东贝集团: 湖北东贝机电集团股份有限公司董事和高级管理人员持股变动管理制度（2025年8月修订）

General Principles - The company establishes a management system for the shareholding changes of its directors and senior management to maintain market order and clarify rights and obligations [2] - Directors and senior management must be aware of laws prohibiting insider trading and market manipulation before trading company shares [2] Information Reporting and Shareholding Management - Directors and senior management must report personal information to the company secretary at specific times, including when they are newly appointed or when their information changes [3][4] - The company will confirm shareholding information as required by the China Securities Depository and Clearing Corporation [5] Lock-up Periods and Transfer Restrictions - Newly acquired shares by directors and senior management are subject to a lock-up period, with 100% of shares locked for one year post-listing and 75% for subsequent purchases [4][6] - After the lock-up period, a certain percentage of shares will be available for transfer each year, with specific calculations for unlockable shares [6][7] Conditions for Share Transfer - Directors and senior management cannot transfer shares under certain conditions, such as within one year of listing or within six months after leaving the company [21][22] - They must also ensure that related parties do not trade based on insider information [10] Information Disclosure Management - Directors and senior management must disclose share trading activities within two trading days, including details of shareholdings before and after the transaction [28][29] - A reduction plan must be reported before any share reduction, detailing the number of shares and the reasons for the reduction [30][31] Penalties for Violations - The company may impose internal penalties on directors and senior management for violations of laws and regulations, in addition to any external penalties imposed by regulatory authorities [34] Miscellaneous Provisions - The company reserves the right to interpret and amend this management system as necessary, ensuring compliance with national laws and regulations [36][38]