海航控股: 北京德恒律师事务所关于海南航空控股股份有限公司内幕信息知情人登记制度的制定和执行情况的核查意见

Core Viewpoint - The special legal opinion issued by Beijing Deheng Law Firm confirms that Hainan Airlines Holding Co., Ltd. has established and executed an insider information registrant system in compliance with relevant laws and regulations [1][4]. Group 1: Insider Information Registrant System Development - The company has developed an insider information registrant system in accordance with the Company Law, Securities Law, and relevant disclosure management regulations [4]. - The system clearly defines the scope of insider information and registrants, management procedures, trading restrictions, and penalties [4]. - The insider information registrant management system was publicly announced on March 22, 2022 [4]. Group 2: Execution of the Insider Information Registrant System - The company has implemented necessary confidentiality measures during the planning of the transaction, limiting the knowledge of sensitive information to a defined group [5]. - Insider registrants related to the transaction have been documented, and the list has been reported to the Shanghai Stock Exchange in a timely manner [5]. - All intermediary institutions involved in the transaction have signed confidentiality agreements to prevent the disclosure of sensitive information to unrelated third parties [5]. Group 3: Conclusion - The legal opinion concludes that the company has complied with the Securities Law and relevant regulations in establishing and executing the insider information registrant system [5].