General Principles - The purpose of the insider information management system is to standardize the management of insider information, enhance confidentiality, and maintain the principles of open, fair, and just information disclosure [1][2] - The board of directors is responsible for the management of insider information, with the board secretary organizing its implementation [1][2] Insider Information Management - No department, subsidiary, or individual may disclose insider information without the approval of the board secretary [2][3] - Only the board secretary, with written authorization from the board, can release any undisclosed significant information [2][3] - The scope of insider information includes company operations, financials, and any information that could significantly impact stock prices [8][9] Definition and Scope of Insider Information - Insider information includes major changes in business policies, significant investments, important contracts, major debts, and other critical operational changes [3][4] - Specific examples of insider information include major asset transactions exceeding 30% of total assets, significant losses, and changes in shareholder control [3][4] Insider Information Knowledgeable Persons - Insider information knowledgeable persons include company directors, senior management, and any individuals who can access insider information due to their roles [4][5] - Non-insider knowledgeable persons must refrain from inquiring about insider information and will become knowledgeable if they learn such information [5][6] Registration and Record-Keeping - Company directors and senior management are obligated to report insider information and assist in maintaining accurate records of knowledgeable persons [11][12] - The company must maintain a detailed record of insider information knowledgeable persons, including the time, location, and nature of the information [12][13] Confidentiality Management - Insider knowledgeable persons are required to maintain confidentiality and may be subject to penalties for breaches [27][28] - The company must ensure that the number of individuals aware of insider information is minimized before public disclosure [28][29] Accountability and Penalties - The company will conduct self-inspections of insider trading activities and report any violations to regulatory authorities [35][36] - Violations of insider information confidentiality may result in disciplinary actions, including termination and legal consequences [36][37]
东箭科技: 内幕信息知情人登记管理制度（2025年7月修订）