Antu Biological Information Disclosure Suspension and Exemption System (enacted in October 2025)
Zhengzhou Antu Bioengineering Co., Ltd. Information Disclosure Suspension and Exemption System
Zhengzhou Antu Bioengineering Co., Ltd.
Information disclosure suspension and exemption system
(Enacted in October 2025)
Chapter 1 General Provisions
Article 1 In order to regulate the suspension and exemption of information disclosure of Zhengzhou Antu Bioengineering Co., Ltd. (hereinafter referred to as the "Company"), strengthen the supervision of information disclosure, and safeguard the legitimate rights and interests of the company, the company's investors and other stakeholders, in accordance with the Company Law of the People's Republic of China, the Law of the People's Republic of China on the Protection of State Secrets, and the Securities Law of the People's Republic of China This system is formulated based on the provisions of relevant laws, regulations, normative documents such as the "Measures for the Administration of Information Disclosure by Listed Companies", the "Regulations on the Suspension and Exemption of Information Disclosure by Listed Companies", the "Shanghai Stock Exchange Stock Listing Rules" and the "Shanghai Stock Exchange Self-Regulatory Guidelines for Listed Companies No. 2 - Management of Information Disclosure Matters" and the "Articles of Association of Zhengzhou Antu Bioengineering Co., Ltd." (hereinafter referred to as the "Articles of Association"), combined with the actual situation of the company's information disclosure work.
Article 2 This system shall apply to companies and other information disclosure obligors who, in accordance with the provisions of the Listing Rules and other relevant laws, regulations and normative documents, suspend or exempt from the disclosure of interim reports, and exempt from disclosure in periodic reports and interim reports the content stipulated or required to be disclosed by the China Securities Regulatory Commission (hereinafter referred to as the "China Securities Regulatory Commission") and the Shanghai Stock Exchange.
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.
Chapter 2 Scope and Conditions of Suspension and Exemption from Disclosure of Information
Article 4 The company shall prudently determine the suspension or exemption of information disclosure and implement it after performing internal review procedures. In principle, the scope of suspended or exempted matters should remain the same as when the company's stocks were first listed on the Shanghai Stock Exchange. If it is planned to add suspended or exempted disclosure matters after listing, there should be solid and sufficient evidence, and the scope of suspended or exempted matters should not be expanded arbitrarily.
Article 5 Companies and other information disclosure obligors are exempt 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 lead to violations of state confidentiality regulations and management requirements (hereinafter collectively referred to as state secrets). State secrets as referred to in this system refer to Zhengzhou Antu Bioengineering Co., Ltd. Information Disclosure Suspension and Exemption System that 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 in the fields of politics, economy, national defense, diplomacy, etc. if leaked.
Safety and Benefit Information.
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 company's chairman and board secretary should enhance the legal awareness of keeping state secrets and ensure that the information disclosed does not violate state confidentiality regulations.
Article 6 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 postponed 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 7 After the company and other information disclosure obligors suspend or exempt from disclosure of trade secrets, if any of the following circumstances occurs, they shall promptly disclose the information and explain the main reasons for identifying the information as trade secrets, internal review procedures, and the purchase and sale of company stocks by relevant insiders during the non-disclosure period, etc.:
(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 8 If the relevant information in the periodic report to be disclosed by the company 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 disclosure in the above method, the interim report can be exempted from disclosure.
Chapter 3 Internal Procedures and Reporting of Suspended and Exempted Disclosure Matters
Article 9 If a company decides to suspend or exempt specific information from disclosure, the secretary of the company's board of directors shall be responsible for registering the "Information Disclosure Suspension and Exemption Business Approval Form" (Appendix 1), and after it is signed and confirmed by the chairman of the company, it shall be properly filed and kept by the Securities Affairs Department for a period of ten years. The registration and filing contents generally include:
Zhengzhou Antu Bioengineering Co., Ltd. Information Disclosure Suspension and Exemption System
(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 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 stipulated 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 10 Internal review and approval process for information suspension and exemption from disclosure:
(1) When various departments, subsidiaries or branches of the company encounter matters that are suspended or exempted from disclosure as described in this system, the relevant person in charge should submit the application document for the suspension or exemption of information disclosure, together with relevant information, to the company's securities affairs department as soon as possible;
(2) After the Securities Affairs Department submits the above information to the secretary of the board of directors for review and approval, it will be submitted to the chairman of the board for approval;
(3) If the chairman of the board of directors decides to suspend or exempt specific information from disclosure, after signing and confirming the application documents, the information will be suspended or exempted from disclosure, and the relevant information will be properly archived and kept by the Securities Affairs Department for a period of not less than 10 years;
(4) If the application for suspension or exemption from disclosure is not reviewed and approved by the secretary of the board of directors or approved by the chairman of the board, the company shall promptly disclose it to the outside world in accordance with the provisions of the "Listing Rules" and other relevant laws, regulations, normative documents and the company's "Information Disclosure Management System".
Article 11 Companies and other information disclosure obligors shall submit relevant registration materials that are suspended or exempted from disclosure during the reporting period to the Henan Securities Regulatory Bureau and the Shanghai Stock Exchange within ten days after the annual report, semi-annual report, and quarterly report are announced.
Chapter 4 Punishment
Article 12 The company has established a responsibility 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 occurs in circumstances that should be disclosed in a timely manner as stipulated in this system and fails to be disclosed in a timely manner, which brings 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.
Zhengzhou Antu Bioengineering Co., Ltd. Information Disclosure Suspension and Exemption System
Chapter 5 Supplementary Provisions
Article 13 Matters not covered by this system shall be implemented in accordance with the relevant national laws and regulations, normative documents and the company's Articles of Association. If this system conflicts with laws, regulations, normative documents promulgated by the state in the future, or the company's Articles of Association after being modified through legal procedures, the latest provisions of the relevant laws, regulations, normative documents, and the company's Articles of Association shall apply.
Article 14 This system shall be interpreted by the company's board of directors and shall take effect from the date of review and approval by the board of directors. The same shall apply when it is revised. Zhengzhou Antu Bioengineering Co., Ltd. Information Disclosure Suspension and Exemption System
Attachment 1:
Zhengzhou Antu Bioengineering Co., Ltd. Information Disclosure Suspended and Exempted Matters Approval Form Matters Suspended or Exempted from Disclosure
Application time, application department and personnel
□Suspension of disclosure of interim report
Methods of suspension or exemption: Exemption from disclosure of interim reports
□Exemption from disclosure of relevant content in regular reports and temporary reports□State secrets
Type of suspension or exemption
□Trade secrets
Information disclosure of exempted information □Annual report, semi-annual report, quarterly report documents □Interim report
□Major transactions □Daily transactions □Related transactions □Types of core technical information exempt from disclosure in periodic reports □Names of customers and suppliers in periodic reports
□Others, please specify
Reasons for suspension or exemption from disclosure and
Basis
Suspension of disclosure period
Disclosure that may have consequences for the company or others
impact on life
Whether the suspension or exemption matters have been filled in. Whether the relevant insiders are registered as insiders Yes Yes No Yes No Sign a written confidentiality commitment to apply for the opinion of the department head
Review opinions of the Board Secretary
Approval by the Chairman
Zhengzhou Antu Bioengineering Co., Ltd. Information Disclosure Suspension and Exemption System
Attachment 2:
Zhengzhou Antu Bioengineering Co., Ltd.
Letter of Confidentiality Commitment on Suspension or Exemption of Information Disclosure
As an insider of the __________________ matter of Zhengzhou Antu Bioengineering Co., Ltd., I declare and undertake as follows:
I know and will abide by the relevant contents of the company's "Information Disclosure Suspension and Exemption System";
I promise to keep strictly confidential the information that I know is suspended or exempted from disclosure, and will not leak, report or disseminate any information in any form without authorization before the company discloses information on suspended or exempted disclosure matters;
I promise not to use information that is suspended or exempted from disclosure to buy or sell or recommend others to buy or sell the company's securities and their derivatives, and not to engage in insider trading or cooperate with others to manipulate the trading prices of the company's stocks and their derivatives; I shall not use inside information in investment value analysis reports, research reports and other documents.
If the company's suspension or exemption matters are leaked due to my improper confidentiality, I am willing to bear the corresponding legal responsibility.
Signature or seal of the promisee:
Promisor's ID number:
Signing time: