天目药业: 杭州天目山药业股份有限公司内幕信息知情人登记管理制度(2025年8月修订)

Core Viewpoint - The article outlines the insider information management system of Hangzhou Tianmu Mountain Pharmaceutical Co., Ltd., emphasizing the importance of confidentiality and compliance with relevant laws and regulations in managing insider information [1][2]. Group 1: Insider Information Definition and Scope - Insider information is defined as unpublicized information that significantly impacts the company's operations, finances, or stock market prices, as per the Securities Law [2][3]. - Examples of insider information include shareholder and board resolutions, financial reports, major investments, significant changes in business operations, and any legal or regulatory investigations [2][3][4]. Group 2: Insider Information Knowledge Personnel - Insider information knowledge personnel include company directors, senior management, shareholders holding over 5% of shares, and other individuals or entities that acquire insider information through their duties [4][5]. - The company is required to maintain a complete record of all insider information knowledge personnel, including their details and the timeline of their knowledge [5][6]. Group 3: Confidentiality and Management - Insider information must not be disclosed externally before it is publicly announced, and knowledge should be limited to the smallest possible group [6][7]. - External parties receiving insider information must be informed of their confidentiality obligations and the information must be clearly marked as "insider information" [7][8]. Group 4: Accountability and Penalties - The company will impose administrative and financial penalties on insider information knowledge personnel who leak information or engage in insider trading that causes significant harm to the company [9][10]. - Violations of laws and regulations regarding insider information may lead to criminal charges and referral to judicial authorities [10][11].