Focus Media(SZ:002027) Zheng Quan Zhi Xing·2025-05-21 13:40Core Viewpoint - The company has established a comprehensive insider information management system to ensure confidentiality, fairness, and compliance with relevant laws and regulations regarding insider information disclosure [1][2]. Chapter Summaries Chapter 1: General Principles - The company aims to regulate insider information management and enhance confidentiality to protect investors' rights [1]. - The board of directors is responsible for managing insider information, with the chairman as the primary responsible person [1]. Chapter 2: Scope of Insider Information - Insider information includes any unpublicized information that could significantly impact the company's operations, finances, or stock prices [2]. - Specific examples of insider information include major changes in business strategy, significant asset transactions exceeding 30% of total assets, and major losses or debts [2][3]. Chapter 3: Scope of Insider Information Recipients - Insider information recipients include company directors, senior management, major shareholders, and relevant external personnel who can access insider information [4]. Chapter 4: Insider Information Flow and Filing Procedures - The company must maintain accurate records of insider information recipients and the details of their knowledge of such information [5][6]. - Each insider information event must be documented separately, and a memorandum of significant events must be created for major transactions [6][7]. Chapter 5: Confidentiality Responsibilities and Accountability - Insider information recipients are obligated to maintain confidentiality and are prohibited from disclosing or trading based on insider information [8][9]. - The company must implement measures to limit the dissemination of insider information within the organization [8]. Chapter 6: Additional Provisions - The company is responsible for revising and interpreting the insider information management system as necessary [10]. - The system will take effect upon approval by the board of directors and will be updated as needed [10].