岩山科技: 内幕信息知情人登记备案制度（2025年5月）

General Principles - The purpose of the insider information management system is to standardize the management of insider information, enhance confidentiality, and maintain fair information disclosure principles according to relevant laws and regulations [1][2]. - The Board of Directors is designated as the management body for insider information within the company [1]. Insider Information Management - The Board of Directors must register and report insider information personnel promptly, ensuring the accuracy and completeness of the records, with the Chairman being the primary responsible person [2]. - The company’s Securities Department is the sole entity responsible for information disclosure, and no department or individual may disclose insider information without Board approval [2][3]. Scope of Insider Information - Insider information includes any unpublicized information that significantly affects the company's operations, finances, or stock trading prices [3][4]. - Specific examples of insider information include major changes in business strategy, significant asset transactions exceeding 30% of total assets, and major debt defaults [4][5]. Insider Information Personnel - Insider information personnel include company directors, senior management, and external parties who can access insider information due to their roles [5][6]. - The company must maintain a detailed record of insider information personnel, including their relationship with the company and the nature of the information accessed [6][10]. Reporting and Documentation - The company is required to submit insider information personnel records to the Shenzhen Stock Exchange within five trading days after the information is publicly disclosed [7][8]. - A memorandum documenting the process of significant matters must be created, detailing key timelines and involved personnel [8][9]. Compliance and Penalties - The company prohibits insider personnel from engaging in securities trading based on insider information and mandates strict confidentiality obligations [12][23]. - Violations of the insider information management system may result in penalties ranging from warnings to legal action, depending on the severity of the breach [26][29]. Miscellaneous - The insider information management system is subject to revisions and interpretations by the Board of Directors, and any inconsistencies with future laws will be resolved in favor of the latter [30][32].