上海凤凰: 上海凤凰董事、高级管理人员持有和买卖本公司股票管理制度

General Principles - The management system for the shareholding and trading of Shanghai Phoenix Enterprise (Group) Co., Ltd. aims to strengthen the management of shares held by directors and senior management, based on various laws and regulations [1][2] - This system applies to the shares held by directors and senior management, including those held in others' accounts and through margin trading [1][2] Shareholding Change Reporting Management - The company secretary is responsible for managing the identity information and shareholding data of directors and senior management, ensuring timely reporting to regulatory bodies in case of violations [5][6] - Directors and senior management must report their shareholding information and any changes within specified timeframes [6][7] Restrictions on Shareholding Changes - There are specific prohibitions on share transfers for directors and senior management under certain conditions, such as within six months of leaving the company or during investigations [12][13] - Directors and senior management are prohibited from short-selling the company's shares or engaging in derivative trading based on the company's stock [5][12] Regulations on Share Reduction Behavior - Directors and senior management must adhere to commitments regarding shareholding ratios, holding periods, and methods of reduction [15][16] - During their tenure, they can only transfer up to 25% of their total shareholding from the previous year, with exceptions for certain circumstances [16][17] Information Disclosure Management - Prior to trading, directors and senior management must notify the company secretary of their trading plans, who will verify compliance with disclosure requirements [20][21] - Any share reduction must comply with legal and regulatory disclosure obligations, ensuring the information is truthful and complete [21][22] Accountability - Directors and senior management who violate the trading regulations may face penalties from regulatory bodies and potential internal disciplinary actions [30][31] - The company is responsible for ensuring compliance with the established management system and may take action against those who cause losses through violations [30][31]