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佳都科技: 佳都科技内幕信息知情人登记管理制度(草案)(H股发行并上市后适用)

Core Viewpoint - The draft of the insider information management system aims to enhance the governance structure of Jiadu Technology Group Co., Ltd., ensuring the authenticity, accuracy, completeness, timeliness, and fairness of information disclosure, while preventing the abuse of insider information by insiders [1][13]. Group 1: General Provisions - The management of insider information is the responsibility of the company's board of directors, with the chairman as the primary responsible person [2]. - The board office is tasked with the daily management of insider information, prohibiting any department or individual from disclosing insider information to the outside [2]. Group 2: Scope of Insider Information - Insider information refers to non-public information that significantly impacts the company's operations, finances, or market price of its stocks and derivatives, as defined by the Securities Law [3]. - Non-public information is defined as information not officially disclosed by the company in designated media or websites [3]. Group 3: Responsibilities of Insiders - Insiders, including directors, senior management, and significant shareholders, must strictly adhere to confidentiality obligations and are prohibited from leaking insider information or engaging in insider trading [5][6]. - The company must maintain accurate and complete records of insider information and ensure that all insiders confirm their understanding of confidentiality obligations [6][9]. Group 4: Registration and Record Management - The company is required to maintain a detailed record of insiders, including the timing, location, basis, method, and content of the insider information they are privy to [12]. - The board of directors must ensure the accuracy and completeness of the insider information records, with the chairman and board secretary responsible for signing off on these records [10]. Group 5: Accountability and Training - The company must enhance supervision of insiders and impose penalties for any violations, including potential criminal prosecution for serious offenses [12]. - Ongoing education and training for insiders are essential to ensure they understand their rights, obligations, and legal responsibilities regarding insider information [12].