顺发恒业: 《内幕信息知情人登记管理制度》

Core Points - The article outlines the insider information management system of Shunfa Hengneng Co., Ltd, aiming to enhance confidentiality and ensure fair information disclosure [2][3]. Group 1: General Provisions - The system is established to regulate insider information management and strengthen confidentiality in accordance with relevant laws and regulations [2]. - The Board of Directors is designated as the management body for insider information, with the Chairman and the Board Secretary responsible for maintaining accurate and complete insider information records [2][3]. Group 2: Definition of Insider Information and Insiders - Insider information includes unpublicized information that significantly impacts the company's operations, finances, or stock market prices, as defined by the Securities Law [2][3]. - Insiders are defined as individuals or entities that have direct or indirect access to insider information, including company directors, senior management, and significant shareholders [3][4]. Group 3: Registration and Record-Keeping - The company must maintain a record of insiders prior to the public disclosure of insider information, including details about the timing, location, and nature of the information [5][6]. - In cases of major events such as acquisitions or asset restructuring, a memorandum detailing the process must also be created and submitted to the Shenzhen Stock Exchange within five trading days after disclosure [5][6]. Group 4: Confidentiality Management - Insiders are required to sign confidentiality agreements to acknowledge their obligations and the consequences of breaching these obligations [8][9]. - The company must control the dissemination of insider information within its departments and subsidiaries, requiring approval from department heads for any internal sharing [12][13]. Group 5: Accountability and Penalties - The company is responsible for self-examination regarding insider trading and must report any violations to regulatory authorities within two working days [21]. - Penalties for violations may include disciplinary actions such as warnings, demotions, or termination of contracts, depending on the severity of the breach [21][22].