中大力德: 内幕信息知情人管理制度（2025年8月）

Core Viewpoint - The company has established a comprehensive insider information management system to ensure confidentiality, protect investor rights, and comply with relevant laws and regulations regarding insider information disclosure. Group 1: General Provisions - The board of directors is responsible for managing insider information, with the chairman as the primary person accountable for confidentiality [1] - Any department or individual must not disclose insider information without board approval, and all external communications must be reviewed by the board secretary [2] Group 2: Scope of Insider Information - Insider information includes significant changes in business strategy, major investments, important contracts, and any information that could materially affect stock prices [3][4] - Individuals who can access insider information include company directors, senior management, major shareholders, and certain external parties involved in business dealings [8] Group 3: Insider Information Registration Management - The company must maintain a record of insider information personnel, including their names, positions, and how they obtained the information [11] - A detailed archive of insider information must be established, documenting the stages of information flow and the individuals involved [12][13] Group 4: Confidentiality Management - All insider information personnel must take necessary measures to limit the knowledge of insider information to the smallest possible group [22] - Individuals with over 5% shareholding must control the information disclosure scope and report any significant market rumors to the board secretary [24] Group 5: Accountability - Violations of insider information regulations can lead to disciplinary actions, including warnings, demotions, or termination of employment [27] - The company must report any insider trading or information leakage incidents to regulatory authorities within two working days [29] Group 6: Training and Implementation - The company is responsible for educating insider information personnel about their rights, obligations, and legal responsibilities to prevent insider trading [32] - The insider information management system will be revised and interpreted by the board of directors, coming into effect upon approval [35]