迅捷兴: 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 Shenzhen Xunjiexing Technology Co., Ltd, emphasizing compliance with relevant laws and regulations while protecting state and commercial secrets [1][2][3] Summary by Sections General Principles - The purpose of the system is to standardize the deferral and exemption of information disclosure, ensuring compliance with the Securities Law of the People's Republic of China and the listing rules of the Shanghai Stock Exchange [1] - The company can independently assess the need for deferral or exemption without prior application to the exchange, subject to post-event supervision [3] Scope of Deferral and Exemption - Information that qualifies for deferral or exemption includes state secrets and commercial secrets, provided there is sufficient evidence to justify non-disclosure [2][3] - Specific conditions for deferral or exemption of commercial secrets include potential harm from disclosure, such as unfair competition or violation of others' commercial interests [2] Management Process for Deferral and Exemption - Information must not have leaked, and insiders must commit to confidentiality for deferral or exemption to be valid [4] - The company can use alternative methods such as anonymization or summarization to protect sensitive information in reports [4][5] - A thorough internal review process is required before implementing deferral or exemption, with documentation maintained for at least ten years [5][6] Responsibilities and Reporting - The board secretary is responsible for coordinating deferral and exemption matters, with the securities department assisting in the process [6] - All relevant parties must report significant information that may require deferral or exemption, ensuring the accuracy and completeness of submitted materials [6][7] - The company must submit documentation of deferral or exemption actions to the exchange and regulatory authorities within ten days after the reporting period [6][8] Additional Provisions - The system will be effective upon approval by the board and will be implemented following the company's initial public offering [8] - Any matters not covered by this system will adhere to the relevant laws and regulations set forth by the China Securities Regulatory Commission and the Shanghai Stock Exchange [8]