佰维存储: 信息披露暂缓与豁免业务管理制度（2025年7月修订）

Core Viewpoint - The document outlines the management system for information disclosure deferral and exemption for Shenzhen Baiwei Storage Technology Co., Ltd, ensuring compliance with relevant laws and regulations while protecting sensitive information [1][2]. Group 1: General Principles - The company establishes this system to regulate the procedures for deferring and exempting information disclosure, ensuring compliance with the Securities Law of the People's Republic of China and other relevant regulations [1]. - The company and other obligated parties must disclose information truthfully, accurately, completely, timely, and fairly, avoiding misuse of deferral or exemption to evade disclosure obligations [1][2]. Group 2: Applicable Situations for Deferral and Exemption - Information can be deferred or exempted if it involves state secrets or other matters that may violate confidentiality regulations, provided there is sufficient evidence [2]. - The company has an obligation to protect state secrets and must not disclose them through any means, including investor interactions or media interviews [2]. - Commercial secrets can be deferred or exempted if their disclosure could lead to unfair competition or harm the interests of the company or others [2][3]. Group 3: Internal Management Process - The board secretary is responsible for organizing and coordinating deferral and exemption matters, reporting to the board of directors [4]. - The Securities and Legal Department handles daily operations related to information disclosure deferral and exemption [4]. - All departments must submit relevant materials regarding deferral or exemption reasons and internal review processes to the Securities and Legal Department [5]. Group 4: Record Keeping and Reporting - The company must maintain records of deferral and exemption matters for at least 10 years, including the type of documents and internal review procedures [5][6]. - After annual, semi-annual, or quarterly reports, the company must submit related materials regarding deferral or exemption to the local securities regulatory authority within 10 days [6]. Group 5: Accountability and Penalties - The company has established a responsibility accountability mechanism for deferral and exemption matters, with potential penalties for those who fail to comply with the regulations [7][8].