东方环宇: 东方环宇董事、高级管理人员持股及变动管理制度

Core Viewpoint - The document outlines the management system for the shareholding and trading activities of directors and senior management at Xinjiang Dongfang Huanyu Gas Co., Ltd. (stock code: 603706), emphasizing compliance with relevant laws and regulations to prevent insider trading and ensure transparency in share transactions. Group 1: General Principles - The system aims to strengthen the management of shares held by directors and senior management, clarifying procedures based on various laws and regulations, including the Company Law and Securities Law [1] - This system applies to shares held by directors, senior management, and other specified individuals or organizations [2] Group 2: Trading Declaration - Directors and senior management must submit their trading plans in writing to the board secretary at least three trading days before executing any trades [4] - The board secretary is responsible for verifying compliance with disclosure and significant matters before notifying relevant parties of any potential violations [4] Group 3: Transferable Shares Calculation - Directors and senior management are restricted to transferring no more than 25% of their total shares during their term and within six months after their term ends, with exceptions for certain circumstances [10] - The calculation of transferable shares is based on the total number of shares held at the end of the previous fiscal year [11] Group 4: Prohibited Trading Situations - Directors and senior management are prohibited from trading shares during specific periods, such as 15 days before the annual or semi-annual report announcements [11] - The document specifies conditions under which shares cannot be transferred, including during the first year post-IPO and within six months after leaving the company [16] Group 5: Disclosure of Trading Activities - Directors and senior management must report any changes in shareholding within two trading days, including details of the transaction [14] - The board secretary is responsible for managing and reporting the identity and shareholding data of relevant individuals [15] Group 6: Responsibilities and Penalties - Violations of the system may result in penalties, including warnings, recovery of profits from illegal trades, and potential civil or criminal liability [17][18] - The company must maintain complete records of any violations and report them to regulatory authorities as required [27]