金橙子: 《信息披露暂缓与豁免制度》

Core Points - The document outlines the information disclosure deferral and exemption system for Beijing Jinchengzi Technology Co., Ltd, ensuring compliance with national secrecy obligations and protecting investors' rights [3][4][6] - The system is established based on various laws and regulations, including the Company Law and Securities Law of the People's Republic of China, as well as the listing rules of the Shanghai Stock Exchange [3][4] - The company must maintain proper documentation and internal procedures for any deferral or exemption of information disclosure, ensuring that such actions are justified and well-supported [2][5][6] Summary by Sections General Principles - The company and related information disclosure obligors must strictly adhere to national secrecy obligations and avoid disclosing state secrets through any form of communication [1][3] - The system aims to regulate the handling of information disclosure deferrals and exemptions, ensuring legal compliance and investor protection [3] Scope of Deferral and Exemption - Information can be exempted from disclosure if it involves state secrets or commercial secrets that could lead to unfair competition or harm to the company or others [4][6] - Specific conditions for deferral or exemption include core technology information, operational information, and other circumstances that could severely damage interests [4][6] Internal Review Procedures - Any department or subsidiary that believes information should be deferred or exempted must report it to the securities department with supporting documentation [6] - The company must implement internal review procedures to ensure that deferral or exemption actions are carefully considered and that measures are in place to prevent information leaks [6] Responsibilities and Penalties - The securities department is responsible for managing information disclosure deferrals and exemptions [6] - Individuals involved in the deferral or exemption process must ensure the accuracy and completeness of the information submitted [5][6] - Violations of the system may result in disciplinary actions against responsible individuals, including warnings or performance penalties [6][7]