QM HOME(SH:603818) Zheng Quan Zhi Xing·2025-08-29 17:57Core Points - The article outlines the insider information management system of Qu Mei Home Group Co., Ltd, aimed at regulating insider information management, enhancing confidentiality, and protecting investors' rights [2][3]. Group 1: General Principles - The system is established in accordance with various laws and regulations, including the Company Law and Securities Law, to ensure fair information disclosure and protect investors' rights [2]. - The board of directors is responsible for the management of insider information, ensuring that the insider information registry is accurate and complete before public disclosure [3]. Group 2: Scope of Insider Information - Insider information includes significant changes in business policies, major investments exceeding 30% of total assets, important contracts, major debts, significant losses, and changes in external conditions affecting operations [3][4]. - The definition of insider information also encompasses changes in management, significant shareholder changes, major lawsuits, and any criminal investigations involving the company or its executives [4][5]. Group 3: Insider Information Registrants - Insider information registrants include company directors, senior management, shareholders holding over 5% of shares, and personnel who may acquire insider information due to their roles [8][9]. - The company must maintain a complete record of all individuals who have access to insider information, including the time, method, and content of the information received [9][10]. Group 4: Management and Registration Procedures - The company must ensure that insider information is circulated only within the relevant departments and that any external disclosure is approved by the board secretary [7][8]. - A registration form for insider information registrants must be filled out accurately and submitted to the Shanghai Stock Exchange within five trading days after the information is publicly disclosed [12][18]. Group 5: Confidentiality Management - Insider information registrants are required to maintain confidentiality and are prohibited from disclosing insider information to external parties or using it for personal gain [21][22]. - The company must implement measures to prevent unauthorized access to insider information and ensure that any requests for such information from major shareholders are justified [23][24]. Group 6: Accountability and Penalties - Violations of the insider information management system may result in disciplinary actions, including termination of employment and legal consequences for severe breaches [27][32]. - The company reserves the right to pursue civil liability against individuals who cause losses through unauthorized disclosure of insider information [32][33].