宣亚国际: 《内幕信息知情人登记制度》（2025年7月）

Core Viewpoint - The document outlines the insider information management system of Xuan Ya International Marketing Technology (Beijing) Co., Ltd, emphasizing the importance of confidentiality and compliance with relevant laws and regulations to protect investors' rights and ensure fair information disclosure [1][2]. Group 1: Insider Information Management - The board of directors is designated as the insider information management body, with the board secretary responsible for confidentiality management and daily operations handled by the securities department [2]. - Any department or individual must not disclose insider information without board approval, and all external communications involving such information require prior review by the board secretary [2][3]. - Insider information includes significant changes in business operations, major investments, important contracts, and any events that could materially affect the company's stock price [3][4]. Group 2: Scope of Insider Information - Insider information encompasses various aspects such as major operational changes, significant asset transactions exceeding 30% of total assets, and any substantial losses or debts [3][4]. - Individuals classified as insider information personnel include company executives, major shareholders, and those who can access insider information due to their roles or relationships with the company [4][5]. Group 3: Registration and Documentation - The company must maintain a record of insider information personnel, including details about when and how they became aware of the information, and this must be reported to the Shenzhen Stock Exchange within five trading days after public disclosure [4][6]. - The board of directors is responsible for ensuring the accuracy and completeness of the insider information personnel records, with the chairman and board secretary confirming the documentation [6][7]. Group 4: Confidentiality and Compliance - Insider information personnel are required to keep the information confidential and must not engage in insider trading or assist others in manipulating stock prices [8][9]. - The company must implement confidentiality agreements with relevant parties involved in significant transactions to safeguard sensitive information [8][9]. Group 5: Accountability and Penalties - The company is mandated to conduct self-inspections regarding insider trading activities within five trading days following the release of annual and semi-annual reports [9][10]. - Violations of the insider information management rules can lead to disciplinary actions, including warnings, demotions, or even legal consequences for severe breaches [10][11].