We are short China Huishan Dairy Holdings (6863 HK / “Huishan”) because we believe it is worth close to Zero. We conclude Huishan is a fraud. In this first report on Huishan, we detail the following conclusions and supporting facts. Since at least 2014, the company has reported fraudulent profits largely based on the lie that it is substantially self-sufficient in producing alfalfa. We found overwhelming evidence that Huishan has long purchased substantial quantities of alfalfa from third parties, which gives us no doubt that Huishan’s financials are fraudulent. We believe Huishan has engaged in CapEx fraud related to its cow farms. We estimate that Huishan has overstated the spending on these farms by RMB 893 million to RMB 1.6 billion. The primary purpose of the CapEx fraud is likely to support the company’s income statement fraud.

In Part 1, we explained our conclusions that Huishan fraudulently inflates its profit margins, CapEx, and cash balance. In Part 2, we will detail our conclusion that Huishan’s reported revenue is also fraudulent. VAT data from the State Administration of Taxation (“SAT”) show that Huishan reports a significant amount of fraudulent revenue.