HQTI(SH:688281) Zheng Quan Zhi Xing·2025-08-21 16:39Core Points - The document outlines the information disclosure deferral and exemption management system for Shaanxi Huaqin Technology Industrial Co., Ltd, aiming to ensure compliance with relevant laws and regulations [1][2] - The system emphasizes the importance of accurate, complete, and timely information disclosure while prohibiting the misuse of deferral or exemption to mislead investors [2][3] - It establishes internal review procedures for determining deferral and exemption matters, requiring documentation and approval from the board of directors [5][8] Group 1: General Principles - The purpose of the system is to regulate the deferral and exemption of information disclosure, ensuring compliance with the Securities Law and other relevant regulations [1] - Information disclosure obligors include the company, its directors, senior management, core technical personnel, shareholders, and other related parties [2] - The company must not abuse deferral or exemption to evade disclosure obligations or engage in insider trading [2][3] Group 2: Scope of Deferral and Exemption - Information can be deferred or exempted if it involves state secrets or other matters that may violate confidentiality regulations [3][4] - Commercial secrets can also be deferred or exempted if disclosure could lead to unfair competition or harm the interests of the company or others [4][5] - If the reasons for deferral or exemption are no longer valid, the company must disclose the information promptly [5][6] Group 3: Internal Review Procedures - The company must establish internal procedures for reviewing deferral and exemption requests, which must be approved by the board of directors [5][8] - The board secretary's office is responsible for organizing and coordinating the specific affairs related to deferral and exemption [6][7] - Documentation must be maintained for all deferral and exemption matters, including reasons for deferral and the internal review process [6][10] Group 4: Accountability and Compliance - The company has established a responsibility accountability mechanism for deferral and exemption practices, with potential penalties for non-compliance [7][9] - The system must align with the listing rules and other relevant regulations of the Shanghai Stock Exchange [9][10] - The board of directors is responsible for interpreting and revising the system as necessary [9][10]