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璞泰来: 内幕信息知情人登记管理制度(2025年修订)

Core Viewpoint - The document outlines the insider information management system of Shanghai Putailai New Energy Technology Co., Ltd, aimed at regulating insider information management and protecting investors' rights [1][2]. Group 1: Insider Information Definition - Insider information refers to non-public information that significantly impacts the company's operations, finances, or stock market prices, including major events that affect stock trading prices by over 30% or significant changes in assets [1][4]. - Specific events classified as insider information include major asset restructuring, high ratio share transfers, changes in actual controllers, and significant financial impacts [6][10]. Group 2: Insider Information Knowledge Person Scope - Insider information knowledge persons include company directors, senior management, shareholders with over 5% ownership, and individuals who can access insider information due to their roles or business relations [1][5]. - The scope also extends to external parties such as securities firms, regulatory bodies, and other relevant personnel who may gain access to insider information [1][5]. Group 3: Registration and Reporting Procedures - The company must maintain a record of insider information knowledge persons, detailing the time, method, and content of the information they accessed, and submit this information within 5 trading days after public disclosure [3][8]. - A significant event progress memorandum must be created for major transactions, documenting each step and key participants involved, and submitted within the same timeframe [4][10]. Group 4: Responsibilities and Compliance - The company is responsible for ensuring that insider information knowledge persons are aware of their confidentiality obligations and must confirm the accuracy of the information provided [9][10]. - Any violations of insider trading regulations by knowledge persons will lead to accountability measures, including potential compensation for damages caused to the company [10][11].