General Principles - The information disclosure management system is established to regulate the information disclosure behavior of Shenzhen Lihe Microelectronics Co., Ltd. and related parties, ensuring compliance with laws and regulations while protecting shareholders' rights [1][2] - The term "information" refers to any matter that may significantly impact the trading price of securities or investment decisions, including mandatory disclosures and voluntarily disclosed information by the company [1] Disclosure Timeliness and Responsibilities - Timely disclosure is defined as within two trading days from the triggering event [2] - The system applies to the board of directors, senior management, and other relevant personnel, including shareholders holding more than 5% of shares [2][3] Basic Principles of Disclosure - Information disclosure is a continuous responsibility, requiring strict adherence to legal and regulatory requirements [2][3] - The company must ensure that all shareholders receive information in a truthful, accurate, complete, and timely manner, without any misleading statements or omissions [2][3] Management of Insider Information - The company must establish an insider information management system to limit the number of individuals with access to insider information before its legal disclosure [3][4] - Any insider must not disclose or use insider information for trading purposes before it is publicly disclosed [3][4] Regular Reporting Requirements - The company is required to disclose annual, semi-annual, and quarterly reports, with specific deadlines for each [6][7] - Financial reports must be audited by a qualified accounting firm before disclosure [6][7] Temporary Reporting Requirements - The company must disclose significant transactions that meet certain thresholds, such as asset transactions exceeding 10% of total assets or significant profit impacts [12][13] - Related party transactions must also be disclosed if they exceed specified amounts [15][16] Major Events Disclosure - The company must disclose major events that could significantly affect the trading price of its securities, including legal issues, financial difficulties, or significant operational changes [16][17] - Disclosure must occur at the earliest of specific triggering events, such as board resolutions or when management becomes aware of the event [28][29] Internal Control and Compliance - The company must implement internal controls for financial management and accounting, ensuring compliance with disclosure requirements [51][52] - An audit committee is responsible for overseeing the company's internal controls and external audits [52][53] Confidentiality and Penalties - All personnel with access to undisclosed information are obligated to maintain confidentiality and are prohibited from insider trading [62][63] - Violations of disclosure obligations may result in penalties, and the company reserves the right to pursue legal action against responsible individuals [66][67]
力合微: 信息披露管理制度(2025年8月修订)