重大信息内部保密

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德方纳米: 重大信息内部保密制度(2025年6月)
Zheng Quan Zhi Xing· 2025-06-09 12:25
Core Points - The document outlines the internal confidentiality system for Shenzhen Defang Nano Technology Co., Ltd, aimed at regulating the handling of significant information to ensure fair disclosure and protect the rights of shareholders and stakeholders [1][2] - The board of directors is designated as the management body for the confidentiality of significant information, with the board secretary responsible for overseeing this work [1][2] - The document defines "significant information" as any undisclosed information that could impact the company's operations, finances, or stock prices [8][9] Summary by Sections General Principles - The internal confidentiality system is established in accordance with relevant laws and regulations, including the Company Law and the Listing Rules [1] - The board of directors and the board secretary are responsible for managing and overseeing the confidentiality of significant information [1][2] Definition and Scope of Significant Information - Significant information includes undisclosed data related to production, operations, and finances that could influence stock trading decisions [8] - The scope encompasses insider information as defined by the Securities Law and other relevant regulations [9] Definition and Scope of Internal Personnel - Internal personnel are defined as individuals who have access to significant information due to their roles within the company [10][11] - This includes directors, senior management, and major shareholders [10][11] Confidentiality Obligations - Internal personnel are required to maintain confidentiality regarding significant information and are prohibited from trading company securities based on undisclosed information [12][13] - The company must ensure timely disclosure of significant information through designated media [15][16] Penalties - Violations of confidentiality obligations may result in penalties, including potential criminal charges for severe breaches [28][29] Miscellaneous Provisions - The document stipulates that any amendments must comply with national laws and regulations, and the board of directors is responsible for the interpretation and modification of the system [31][32]