Workflow
燕京啤酒: 敏感信息排查管理制度(2025年8月)

Core Points - The article outlines the sensitive information management system established by Beijing Yanjing Beer Co., Ltd to enhance the collection, confidentiality, and disclosure of sensitive information, aiming to reduce insider trading and stock price manipulation while protecting the interests of minority investors [2][3][4] Group 1: Sensitive Information Definition and Management - Sensitive information refers to any information that may significantly impact the trading price of the company's stock and derivatives, as well as other information recognized as sensitive by the China Securities Regulatory Commission and Shenzhen Stock Exchange [2][3] - The board of directors is responsible for organizing the identification and management of sensitive information, including the prevention of leaks and ensuring proper reporting [3][4] Group 2: Reporting Obligations - Reporting obligations apply to various stakeholders, including directors, senior management, and significant shareholders, who must establish a reporting system tailored to their respective units [3][4] - Specific categories of sensitive information that require reporting include related party transactions, significant operational events, and sudden incidents that could affect the company's financial status [4][5][6] Group 3: Reporting Thresholds - The company has set specific monetary thresholds for reporting related party transactions, such as transactions exceeding 300,000 yuan with related individuals or 3 million yuan with related entities, which also must exceed 0.5% of the company's latest audited net assets [5][6] - For regular transactions, the thresholds include transactions that exceed 10% of the company's total audited assets or net assets, with absolute amounts specified [7][8] Group 4: Internal Reporting Procedures - Upon becoming aware of sensitive information, obligated individuals must report to the board secretary and relevant departments within two working days, providing both written and electronic documentation [10][11] - The board secretary is responsible for proposing disclosure plans for sensitive information and ensuring compliance with legal and regulatory requirements [10][11] Group 5: Accountability and Penalties - All departments and individuals with knowledge of sensitive information are bound by confidentiality obligations and may face disciplinary actions, including termination, for breaches of these obligations [11][11] - The company reserves the right to pursue legal action against external parties, such as consultants or intermediaries, who disclose sensitive information without authorization [11]