Chengtou Holding(SH:600649) Zheng Quan Zhi Xing·2025-06-20 13:14Core Viewpoint - The document outlines the insider information and knowledge management system of Shanghai Urban Investment Holding Co., Ltd., aiming to ensure fair information disclosure and prevent insider trading. Group 1: Purpose and Basis - The system is established to maintain the principle of fair information disclosure and regulate the behavior of insiders to prevent the abuse of knowledge rights and unauthorized disclosure of insider information [1]. Group 2: Definition of Insider Information - Insider information refers to non-public information that significantly impacts the company's operations, finances, or stock market prices, including major events that could affect stock trading prices [2]. Group 3: Scope of Insider Information Knowledge - Individuals who can access or obtain insider information due to their shareholding, management position, or professional role are considered insiders, including senior management, actual controllers, and related personnel [2][3]. Group 4: Confidentiality Obligations - Insiders are required to maintain confidentiality before the public disclosure of insider information [3]. Group 5: Management of Insider Information - The company must establish a clear management department and personnel responsible for insider information management, ensuring compliance with disclosure regulations [4]. Group 6: Reporting and Disclosure Regulations - After decisions involving insider information, relevant parties must promptly notify the company, which will then disclose the information according to regulations [5]. Group 7: Control of Insider Information - Insiders must not disclose insider information through internal channels or external communications before it is publicly disclosed, and must act to clarify any market rumors or unusual trading activities [6]. Group 8: Registration Management of Insiders - The company must maintain a registry of insiders, documenting their access to insider information and ensuring accurate records are kept [7]. Group 9: Supervision and Accountability - The company is responsible for self-examination of insider trading activities and must report any violations to regulatory authorities within two working days [10]. Group 10: Penalties for Violations - Violations of the insider information management system may result in disciplinary actions for internal personnel, including warnings, demotions, or termination, and external violators may face legal consequences [11].