汇通能源: 信息披露暂缓与豁免事务管理制度

Core Points - The document outlines the information disclosure policy of Shanghai Huitong Energy Co., Ltd, focusing on the conditions under which the company can defer or exempt information disclosure to protect commercial secrets and national security [1][2][3] Group 1: Information Disclosure Conditions - The company can defer or exempt disclosure of information that involves commercial secrets if it meets specific criteria, such as potential harm to competitive advantage or violation of others' commercial secrets [1][2] - Information can also be exempted if it is proven to involve state secrets that could violate national confidentiality regulations [2] - The definition of "commercial secrets" includes non-public technical and operational information that provides economic benefits and is protected by confidentiality measures [2][3] Group 2: Internal Review Procedures - The company must conduct a careful assessment to determine if the information qualifies for deferral or exemption, ensuring that it has not been leaked and that insiders have committed to confidentiality [3][4] - The board secretary is responsible for reviewing and documenting the information that qualifies for deferral or exemption within two trading days [3][4] - Documentation must include the type of report, nature of the information, and internal review procedures, with a retention period of ten years for such records [4][5] Group 3: Disclosure Obligations - If the reasons for deferral or exemption are no longer valid, or if the information becomes difficult to keep confidential, the company must disclose the information promptly [4][5] - The company is required to submit relevant registration materials regarding deferred or exempted disclosures to regulatory authorities within ten days after the publication of annual, semi-annual, or quarterly reports [4][5] Group 4: Responsibilities and Penalties - The chairman of the board is directly responsible for the implementation of this disclosure policy, while department heads are accountable for managing and reporting related matters [5] - Failure to report relevant matters that lead to significant errors in information disclosure may result in administrative and financial penalties for responsible individuals [5]