鑫铂股份: 董事和高级管理人员持股管理制度（2025年8月）

General Principles - The management system for the shareholding of directors and senior management of Anhui Xinbo Aluminum Industry Co., Ltd. is established to strengthen the management of stock holdings and trading by directors and senior management [1][2] - This system applies to directors, senior management, and other specified individuals or organizations holding or trading the company's stocks [1] Trading Regulations - Directors and senior management must notify the board secretary in writing before trading company stocks, and the board secretary must verify the situation regarding information disclosure and significant events [2][3] - There are restrictions on the transfer of shares held by directors and senior management, including a limit of 25% of their total holdings per year, with exceptions for certain circumstances [4][5] Reporting and Disclosure - Directors and senior management must ensure that their stock trading data submitted to the Shenzhen Stock Exchange is accurate and timely, and they bear legal responsibility for any discrepancies [3][4] - Any changes in shareholding must be reported to the board secretary two trading days in advance, and the board must disclose this information to the Shenzhen Stock Exchange [10][11] Lock-up Periods - Shares held by directors and senior management are subject to lock-up periods under specific conditions, such as one year after the company's stock listing and six months after leaving their positions [8][9] - Upon leaving, directors and senior management must report their departure and have their shares locked for six months, with specific conditions for unlocking after this period [6][7] Prohibited Trading Periods - Directors and senior management are prohibited from trading company stocks during certain periods, including 15 days before annual and semi-annual reports and five days before quarterly reports [10][11] Penalties for Violations - Any violations of the trading regulations will result in the company reclaiming any profits made from such trades, and severe cases may lead to disciplinary actions against the responsible individuals [13]