Thalys(SH:603716) Zheng Quan Zhi Xing·2025-08-29 16:52General Principles - The purpose of the insider information management system is to regulate the management of insider information, enhance confidentiality, and maintain the principles of public, fair, and just information disclosure [2][3] - The system is established in accordance with various laws and regulations, including the Company Law and Securities Law of the People's Republic of China [2] Responsibilities - The chairman of the board is the primary responsible person for the management of insider information and must ensure the accuracy and completeness of the insider information records [2][3] - The board secretary is responsible for the daily management of insider information and must cooperate with the chairman in maintaining confidentiality [3] Definition of Insider Information - Insider information refers to non-public information that could significantly impact the company's operations, finances, or stock market prices [3][4] - Specific events that qualify as insider information include major asset restructuring, significant changes in shareholder equity, and other events that could affect stock prices [4][5] Registration and Disclosure of Insider Information - The company must report insider information to the stock exchange when significant events occur, such as major asset restructuring or changes in control [4][5] - Insider information must be documented, including details about the individuals who are privy to such information and the circumstances under which they gained access [5][6] Confidentiality Obligations - Individuals with insider information are required to maintain confidentiality and are prohibited from disclosing or trading based on that information before it is publicly disclosed [5][10] - The company must take necessary measures to limit the number of individuals who have access to insider information [5][11] Record Keeping - The company must maintain detailed records of insider information, including the names and details of individuals who have access to such information, and the circumstances of their access [6][7] - Records must be updated and submitted to regulatory bodies within specified timeframes following the public disclosure of insider information [6][8] Accountability and Penalties - Violations of the insider information management system may result in disciplinary actions, including potential legal consequences for severe breaches [13][14] - The company reserves the right to pursue accountability against individuals or entities that cause losses due to violations of the insider information regulations [13][14]