General Principles - The management system for the holding and trading of company stocks by directors and senior management is established to enhance compliance with relevant laws and regulations [2][3] - The system is based on the Company Law, Securities Law, and various self-regulatory guidelines from the Shenzhen Stock Exchange [2] Holding and Reporting Requirements - Directors and senior management must ensure that their stock holdings are reported accurately and timely to the Shenzhen Stock Exchange [4][5] - They are required to submit personal and family information for reporting within specified timeframes, such as within two trading days after a change in their status [4][5] Restrictions on Trading Company Stocks - Directors and senior management must notify the board secretary of their trading plans in writing before executing any trades [7][8] - There are limits on the amount of stock that can be transferred annually, capped at 25% of their total holdings, with specific exceptions [8][9] Lock-up and Trading Prohibitions - Stocks held by directors and senior management are subject to lock-up periods, with varying conditions based on the time since the company went public [10][11] - Trading is prohibited during certain periods, such as 15 days before the release of annual or semi-annual reports [25][26] Disclosure of Trading Activities - Any changes in stock holdings must be reported within two trading days, including details such as the number of shares before and after the change [13][14] - Directors and senior management must disclose their stock trading plans, including the number of shares and the reasons for trading [23][24] Penalties for Non-compliance - Any profits made from buying and selling company stocks within a six-month period must be returned to the company [21] - The board of directors is responsible for enforcing these rules and may impose penalties for violations [21][22]
悍高集团: 董事、高级管理人员持有和买卖公司股票管理制度