Request for Clarification and Response by the Special Bidding Committee

On 5 September 2025, BLS International submitted a request for clarification regarding the interpretation of the Notice of Bidding and its Annexes, as a follow-up to the Special Bidding Committee's clarifications issued on 4 September 2025 (available at: https://www.gov.br/mre/pt-br/embaixada-pequim/requests-for-clarification-and-responses-by-the-special-bidding-committee-2).

The request was submitted in a timely manner and will be addressed below.

Query: "What has been clarified from your end basis the whole response to our previous Query 4, is that ancillary service providers like Courier companies, Internet Service providers etc., can be used, but sub-contracting prohibited for the two core services. And Bidder are required to submit the business / operating licenses of the ancillary service providers as well and we shall do so. However, we want to be absolutely sure on the list of partners and their licenses that needs to be submitted. Hence, we want to bring to the attention on our company formation in China. Our companies set up in China for carrying our visa processing services for Brazil Embassy (currently running operations) has 95% majority stake and 5% stake with local Chinese firms, as it is common for foreign companies to have a local minority partner in China to comply with local regulations, but the controlling interest remains with the parent company (BLS International in our case). We are kindly seeking a clarification, that are we supposed to submit the operating / business licenses for the minority stake 5% local Chinese firms as well, along with BLS Chinese entities own Operating licenses?"

Response. Item 7.1.1 of the Notice of Bidding states that "bidders must submit documentation proving compliance with all legal requirements to work with activities related to this bidding process, including copies of the operating license, the list of partner companies and subcontractors, if any, and copies of the operating licenses of the partner companies and subcontractors. The bidders shall be responsible for the authenticity and legality of the submitted documents".

This provision encompasses "subcontractors" and "partner companies", including those with which foreign bidders may collaborate to fulfill local licensing requirements under Chinese law. It does not extend to shareholders (equity holders) of the bidding entity, unless the shareholder itself acts as a subcontractor or license holder on behalf of the bidding entity.