壹网壹创: 内幕信息知情人登记管理制度（2025年8月）

Core Viewpoint - The company has established a system for managing insider information to ensure confidentiality, maintain fair information disclosure, and protect investors' rights. Group 1: Insider Information Management - The board of directors is responsible for managing insider information and ensuring the accuracy and completeness of insider information records, with the chairman as the primary responsible person [1] - Any department or individual within the company must not disclose insider information without board approval, and all external communications involving insider information must be reviewed by the board secretary [2] - A real-time reporting system for significant information is implemented, requiring responsible parties to report major events or insider information to the board secretary on the same day [2] Group 2: Definition and Scope of Insider Information - Insider information includes significant changes in business policies, major investments, important contracts, and other events that could materially affect the company's stock price [6][7] - Individuals classified as insider information personnel include company directors, senior management, and shareholders holding more than 5% of the company's shares [7] Group 3: Insider Information Registration Management - The company must maintain a record of insider information personnel, including the time, location, and nature of the information they received [8][9] - Shareholders and related parties involved in significant events affecting the company must complete the insider information registration form [9] Group 4: Confidentiality Management - The company must take necessary measures to control the dissemination of insider information and ensure that only a minimal number of individuals are aware of it before public disclosure [17] - All materials containing insider information must be marked accordingly and handled with appropriate confidentiality measures [19] Group 5: Accountability and Penalties - The company will conduct regular checks on the management of insider information and may impose penalties on individuals who fail to comply with confidentiality measures [25] - Violations of the insider information management system may result in disciplinary actions, including warnings, demotions, or termination of employment [26][28]