General Principles - The company establishes a management system for the shares held by its directors and senior management to strengthen oversight based on relevant laws and regulations [1][2] - This system applies to the management of shares held and traded by the company's directors and senior management [1] Information Reporting and Disclosure - Directors and senior management must report personal information to the company within specified timeframes, including changes in their personal information and shareholdings [2][3] - The company is responsible for ensuring the accuracy and timeliness of the reported data and must disclose trading activities of its directors and senior management [2][3] Shareholding and Trading Restrictions - Directors and senior management are prohibited from transferring shares under certain conditions, including within six months of leaving the company or during investigations [8][9] - There are specific limits on the percentage of shares that can be transferred annually, with a maximum of 25% of their total holdings [5][9] Trading Procedures - Directors and senior management must notify the company in writing of their trading plans at least two trading days in advance for purchases and fifteen trading days for sales [4][5] - Any trading activity must be reported to the stock exchange within two trading days of the transaction [4][5] Violations and Penalties - The company will impose penalties on directors and senior management for violations of trading regulations, which may include warnings, demotions, or legal actions [12][13] - Any profits gained from illegal trading activities must be returned to the company, and the company must disclose the details of such violations [12][13]

General Principles - The management system for the shareholding and trading of Shanghai Phoenix Enterprise (Group) Co., Ltd. aims to strengthen the management of shares held by directors and senior management, based on various laws and regulations [1][2] - This system applies to the shares held by directors and senior management, including those held in others' accounts and through margin trading [1][2] Shareholding Change Reporting Management - The company secretary is responsible for managing the identity information and shareholding data of directors and senior management, ensuring timely reporting to regulatory bodies in case of violations [5][6] - Directors and senior management must report their shareholding information and any changes within specified timeframes [6][7] Restrictions on Shareholding Changes - There are specific prohibitions on share transfers for directors and senior management under certain conditions, such as within six months of leaving the company or during investigations [12][13] - Directors and senior management are prohibited from short-selling the company's shares or engaging in derivative trading based on the company's stock [5][12] Regulations on Share Reduction Behavior - Directors and senior management must adhere to commitments regarding shareholding ratios, holding periods, and methods of reduction [15][16] - During their tenure, they can only transfer up to 25% of their total shareholding from the previous year, with exceptions for certain circumstances [16][17] Information Disclosure Management - Prior to trading, directors and senior management must notify the company secretary of their trading plans, who will verify compliance with disclosure requirements [20][21] - Any share reduction must comply with legal and regulatory disclosure obligations, ensuring the information is truthful and complete [21][22] Accountability - Directors and senior management who violate the trading regulations may face penalties from regulatory bodies and potential internal disciplinary actions [30][31] - The company is responsible for ensuring compliance with the established management system and may take action against those who cause losses through violations [30][31]

Core Viewpoint - The document outlines the management system for the shareholding and trading behavior of directors and senior management at Suzhou Hesheng New Materials Co., Ltd, ensuring compliance with relevant laws and regulations [1][2][3]. Group 1: General Provisions - The system is established to regulate the trading of company shares by directors and senior management, based on various laws including the Company Law and Securities Law [1]. - Directors and senior management must comply with the system, which includes shares held in their name and those held through others [1][2]. Group 2: Information Reporting and Disclosure - Directors and senior management are required to report their personal and family information to the Shenzhen Stock Exchange and the China Securities Depository and Clearing Corporation within specified timeframes [2][4]. - Any changes in shareholding must be reported within two trading days, including details such as the number of shares before and after the change [2][3]. Group 3: Shareholding Management - Directors and senior management must notify the board secretary of their trading plans before executing trades, allowing for risk assessment [3][4]. - There are restrictions on the transfer of shares, including a limit of 25% of total shares held that can be transferred in a year, with exceptions for certain circumstances [5][6]. Group 4: Responsibilities and Penalties - Violations of the regulations may lead to internal disciplinary actions and potential compensation for losses incurred by the company [9][10]. - The document emphasizes the importance of compliance with laws and regulations, with specific penalties outlined for non-compliance [9].