

General Provisions - The purpose of the guidelines is to regulate the management of insider information at China Aluminum Corporation, enhance confidentiality, maintain fair information disclosure, and protect investors' rights [1][2] - The guidelines apply to all departments, subsidiaries, and other enterprises managed by the company [1] Scope of Insider Information - Insider information refers to information that significantly impacts the company's operations, finances, or the trading market for its securities, which has not been publicly disclosed [2] - Examples of insider information include major changes in business strategy, significant operational losses, major investments, and changes in shareholder structure [2] Scope of Insider Information Insiders - Insiders are individuals or entities that can access insider information directly or indirectly before it is publicly disclosed [3][4] - This includes company directors, senior management, major shareholders, and employees who have access to such information due to their roles [4] Registration and Record-Keeping of Insiders - The company must maintain a record of insiders, including the time, place, and manner in which they accessed insider information [5][6] - The board of directors is responsible for ensuring the accuracy and completeness of these records [5] Confidentiality Management - Insiders are obligated to keep insider information confidential and must not disclose it before it is publicly released [11] - Measures must be taken to limit the number of individuals who have access to insider information [11][12] Penalties for Violations - Violations of the guidelines can result in disciplinary actions, including warnings, demotions, or legal consequences [13][14] - The company reserves the right to pursue civil liability for significant breaches that cause major losses [13]