Zheng Quan Zhi Xing·2025-08-15 12:16General Principles - The company has established an insider information management system to enhance confidentiality and protect investors' rights, in accordance with relevant laws and regulations [2][3] - The board of directors is responsible for the management of insider information, with the board secretary organizing its implementation [2][3] Scope of Application - The insider information management system applies to the company, its subsidiaries with over 50% control, and other companies where the company can exert significant influence [2] Definition of Insider Information - Insider information refers to specific information related to the company's operations, finances, or securities that has not been publicly disclosed and could significantly impact market prices [3][4] - Examples of insider information include major contracts, significant debts, major losses, changes in management, and other critical corporate actions [3][4][5] Insider Information Recipients - Insider information recipients include company directors, senior management, major shareholders, and other individuals who can access insider information due to their roles or relationships with the company [5][6] Registration and Record-Keeping - The company must report insider information recipient records to the Shanghai Stock Exchange for significant events such as major asset restructuring, stock issuance, and other impactful corporate actions [6][9] - The registration must include details such as the recipient's name, position, identification number, and the nature of the insider information [7][8] Confidentiality Obligations - Insider information recipients are required to maintain confidentiality and are prohibited from disclosing or trading based on insider information before it is publicly disclosed [12][13] - The company must ensure that all departments and subsidiaries adhere to the insider information management system and may establish additional confidentiality protocols as needed [11][12] Accountability and Penalties - The company is responsible for investigating any insider trading or information leakage and must report findings to regulatory authorities [12][13] - Violations of the insider information management system may result in administrative and economic penalties, and serious breaches could lead to criminal prosecution [12][13] Implementation and Amendments - The insider information management system will be implemented upon approval by the board of directors and will be subject to amendments in accordance with changes in laws and regulations [14]