SUNWAY COMM(SZ:300136) Zheng Quan Zhi Xing·2025-08-14 13:13General Principles - The management system for the shares held by the board and senior management of Shenzhen Sineva Communication Co., Ltd. aims to strengthen the management of shares and maintain market order, in accordance with relevant laws and regulations [1][2]. Scope of Application - This system applies to the shares held by the company's board and senior management, including shares registered in their names and those held through others' accounts [2]. Prohibited Trading Activities - Board members and senior management are prohibited from transferring shares under certain conditions, such as within one year of the company's stock listing or within six months after leaving their position [4][5]. - They are also restricted from trading during specific periods, including 15 days before the announcement of annual or semi-annual reports [5][6]. Shareholding Changes - Any planned transfer of shares must be reported to the stock exchange 15 trading days in advance, detailing the number of shares, reasons for transfer, and other relevant information [6][7]. - After completing a transfer, board members and senior management must report the completion within two trading days [8]. Information Disclosure and Reporting - Board members and senior management must report their personal information to the company at specified times, including when they are newly appointed or when their information changes [9][10]. - Any changes in shareholding must be reported within two trading days, including details of the number of shares before and after the change [11][12]. Accountability and Penalties - Violations of this system may result in penalties, including warnings, demotions, or legal actions, depending on the severity of the violation [13][14]. - The company is responsible for reporting any illegal trading activities to the relevant authorities [14][15]. Additional Provisions - The system also applies to the family members of board members and senior management regarding their trading activities [15][16]. - The board is responsible for the formulation, modification, and interpretation of this system [17].