萤石网络: 内幕信息知情人登记管理制度（2025年8月）

Core Viewpoint - The document outlines the insider information management system of Hangzhou Yingshi Network Co., Ltd, aiming to regulate insider information handling, enhance confidentiality, and prevent insider trading while ensuring fair information disclosure to protect investors' rights. Group 1: General Provisions - The system is established based on various laws and regulations, including the Company Law and Securities Law of the People's Republic of China [1] - The scope of the system includes all departments, subsidiaries, and companies controlled by the company [1] - The board of directors is responsible for ensuring the accuracy and completeness of the insider information knowledge person records [1] Group 2: Insider Information Definition - Insider information refers to non-public information that could significantly impact the company's operations, finances, or stock prices [7] - Examples of insider information include major changes in business strategy, significant asset transactions exceeding 30% of total assets, and major debt defaults [7][8] Group 3: Insider Information Knowledge Person Management - The board office is responsible for managing the registration of insider information knowledge persons [2] - Individuals who have access to insider information must maintain confidentiality and are prohibited from insider trading [6] - The registration process involves documenting the details of individuals who have access to insider information, including their roles and the nature of the information [5][6] Group 4: Reporting Requirements - The company must report insider information knowledge person records to the Shanghai Stock Exchange for significant events such as major asset restructuring and stock issuance [16][18] - The company is required to submit these records within five trading days after the initial public disclosure of insider information [10] Group 5: Confidentiality Management - All directors and senior management must enhance their understanding of securities laws and confidentiality obligations [23] - Confidentiality agreements must be signed with external parties who receive insider information [13] - The company must ensure that insider information is disclosed only through approved channels and to authorized individuals [31] Group 6: Accountability - Insider information knowledge persons are held accountable for any breaches of confidentiality, which may lead to legal consequences [33] - The company will conduct self-checks on insider trading activities and report any violations to regulatory authorities [36]