Core Viewpoint - The document outlines the management system for the shares held by directors and senior management of Zhejiang Xinkai Technology Group Co., Ltd., emphasizing compliance with relevant laws and regulations regarding share trading and insider information [1]. Chapter Summaries Chapter 1: General Principles - The management system is established to regulate the shareholding and trading activities of the company's directors and senior management, in accordance with various laws and regulations [1][2]. - The system applies specifically to the shares held by the company's directors and senior management [1]. Chapter 2: Stock Trading Regulations - Directors and senior management must be aware of laws prohibiting insider trading and market manipulation before trading shares [1]. - Shares held by directors and senior management cannot be transferred under specific conditions, including within one year of the company's stock listing and six months after leaving the company [3]. - Trading restrictions are in place during certain periods, such as before the announcement of annual and quarterly reports [4]. - A maximum of 25% of the total shares held can be transferred annually, with exceptions for certain circumstances [4]. - New shares acquired through various means are subject to specific transfer rules, including a 25% limit on newly unrestricted shares in the year of acquisition [5]. Chapter 3: Information Reporting and Disclosure - The company secretary is responsible for managing and reporting the shareholding data of directors and senior management [7]. - Directors and senior management must report any changes in their shareholdings within two trading days [8]. - Multiple securities accounts held by directors and senior management must be consolidated into one account for reporting purposes [9]. Chapter 4: Supplementary Provisions - The management system will be revised and interpreted by the board of directors, and it will take effect upon approval [11].

Core Points - The document outlines the management measures for the shares held by directors and senior management of Shanghai Yanshan Technology Co., Ltd. to ensure compliance with relevant laws and regulations [1][2][3] Group 1: Management Procedures - The management measures apply to the shares held by directors and senior management, emphasizing the need for compliance with laws regarding insider trading and market manipulation [1][2] - The company secretary is responsible for managing the identity and shareholding data of directors and senior management, including quarterly checks on share trading disclosures [2][7] - Directors and senior management must notify the company secretary in writing of their trading plans before buying or selling shares, and the secretary must verify compliance with relevant regulations [2][5] Group 2: Trading Restrictions - Directors and senior management, along with shareholders holding more than 5% of shares, are prohibited from engaging in margin trading involving the company's stock [2][4] - There are specific periods during which directors and senior management are not allowed to trade the company's shares, including 15 days before the annual and semi-annual reports and 5 days before quarterly reports [5][6] - Directors and senior management must ensure that their immediate family members and related parties do not trade based on insider information [6][7] Group 3: Reporting and Compliance - The company must report any violations of trading regulations by directors and senior management to the relevant authorities and recover any profits made from such violations [5][7] - The company is required to submit accurate and timely reports to the Shenzhen Stock Exchange regarding any changes in shareholding by directors and senior management [3][4] - The document stipulates that any amendments to the management measures must comply with national laws and regulations, and the company must update the measures accordingly [7][8]