敏感信息管理

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潞安环能: 山西潞安环保能源开发股份有限公司敏感信息管理制度
Zheng Quan Zhi Xing· 2025-08-27 11:24
Core Points - The company has established a sensitive information management system to enhance governance and regulate the disclosure of sensitive information [1][2] - Sensitive information is defined as any information that could significantly impact the trading price of the company's stock and other information recognized as sensitive by regulatory authorities [1] - The system outlines the responsibilities of information disclosure personnel, including those involved in major transactions, asset restructuring, and significant risks [2][4] Group 1: Information Disclosure Responsibilities - The board of directors' office is responsible for collecting, safeguarding, and disclosing sensitive information [2] - Information disclosure personnel must report sensitive matters, including major transactions, daily transactions, related party transactions, and significant risk events [2][4] - Shareholders holding more than 5% of the company's shares must report any changes in their shareholding status that could affect the company [5] Group 2: Reporting and Compliance - Information disclosure personnel are required to report sensitive matters that meet specific thresholds, such as major transactions exceeding 10% of total assets or net assets [5][6] - The company must ensure that any information intended for external reporting is reviewed and approved by the board of directors' office [6][7] - Confidentiality obligations are imposed on information disclosure personnel to prevent insider trading and unauthorized disclosure of sensitive information [7][8] Group 3: Implementation and Effectiveness - The sensitive information management system is effective upon approval by the board of directors [8] - The board of directors retains the authority to interpret and amend the system as necessary [8]
燕京啤酒: 敏感信息排查管理制度(2025年8月)
Zheng Quan Zhi Xing· 2025-08-10 08:16
Core Points - The article outlines the sensitive information management system established by Beijing Yanjing Beer Co., Ltd to enhance the collection, confidentiality, and disclosure of sensitive information, aiming to reduce insider trading and stock price manipulation while protecting the interests of minority investors [2][3][4] Group 1: Sensitive Information Definition and Management - Sensitive information refers to any information that may significantly impact the trading price of the company's stock and derivatives, as well as other information recognized as sensitive by the China Securities Regulatory Commission and Shenzhen Stock Exchange [2][3] - The board of directors is responsible for organizing the identification and management of sensitive information, including the prevention of leaks and ensuring proper reporting [3][4] Group 2: Reporting Obligations - Reporting obligations apply to various stakeholders, including directors, senior management, and significant shareholders, who must establish a reporting system tailored to their respective units [3][4] - Specific categories of sensitive information that require reporting include related party transactions, significant operational events, and sudden incidents that could affect the company's financial status [4][5][6] Group 3: Reporting Thresholds - The company has set specific monetary thresholds for reporting related party transactions, such as transactions exceeding 300,000 yuan with related individuals or 3 million yuan with related entities, which also must exceed 0.5% of the company's latest audited net assets [5][6] - For regular transactions, the thresholds include transactions that exceed 10% of the company's total audited assets or net assets, with absolute amounts specified [7][8] Group 4: Internal Reporting Procedures - Upon becoming aware of sensitive information, obligated individuals must report to the board secretary and relevant departments within two working days, providing both written and electronic documentation [10][11] - The board secretary is responsible for proposing disclosure plans for sensitive information and ensuring compliance with legal and regulatory requirements [10][11] Group 5: Accountability and Penalties - All departments and individuals with knowledge of sensitive information are bound by confidentiality obligations and may face disciplinary actions, including termination, for breaches of these obligations [11][11] - The company reserves the right to pursue legal action against external parties, such as consultants or intermediaries, who disclose sensitive information without authorization [11]
威海广泰: 敏感信息排查管理制度
Zheng Quan Zhi Xing· 2025-06-10 04:17
Core Points - The company has established a system for managing sensitive information to prevent insider trading and protect the interests of small investors [1][2] - Sensitive information is defined as information that could significantly impact the trading price of the company's stock and derivatives [1] - The board secretary is responsible for organizing the identification and management of sensitive information [2][3] Section Summaries General Provisions - The company aims to strengthen the management of sensitive information in accordance with relevant laws and regulations [1] - Sensitive information includes reports and rumors from various media that could affect the company's stock price [1] Sensitive Information and Reporting Standards - Key personnel responsible for identifying sensitive information include board members, senior management, and major shareholders [1][2] - Relevant departments must conduct thorough checks on sensitive information within their scope of responsibility [2] Management Structure - The board secretary is directly responsible for the sensitive information management process [2] - The board office assists in the collection, confidentiality, and disclosure of sensitive information [2] Internal Reporting Procedures - Obligated personnel must report sensitive information immediately to the board office or the board secretary [3] - The board office will analyze reported information and decide on the necessary disclosure procedures [3] Strengthening Internal Supervision - The company will educate board members and senior management on laws and regulations to prevent insider trading [4] - A record of individuals with access to sensitive information will be maintained throughout its lifecycle [4] Supplementary Provisions - The system will be revised in accordance with new laws and regulations [5] - The board of directors is responsible for the interpretation of this system [5]