首药控股: 首药控股（北京）股份有限公司董事和高级管理人员所持本公司股份及其变动管理办法（2025年8月）

Core Viewpoint - The document outlines the management measures for the shares held by directors and senior management of Shouyao Holdings (Beijing) Co., Ltd, emphasizing the regulations and procedures for share transactions to ensure compliance with relevant laws and regulations [1][8]. Summary by Sections Management of Shareholding - The shares held by directors and senior management include those registered in their names and those held through others' accounts, as well as shares in their credit accounts if engaged in margin trading [1]. - Directors and senior management are prohibited from short selling the company's shares [1]. Trading Restrictions - Directors and senior management cannot buy or sell company shares during specific periods, including 15 days before annual and semi-annual reports, 5 days before quarterly reports, and during significant events until disclosure [1]. - Shares cannot be transferred within one year of the company's stock listing or within six months after leaving the company [2]. Transfer Limits - The maximum shares that directors and senior management can transfer in a year is capped at 25% of their total holdings, with exceptions for certain circumstances [3]. - Newly acquired shares can be transferred at a rate of 25% in the year of acquisition, while limited shares count towards the next year's transferable amount [4]. Disclosure Requirements - Directors and senior management must report and disclose their share transfer plans to the Shanghai Stock Exchange 15 trading days before selling [10]. - After completing a transfer, they must report to the exchange within two trading days [5]. Compliance and Reporting - Any changes in shareholding must be reported within two trading days, including details of the change [12]. - Violations of securities laws regarding share transactions result in the company reclaiming profits from the directors and senior management [6]. Additional Provisions - The document states that if the company's articles of association impose stricter conditions than these measures, those conditions must be followed [9]. - The board of directors is responsible for interpreting and updating these measures as necessary [19].