Haite Biotechnology: Information Disclosure Suspension and Exemption Management System
Wuhan Haite Biopharmaceutical Co., Ltd.
Information disclosure suspension and exemption management system
Chapter 1 General Provisions
Article 1 In order to regulate the suspension and exemption of information disclosure by Wuhan Haite Biopharmaceutical Co., Ltd. (hereinafter referred to as the "Company") and other information disclosure obligors, ensure that the company performs its information disclosure obligations in accordance with laws and regulations, and protect the legitimate rights and interests of investors, in accordance with the "Measures for the Administration of Information Disclosure of Listed Companies", "Regulations on the Administration of Suspension and Exemption of Information Disclosure by Listed Companies", "Shenzhen Stock Exchange Stock Listing Rules", "Shenzhen Stock Exchange Self-Discipline Supervision Guidelines for Listed Companies No. 5 - Management of Information Disclosure Affairs" and "Articles of Association of Wuhan Haite Biopharmaceutical Co., Ltd." (hereinafter referred to as the "Articles of Association") and other laws, regulations and rules, this system is formulated.
Article 2 This system shall apply to companies and other information disclosure obligors that suspend or exempt from disclosure of temporary reports, and exempt from disclosure of content stipulated or required to be disclosed by the China Securities Regulatory Commission and Shenzhen Stock Exchange in regular reports and temporary reports.
Article 3 Companies and other information disclosure obligors shall disclose information truthfully, accurately, completely, timely and fairly, and may not abuse suspension or exemption from disclosure to avoid information disclosure obligations or mislead investors, or engage in illegal activities such as insider trading and market manipulation.
Article 4 Companies and other information disclosure obligors shall prudently determine information disclosure suspensions and exemptions, implement them after performing internal review procedures, and accept the supervision of relevant regulatory authorities.
Chapter 2 Scope and methods of suspension and exemption of information disclosure
Article 5 The company and other information disclosure obligors have conclusive and sufficient evidence to prove that the information to be disclosed involves
and state secrets or other matters whose disclosure may lead to violation of state confidentiality regulations and management requirements (hereinafter collectively referred to as "state secrets"), are exempt from disclosure in accordance with the law.
Article 6 Companies and other information disclosure obligors have the obligation to keep state secrets. They are not allowed to disclose state secrets through information disclosure, investor interactive Q&A, press releases, interviews, or any other form. They are not allowed to conduct business promotions in the name of confidential information.
The chairman of the company and the secretary of the board of directors should enhance the legal awareness of protecting state secrets and ensure that the information disclosed does not violate state confidentiality regulations.
Article 7 If the information to be disclosed by the company and other information disclosure obligors involves trade secrets or confidential business information (hereinafter collectively referred to as "trade 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.
Article 8 After the company and other information disclosure obligors are suspended or exempted from disclosure of business secrets, if any of the following circumstances occurs, they shall disclose it in a timely manner:
(1) The reason for suspension or exemption from disclosure has been eliminated;
(2) It is difficult to keep the relevant information confidential;
(3) Relevant information has been leaked or rumors have appeared in the market.
Article 9 If the relevant information in the periodic report that the company intends to disclose involves state secrets or commercial secrets, it may be exempted from disclosure of this part of the information by using anonymity, summarizing, or concealing key information, etc.
If the relevant information in the interim report to be disclosed by the company and other information disclosure obligors involves state secrets or commercial secrets, it can be exempted from disclosure of this part of the information by using anonymity, summary summary or concealment of key information; if there is still a risk of leakage after the above method is used, the interim report can be exempted from disclosure.
Article 10 If a company and other information disclosure obligors postpone the disclosure of an interim report or the relevant content in an interim report, they shall disclose it in a timely manner after the reasons for the postponement of disclosure are eliminated. At the same time, they shall explain the main reasons for identifying the information as a trade secret, the internal review procedures, and the purchase and sale of securities by relevant insiders during the period of postponement of disclosure, etc.
Chapter 3 Internal Review Procedures for Suspension and Exemption of Information Disclosure
Article 11 If the relevant departments of the company (including controlled subsidiaries) and other information disclosure obligors intend to apply for the suspension or exemption of disclosure of specific information, they shall perform the following internal review procedures:
(1) Relevant departments of the company (including controlled subsidiaries) and other information disclosure obligors should fill in the registration matter form for suspension or exemption from disclosure (see attachment), and submit relevant information to the securities investment department of the company.
(2) The Securities Investment Department shall report the materials to the Secretary of the Board of Directors in a timely manner. The Secretary of the Board of Directors shall be responsible for reviewing whether the application for suspension or exemption of disclosure matters meets the conditions, and shall submit the review opinions to the Chairman of the Company.
(3) The chairman of the board of directors shall make decisions on matters to be suspended or exempted from disclosure.
Article 12 If the company suspends or exempts the disclosure of relevant information, the secretary of the board of directors shall promptly register it on file and the chairman shall sign for confirmation. The company shall properly preserve relevant registration materials, and the retention period shall not be less than ten years.
Article 13 Companies and other information disclosure obligors that suspend or exempt from disclosure of relevant information shall register the following matters:
(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) Types of documents involved in exemption from disclosure, including annual reports, semi-annual reports, quarterly reports, interim reports, etc.;
(3) Types of information exempt 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 14 Companies and other information disclosure obligors shall submit relevant registration materials that are suspended or exempted from disclosure during the reporting period to the Shandong Securities Regulatory Bureau and the Shenzhen Stock Exchange within ten days after the annual report, semi-annual report, and quarterly report are announced.
Chapter 4 Accountability
Article 15 If the suspension or exemption is not in compliance with the above provisions, or there is a violation of the provisions of this system to handle suspension or exemption disclosure business, etc., which brings adverse effects or losses to the company and investors, the company will take corresponding disciplinary measures against the relevant personnel who are directly responsible and the person in charge in accordance with the relevant laws and regulations and the company's management system as appropriate.
Chapter 5 Supplementary Provisions
Article 16 "State secrets" as referred to in this system refers to information that is stipulated in 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.
Article 17 "Business secrets" as mentioned in this system refers to commercial information such as technical information and business information that is not known to the public, has commercial value and has been kept secret by the right holder as stipulated in the relevant national anti-unfair competition laws, regulations and departmental rules.
Article 18 Matters not covered by this system shall be implemented in accordance with the relevant national laws, administrative regulations, departmental rules, normative documents and the Articles of Association. If this system conflicts with laws, administrative regulations, departmental rules, normative documents promulgated by the country in the future, or the Articles of Association that have been modified through legal procedures, the new regulations will apply, and this system will be revised in a timely manner.
Article 19 This system will come into effect after being reviewed and approved by the company's board of directors, and the board of directors will be responsible for interpretation.
Accessories
Registration matters for suspension of disclosure of trade secrets
Securities code: Securities abbreviation: Number: No. X of 20XX
Registration date:
Registration matters Registration content
trade secret
Trade Secrets Confidential Business Information
Exemption from disclosure of interim reports Yes□ No□ Exemption from disclosure of relevant contents in periodic reports Yes□ No□
(1) Methods of exemption from disclosure
Exemption from disclosure of relevant contents in interim reports Yes□ No□
Annual report Yes□ No□ Semi-annual report Yes□ No□ Interim report Yes□ No□
(2) Postponement of information disclosure
Information disclosure document First quarter report Yes□ No□ Third quarter report Yes□ No□
Major transactions Yes □ No □ Daily transactions Yes □ No □ Related transactions Yes □ No □ Major litigation and arbitration Yes □ No □ Customer name Yes □ No Supplier name Yes □ No □ Core technical information Yes □ No □
(3) Suspension of disclosure of information
Type External investment information Yes □ No □ Main business information Yes □ No □ Main holding and joint stock company information Yes □ No □
Sub-Industry/Region/Product Information Yes□ No□
Others (note: please specify later)
(4) Internal audit procedures Whether the internal audit has been completed Yes □ No □
(5) Whether the relevant information has been passed
Has it been disclosed through other means? Yes □ No □ Disclosed through other means
(6) Determined to be a trade secret
(Note: Please specify later)
main reason
(7) Disclosure of information about the company or other parties
(Note: Please specify later)
possible impact on people
(8) Insiders of insider information (Note: Each matter corresponds to a list, which should be reported in the list of insiders of insider information)
Yes □ No □
(9) Resumption of disclosure status (Note: If you fill in “Yes”, you must further fill in the status of resumption of disclosure
)
(10) Other companies deem it necessary
(Note: Please specify later)
Things to register
Chairman: (Signature) Secretary of the Board of Directors: (Signature) Trade secret exemption disclosure registration matters
Securities code: Securities abbreviation: Number: No. X of 20XX
Registration date:
Registration matters Registration content
trade secret
Trade Secrets Confidential Business Information
Exemption from disclosure of interim reports Yes □ No □
(1) Methods of exemption from disclosure
Exemption from disclosure of relevant contents in periodic reports Yes□ No□ Exemption from disclosure of relevant contents in interim reports Yes□ No□
Annual report Yes□ No□ Semi-annual report Yes□ No□ First quarter report Yes□ No□
(2) Ownership of exempted information from disclosure
Information Disclosure Document Third Quarter Report Yes□ No□ Interim Report Yes□ No□
Major transactions Yes □ No □ Daily transactions Yes □ No □ Related transactions Yes □ No □ Major litigation and arbitration Yes □ No □ Customer name Yes □ No Supplier name Yes □ No □ Core technical information Yes □ No □
(3) Categories of information exempt from disclosure
Type of foreign investment information Yes□ No□
Main business information Yes □ No □ Main holding company information Yes □ No □ Industry/region/product information Yes □ No □ Others (Note: Please specify later)
(4) Internal audit procedures Whether the internal audit has been completed Yes □ No □
(5) Whether the relevant information has been passed
Has it been disclosed through other means? Yes □ No □ Disclosed through other means
(6) Determined to be a trade secret
(Note: Please specify later)
main reason
(7) Disclosure of information about the company or other parties
(Note: Please specify later)
possible impact on people
(8) Insider information insiders (Note: Each matter corresponds to a list, which should be reported in the insider information list person list module)
(9) Other companies deem it necessary
(Note: Please specify later)
Things to register
Chairman: (Signature) Secretary of the Board of Directors: (Signature) State secrets exemption from disclosure registration matters
Securities code: Securities abbreviation: Number: No. X of 20XX
Registration date:
Registration matters Registration content
state secret
State secrets and other matters whose disclosure may lead to violations of state confidentiality regulations and management requirements
Exemption from disclosure of interim reports Yes□ No□
(1) Methods exempted from disclosure: Exemption from disclosure of relevant content in periodic reports Yes □ No □ Method
Exemption from disclosure of relevant contents in interim reports Yes□ No□
Annual report Yes□ No□ Semi-annual report Yes□ No□
First Quarter Report Yes□ No□
(2) Exemption from disclosure of information
Third Quarter Report Yes□ No□
Related information disclosure documents
Interim report Yes□ No□
Major transactions Yes □ No □ Daily transactions Yes □ No □ Related transactions Yes □ No □ Major litigation and arbitration Yes □ No □ Customer name Yes □ No Supplier name Yes □ No □
(3) Exemption from disclosure of information
Type Core technology information Yes □ No □Foreign investment information Yes □ No □Main business information Yes □ No □
Information on major holding and participating companies Yes□ No□Industry/region/product information Yes□ No□Other information Yes□ No□
(4) Internal audit procedures Whether the internal audit has been completed Yes □ No □
Chairman: (Signature) Secretary of the Board of Directors: (Signature)