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佐力药业: 外部信息使用人登记制度(2025年8月)

Core Points - The company has established a system for managing external information users to strengthen the management of individuals who have access to undisclosed significant information [1][2] - The system applies to all departments, subsidiaries, and personnel who can access insider information, including directors and senior management [1] - Insider information includes any undisclosed information that could significantly impact the company's operations, finances, or stock prices [1] Summary by Sections External Information Users - The system defines "external information users" as specific units and personnel authorized to request information from the company, including government departments [1] - The company reserves the right to refuse requests for insider information that do not comply with legal regulations or the company's articles of association [1] Confidentiality Obligations - Directors, senior management, and other relevant personnel have a confidentiality obligation during the preparation of regular and interim reports and major corporate events [2] - Information must not be leaked in any form before public disclosure, including during earnings calls, analyst meetings, or media interviews [2] Information Disclosure Procedures - The company must follow internal procedures for disclosing information, requiring approval from various levels of management before external communication [2] - When disclosing undisclosed information, the company must register the recipients as insider information recipients and inform them of their confidentiality obligations [2] Consequences of Breach - If external information users leak or misuse insider information, the company may pursue compensation based on the severity of the breach [3] - In cases of improper confidentiality leading to leaks, the company must notify the stock exchange and announce the breach promptly [3] Implementation and Amendments - The system is effective from the date of approval by the board of directors and will be revised as necessary [3]