General Principles - The company establishes an insider information management system to enhance confidentiality and prevent insider trading, ensuring fair and transparent information disclosure [2][3] - The system applies to the company, its subsidiaries, and significant affiliates, ensuring comprehensive coverage of insider information management [2] Responsibilities and Management - The board of directors is responsible for managing the registration of insider information personnel, with the board secretary overseeing implementation [3] - The company’s securities department handles daily operations related to insider information registration, disclosure, and management [4] Definition of Insider Information - Insider information includes any non-public information that could significantly impact the company's stock price, such as major operational changes, significant investments, or financial losses [4][5] - Specific examples of insider information include changes in management, major debts, and significant legal issues [5] Insider Information Personnel - Insider information personnel include company directors, senior management, and significant shareholders, as well as individuals who may gain access to insider information through their roles [6] - The company must ensure that all insider information personnel understand their rights, obligations, and legal responsibilities [4] Information Flow and Registration - The company must maintain a detailed record of insider information personnel, including the time and manner in which they received insider information [10][12] - All insider information personnel are required to take necessary measures to limit the dissemination of insider information before it is publicly disclosed [9][10] Compliance and Penalties - The company is obligated to report any violations of insider information regulations to the relevant authorities and may impose penalties on violators [16][28] - The company must conduct self-inspections regarding insider trading and report findings to regulatory bodies within two working days [19][20] Documentation and Record Keeping - The company must maintain insider information personnel records for at least ten years, allowing regulatory bodies to access these records as needed [21] - A specific format for documenting insider information personnel is provided, ensuring consistency and compliance with regulations [19]
深科达: 内幕信息知情人登记管理制度(2025年5月)