Core Points - The company establishes a system for managing insider information to ensure confidentiality and compliance with relevant laws and regulations [1][2][3] - The board of directors is responsible for insider information management, with the secretary organizing implementation and the securities department handling daily operations [1][2] - Insider information is defined as non-public information that could significantly impact the company's operations, finances, or stock prices [3][4] Group 1: Insider Information Management - The company prohibits any department or individual from disclosing insider information without the approval of the board secretary [2] - All company personnel, including directors and senior management, must maintain confidentiality regarding insider information [2][3] - The company must keep a complete record of all individuals who have access to insider information before it is publicly disclosed [6][7] Group 2: Scope of Insider Information - Insider information includes significant changes in business strategy, major investments, important contracts, and financial difficulties [3][4][5] - The company must report insider information to regulatory bodies within five trading days after public disclosure [6][10] - Individuals who have access to insider information are classified as insider information insiders and must adhere to confidentiality obligations [4][8] Group 3: Confidentiality Obligations - Insider information insiders are required to keep the information confidential and cannot trade or suggest trading based on this information [10][11] - The company must limit the circulation of insider information to the smallest necessary group before public disclosure [8][9] - Any breach of confidentiality by insiders may result in disciplinary actions from the company and potential legal consequences [14][15]
东来技术: 内幕信息知情人登记管理制度