Core Viewpoint - The document outlines the insider information management system of Shenzhen Demingli Technology Co., Ltd., aiming to regulate insider information handling, enhance confidentiality, and prevent insider trading while ensuring fair information disclosure to protect investors' rights [1][2]. Summary by Sections General Principles - The system is established based on relevant laws and regulations, including the Company Law and Securities Law of the People's Republic of China, to ensure the confidentiality of insider information and prevent insider trading [1]. - The Board of Directors is responsible for managing insider information, with the Chairman as the main responsible person and the Board Secretary handling the registration and reporting of insider information [2]. Scope of Insider Information - Insider information refers to non-public information that could significantly impact the company's operations, finances, or stock market prices [3]. - Examples of insider information include major events affecting stock prices, significant changes in financial conditions, and legal actions against senior management [3][4]. Insider Information Recipients - Insider information recipients include company directors, senior management, shareholders holding over 5% of shares, and other individuals who can access insider information due to their roles [4][5]. Registration and Filing of Insider Information Recipients - The company must maintain accurate records of insider information recipients and ensure timely reporting of any changes [5][6]. - All parties involved in significant company matters must complete the insider information recipient records [6][7]. Confidentiality Management and Accountability - Insider information recipients are obligated to maintain confidentiality and are prohibited from disclosing or trading based on insider information before it is publicly disclosed [9][10]. - The company will investigate any violations of confidentiality and take appropriate disciplinary actions, including legal consequences if necessary [11][12]. Miscellaneous Provisions - The system will be effective upon approval by the Board of Directors and will be interpreted by the Board [13].
德明利: 内幕信息知情人登记管理制度（2025年9月）