations. The foreign invested enterprise is subject to the withholding tax starting from January 1, 2008. There were no dividends distributed in the years 
ended December 31, 2018 and 2017.

Income tax expenses consist of the following:

Current:
China
Foreign

Deferred:
China
Foreign

Income tax expenses

Year Ended December 31,
2017

2016

2018

2,147,164
-
2,147,164

$

$

(17,777)
-
(17,777) $
$

2,129,387

$
$

$
$

665,745
-
665,745

25,811
-
25,811
691,556

$

$
$

910,231
-
910,231

15,817
-
15,817
926,048

Reconciliation from the expected income tax expenses calculated with reference to the statutory tax rate in the PRC of 25% is as follows:

Computed "expected" income tax expenses
Effect on tax incentive / holiday
Non-deductable / (taxable) expense
Income tax expenses

$

$

F-39

Year Ended December 31,
2017

$

$

1,647,484
(993,090)
37,162
691,556

$

$

2018
3,378,592
(1,377,961)
128,756
2,129,387

2016

1,562,382
(653,029)
16,695
926,048

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

Components of net deferred tax assets are as follows:

Provision of doubtful accounts
Reserve for inventories
Deferred tax assets
Valuation allowance
Net deferred tax assets

2018

December 31,
2017

2016

$

$

$

140,930
18,206
159,136
0
159,136

$

$

$

130,346
19,165
149,511
0
149,511

$

$

$

147,899
18,052
165,951
0
165,951

Realization  of  deferred  tax  assets  is  dependent  upon  future  taxable  earnings  in  related  tax  jurisdictions.  In  the  past,  management  had  established  and 
maintained a full valuation allowance for the foreign, mainly for China deferred tax assets. During the fourth quarter of fiscal 2018, the Company assessed 
that it is more likely than not that it will realize the China deferred tax assets. The positive evidence, which existed at that time, that outweighed the negative 
evidence to release the valuation allowance included the fiscal 2018 and three year cumulative profitability driven by strong demand of certain new generation 
products, availability of resources to expand manufacturing capacity, and forecasted China operating profits in the future periods. The Company's valuation 
allowance was $0 in fiscal 2018, 2017 and 2016, respectively.

As of December 31, 2018, the Company did not have a liability for unrecognized tax benefits. The Company records interest and penalties, if any, related to 
unrecognized tax benefits in income tax expense. As of 2018, 2017 and 2016, the Company had accrued $0, respectively, for interest and penalties related to 
uncertain tax positions.

Income (loss) before income taxes from PRC and non-PRC sources for the year ended December 31, 2018, 2017 and 2016 are summarized as follows:

Income (loss) before income taxes consists of:
PRC
Non- PRC
Total

Year Ended December 31,
2017

2016

2018

13,778,524
-264,154
13,514,370

6,738,581
-148,647
6,589,934

6,530,295
-280,765
6,249,530

The Company's U.S. federal and state income tax returns are generally not subject to examination by the tax authorities for tax years before fiscal 2016. For all 
federal and state net operating loss and credit carryovers, the statute of limitations does not begin until the carryover items are utilized. The taxing authorities 
can examine the validity of the carryover items and if necessary, adjustments may be made to the carryover items. The Company's China income tax returns 
are generally not subject to examination by the tax authorities for tax years before 2014.

F-40

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

NOTE 17 – GEOGRAPHICAL SALES AND SEGMENTS

Our management does not capture financial information or utilize operating segments to make decisions about the business. Management believes that it 
operates in one business segment. However, our management does rely on sales by geographical area as useful information in managing the business.

Information for the Company’s sales by geographical area for the years ended December 31, 2018, 2017 and 2016 are as follows:

Domestic Sales
International Sales

NOTE 18 – SUBSEQUENT EVENTS

Year Ended December 31,
2017

2016

2018

$

$

131,642,673
4,462,194
136,104,867

$

$

126,930,386
5,445,529
132,375,915

$

$

112,119,286
4,909,868
117,029,154

The Company’s management has evaluated subsequent events through the date these financial statements were issued, and there were no material subsequent 
events requiring adjustments to the financial statements or disclosure.

F-41

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
SCHEDULE I
CONDENSED PARENT COMPANY FINANCIAL INFORMATION

OSSEN INNOVATION CO., LTD
CONDENSED BALANCE SHEETS AS OF DECEMBER 31, 2018 AND 2017

ASSETS
Current Assets
Cash

Total Current Assets
Investments in subsidiaries
TOTAL ASSETS

LIABILITIES AND SHAREHOLDERS’ EQUITY
Current Liabilities
Other payables and accrued liabilities
Due to shareholder

Total Current Liabilities

TOTAL LIABILITIES

EQUITY
Shareholders' Equity
Ordinary shares, $0.01 par value: 100,000,000 shares authorized; 20,000,000 shares issued; 19,791,110 shares 
outstanding as of December 31, 2018 and 2017
Additional paid-in capital
Statutory reserve
Retained earnings
Accumulated other comprehensive income/(loss)
Treasury stock, at cost: 208,890 shares as of December 31, 2018 and 2017
TOTAL SHAREHOLDERS’ EQUITY
TOTAL LIABILITIES AND SHAREHOLDERS’ EQUITY

F-42

December,31

2018

2017

$

$

$

$

$

$

4,796
4,796
108,509,080
108,513,876

205,000
1,663,022
1,868,022
1,868,022

200,000
33,971,455
7,764,813
68,959,065
(4,057,326)
(192,153)
106,645,854
108,513,876

$

$

$

$

$

$

2,967
2,967
103,865,513
103,868,480

1,251,423
351,499
1,602,922
1,602,922

200,000
33,971,455
6,672,254
59,386,668
2,227,334
(192,153)
102,265,558
103,868,480

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
SCHEDULE I
CONDENSED PARENT COMPANY FINANCIAL INFORMATION

OSSEN INNOVATION CO., LTD CONDENSED STATEMENTS
OF OPERATIONS FOR THE YEARS ENDED DECEMBER 31, 2018, 2017 AND 2016

REVENUES
COST OF GOODS SOLD
GROSS PROFIT
Selling expenses
General and administrative expenses

Total Operating Expenses

LOSS FROM OPERATIONS
Financial expenses, net
Equity in income of subsidiaries
INCOME BEFORE INCOME TAX
INCOME TAX
NET INCOME
OTHER COMPREHENSIVE INCOME
Foreign currency translation gain (loss)
TOTAL OTHER COMPREHENSIVE INCOME (LOSS)
COMPREHENSIVE INCOME (LOSS)

F-43

Year Ended December,31
2017

2016

2018

$

$

-
-
-
-
263,002
263,002

$

-
-
-
-
146,687
146,687

(263,002)
268
10,927,690
10,664,956
-
10,664,956

(146,687)
317
5,492,315
5,345,311
-
5,345,311

-
-
-
-
279,893
279,893

(279,893)
184
5,104,050
4,823,973
-
4,823,973

(6,284,660)
(6,284,660)
4,380,296

$

6,606,207
6,606,207
11,951,518

$

(6,975,100)
(6,975,100)
(2,151,127)

$

OSSEN INNOVATION CO., LTD. AND SUBSIDIARIES
SCHEDULE I
CONDENSED PARENT COMPANY FINANCIAL INFORMATION

OSSEN INNOVATION CO., LTD CONDENSED
STATEMENTS OF CASH FLOWS FOR THE YEARS ENDED
DECEMBER 31, 2018, 2017 AND 2016

CASH FLOWS FROM OPERATING ACTIVITIES:
Net income
Adjustments to reconcile net income to net cash provided by operating activities:
Equity in earnings of subsidiaries
Other payables and accrued liabilities
Due to shareholder
Net cash provided by / (used in) operating activities

$

10,664,956

$

5,345,311

$

4,823,973

(10,927,690)
(1,046,423)
1,311,523
2,366

(5,492,315)
102,517
44,000
(487)

(5,104,050)
213,909
25,000
(41,168)

Year Ended December,31
2017

2016

2018

CASH FLOWS FROM INVESTING ACTIVITIES:
Net cash provided by / (used in) investing activities

CASH FLOWS FROM FINANCING ACTIVITIES:
Treasury stock purchased
Net cash used in financing activities

INCREASE / (DECREASE) IN CASH
Effect of exchange rate changes on cash
Cash at beginning of period
CASH AT END OF PERIOD

-

-
-

-

-
-

2,366
(537)
2,967
4,796

$

(487)
(7)
3,461
2,967

$

$

-

(36,810)
(36,810)

(77,978)
(54)
81,493
3,461

F-44

List of Subsidiaries of Ossen Innovation Co. Ltd.

Name

Ossen Innovation Materials Group Co., Ltd.

Ossen Group (Asia) Co., Ltd.

Topchina Development Group Ltd.

Ossen Innovation Materials Co. Ltd.

Ossen (Jiujiang) New Materials Co., Ltd.

EXHIBIT 8.1

Country of Incorporation

British Virgin Islands

British Virgin Islands

British Virgin Islands

People’s Republic of China

People’s Republic of China

CERTIFICATION OF PRINCIPAL EXECUTIVE OFFICER AND PRINCIPAL FINANCIAL OFFICER
PURSUANT TO EXCHANGE ACT RULE 13A-14(A)/15D-14(A) AS ADOPTED PURSUANT TO SECTION 302
OF THE SARBANES-OXLEY ACT OF 2002

EXHIBIT 12.1

I, Wei Hua, certify that:

1. I have reviewed this annual report on Form 20-F of Ossen Innovation Co., Ltd.;

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the 
statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial 
condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange 
Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f) for the company 
and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that 
material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during 
the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to 
provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance 
with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the 
disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the period covered by the annual report 
that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the 
registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to 
adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over 
financial reporting.

Date: May 14, 2019

/s/ Wei Hua
Wei Hua
Chief Executive Officer and Chief Financial Officer
(Principal Executive Officer and Principal Financial and Accounting Officer)

EXHIBIT 13.1

CERTIFICATION OF THE PRINCIPAL EXECUTIVE OFFICER AND PRINCIPAL FINANCIAL OFFICER
PURSUANT TO 18 U.S.C. SECTION 1350, AS ADOPTED PURSUANT TO SECTION 906
OF THE SARBANES-OXLEY ACT OF 2002

In connection with the Annual Report of Ossen Innovation Co. Ltd. (the "Registrant") on Form 20-F for the year ended December 31, 2018, as filed 
with the Securities and Exchange Commission on the date hereof (the "Report"), the undersigned certifies pursuant to 18 U.S.C. 1350, as adopted pursuant to 
Section 906 of the Sarbanes-Oxley Act of 2002, that:

1.

2.

The Report, fully complies with the requirements of Section 13(a) or Section 15(d) of the Securities Exchange Act of 1934, as amended; and

The  information  contained  in  the  Report  fairly  presents,  in  all  material  respects,  the  financial  condition  and  results  of  operations  of  the 
Registrant.

Date: May 14, 2019

/s/ Wei Hua
Wei Hua
Chief Executive Officer and Chief Financial Officer
( Principal Executive Officer and Principal Financial and Accounting Officer)