福然德: 福然德股份有限公司信息披露暂缓及豁免管理制度

Core Points - The article outlines a management system for the deferral and exemption of information disclosure by companies, ensuring compliance with relevant laws and regulations [1][2] - Companies can autonomously determine whether to defer or exempt disclosure of information that involves trade secrets, without needing to apply to the Shanghai Stock Exchange [1][2] - Specific conditions under which companies can defer or exempt disclosure include potential unfair competition, infringement of commercial secrets, and significant harm to interests [1][2][3] Summary by Sections Information Disclosure Management - The system is established to regulate the deferral and exemption of information disclosure, in accordance with the Securities Law and relevant stock exchange rules [1] - Companies are responsible for assessing the need for deferral or exemption based on the nature of the information [1][2] Definition of Trade Secrets - Trade secrets are defined as information that is not publicly known, provides economic benefits, and is subject to confidentiality measures [2] - National secrets are also defined, relating to information that impacts national security and interests [2] Procedures for Deferral and Exemption - Business leaders must submit relevant project materials and reasons for deferral or exemption to the board office for review [2][3] - The board secretary must assess whether the information meets the criteria for deferral or exemption within two trading days [2][3] Documentation and Record-Keeping - Companies must maintain records of deferred or exempted disclosures for at least ten years, including details of the internal review process and insider information [3][4] - Specific information regarding the type of disclosure, internal review procedures, and reasons for deferral must be documented [3] Conditions for Disclosure After Deferral - Companies must disclose information if the reasons for deferral are no longer valid, if confidentiality is compromised, or if the information has leaked [4] - Relevant materials must be submitted to regulatory bodies within ten days following the publication of periodic reports [4]