宣亚国际: 《董事、高级管理人员持有和买卖公司股票管理制度》（2025年7月）

Core Viewpoint - The document outlines the management system for the shareholding and trading of company stocks by directors and senior management of Xuan Ya International Marketing Technology (Beijing) Co., Ltd, emphasizing compliance with relevant laws and regulations to maintain market order and transparency [1][2]. Group 1: General Provisions - The system aims to strengthen the management of shares held by directors and senior management, ensuring adherence to the Company Law and Securities Law [1]. - It applies to all directors and senior management, including the CEO, vice presidents, and financial directors, who must comply with the reporting obligations regarding their shareholdings [2]. Group 2: Information Reporting and Disclosure - The company secretary is responsible for managing the data and information related to the shareholdings of directors and senior management, ensuring timely reporting to the Shenzhen Stock Exchange [5]. - Directors and senior management must report their shareholding information within specific timeframes, such as within two trading days after changes occur [6][8]. Group 3: Shareholding Changes Management - Directors and senior management must notify the company secretary of their trading plans in writing before buying or selling shares, ensuring compliance with legal and regulatory requirements [7]. - Any changes in shareholdings must be reported within two trading days, including details such as the number of shares before and after the change [8][9]. Group 4: Restrictions on Trading - Directors and senior management are prohibited from trading company shares during certain periods, such as 15 days before the annual or semi-annual report announcements [9]. - Specific conditions restrict the transfer of shares, including a limit of 25% of their total shareholdings within a year [8][10]. Group 5: Responsibilities and Penalties - Violations of the trading regulations may result in disciplinary actions, including warnings, demotions, or legal consequences, depending on the severity of the breach [35][36]. - The company is required to maintain records of any violations and report them to regulatory authorities as necessary [36].