ST华通: 内幕信息知情人管理制度（2025年8月）

Core Viewpoint - The article outlines the insider information management system of Zhejiang Century Huatong Group Co., Ltd., emphasizing the importance of confidentiality and compliance with relevant laws to prevent insider trading and ensure fair information disclosure. Group 1: Insider Information Management - The management of insider information is the responsibility of the board of directors, with the chairman as the primary responsible person [1] - All departments and individuals within the company are prohibited from disclosing insider information to external parties [1] - Directors, senior management, and all employees must maintain confidentiality regarding insider information [1] Group 2: Definition and Scope of Insider Information - Insider information refers to non-public information that could significantly impact the company's operations, finances, or stock prices [2] - Examples of insider information include major changes in business strategy, significant asset transactions exceeding 30% of total assets, and major lawsuits or arbitration [2][3] Group 3: Insider Information Recipients - Insider information recipients include company directors, senior management, and external parties involved in significant transactions or decisions [3] - Individuals related to insiders, such as family members or business associates, may also gain access to insider information [3] Group 4: Registration and Documentation - The company must maintain a detailed record of insider information recipients and submit this information to the Shenzhen Stock Exchange within five trading days after the information is publicly disclosed [4] - A memorandum documenting the progress of significant matters must be created and submitted to the exchange [6] Group 5: Confidentiality Obligations - Insider information recipients are obligated to keep information confidential and are prohibited from trading based on insider information [10] - The company must control the number of individuals with access to insider information to the minimum necessary [10] Group 6: Accountability and Compliance - Violations of the insider information management system may result in disciplinary actions against internal personnel and potential legal consequences for external parties [27] - The board of directors is responsible for verifying the accuracy and completeness of insider information recipient records [8]