科净源: 内幕信息知情人登记管理制度 (2025年8月)

Core Points - The article outlines the insider information management system of Beijing Kejingyuan Technology Co., Ltd, emphasizing the importance of confidentiality and fair disclosure to protect investors' rights [2][3][12] - The system is established in accordance with relevant laws and regulations, including the Company Law and Securities Law of the People's Republic of China [2][3] - The board of directors is responsible for the management of insider information, with the secretary of the board organizing its implementation [2][3] Group 1: Insider Information Management - The company must not disclose insider information without board approval, and any external communication involving such information requires board review [2][3] - Insider information includes significant changes in business strategy, major investments, important contracts, and any events that could materially affect the company's financial status [6][7] - The company must maintain a record of individuals who have access to insider information, including their relationship to the company and the nature of the information accessed [5][10] Group 2: Responsibilities of Insider Information Holders - Directors, senior management, and other insiders are prohibited from leaking insider information or engaging in insider trading [3][12] - The company must ensure that the number of individuals aware of insider information is minimized before public disclosure [12][25] - Any insider who violates confidentiality or engages in insider trading will face penalties, and the company will report such incidents to regulatory authorities [12][29] Group 3: Documentation and Reporting - The company is required to maintain detailed records of insider information and the individuals who have access to it, including their names, roles, and the specifics of the information [10][11] - A memorandum documenting the progress of significant corporate actions must be created and submitted to the Shenzhen Stock Exchange within five trading days after the information is disclosed [9][10] - The company must regularly review and update the insider information records to ensure accuracy and compliance with regulations [11][12]