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欣旺达: 《境外发行证券与上市相关保密和档案管理工作制度》(2025年7月)

Core Viewpoint - The document outlines the confidentiality and archival management system for the overseas issuance of securities and listing by Xinwanda Electronics Co., Ltd, emphasizing the importance of safeguarding national economic security and public interests during the process [1]. Group 1: Scope and Applicability - The system applies to the company and its subsidiaries, as well as the securities companies and service institutions hired for overseas issuance and listing [2]. - It covers the entire process of overseas issuance and listing, including preparation, application, review/filing, and listing stages [1]. Group 2: Legal Compliance and Confidentiality - The company and involved parties must strictly adhere to relevant Chinese laws and regulations, enhancing awareness of confidentiality and archival management responsibilities [4]. - Any documents or materials involving state secrets must be approved by the competent authority before disclosure [5]. Group 3: Document Management and Security - The company must ensure that any documents provided to securities companies and service institutions are handled according to national confidentiality regulations [7]. - If any documents are determined to involve state secrets, they cannot be disclosed without proper approval [6]. Group 4: Oversight and Accountability - The company is required to conduct regular self-checks on confidentiality and archival management matters and may request checks on service institutions [14]. - Any violations of the system may lead to corrective measures, including reporting to government authorities if necessary [15][16]. Group 5: Implementation and Amendments - The system will take effect upon approval by the company's board of directors and will be subject to amendments as needed [18].