Transwarp(SH:688031) Zheng Quan Zhi Xing·2025-05-29 09:13General Overview - The document outlines the management system for the shares held by the directors and senior management of StarRing Information Technology (Shanghai) Co., Ltd, detailing the procedures for shareholding and changes in shareholding [1][2]. Shareholding Rules - Directors and senior management (referred to as "DGA") are prohibited from engaging in margin trading or derivative trading involving the company's shares [1]. - DGA can sell shares through the Shanghai Stock Exchange or other legally permitted methods, adhering to relevant laws and regulations [2]. - DGA must ensure the accuracy and timeliness of their shareholding data and report any violations to the regulatory authorities [2]. Restrictions on Share Transfers - DGA are restricted from transferring shares under specific conditions, such as within one year of the company's stock listing or within six months after leaving their position [2][3]. - Additional restrictions apply if the company is under investigation for securities violations or if the DGA is personally involved in such investigations [2]. Trading Blackouts - DGA are prohibited from trading company shares during certain blackout periods, including 15 days before the annual and semi-annual reports and 5 days before quarterly reports [3][4]. Reporting and Disclosure - DGA must report any changes in their shareholding within two trading days and disclose relevant information through the Shanghai Stock Exchange [12][17]. - Any planned share reductions must be reported 15 trading days in advance, including details such as the number of shares, method, and reason for reduction [14][15]. Compliance and Penalties - DGA must ensure that their family members and controlled entities do not trade based on insider information [19]. - Violations of the share trading rules may result in disciplinary actions from the company and regulatory authorities [20]. Final Provisions - The management system is subject to national laws and regulations, and any inconsistencies will defer to those legal standards [21][22]. - The system will take effect upon approval by the company's board of directors [23].