Analysis of Changshan Pharmaceutical's Commercial Bribery Case and Credit Rating Risks

Based on the information I have obtained, I will now systematically analyze Changshan Pharmaceutical’s commercial bribery case and its potential impact on the company’s credit rating.

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According to the notification released by the National Healthcare Security Administration (NHSA) on January 11, 2026 [1][2], this case originated from a routine inspection by the Putuo District Administration for Market Regulation of Shanghai. The core facts of the case are as follows:

Item	Details
Involved Product	Dalteparin Sodium Injection (trade name “Wanmainning”)
Promotion Service Provider	Shanghai Haiyilai Enterprise Consulting Management Partnership (CSO)
Distribution Enterprise	Shanghai Hongjian Pharmaceutical Co., Ltd.
Bribery Amount	RMB 35,046 (4 WeChat transfers in installments)
Prescribed Drug Volume	18,275 vials
Service Provider’s Revenue	RMB 868,677
Penalty Result	The Putuo District Administration for Market Regulation of Shanghai imposed a 300,000 yuan fine on the CSO

After calculation, for each vial of Wanmainning prescribed, doctors could receive a kickback of approximately

[3].

The key feature of this case is the

approach adopted by the regulatory authorities:

1. After receiving the case information, the Shanghai Pharmaceutical Affairs Institute initiated the price procurement credit evaluation procedure against the involved distribution enterprise
2. Required the distribution enterprise to identify the actual controlling entity responsible for the dishonest act
3. Shanghai Hongjian Pharmaceutical Co., Ltd. submitted materials such as sales contracts and invoices with Changshan Pharmaceutical
4. The Shanghai Pharmaceutical Affairs Institute clearly stated that it would penetrate to
   Changshan Pharmaceutical, the manufacturing enterprise
   , and formally initiated the credit evaluation procedure [1][2]

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According to the

established by the NHSA in 2020 [3], the rating standards are as follows:

Dishonesty Level	Cumulative Bribery Amount Threshold	Handling Measures
General Dishonesty	≥ RMB 10,000	Reminder and warning, risk prompt
Serious Dishonesty	≥ RMB 500,000	Revoke the listing and distribution qualifications of the involved products
Extra Serious Dishonesty	≥ RMB 1,000,000	Revoke the listing and distribution qualifications of all products nationwide

As of December 2025, a total of 70 pharmaceutical enterprises were included in the “Extra Serious Dishonesty” and “Serious Dishonesty” lists [3].

This case has a particularly significant impact on Changshan Pharmaceutical’s credit rating, mainly based on the following factors:

According to the company’s 2024 annual report data [1][2]:

• Heparin-based products account for
  nearly 87%
  of the company’s total revenue
• Revenue from low-molecular-weight heparin preparations accounts for approximately
  50%
• Ordinary heparin raw materials, low-molecular-weight heparin raw materials, and preparations constitute the absolute main business

Product	Centralized Procurement Status
Nadroparin Calcium Injection	Won the bid in the 8th National Centralized Procurement in 2023
Low-Molecular-Weight Heparin Calcium Injection	Subject to provincial centralized procurement price limits, failed to pass consistency evaluation

Although winning the bid led to sales growth, due to the significant decline in the winning bid price, the revenue from Nadroparin Calcium Injection decreased by

year-on-year [1].

Financial Indicator	2023	2024	First Three Quarters of 2025
Operating Revenue	—	RMB 1.031 billion (-26.92%)	RMB 681 million (-13.11%)
Net Profit Attributable to Shareholders	Loss of RMB 1.24 billion	Loss of RMB 249 million	Loss of RMB 44.8174 million (-714.77%)

The company has recorded consecutive losses, and its profitability continues to weaken [2].

If Changshan Pharmaceutical’s credit rating is downgraded, it may face the following risks:

Impact Dimension	Specific Consequences
Involved Product Dimension	Dalteparin Sodium Injection (Wanmainning) may face listing restrictions or price adjustments
Centralized Procurement Qualification Dimension	Uncertainty regarding eligibility for future centralized procurement
Corporate-wide Dimension	Inability to participate in national or alliance-based drug centralized procurement during the dishonesty period
Operation Dimension	The core growth driver is cut off, causing a double blow to the loss-making enterprise

Lu Chuanyong, General Manager of Wuhan Hary Pharmaceutical, analyzed: “The impact of credit evaluation on pharmaceutical companies has clear directionality: if it is directly related to a product, the product may face price cuts or suspension of listing; if it is identified as a corporate-wide serious dishonest act, the enterprise will be unable to participate in national or alliance-based drug centralized procurement during the dishonesty period.” [1]

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The NHSA chose to release a heavyweight notification of this case in early 2026, sending

[2]:

1. End of the “Lightning Rod” Era
   : Pharmaceutical enterprises can no longer achieve legal isolation through outsourcing service agreements, and the compliance “firewall” function of CSOs has failed
2. Traceability-based Accountability Logic
   : Regulatory authorities traced legal liabilities directly to the pharmaceutical entity by reviewing contracts and invoices from the distribution link
3. Reflection of Micro-level Control
   : The precise disclosure of the 1.9 yuan kickback per vial shows that regulatory authorities have achieved micro-level control over the implementation details of centralized procurement varieties

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Risk Level	Assessment Description
High	Based on comprehensive factors such as current performance pressure, high dependence on centralized procurement, and single business focus
Main Trigger Factors	The commercial bribery act has a substantive connection to specific product sales; although the amount is small, it involves a centralized procurement variety
Uncertainty	The company responded that “there is no conclusion yet” [1], and we need to wait for the official credit evaluation result from the Shanghai Pharmaceutical Affairs Institute

1. Continuous Tracking
   : Pay attention to the progress of the subsequent credit evaluation procedure and the official rating result from the Shanghai Pharmaceutical Affairs Institute
2. Performance Impact
   : If the credit rating is downgraded, it will be a major negative for the core heparin business
3. Concept Hedging
   : Although Ebenatide, a GLP-1 innovative drug, is in the marketing registration stage, it is difficult to offset the pressure on the core heparin business in the short term [1]
4. Compliance Risk
   : This case marks that “penetrative regulation” has become a trend under the normalized anti-corruption in the pharmaceutical industry

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[1] Sina Finance - “Fined 300,000 Yuan for Bribing Doctors! Service Provider of "GLP-1 Star Stock" Changshan Pharmaceutical Exposed” (https://finance.sina.com.cn/jjxw/2026-01-12/doc-inhfziuy0087303.shtml)

[2] Caizhongshe/Sina Finance - “Heparin Leader Implicated in Commercial Bribery, Changshan Pharmaceutical Faces Centralized Procurement Credit Crisis” (https://finance.sina.com.cn/stock/zqgd/2026-01-12/doc-inhfzysp6799943.shtml)

[3] Caifuhao/Eastmoney - “Changshan Pharmaceutical’s "Wanmainning" Involved in Pharmaceutical Commercial Bribery Case” (https://caifuhao.eastmoney.com/news/20260112142445750647390)