申通地铁: 申通地铁信息披露暂缓与豁免业务内部管理制度

Core Viewpoint - The document outlines the internal management system for information disclosure deferral and exemption at Shanghai Shentong Metro Co., Ltd, emphasizing compliance with relevant laws and regulations to protect investors' rights [1][2]. Group 1: Information Disclosure Management - The company establishes this system to regulate information disclosure deferral and exemption behaviors, ensuring compliance with the Securities Law and Stock Listing Rules [1]. - The methods for deferring or exempting information disclosure include deferring temporary reports, exempting temporary reports, and using aliases or summaries to conceal key information in periodic reports [3][4]. - The company and related disclosure obligors must disclose information truthfully, accurately, completely, timely, and fairly, and must not misuse deferral or exemption to evade disclosure obligations [1][2]. Group 2: Confidentiality and Exemption Criteria - Information that involves state secrets or commercial secrets can be exempted from disclosure if there is sufficient evidence proving that disclosure may violate confidentiality regulations [2][3]. - The criteria for deferring or exempting disclosure of commercial secrets include core technology information that may lead to unfair competition, operational information that may infringe on others' commercial secrets, and other situations that may severely harm interests [2][3]. Group 3: Internal Approval and Documentation - The company must carefully determine deferral or exemption items and take effective measures to prevent leaks of deferred or exempted information [3][4]. - A registration process is required for deferral or exemption decisions, which includes documenting the method of exemption, types of documents involved, and the internal approval process [4][5]. - If the reasons for deferral or exemption are eliminated or if the information becomes difficult to keep confidential, the company must disclose the information promptly [5].