星宸科技: 信息披露管理制度（草案）（H股发行上市后适用）

General Principles - The information disclosure management system is established to regulate the information disclosure behavior of the company, enhance management of disclosure affairs, and protect investors' rights [1][2] - The system applies to various stakeholders including the company, directors, senior management, shareholders, and other parties involved in significant transactions [2][3] Information Disclosure Obligations - The term "information" refers to significant information that could impact the trading price of the company's stock or investment decisions, which has not yet been disclosed to investors [2] - The company must ensure that all disclosed information is true, accurate, complete, and timely, without any misleading statements or omissions [4][5] Disclosure Procedures - The board secretary is responsible for coordinating and organizing the company's information disclosure matters, ensuring compliance with relevant laws and regulations [5][6] - Information must be disclosed through designated media and submitted to the securities regulatory authority for review or filing [2][6] Reporting Requirements - The company is required to disclose periodic reports, including annual, semi-annual, and quarterly reports, within specified timeframes after the end of each reporting period [12][13] - For H shares, the annual report must be disclosed within four months after the fiscal year-end, and the semi-annual report within three months after the first half of the fiscal year [13] Temporary Reports - Temporary reports must be issued for significant events that could impact the company's stock price, and these must be disclosed immediately upon occurrence [38][39] - The company must report any major changes in business operations, significant investments, or other events that could materially affect its financial status [39][40] Confidentiality and Insider Trading - The company and its related parties must not disclose undisclosed significant information before it is made public, and must avoid insider trading [7][24] - Any insider information must be handled with strict confidentiality, and relevant parties must comply with disclosure obligations [24][25] Compliance and Penalties - Violations of the information disclosure management system may result in administrative and economic penalties for responsible individuals, and the company retains the right to pursue legal action [60][61] - The company must maintain accurate records of any information that is temporarily withheld from disclosure, including the reasons and internal approval processes [10][11]