Yiming Pharmaceutical: Internal confidentiality system for major information
Tibet Yiming Xiya Pharmaceutical Technology Co., Ltd. Internal confidentiality system for major information
Tibet Yiming Xiya Pharmaceutical Technology Co., Ltd.
Internal confidentiality system for important information
(Revised in April 2026)
Chapter 1 General Principles
Article 1 In order to regulate the internal confidentiality of major information of Tibet Yimingxiya Pharmaceutical Technology Co., Ltd. (hereinafter referred to as the "Company" or the "Company"), ensure the fairness of information disclosure, 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 "Measures for the Administration of Information Disclosure of Listed Companies" , "Shenzhen Stock Exchange Stock Listing Rules", "Shenzhen Stock Exchange Listed Companies Self-Regulatory Guidelines No. 1 - Standardized Operation of Main Board Listed Companies" and other laws and regulations and the provisions of the "Articles of Association of Tibet Yiming Xiya Pharmaceutical Technology Co., Ltd." (hereinafter referred to as the "Articles of Association"), combined with the actual situation of the company, this system is formulated.
Article 2 The Board of Directors is the management agency for internal confidentiality of the company’s major information.
Article 3 The chairman of the board of directors is the first person responsible for the internal confidentiality of the company’s major information; the secretary to the board of directors is the direct person in charge of the company’s internal confidentiality of major information and is responsible for coordinating and organizing specific matters concerning the confidentiality of the company’s inside information; the board of directors’ office is specifically responsible for the supervision and disclosure of the company’s inside information.
Article 4 The secretary of the board of directors and the office of the board of directors are responsible for the reception, consultation (questioning) and services of securities regulatory agencies, Shenzhen Stock Exchange, securities companies and other intermediary institutions, news media, and shareholders.
Article 5 The Office of the Board of Directors is the company’s only information disclosure agency. Without the approval of the board of directors or the consent of the secretary of the board of directors, no department or individual of the company may leak, report, or communicate to the outside world any material information or information disclosure content involving the company. External reporting and transmission of documents, disks, audio and video materials, CDs and other materials involving inside information and information disclosure must be reviewed and approved by the secretary of the board of directors (and reported to the board of directors for review depending on the importance) before they can be reported or transmitted to the outside world.
Article 6 The company’s directors, senior managers and all departments and subsidiaries of the company should do a good job in keeping important information confidential internally.
Article 7 The company, its directors, senior managers and major information insiders shall not disclose the company's major undisclosed information, engage in insider trading or cooperate with others to manipulate securities trading prices.
Tibet Yiming Xiya Pharmaceutical Technology Co., Ltd. Internal confidentiality system for major information
Chapter 2 The meaning and scope of significant information
Article 8 "Major information" as used in this system refers to information known to insiders that involves the company's production, operation, finance and other information or that may have a greater impact on the trading prices of the company's securities and derivatives that have not yet been made public. Not yet public refers to matters that have not yet been officially disclosed in the company's designated media for information disclosure.
Article 9 The scope of material information referred to in this system includes but is not limited to:
(1) Major changes in the company’s business policy and business scope;
(2) The company's major investment behavior and major property purchase decisions. The company's purchase and sale of major assets within one year exceeds 30% of the company's total assets, or the mortgage, pledge, sale or scrapping of the company's main assets for business operations exceeds 30% of the assets at one time;
(3) The company enters into important contracts, provides major guarantees or engages in related transactions, which may have a significant impact on the company's assets, liabilities, equity and operating results;
(4) The company incurs major debts and fails to pay off major debts that are due, or is liable for large amounts of compensation;
(5) The company suffers significant losses or losses;
(6) Major changes in the external conditions of the company’s production and operation;
(7) The company’s directors or managers change and the chairman or manager is unable to perform their duties;
(8) Shareholders or actual controllers who hold more than 5% of the company's shares have major changes in their shareholding or control of the company, and there are major changes in the company's actual controllers and other companies they control that engage in the same or similar business as the company;
(9) The company’s plans for dividend distribution and capital increase, important changes in the company’s equity structure, the company’s decisions on capital reduction, merger, division, dissolution and filing for bankruptcy; or it enters bankruptcy proceedings in accordance with the law and is ordered to close down;
(10) Major lawsuits and arbitrations involving the company, resolutions of the shareholders’ meeting and the board of directors are revoked or declared invalid in accordance with the law;
(11) The company is suspected of violating laws and regulations and is investigated by the competent authorities, or is subject to criminal penalties or major administrative penalties; the company's directors and senior managers are suspected of violating laws and regulations and are investigated by the competent authorities or take compulsory measures;
(12) Newly announced laws, regulations, rules, and industry policies may have a significant impact on the company; Tibet Yimingxiya Pharmaceutical Technology Co., Ltd. Internal Confidentiality System for Major Information
(13) The board of directors forms relevant resolutions on the issuance of new shares or other refinancing plans and equity incentive plans;
(14) A court ruling prohibits the controlling shareholder from transferring its shares; more than 5% of the company's shares held by any shareholder are pledged, frozen, judicially auctioned, placed in custody, established as a trust, or have voting rights restricted in accordance with the law;
(15) The main assets are sealed, detained, frozen or mortgaged or pledged;
(16) Main or all business has come to a standstill;
(17) Providing major external guarantees;
(18) Obtaining large government subsidies and other additional income that may have a significant impact on the company's assets, liabilities, equity or operating results;
(19) Change accounting policies and accounting estimates;
(20) Because the information previously disclosed contains errors, is not disclosed in accordance with regulations, or is falsely recorded, it is ordered to make corrections by relevant authorities or is corrected as decided by the board of directors;
(21) Information related to the company’s performance, profit distribution and other matters, such as financial performance, profit forecast, profit distribution and conversion of capital reserve funds into share capital, etc.;
(22) Information related to company acquisitions, mergers, asset restructuring and other matters;
(23) Information related to the company's business matters, such as developing new products and new inventions, formulating major future business plans, obtaining patents and government department approvals, and signing major contracts;
(24) Information related to transactions and related party transactions that should be disclosed;
(25) Other important information that has a significant impact on securities trading prices as determined by the securities regulatory authority of the State Council.
Chapter 3 The meaning and scope of insiders of inside information
Article 10 An insider of inside information refers to a person who can obtain inside information or major information before the inside information is made public.
Article 11 The scope of insiders of inside information includes but is not limited to:
(1) Directors, supervisors (if any) and senior managers of the company and its controlled subsidiaries;
(2) Personnel within the company who participate in the planning, demonstration, decision-making and other aspects of major matters;
(3) Financial personnel, internal auditors, and information personnel who know inside information due to their positions in the company Tibet Yiming Xiya Pharmaceutical Technology Co., Ltd. Internal Confidentiality System for Major Information
Disclosure staff, etc.;
(4) Natural person shareholders holding more than 5% of the company’s shares;
(5) Directors, supervisors and senior managers of legal person shareholders holding more than 5% of the company’s shares;
(6) The actual controller of the company and its directors, supervisors, and senior managers;
(7) The counterparty and its related parties and their controlling shareholders, actual controllers, directors, supervisors and senior managers;
(8) Employees of accounting firms, law firms, sponsor agencies and other securities service institutions;
(9) Personnel from external units who obtain relevant inside information from the company in accordance with the law;
(10) Personnel from external units involved in the planning, demonstration, decision-making, approval and other aspects of major matters;
(11) Administrative department personnel who have access to inside information;
(12) Other persons who know the company’s relevant inside information due to family relationships, business relationships, etc. of the relevant persons specified in items (1) to (10) above.
(13) Immediate relatives of natural persons who meet the above requirements;
(14) Other insiders specified by the China Securities Regulatory Commission.
Chapter 4 Confidentiality System
Article 12 Before the company's major information is released, internal personnel have the obligation to keep confidential the major information they know and are not allowed to leak, report or transmit the company's relevant information to the outside in any form without authorization.
Article 13: Insiders shall not buy or sell company securities after obtaining major information and before the information is publicly disclosed, nor may they recommend others to buy or sell company securities or seek illegal benefits through other means.
Article 14 Directors, senior managers and other insiders of the company should control the scope of information to the minimum before publicly disclosing the company's information.
Article 15 The company shall ensure that the company’s information is disclosed in designated newspapers or websites within the time limit specified in the information disclosure system for listed companies. Information disclosed in other public media shall not precede the company's information disclosure to designated newspapers or websites. Important information must not be disseminated or posted in any form on the company's internal website or other public websites before it is officially announced.
The company shall not use press conferences or answering questions from reporters as a substitute for the company's official announcement.
Article 16 The company has or is planning to acquire, sell assets, related transactions or other major events Tibet Yiming Xiya Pharmaceutical Technology Co., Ltd. Internal confidentiality system for major information
When doing so, the principle of staged disclosure should be followed and information disclosure obligations should be fulfilled. Before the above-mentioned events are disclosed, directors, senior managers and relevant insiders should ensure that relevant information is kept strictly confidential. If the information is difficult to keep confidential, has been leaked, or the company's stock price has obviously fluctuated abnormally, the company should disclose it immediately.
Article 17 When a company plans to discuss or implement major restructuring, refinancing and other important matters that may have a significant impact on the company's stock price, it shall truthfully and completely record the list of insiders of all insider information in all aspects of reporting, transmission, preparation, review and disclosure of the above information before it is made public, as well as the time when the insider became aware of the inside information. The above records shall be kept together with the project documents and the reporting procedures shall be performed in accordance with relevant laws and regulations.
Article 18 The company shall do a good job in monitoring media information and investigating sensitive information. The investigation of sensitive information shall be led by the Office of the Board of Directors, which shall organize other relevant departments to clean up and investigate the websites and internal publications of the company and its subsidiaries, controlling shareholders and affiliated enterprises. At the same time, the company shall manage the collection, confidentiality and disclosure of sensitive information. When necessary, the Office of the Board of Directors may conduct on-site inspections of various departments and subsidiaries to prevent insider trading and stock price manipulation and effectively protect the interests of small and medium-sized investors. If the company's major information is leaked, the company, in addition to holding the insiders who leaked the information accountable, should immediately report the situation to the Shenzhen Stock Exchange, take immediate public disclosure to remedy the situation, and make the information available to the public.
Article 19 When the company carries out external cooperation or business activities, it must sign a confidentiality agreement with the other party if it involves disclosing the company's confidential information to the other party.
Article 20: Insiders who have the opportunity to obtain major information shall not leak major information to others, or use inside information to benefit themselves, their relatives or others.
Article 21 Non-internal personnel should consciously refrain from inquiring about important information. Non-insiders become insiders once they become aware of material information and are also bound by this system.
Article 22 Internal personnel should properly keep documents, disks, optical disks, audio and video materials, meeting minutes, resolutions and other materials containing important information, and are not allowed to lend them to others for reading or copying, nor are they allowed to be carried or kept by others on their behalf.
Article 23 Staff should take corresponding measures to ensure that relevant major information stored on computers is not accessed or copied.
Article 24 When typists print text materials with important information content, they should set up warning signs, and irrelevant personnel are not allowed to stay on site.
Article 25 Before the announcement of major information, internal personnel shall abide by this system and shall not disclose relevant major Tibet Yimingxiya Pharmaceutical Technology Co., Ltd. Internal Confidentiality System
Information content is leaked, reported, and transmitted to the outside world.
Article 26 Before the announcement of major information, the company's financial and audit staff shall not leak or submit the company's quarterly, interim, and annual statements and related data to the outside world.
Article 27 Company employees shall keep confidential all information related to the company's operations or affairs that they learn during the employment contract period, and shall not disclose any confidential information directly or indirectly to any person, company or institution in any way. Regardless of whether they are employed or profiting from it, employees are not allowed to communicate with any individual, company or institution, or use any confidential information related to the company without authorization or signing of a relevant confidentiality agreement.
Article 28 When a company employee is transferred or resigns, he must hand over the confidential documents or other items under his control to his superior supervisor and shall not hand them over to other personnel at will.
Chapter 5 Punishment
Article 29 If a person with knowledge of major information violates relevant laws, regulations, normative documents and the provisions of this system, causing serious consequences or causing losses to the company, the company will impose the following sanctions on the responsible person based on the severity of the case:
(1) Notify criticism;
(2) Warning;
(3) Demerits;
(4) Fines;
(5) Demotion and salary reduction;
(6) Dismissal and removal;
(7) Termination of labor contract.
The above sanctions may be imposed individually or concurrently, and the person who violates the above provisions may be required to bear liability for damages.
Article 30 If an insider violates the above provisions, causes serious consequences in society, causes serious losses to the company, and constitutes a crime, he or she will be transferred to the judicial authority for criminal liability in accordance with the law.
Article 219 of the Criminal Law of the People's Republic of China Crime of infringement of commercial secrets:
Anyone who commits any of the following infringements of trade secrets and causes heavy losses to the right holder of the trade secrets shall be punished with three penalties: Tibet Yiming Xiya Pharmaceutical Technology Co., Ltd. Internal Confidentiality System for Major Information
Fixed-term imprisonment of not more than three years or criminal detention, and concurrently or solely a fine; if particularly serious consequences are caused, he shall be sentenced to fixed-term imprisonment of not less than three years but not more than seven years, and also fined:
(1) Obtaining the right holder’s business secrets through theft, inducement, coercion or other unfair means;
(2) Disclosing, using or allowing others to use the right holder’s business secrets obtained by means of the preceding paragraph;
(3) Violating the agreement or the obligee's requirement to keep it confidential by disclosing, using or allowing others to use the business secrets in his possession.
Article 180 of the Criminal Law of the People's Republic of China: Crimes of Insider Trading and Disclosure of Insider Information
Persons with knowledge of inside information about securities or futures trading or persons who illegally obtain inside information about securities or futures transactions buy or sell securities, or engage in activities related to such insider information before the issuance of securities, securities or futures transactions or other information that has a significant impact on securities or futures trading prices is made public. Futures trading related to behind-the-scenes information, or leaking such information, and the circumstances are serious, he shall be sentenced to fixed-term imprisonment of not more than five years or criminal detention, and concurrently or solely a fine of not less than one time and not more than five times the illegal income; if the circumstances are particularly serious, he shall be sentenced to fixed-term imprisonment of not less than five years but not more than 10 years, and shall be fined not less than one time but not more than five times the illegal income.
If a unit commits the crime in the preceding paragraph, the unit shall be fined, and the person directly in charge and other directly responsible persons shall be sentenced to fixed-term imprisonment of not more than five years or criminal detention.
Chapter 6 Supplementary Provisions
Article 31 Matters not covered by this system shall be implemented in accordance with relevant laws, administrative regulations, normative documents and the Articles of Association. If this system conflicts with laws, administrative regulations and normative documents promulgated by the state in the future or the revised Articles of Association, this system will be implemented and revised in accordance with the relevant national laws, administrative regulations, normative documents and the Articles of Association.
Article 32 This system shall take effect from the date of review and approval by the company's board of directors, and the same shall apply when it is modified.
Article 33 The right to interpret this system belongs to the company's board of directors.