星宸科技: 内幕信息知情人登记管理制度（草案）（H股发行上市后适用）

General Principles - The purpose of the insider information management system is to regulate the management of insider information, enhance confidentiality, and protect investors' rights according to relevant laws and regulations [2][12] - The system applies to the management of insider information and its informants, including directors, senior management, and departments within the company [2][4] Insider Information Management - The Board of Directors is the management body for insider information, with the Chairman as the primary responsible person and the Board Secretary handling specific tasks [3] - Directors, senior management, and insider information informants are prohibited from disclosing insider information before it is publicly disclosed [3][10] Definition and Scope of Insider Information - Insider information refers to non-public information that significantly impacts the company's operations, finances, or stock trading prices, including major changes in business strategy, significant asset transactions, and major losses [4][5] - The scope of insider information informants includes company directors, senior management, and individuals who can access insider information due to their roles [5][6] Registration and Filing of Insider Information Informants - The company must maintain a record of insider information informants and file this information with the relevant regulatory bodies within five trading days after the information is publicly disclosed [6][7] - The registration file must include detailed personal and professional information about the informants [6] Confidentiality Management - The company must control the flow of insider information to a minimum number of people and ensure that any external disclosure is approved by the Board Secretary [10][11] - Insider information informants are prohibited from trading the company's securities or suggesting others do so before the information is publicly disclosed [10][11] Accountability and Penalties - Violations of the insider information management system can lead to disciplinary actions, including warnings, demotions, or termination of employment [11] - The company reserves the right to pursue legal action against informants who leak insider information and cause significant losses [11][12] Implementation and Effectiveness - The system will take effect upon the company's H-share listing on the Hong Kong Stock Exchange and will replace any previous insider information management systems [12]