Meikang Biotech: Information Disclosure Suspension and Exemption Management System (October 2025)
Meikang Biotechnology Co., Ltd.
Information disclosure suspension and exemption management system
Chapter 1 General Principles
Article 1 In order to regulate the suspension and exemption of information disclosure of Meikang Biotechnology Co., Ltd. (hereinafter referred to as the "Company"), ensure that the company and relevant information disclosure obligors (hereinafter referred to as the "information disclosure obligors") perform their information disclosure obligations in compliance with laws and regulations, and protect the legitimate rights and interests of investors, in accordance with the "Company Law of the People's Republic of China", "Securities Law of the People's Republic of China" and "Information of Listed Companies" This system is formulated based on the actual situation of the company's information disclosure work, including the "Information Disclosure Management Measures", the "Shenzhen Stock Exchange GEM Stock Listing Rules" (hereinafter referred to as the "Stock Listing Rules"), as well as relevant laws, regulations, rules and the "Articles of Association of Meikang Biotechnology Co., Ltd." (hereinafter referred to as the "Articles of Association"), the company's "Information Disclosure Management System" and other provisions.
Article 2 This system shall apply to companies that handle information disclosure suspension or exemption business in accordance with the provisions of the Stock Listing Rules and other relevant business rules of the Shenzhen Stock Exchange.
Article 3 If the information to be disclosed by the company and other information disclosure persons is subject to suspension or exemption from disclosure as stipulated in the Stock Listing Rules and other relevant business rules of the exchange, the company shall make its own prudent judgment and accept the subsequent supervision of the Shenzhen Stock Exchange on matters related to the suspension and exemption of information disclosure.
Article 4 The information disclosure obligors referred to in this system refer to the company and its directors, senior managers, shareholders, actual controllers, acquirers, parties involved in major asset reorganizations, refinancings, major transactions and other natural persons, units and their related personnel, bankruptcy administrators and their members, and other entities with information disclosure obligations stipulated by laws, administrative regulations and the China Securities Regulatory Commission.
This system applies to all departments of the company and all subsidiaries within the scope of consolidated statements.
Chapter 2 Applicable circumstances of suspension and exemption of information disclosure
Article 5 If the information to be disclosed by the company and other information disclosure persons is uncertain, is a temporary business secret, etc., and if timely disclosure may damage the interests of the company or mislead investors, the disclosure may be postponed in accordance with the law.
Article 6 Companies and other information disclosure obligors may be exempted from disclosure in accordance with the law if they have solid and sufficient evidence to prove that the information to be disclosed involves state secrets or other matters whose disclosure may cause them to violate relevant state confidentiality regulations and management requirements (hereinafter collectively referred to as "state secrets").
Article 7 If the information to be disclosed by the company and other information disclosure obligors involves business secrets or confidential business information (hereinafter collectively referred to as "business secrets"), if it meets one of the following circumstances and has not been made public or leaked, the disclosure may be suspended or exempted:
(1) It is core technical information, etc., which may lead to unfair competition after disclosure;
(2) It is the company’s own business information, customers, suppliers and other other people’s business information, which after disclosure may infringe the company’s or others’ business secrets or seriously damage the interests of the company or others;
(3) Other circumstances that may seriously damage the interests of the company and others after disclosure.
If the information to be disclosed by the company and other information disclosure obligors is uncertain, is a temporary business secret, etc., and if timely disclosure may harm the company's interests or mislead investors, the disclosure may be postponed in accordance with this system. If suspension of disclosure is adopted, the period of suspension of disclosure or the conditions or circumstances for future disclosure should be clearly stated.
Article 8 Information that is suspended from disclosure shall meet the following conditions:
(1) Relevant information has not been leaked;
(2) The insider of the relevant inside information has promised in writing to keep it confidential;
(3) There are no abnormal fluctuations in the trading of the company’s stocks and their derivatives.
Article 9 "Business secrets" as mentioned in this system refers to technical information and business information that are stipulated in the relevant national anti-unfair competition laws, regulations and departmental rules, are not known to the public, can bring economic benefits to the right holder, are practical, and have been kept secret by the right holder.
The term "state secrets" as mentioned in this system refers to information that is stipulated in the relevant national confidentiality laws, regulations and departmental rules, is related to national security and interests, is determined in accordance with legal procedures, is limited to a certain range of personnel within a certain period of time, and may damage the country's security and interests in the fields of politics, economy, national defense, diplomacy and other fields if leaked.
Chapter 3 Internal Management Procedures for Information Disclosure Suspension and Exemptions
Article 10 Companies and other information disclosure obligors shall prudently determine matters that are suspended or exempted from information disclosure, and take effective measures to prevent the leakage of information that is suspended or exempted from disclosure. They shall not arbitrarily expand the scope of suspended or exempted matters, and shall not abuse the suspension or exemption procedures to avoid the information disclosure obligations that should be fulfilled.
Article 11 The application and approval process for suspension or exemption of information disclosure is as follows:
(1) Relevant departments or subsidiaries of the company or other information disclosure obligors should promptly fill in the "Registration and Approval Form for Information Disclosure Suspension or Exemption Matters" (hereinafter referred to as the "Approval Form", Appendix 1), and submit the aforementioned "Approval Form" signed by the person in charge of the department or subsidiary and other information disclosure obligors. Form", submit a written application to the Securities Affairs Department together with the "Informant Registration Form for Information Disclosure Suspension and Exemption Matters" (Attachment 2), "Confidentiality Commitment Letter for Information Disclosure Suspension and Exemption Matters" (Attachment 3) and other relevant materials, and be responsible for the authenticity, accuracy and completeness of the submitted materials;
(2) The company's securities affairs department is responsible for reviewing whether the information to be suspended or exempted from disclosure meets the conditions for suspension or exemption from disclosure. If necessary, it can be submitted to the secretary of the company's board of directors after countersigning and approval by the relevant departments;
(3) The secretary of the company's board of directors shall review the matters to be suspended or exempted from disclosure and sign his opinions on the "Approval Form";
(4) The chairman of the company shall make the final decision on the handling of matters to be suspended or exempted from disclosure, and sign the Approval Form for confirmation.
Article 12 If the company decides to suspend or exempt specific information from disclosure, the secretary of the company's board of directors shall be responsible for registration, and after signature and confirmation by the chairman of the company, it shall be handed over to the Securities Affairs Department for proper filing and safekeeping. Relevant personnel shall promise in writing to keep it confidential.
Registration matters generally include:
(1) Methods of exemption from disclosure, including exemption from disclosure of temporary reports, exemption from disclosure of periodic reports or relevant content in temporary reports, etc.;
(2) The types of documents involved in the suspension or exemption of disclosure, including annual reports, semi-annual reports, quarterly reports, interim reports, etc.;
(3) Types of information that are suspended or exempted from disclosure, including major transactions, daily transactions or related transactions in temporary reports, names of customers and suppliers in annual reports, etc.;
(4) Internal audit procedures;
(5) Other matters that the company deems necessary to register.
If disclosure is suspended or exempted due to the involvement of trade secrets, in addition to promptly registering the matters specified in the preceding paragraph, it is also necessary to register whether the relevant information has been disclosed through other means, the main reasons for identifying it as a trade secret, the possible impact of disclosure on the company or others, the list of insiders of inside information, and other matters.
Article 13 Where the suspension or exemption from disclosure has been made, the applicant shall pay close attention, continue to track and promptly report the progress of the matter to the Securities Affairs Department.
Article 14 If any of the following circumstances occurs for information that has been suspended or exempted from disclosure, the company and other information disclosure obligors shall promptly verify the relevant situation and disclose it to the public:
(1) Information that has been suspended or exempted from disclosure is leaked or market rumors appear;
(2) The reasons for suspending or exempting disclosure have been eliminated or the time limit has expired;
(3) Abnormal fluctuations occur in the trading of the company’s stocks and their derivatives.
If the reasons for the suspension or exemption of disclosure have been eliminated or the time limit has expired, the company shall promptly announce the relevant information and disclose the reasons for the suspension or exemption of disclosure of the information, the company's internal registration and approval, etc.
Article 15 Companies and other information disclosure obligors shall, within ten days after the announcement of annual reports, semi-annual reports, and quarterly reports, submit relevant registration materials that are suspended or exempted from disclosure during the reporting period to the Securities Regulatory Bureau and the Shenzhen Stock Exchange where the company is registered.
Chapter 4 Punishment
Article 16 The company has established a liability investigation mechanism for information disclosure suspension and exemption business. It will suspend or exempt information that does not fall within the suspension or exemption disclosure conditions stipulated in this system, or if the information that has been suspended or exempted from disclosure is not disclosed in a timely manner under circumstances that should be disclosed in a timely manner as stipulated in this system, causing adverse effects to the company and investors, the company will hold the relevant personnel directly responsible and the person in charge accountable according to the circumstances.
Chapter 5 Supplementary Provisions
Article 17 The company's information disclosure suspension and other matters concerning exemption business must comply with the provisions of the Stock Listing Rules and other relevant business rules of the Shenzhen Stock Exchange.
Article 18 Matters not covered by this system shall be implemented in accordance with the relevant national laws and regulations, normative documents and the Articles of Association. If this system conflicts with laws, regulations, normative documents promulgated by the state in the future, or the Articles of Association after being modified through legal procedures, the latest provisions of the relevant laws, regulations, normative documents, and the Articles of Association shall apply.
Article 19 This system shall take effect and be implemented upon review and approval by the company's board of directors, and the same shall apply when it is modified.
Article 20 The right to interpret this system belongs to the company's board of directors.
Meikang Biotechnology Co., Ltd.
Annex 1 of October 2025
Information Disclosure Suspension or Exemption Registration Approval Form
Application Date: Year Month Date Applicant Applicant Department
□Suspended disclosure Suspended/exempted from disclosure
Matter category
□Exempt from disclosure suspension/exempt from disclosure
Matter content
Suspended/exempt from disclosure
Reasons and basis
Suspension of disclosure period
(if applicable)
Has the inside information been filled in? □ Yes. Yes. Yes. Yes. □ Yes. List of insiders. □ No. No. Written commitment to confidentiality. □ No. Applying organization (department)
Review opinions of the person in charge
Secretary of the Board of Directors
Review comments
Chairman
Review comments
Remarks
Annex 2
Registration form for informants of suspension and exemption matters
Application date: year month day insider
ID number/unified social information and company department/unit
Serial number Name/time of notification Location of notification Method of notification Content of notification Code for registration time Relationship Position
Name
Note 1: If the insider is a unit, the listed company's shareholders, actual controllers, related persons, acquirers, counterparties, etc. should be filled in; if the insider is a natural person, the unit department, position, etc. should also be filled in; Note 2: The method of reporting the information includes but is not limited to interviews, phone calls, faxes, written reports, emails, etc.;
Note 3: When filling in the reported information, you can add additional pages for detailed explanation as needed;
Note 4: The stage of filling in the information includes negotiation and planning, argumentation and consultation, contract conclusion, internal company reporting, transmission, preparation, resolution, etc.; Note 5: If it is a company registration, fill in the name of the company registrant; if it is a company summary, keep the name of the original registrant in the summary form.
Annex 3
Confidentiality Commitment Letter from Insiders of Suspension and Exemption Matters
As an insider of Meikang Biotechnology Co., Ltd. (hereinafter referred to as the "Company"), I (ID number: ) declare and promise as follows:
I clearly understand the contents of the company’s “Information Disclosure Suspension and Exemption System”;
As an insider of the company's suspended or exempted disclosure matters, I have the obligation to keep the information confidential. Before the reasons for the suspended or exempted disclosure matters are eliminated and the time limit expires, I promise not to disclose the information, not to buy or sell the company's stocks and their derivatives, nor to recommend others to buy or sell the company's stocks and their derivatives;
As an insider of the company's suspension or exemption of disclosure matters, I am obliged to actively fill in the company's "Informer Registration Form of Suspension and Exemption Matters" and file it with the company's securities department from the date I learn of the company's suspension or exemption of disclosure matters;
If improper confidentiality leads to the disclosure of matters suspended or exempted from disclosure by the company, I am willing to bear the corresponding legal liability.
Commitment person:
Signing date: year month day