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悍高集团: 内幕信息知情人登记管理制度

General 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 Board of Directors is designated as the management body for insider information, and no department or individual may disclose insider information without Board approval [2][3] Definition and Scope of Insider Information - Insider information refers to undisclosed information that significantly impacts the company's operations, finances, or securities market prices [4][5] - Categories of insider information include major changes in business policies, significant investments, important contracts, major debts, and significant losses [4][5][6] Insider Information Recipients - Insider information recipients include company directors, senior management, shareholders holding more than 5% of shares, and other personnel who can access insider information due to their roles [3][4] - Specific categories of insider information recipients also encompass individuals involved in significant events that could affect the company's securities trading prices [3][4] Registration and Record-Keeping - The company must maintain a record of insider information recipients, including their names, positions, and the nature of the insider information they are privy to [6][8] - The Board of Directors is responsible for ensuring the accuracy and completeness of the insider information recipient records [6][8] Legal Responsibilities and Penalties - Insider information recipients are obligated to maintain confidentiality and are prohibited from trading or suggesting trades based on insider information [11][12] - Violations of these obligations may result in penalties or legal action, including criminal prosecution if warranted [11][12] Miscellaneous Provisions - The insider information management system is subject to relevant laws and regulations, and any conflicts with existing laws will defer to the latter [14] - The Board of Directors is responsible for the formulation, revision, and interpretation of this system, which takes effect upon approval [14]