ZPEC(SH:603619) Zheng Quan Zhi Xing·2025-06-06 11:31General Principles - The company establishes a system for the management of information disclosure deferral and exemption to comply with legal obligations and protect the rights of the company and investors [2][3] - The system is based on relevant laws and regulations, including the Securities Law of the People's Republic of China and the Shanghai Stock Exchange Listing Rules [2] Applicable Situations for Deferral and Exemption - Information that can be deferred from disclosure includes uncertain information or temporary business secrets, where timely disclosure may harm the company's interests or mislead investors [3] - Information that can be exempted from disclosure includes state secrets and commercial secrets, where disclosure may violate confidentiality laws or harm the interests of the company and investors [3] Definition of Commercial and State Secrets - Commercial secrets are defined as technical and operational information that is not publicly known, has commercial value, and is protected by confidentiality measures [3] - State secrets are defined as information related to national security and interests, known only to a limited number of people, and whose disclosure could harm national interests [3] Conditions for Deferral and Exemption - Information must not have been leaked, insiders must provide written confidentiality commitments, and there should be no abnormal trading of the company's stocks or derivatives [3][4] Internal Management Procedures - Specific information requiring deferral or exemption must be documented and submitted to the securities affairs department for review [5] - The company secretary must review the information within two trading days and ensure compliance with deferral or exemption conditions [5] Disclosure Requirements - If the reasons for deferral or exemption are no longer valid, the company must promptly disclose the information [6] - The company must report any deferred or exempted information to the Shanghai Securities Regulatory Bureau and the stock exchange within ten days after the annual, semi-annual, or quarterly report announcements [6] Accountability for Violations - The company has established a mechanism for accountability regarding violations of disclosure regulations, which may result in internal disciplinary actions or compensation claims against responsible individuals [6][7]