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力合微: 内幕信息知情人管理制度(2025年8月修订)

Core Points - The document outlines the insider information management system of Shenzhen Lihe Microelectronics Co., Ltd, emphasizing the importance of confidentiality and compliance with relevant laws and regulations [3][4][5]. Group 1: Insider Information Management - The management of insider information is the responsibility of the board of directors, with the board secretary organizing its implementation [3]. - Any department or individual must not disclose insider information without board approval, and all external communications must be reviewed by the board secretary [3][4]. - Insider information includes significant changes in business policies, major investments, undisclosed financial reports, and other critical events that could impact stock prices [3][4][5]. Group 2: Insider Information Persons - Insider information persons are defined as individuals who can access insider information before it is publicly disclosed, including company directors, senior management, and significant shareholders [4][5]. - The company must maintain accurate records of insider information persons, including their identities, roles, and the nature of the insider information they are privy to [9][10]. - The company is required to report insider information persons to the Shanghai Stock Exchange in a timely manner, especially during significant corporate events [10][12]. Group 3: Confidentiality and Accountability - Insider information persons are obligated to keep the information confidential and are prohibited from trading company stocks based on insider information [25][28]. - The company will impose penalties on individuals who leak insider information or engage in insider trading, including potential criminal prosecution [29][30]. - The board of directors is responsible for ensuring the accuracy and completeness of insider information records and must report any violations to regulatory authorities [30][31].