深天马Ａ: 内幕信息知情人登记制度（2025年8月）

General Principles - The purpose of the insider information management system is to regulate the management of insider information, enhance confidentiality, and maintain fairness in information disclosure according to relevant laws and regulations [1][2] - The board of directors is responsible for timely registration and submission of insider information personnel files, ensuring their authenticity and completeness, with the chairman being the primary responsible person [1][2] Scope of Insider Information and Insiders - Insider information refers to non-public information that significantly impacts the company's operations, finances, or stock market prices, including major events that could affect stock trading prices [2][3] - Insiders include company directors, senior management, and other personnel who can access insider information due to their roles or relationships with the company [3][4] Registration and Management of Insider Information - The company must fill out and maintain insider information personnel files, documenting the timeline and details of insider information access before public disclosure [4][5] - Major events such as significant asset restructuring, high ratio stock transfers, and changes in control must be reported to the Shenzhen Stock Exchange along with the insider information personnel files [5][6] Confidentiality and Accountability - Insiders have a confidentiality obligation and must not disclose insider information or use it for trading purposes before it is publicly disclosed [6][7] - The company must ensure that any provision of non-public information to insiders outside of major shareholders is preceded by a confidentiality agreement [8][9] Record Keeping and Reporting - Insider information personnel files and records of major events must be retained for at least ten years from the date of recording [9][10] - The company is required to conduct self-inspections of insider trading activities following the disclosure of major events and report any violations [10][11]