申通地铁: 申通地铁信息披露事务管理制度

Core Points - The document outlines the information disclosure management system of Shanghai Shentong Metro Co., Ltd. to enhance the quality of information disclosure and protect investors' rights [1][2] - The system applies to various stakeholders including the board of directors, senior management, and major shareholders [1][2] - It emphasizes the importance of timely, accurate, and complete information disclosure, prohibiting any misleading statements or omissions [2][3] Group 1: Information Disclosure Obligations - The board and senior management must ensure that disclosed information is truthful, accurate, and complete [2][3] - Insider information must not be disclosed before legal disclosure, and any misuse of such information for trading is prohibited [2][3] - Information can be voluntarily disclosed as long as it does not conflict with legally required disclosures [3][4] Group 2: Reporting Requirements - The company must disclose periodic reports including annual and interim reports, which should be audited and approved by the board [6][7] - Annual reports must be completed within four months after the fiscal year-end, while interim reports should be completed within two months after the first half of the fiscal year [6][7] - Reports must include significant financial data, shareholder information, and any risks that could impact the company's operations [6][7][8] Group 3: Management of Major Events - The company must immediately disclose any major events that could significantly affect its securities trading [26][27] - Major events include significant changes in business operations, major investments, or any legal issues [26][27] - The company must also disclose any changes in major shareholders or control that could impact its governance [26][27] Group 4: Internal Management and Compliance - The board of directors is responsible for establishing and implementing the information disclosure management system [5][13] - The board secretary coordinates the disclosure process and ensures compliance with legal requirements [5][13] - Regular evaluations of the information disclosure management system are required to ensure its effectiveness [17][18] Group 5: Legal Responsibilities - The company and its information disclosure obligors are subject to supervision by regulatory bodies such as the China Securities Regulatory Commission [69][70] - Directors and senior management are held accountable for the accuracy and completeness of disclosed information [71][72] - Any violations of disclosure regulations may result in penalties or corrective actions [17][69]