No.

SGX Query/Comment

Company's Reply

(a)

Please provide a discussion on the orderbook projects, the type of projects and the impact on margins of such projects.

The orderbook consists of one commercial building and three public building projects and all of them are expected to be completed in FY2009. Barring any unforeseen circumstances, the impact is expected to be positive.

(b)

We note on Page 1 of the results announcement that there is a "translation differences relating to financial statements of foreign subsidiaries" of RMB872,000. Please provide further information on the "foreign subsidiaries".

Translation difference arose from exchange differences on long term advances extended from Sino Construction Limited to one of its subsidiaries, Daqing Xinyuan Construction Installation Co., Ltd.

(c)

Noting that there was no revenue derived from the Group's principal activities in 1Q FY2OO9 and administrative expenses has increased from RMB5.2 million for the quarter ended 31 March 2008 to RMB9.2 million for the quarter ended 31 March 2009, please provide a breakdown with details on the administrative expenses, quantify and explain for significant changes.

Details on the administrative expenses are set out in the table Delow:

(RMB'OOO)

1QO9

1Q08

Remark

Salaries & Wages

2,189

1,323

Salary increment and inclusion of Baixinyuan headcountin Q1 09

Staff welfare & benefits

164

139

Depreciation & amortisation

3,079

2,524

Amortisation of Baixinyuan's land cost in Q1 09

Transportation & motor vehicle expenses

165

170

Utilities & office expenses

122

27

Entertainment & travelling expenses

280

673

Corporate

-

Corporate governance