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秦川物联: 内幕信息知情人登记管理制度(2025年7月)

Core Points - The article outlines the insider information management system of Chengdu Qinchuan Internet of Things Technology Co., Ltd, aimed at preventing insider trading and protecting investors' rights [1][2] - The system is established in accordance with relevant laws and regulations, including the Company Law and Securities Law of the People's Republic of China [1][2] Group 1: Insider Information Management - The board of directors is responsible for managing the registration of insider information personnel, with the board secretary organizing the implementation [2] - The securities affairs department is designated as the daily operational department for managing insider information and personnel [2][4] - Insider information is defined as non-public information that significantly impacts the company's operations, finances, or stock prices [3][4] Group 2: Responsibilities and Obligations - Insider information personnel must maintain confidentiality and are prohibited from trading based on insider information before it is publicly disclosed [2][6] - The company must keep the number of individuals aware of insider information to a minimum before its public disclosure [4][6] - The company is required to submit insider information personnel records to the Shanghai Stock Exchange within five trading days after the information is publicly disclosed [4][9] Group 3: Documentation and Record-Keeping - The company must maintain detailed records of insider information personnel, including the time, place, and manner in which they received the information [4][10] - A memorandum of significant events must be created, documenting each step of major transactions or events that could affect stock prices [8][9] - Records must be kept for at least ten years, and regulatory bodies may access these records for verification [9][11] Group 4: Penalties and Enforcement - Violations of the insider information management system can lead to disciplinary actions against responsible individuals, including fines or termination [11][12] - The company retains the right to pursue legal action against external parties who leak insider information and cause losses [12][13] - The system emphasizes the importance of compliance with regulatory requirements and the need for timely and accurate disclosures [12][13]