Shunya International(SZ:300612) Zheng Quan Zhi Xing·2025-07-18 12:15Core Viewpoint - The document outlines the management system for fund transactions between Xuan Ya International Marketing Technology (Beijing) Co., Ltd. and its related parties, aiming to prevent fund occupation by related parties and protect the rights of the company and its stakeholders [1][5]. Group 1: General Principles - The system is established to regulate fund transactions with controlling shareholders, actual controllers, and other related parties to avoid fund occupation and ensure compliance with relevant laws and regulations [1][2]. - The system applies to fund transactions between subsidiaries included in the company's consolidated financial statements and related parties [1]. Group 2: Types of Fund Occupation - Operating fund occupation refers to fund occupation arising from related transactions such as procurement and sales [2]. - Non-operating fund occupation includes various forms of financial support to related parties, such as paying salaries, benefits, and debts on behalf of related parties, as well as providing funds without genuine transactions [2]. Group 3: Prevention Principles and Regulations - Company directors and senior management are legally obligated to ensure the safety of company funds and must diligently perform their duties according to relevant laws and the company's articles of association [3]. - The company is prohibited from providing funds to related parties through various means, including paying expenses on behalf of related parties or providing loans without proper justification [3][4]. Group 4: Independence and Oversight - The company must maintain independence in assets, personnel, finance, and operations from related parties [4]. - The finance department is responsible for daily prevention and self-inspection of fund occupation, reporting any findings immediately [4][5]. Group 5: Audit and Reporting - The audit management department must conduct regular checks on fund occupation and report findings to the audit committee of the board [5]. - The company must disclose any fund occupation by controlling shareholders or actual controllers in its annual financial reports [5]. Group 6: Legal Obligations and Consequences - The board must take effective measures against related parties that infringe on company assets and report to regulatory authorities if necessary [5][6]. - Violations of the fund management system by directors or senior management may result in administrative penalties and civil liability [6][7]. Group 7: Implementation and Amendments - The system takes effect upon approval by the board of directors and will be amended in accordance with future legal changes [7].