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 beneficial owners and shareholders through a series of passthrough joint venture companies, including Henan Investment Group Company Limited, a company involved in military-civil fusion for the PRC.

Zhu also served as Chairman of the Board and General Manager of Aide Modern Cattle Industry (China) Company Limited (“Aide Cattle China”), a company whose directors included an executive for a PRC defense firm and a company on the U.S. Entity List. Shareholders in Aide Cattle China include PRC state-controlled entities and individuals who have invested in other PRC state-controlled entities. Through Aide Cattle China, Zhu was the primary shareholder of 11 PRC cattle companies.

After Zhu moved to Canada and created additional corporations there, his Canadian company, IND Modern Cattle Development Group Corporation (IND Group), became a minority shareholder in Pioneer Aide China.