能辉科技: 董事、高级管理人员所持本公司股份及其变动管理制度

Core Viewpoint - The document outlines the regulations and procedures for managing the shareholding and trading activities of directors and senior management of Shanghai Nenghui Technology Co., Ltd, emphasizing compliance with relevant laws and regulations to prevent insider trading and market manipulation [1][2][3]. Group 1: Shareholding Management - Directors and senior management must be aware of laws regarding insider trading and market manipulation before trading company shares [1][2]. - The shares held by directors and senior management include those registered in their own accounts and those held through others, but they are prohibited from short selling company shares [2][3]. - There are specific restrictions on transferring shares within certain timeframes, such as one year after the company's stock is listed and six months after leaving the company [2][3][4]. Group 2: Trading Restrictions - Directors and senior management are prohibited from trading company shares during specific periods, including 15 days before the annual and semi-annual reports and five days before quarterly reports [3][4]. - The maximum amount of shares that can be transferred in a year is limited to 25% of the total shares held, with exceptions for certain circumstances [4][5]. Group 3: Information Disclosure - The company secretary is responsible for managing the shareholding data of directors and senior management and must report any violations to the Shenzhen Stock Exchange [6][7]. - Any shareholding changes must be reported within two trading days, including details such as the number of shares before and after the change [8][9]. Group 4: Compliance and Penalties - If directors or senior management violate trading regulations, the company board must recover any profits made from such trades and disclose the situation [9][10]. - The company must ensure that all shareholding information is accurate and timely reported to the relevant authorities [12][13]. Group 5: Additional Provisions - The document specifies that any additional restrictions on share transfers must be reported to the Shenzhen Stock Exchange [10][11]. - The company must comply with national laws and regulations, and any inconsistencies with the company's internal rules must defer to the legal standards [15][16].