NOVEL(SZ:002014) Zheng Quan Zhi Xing·2025-06-24 17:47Core Viewpoint - Huangshan Novel Co., Ltd. has established a management system for the shares held by its directors and senior management, aiming to regulate their trading behavior and ensure compliance with relevant laws and regulations [1]. Chapter Summaries Chapter 1: General Principles - The management system is designed to strengthen the oversight of shares held by directors and senior management, clarifying procedures for trading company stocks [1]. - Directors and senior management must comply with this system and are prohibited from engaging in illegal trading activities [1]. Chapter 2: Registration, Locking, and Unlocking - Shares held by directors and senior management include those registered in their names and those held in others' accounts [2]. - Personal and family information must be reported to the Shenzhen Stock Exchange within specified timeframes upon changes in directorship or management [2][3]. - Accurate and timely reporting of shareholdings is mandatory, and the company is responsible for confirming this information [3][4]. - New shares acquired within the year are subject to a 75% automatic lock-up, while the annual transferable share limit is calculated at 25% of the shares held as of the last trading day of the previous year [4][5]. Chapter 3: Share Trading and Information Disclosure - Directors and senior management must notify the board secretary of their trading plans in writing before executing trades [5]. - If a shareholding increase is planned, a detailed disclosure of the increase plan is required, including the purpose and quantity of shares [6]. - A reduction plan must be reported 15 trading days prior to the sale, detailing the number of shares and reasons for the reduction [7]. Chapter 4: Departure Management - Upon leaving the company, directors and senior management must report their departure and manage share locking and unlocking procedures [14]. - Shares held by departing personnel will be locked for six months following their departure [14]. Chapter 5: Supplementary Provisions - Any matters not covered by this system or conflicting with national laws will be governed by the relevant laws and regulations [31]. - The board of directors is responsible for interpreting this system, which takes effect upon approval [33].