General Principles - The company establishes a system for the deferral and exemption of information disclosure to ensure compliance with legal obligations under the Securities Law and relevant regulations [2][3] - The system applies to both the company and other information disclosure obligors, allowing for deferral or exemption of disclosures required by the China Securities Regulatory Commission and the Shanghai Stock Exchange [2][3] Applicable Situations for Deferral and Exemption - The company must carefully determine the circumstances under which information disclosure can be deferred or exempted, following internal review procedures [3][4] - Deferral or exemption is permitted if the information involves state secrets or other matters that could violate confidentiality regulations [3][4] - Information related to commercial secrets can also be deferred or exempted if it meets specific criteria, such as potential harm to the company or others if disclosed [3][4] Internal Management Process for Deferral and Exemption - The company’s board secretary is responsible for organizing and coordinating deferral and exemption matters under the board's leadership [5][6] - A detailed registration process is required for any deferral or exemption, including the type of information and the reasons for deferral [5][6] - The company must maintain records of deferral and exemption decisions for a period of ten years [5][6] Accountability and Compliance - The company has established a mechanism for accountability regarding deferral and exemption practices, holding responsible parties accountable for non-compliance [6][7] - Any deferral or exemption must be disclosed promptly once the reasons for deferral are no longer applicable [4][6]
宏和科技: 宏和科技信息披露暂缓与豁免业务管理制度