杰美特: 内幕信息及知情人管理制度（2025.07）

Core Points - The document outlines the insider information management system of Shenzhen Jiemite Technology Co., Ltd, aiming to regulate insider information handling and ensure fair disclosure to protect shareholders' rights [1][2]. Group 1: General Provisions - The board of directors is responsible for managing insider information and ensuring the accuracy and completeness of insider information records, with the chairman as the primary responsible person [1]. - The board secretary is tasked with organizing and coordinating the implementation of this system, while the audit committee supervises its execution [1]. Group 2: Insider Information Definition - Insider information refers to undisclosed information that significantly impacts the company's operations, finances, or stock prices, as defined by the Securities Law [2][3]. - The scope of insider information includes major changes in business policies, significant investments, important contracts, major debts, and other critical events affecting the company [3][4]. Group 3: Insider Information Recipients - Insider information recipients include company directors, senior management, and other personnel who may access insider information due to their roles [4][5]. - The list of insider information recipients also extends to shareholders holding more than 5% of the company's shares and relevant external parties involved in significant transactions [5][6]. Group 4: Registration and Management - The company must maintain a registration file for insider information recipients, which includes personal and professional details, and submit this to the Shenzhen Stock Exchange within five working days after the information is disclosed [6][7]. - The board of directors is responsible for verifying the authenticity and completeness of the insider information recipient records [7][8]. Group 5: Confidentiality Obligations - Insider information recipients are obligated to maintain confidentiality before the information is publicly disclosed, and any breach may lead to disciplinary actions [10][11]. - The company must ensure that the flow of insider information is strictly controlled and that necessary confidentiality agreements are in place with external parties [11][12]. Group 6: External Information Users - External information users, defined as those receiving insider information from the company, must also adhere to confidentiality obligations and are subject to the same restrictions as insider information recipients [13][14]. - The company retains the right to refuse to disclose insider information to external parties that do not have a legal basis for such requests [14][15].