Core Points - The document outlines the information disclosure management system of Zhejiang Zhongxin Environmental Protection Technology Group Co., Ltd, aiming to ensure the authenticity, accuracy, and completeness of disclosed information to protect investors' rights [1][2][3] Group 1: General Principles - The system defines "information" as any data that could significantly impact the trading prices of the company's securities and related derivatives [1] - "Disclosure" refers to the public announcement of information within specified timeframes and through designated media [1] - The principle of timely disclosure is emphasized, requiring information to be disclosed within two trading days upon triggering disclosure events [1] Group 2: Disclosure Obligations - The document specifies that disclosure obligations fall on the company, its board members, senior management, shareholders, and other relevant parties [2][4] - Information must be disclosed simultaneously to all investors, prohibiting selective disclosure [3][4] - The company must ensure that all shareholders have equal access to disclosed information [5] Group 3: Reporting Procedures - The document outlines the procedures for drafting, reviewing, and disclosing periodic reports, including the roles of various stakeholders such as the board of directors and the audit committee [18][19] - It mandates that the company must report any inability to disclose periodic reports on time, including reasons and proposed solutions [10][11] Group 4: Content of Reports - Required disclosures include annual reports, interim reports, quarterly reports, and any significant events that could impact trading prices [20][21] - The annual report must include financial statements audited by a qualified accounting firm [22][23] Group 5: Confidentiality and Insider Information - The document emphasizes the importance of confidentiality regarding undisclosed significant information, prohibiting insiders from leaking or trading based on such information [34][35] - The company must implement strict measures to protect commercial secrets and ensure that only authorized personnel have access to sensitive information [50][51] Group 6: Responsibilities and Accountability - The board of directors is responsible for ensuring compliance with the disclosure system, with the board secretary coordinating the disclosure activities [25][26] - Violations of the disclosure obligations may result in penalties and legal consequences for responsible individuals [82][83]

General Principles - The purpose of the management measures is to standardize the management of commercial secrets, prevent leakage incidents, and protect the company's legal rights for stable and efficient development in a competitive market [1] - All employees have an obligation to keep the company's commercial secrets confidential [1] - The administrative department is designated as the management department for commercial secrets [1] Scope of Commercial Secrets - Commercial secrets refer to non-public, commercially valuable information that has been protected by the rights holder through appropriate confidentiality measures [3] - Examples of commercial secrets include undisclosed company strategies, cooperation contracts, internal meeting records, financial data, and unpublicized procurement information [3][4] Classification and Management of Commercial Secrets - Commercial secrets are classified into three levels: Level 1, Level 2, and Level 3, based on the potential damage from their disclosure [4][5] - Level 1 secrets are critical to the company's survival and development, with severe consequences if leaked [5] - Level 2 secrets can cause significant damage if disclosed, while Level 3 secrets may lead to general damage [6] Reporting and Transmission of Commercial Secrets - Departments must report information to the company, with urgent matters reported directly to the general manager [7] - Information must be properly labeled and recorded for future reference [7] Confidentiality Regulations and Measures - The chairman of the board is responsible for managing commercial secrets at the board level, while the general manager oversees management-level secrets [8] - Employees must maintain confidentiality and avoid discussing company secrets in public or private settings [8][9] Violations and Penalties - Employees violating the confidentiality measures may face disciplinary actions, including warnings, demotions, or termination [11] - Serious violations may lead to legal consequences and compensation for damages [11] Applicability and Interpretation - The measures apply to the company and its subsidiaries, with any unresolved issues governed by national laws [12] - The board of directors is responsible for interpreting these measures [12]