新时达: 内幕信息知情人登记、报备和保密制度（2025年6月）

General Principles - The company establishes a system for the registration, reporting, and confidentiality of insider information to enhance the management of insider information and maintain fair information disclosure principles [1][2] - The board of directors is responsible for timely registration and reporting of insider information personnel, ensuring the accuracy and completeness of the insider information personnel archives [1][2] Scope of Insider Information - Insider information includes significant unpublicized information that affects the company's operations, finances, or stock trading prices, as defined by the Securities Law [2][3] - Specific examples of insider information include major changes in business policies, significant asset transactions, important contracts, major debts, and significant losses [2][3][4] Identification of Insider Information Personnel - Insider information personnel are defined as individuals who can access or obtain insider information, including company directors, senior management, and significant shareholders [4][5] - The identification criteria also include external parties involved in significant transactions or regulatory bodies that may access insider information [4][5] Registration and Reporting Procedures - The company must maintain accurate records of all insider information personnel and their knowledge of insider information, with documentation retained for at least ten years [5][6] - The board secretary is responsible for registering insider information personnel and must report to the Shenzhen Stock Exchange within five trading days after the public disclosure of insider information [6][7] Confidentiality Obligations - Insider information personnel are required to maintain confidentiality and are prohibited from disclosing or using insider information for trading purposes before it is publicly disclosed [10][12] - The company must ensure that the number of individuals with access to insider information is minimized and that confidentiality agreements are in place when necessary [12][13] Accountability and Penalties - The company will impose administrative and economic penalties on insider information personnel who violate confidentiality obligations or engage in insider trading [14][15] - Any significant breaches that result in serious consequences for the company may lead to legal action against the responsible individuals [14][15]