海新能科: 董事和高级管理人员所持本公司股份及其变动管理制度（2025年08月）

Core Viewpoint - The document outlines the management system for the shareholding and trading activities of directors and senior management at Beijing Hai New Energy Technology Co., Ltd, emphasizing compliance with relevant laws and regulations to prevent insider trading and ensure transparency in share transactions [3][4][5]. Group 1: General Principles - The system aims to strengthen the declaration, disclosure, supervision, and management of shareholding and trading activities by directors and senior management [3]. - It is based on various legal frameworks including the Company Law and Securities Law of the People's Republic of China [3][4]. Group 2: Trading Regulations - Directors and senior management must notify the company secretary in writing of their trading plans before executing any trades [4][5]. - They are prohibited from engaging in illegal trading activities such as insider trading and market manipulation [4][5]. Group 3: Reporting and Disclosure - Directors and senior management are required to report their shareholding changes within two trading days of any change [12][13]. - The company secretary is responsible for managing the identity and shareholding data of directors and senior management, ensuring accurate and timely disclosures [5][6]. Group 4: Restrictions on Share Transfers - There are specific periods during which directors and senior management are not allowed to sell shares, including 15 days before the announcement of annual or semi-annual reports [13][14]. - Certain conditions restrict the transfer of shares, such as being within one year of the company's stock listing or within six months after leaving the company [7][12]. Group 5: Penalties for Violations - Violations of the established rules may result in disciplinary actions, including warnings, demotions, or legal consequences [21][40]. - The company is obligated to document and report any violations to the relevant regulatory authorities [41].