英诺特: 北京英诺特生物技术股份有限公司董事及高级管理人员所持本公司股份及其变动管理制度（2025年8月修订）

Core Points - The document outlines the management system for shares held by directors and senior management of Beijing Innotech Biotechnology Co., Ltd, emphasizing compliance with relevant laws and regulations [1][2][3] - The system aims to prevent insider trading, market manipulation, and short-term trading by establishing clear trading restrictions and reporting obligations for directors and senior management [2][4] Summary by Sections General Principles - The management system is established to enhance oversight of shares held by directors and senior management, in accordance with various laws and regulations [1] - It applies to all shares held directly or indirectly by these individuals, including those held in others' accounts [2] Trading Restrictions - Directors and senior management are prohibited from trading company shares during specific periods, such as 15 days before the annual and semi-annual report announcements and 5 days before quarterly reports [6][7] - A six-month prohibition on reverse trading is enforced after any legal purchase or sale of shares [4] Transfer Limitations - Shares held by directors and senior management cannot be transferred within one year of the company's stock listing or within six months after leaving their positions [8][9] - Additional restrictions apply if the company is under investigation for securities violations or has received administrative penalties [8] Trading Quantity - Directors and senior management can transfer a maximum of 25% of their total shares annually, with exceptions for certain circumstances [7][12] - Newly acquired shares are included in the calculation of transferable shares for the current year [12] Information Disclosure - The company secretary is responsible for managing and reporting the shareholdings of directors and senior management, ensuring compliance with disclosure requirements [14] - Any changes in shareholdings must be reported within two trading days, and detailed plans for share reductions must be disclosed 15 trading days in advance [10][12]