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精工钢构: 精工钢构信息披露暂缓与豁免业务管理制度

Core Viewpoint - The document outlines the management system for the deferral and exemption of information disclosure by Changjiang Jinggong Steel Structure (Group) Co., Ltd, emphasizing compliance with legal obligations and the protection of state and commercial secrets [2][3][4]. Group 1: General Principles - The purpose of the system is to standardize the deferral and exemption of information disclosure, ensuring compliance with the Securities Law and relevant stock exchange rules [2]. - The company and other obligated parties must disclose information truthfully, accurately, completely, timely, and fairly, avoiding misuse of deferral or exemption to mislead investors [3][4]. - The scope of deferral and exemption should align with the conditions at the time of the company's initial listing on the Shanghai Stock Exchange [2][3]. Group 2: Scope of Deferral and Exemption - Information can be exempted from disclosure if it involves state secrets or could violate confidentiality regulations [3][4]. - Commercial secrets can be deferred or exempted if they pertain to core technology or sensitive business information that could lead to unfair competition or harm the interests of the company or others [3][4][5]. - The company may use alternative methods such as anonymization or summarization to protect sensitive information in periodic reports [4][5]. Group 3: Internal Review Procedures - The board secretary is responsible for organizing and coordinating deferral and exemption matters, with the securities affairs department handling daily operations [5][6]. - Specific information requiring deferral or exemption must be documented, including reasons, duration, and a list of individuals with insider knowledge [5][6]. - The company must promptly disclose information once the reasons for deferral or exemption are no longer valid [6][7]. Group 4: Compliance and Record Keeping - The company must maintain records of deferral and exemption actions for at least ten years and submit relevant materials to regulatory bodies within ten days after periodic reports [6][7]. - If the company faces regulatory actions due to non-compliance with the system, the board must conduct a review and implement corrective measures [7][8].