复星医药: 复星医药内幕信息知情人管理制度（2025年修订）

Core Viewpoint - The document outlines the insider information management system of Shanghai Fosun Pharmaceutical (Group) Co., Ltd., aiming to regulate the management of insider information and protect investors' rights in accordance with relevant laws and regulations. Group 1: General Principles - The company establishes this system to ensure the public, fair, and just disclosure of insider information and to protect investors' legal rights [1] - The board of directors is responsible for maintaining accurate and complete insider information records, with the chairman as the primary responsible person [1] Group 2: Definition and Scope of Insider Information - Insider information refers to undisclosed information that could significantly impact the company's operations, finances, or market price of its securities [2] - Examples of insider information include major events affecting stock prices, significant changes in assets, liabilities, or operational results, and legal actions against key personnel [2][3] Group 3: Insider Information Recipients - Insider information recipients include company directors, senior management, shareholders holding over 5% of shares, and other individuals or entities that can access insider information due to their roles [4] Group 4: Registration and Reporting of Insider Information Recipients - The company must record and report the list of insider information recipients promptly before the information is publicly disclosed [5] - Various stakeholders, including shareholders and service providers, are required to cooperate in maintaining accurate records of insider information recipients [5][6] Group 5: Reporting Obligations - The company must report insider information recipient records to the Shanghai Stock Exchange for significant events such as major asset restructuring and changes in control [7][8] - The reporting must include a comprehensive list of involved parties, including directors, major shareholders, and relevant service providers [8] Group 6: Confidentiality and Accountability - Insider information recipients have a duty to maintain confidentiality and are prohibited from trading the company's securities before public disclosure [10][11] - Violations, such as leaking insider information or engaging in insider trading, will result in penalties and potential criminal prosecution [11][19] Group 7: Miscellaneous Provisions - The system will be effective upon approval by the board of directors and will be revised as necessary [13]