上海建工: 《上海建工信息披露暂缓与豁免业务管理办法》

Core Points - The document outlines the management measures for the deferral and exemption of information disclosure by Shanghai Construction Group Co., Ltd. to ensure compliance with relevant laws and regulations [1][2] - The company can defer disclosure of information that is uncertain or classified as temporary business secrets, where timely disclosure may harm the company's interests or mislead investors [1][2] - Information that can be exempted from disclosure includes state secrets and business secrets, where disclosure may violate confidentiality laws or harm the interests of the company and investors [1][2] Summary by Sections Section 1: Definition of Terms - "Business secrets" are defined as technical and operational information that is not publicly known, has commercial value, and is protected by confidentiality measures [2] - Information involving business secrets can be deferred or exempted from disclosure if it falls under specific conditions, such as core technology information or operational information that could harm the company or others if disclosed [2] Section 2: Conditions for Deferral and Exemption - The company must ensure that the information has not leaked, that insiders have committed to confidentiality, and that there are no abnormal fluctuations in stock trading before deferring or exempting disclosure [3][4] - The internal approval process for deferring or exempting disclosure must be documented and submitted to the board office for review [3][4] Section 3: Reporting and Accountability - The company must report any deferred or exempted information to the Shanghai Securities Regulatory Bureau and the Shanghai Stock Exchange within 10 days after the release of periodic reports [4][5] - If the reasons for deferral or exemption are no longer valid, the company must promptly disclose the relevant information and the circumstances surrounding the deferral or exemption [5][6] Section 4: Disclosure Methods - For periodic reports involving state or business secrets, the company may use alternative methods such as abbreviations or summaries to protect sensitive information [5] - A responsibility accountability mechanism is established for non-compliance with the deferral and exemption procedures, with potential penalties for responsible personnel [5][6] Section 5: Implementation and Compliance - The measures outlined in the document will take effect upon approval by the company's board of directors, with the board secretary responsible for interpretation [6]