光峰科技: 内幕信息管理制度（2025年8月）

Core Points - The document outlines the insider information management system of Shenzhen Guangfeng Technology Co., Ltd, emphasizing the importance of fair and transparent information disclosure to protect investors' rights [1][2] - The board of directors is responsible for managing insider information, ensuring accurate and complete registration of insider information personnel [1][4] - Insider information is defined as non-public information that significantly impacts the company's operations, finances, or stock prices [2][3] Group 1: Insider Information Definition - Insider information includes major changes in business policies, significant investments, important contracts, major debts, substantial losses, and changes in shareholding structure [2][3] - The document specifies that insider information must not be disclosed before it is officially published [4][5] Group 2: Insider Information Personnel - Insider information personnel include company directors, senior management, major shareholders, and individuals who gain access to insider information through their roles [3][4] - The company must maintain a minimal number of insider information personnel and ensure they do not trade company stocks or disclose insider information [4][5] Group 3: Management and Reporting Procedures - The company must fill out and maintain an "Insider Information Personnel Archive" and a "Major Event Progress Memorandum" for significant events affecting stock prices [5][6] - The board secretary is responsible for organizing and ensuring the accuracy of these records, which must be kept for at least 10 years [8][9] Group 4: Confidentiality Obligations - Insider information personnel are required to keep insider information confidential and are prohibited from trading stocks based on non-public information [9][10] - The company must educate insider personnel about their confidentiality obligations and the consequences of violations [9][10] Group 5: Legal Compliance and Penalties - Violations of insider information regulations can lead to severe penalties, including criminal charges for serious breaches [10][11] - The company retains the right to pursue legal action against individuals who improperly disclose insider information and cause financial harm [11]