明泰铝业: 明泰铝业内幕信息知情人登记制度

Core Viewpoint - The document outlines the insider information management system of Henan Mingtai Aluminum Industry Co., Ltd., aiming to enhance corporate governance, ensure fair information disclosure, and protect investors' rights. Group 1: General Principles - The system is established to improve the governance structure of the company and maintain the confidentiality of insider information [1] - The board of directors is responsible for registering and reporting insider information personnel, ensuring the accuracy and completeness of the records [1][2] - The system applies to all departments, subsidiaries, and companies significantly influenced by the company [1] Group 2: Scope of Insider Information and Personnel - Insider information refers to non-public information that significantly impacts the company's operations, finances, or securities trading prices [2] - Examples of insider information include major changes in business strategy, significant asset transactions, and major losses [2][3] - Insider information personnel include company directors, senior management, and any individuals who can access insider information due to their position [3] Group 3: Registration and Record-Keeping - The company must accurately record all stages of insider information discussions and maintain a list of personnel who are privy to such information [4] - Shareholders and related parties must fill out insider information personnel records when significant matters arise [4][5] - The company must keep these records for at least 10 years and submit them to the stock exchange within five trading days after public disclosure [8] Group 4: Confidentiality Management - Insider information personnel must adhere to confidentiality obligations and are prohibited from engaging in illegal trading activities [9] - Departments must report insider information to the board secretary immediately and cooperate in the registration and disclosure process [9] - The company should limit the number of individuals aware of insider information before public disclosure [9] Group 5: Trading Restrictions - Insider information personnel and their associates are prohibited from trading securities based on insider information [11] - Specific trading restrictions apply during certain periods before financial disclosures and significant events [11][12] - Any trading activity must be reported to the board secretary within two trading days [12] Group 6: Responsibilities and Penalties - Violations of the insider information management system may result in penalties, including legal action for severe breaches [12] - The board will issue warnings for violations by external parties and may report to regulatory authorities for further action [12][13] - The system will be revised as necessary to comply with national laws and regulations [13]