ST合纵: 董事、监事和高级管理人员所持本公司股份及其变动管理制度

Core Viewpoint - The document outlines the management system for the shares held by the directors, supervisors, and senior management of Hezhong Technology Co., Ltd., emphasizing compliance with relevant laws and regulations regarding insider trading and share transactions [1][2]. Summary by Sections General Principles - The system is established to strengthen the management of shares held by the company's directors, supervisors, and senior management, clarifying procedures based on various laws and regulations [1]. Management of Share Changes - Directors, supervisors, and senior management must notify the board secretary in writing before buying or selling shares, ensuring compliance with legal and regulatory requirements [2][3]. - The board secretary is responsible for managing the data and information regarding the shareholdings of the aforementioned individuals and must report any violations to regulatory authorities [3]. Restrictions on Share Transfers - There are specific conditions under which shares held by directors, supervisors, and senior management cannot be transferred, including within one year of the company's stock listing and within six months after leaving the company [4]. - The maximum amount of shares that can be transferred annually is limited to 25% of the total shares held [5]. Reporting Requirements - Changes in shareholdings must be reported within two trading days, including details such as the number of shares before and after the change [18]. - Directors, supervisors, and senior management must ensure timely and accurate reporting of their shareholdings and any changes [7]. Shareholding Increase and Decrease Regulations - Specific rules govern the increase and decrease of shareholdings, including the requirement to disclose plans for share increases and reductions [10][27]. - In cases of significant corporate events, individuals must disclose their shareholding plans and any related changes [12]. Additional Provisions - The document specifies that the terms used align with those in the company's articles of association, and any matters not covered will follow national laws and regulations [31][32]. - The system takes effect upon approval by the board of directors [33].