Information disclosure suspension and exemption management system of Zhejiang Chengyi Pharmaceutical Co., Ltd. (formulated in August 2025)
Zhejiang Chengyi Pharmaceutical 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 Zhejiang Chengyi Pharmaceutical Co., Ltd. (hereinafter referred to as the "Company") and other information disclosure obligors, urge the company and relevant information disclosure obligors to perform information disclosure obligations in compliance 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" and "Shanghai Stock Exchange Self-Discipline Supervision Guidelines" No. 2 - Management of Information Disclosure Affairs" and the "Articles of Association of Zhejiang Chengyi Pharmaceutical Co., Ltd." (hereinafter referred to as the "Articles of Association") and other provisions, 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 (hereinafter referred to as the "China Securities Regulatory Commission") and stock exchanges in regular reports and temporary reports.
Article 3 Information disclosure obligors refer to the company and its directors, senior managers, shareholders, actual controllers, acquirers, parties involved in major asset reorganization, refinancing, major transactions and other natural persons, units and their related personnel, the bankruptcy administrator and its members, and other entities that bear information disclosure obligations as stipulated by laws, administrative regulations and the China Securities Regulatory Commission.
Article 4 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 5 Companies and other information disclosure obligors shall prudently determine information disclosure suspensions and exemptions and implement them after performing internal review procedures. In principle, the scope of suspended or exempted matters should be consistent with that when the company's shares were first listed on the stock exchange. If it is planned to add suspended or exempted disclosure matters after listing, there should be solid and sufficient evidence.
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 lead to violations of state confidentiality regulations and management requirements (hereinafter collectively referred to as "state secrets").
Article 7 Companies and other information disclosure obligors have the obligation to keep state secrets and shall not disclose state secrets through information disclosure, investor interactive Q&A, press releases, interviews, or any other form.
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Conduct business promotion 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 8 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 belongs to the company’s own business information, customers, suppliers and other other people’s business information, and the 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 9 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 10 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.
Article 11 If a company and other information disclosure obligors postpone the disclosure of an interim report or the relevant contents in an interim report, they shall disclose it in a timely manner after the reasons for the postponement of disclosure are eliminated, and at the same time 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.
Article 12 Information disclosure suspension and exemption business shall be under the unified leadership and management of the company's board of directors. The board secretary is responsible for organization and coordination. The company's board of directors office assists the board secretary in handling specific affairs of information disclosure suspension and exemption.
When relevant departments and personnel report major information or other information that should be disclosed, if they believe that such information needs to be postponed or exempted from disclosure, they should submit a written application to the office of the board of directors and review the submitted application materials.
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Responsible for authenticity, accuracy and completeness.
After receiving the application, the board of directors office will review whether the relevant information complies with laws, regulations, normative documents, Shanghai Stock Exchange business rules and the information disclosure suspension or exemption stipulated in this system, and report the review opinions to the board secretary. After review, the board secretary will report the opinions to the company's chairman, who will make the final decision on the handling of the proposed suspension or exemption from disclosure.
Article 13 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 14 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 interim reports, exemption from disclosure of periodic reports or relevant content in interim 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 interim 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 the disclosure of trade secrets is suspended or exempted, 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 15 Companies and other information disclosure obligors shall submit relevant registration materials that are suspended or exempted from disclosure during the reporting period to the Zhejiang Securities Regulatory Bureau and the stock exchange within ten days after the annual report, semi-annual report, and quarterly report are announced.
Article 16 If the suspension or exemption does not comply with the above provisions or the reasons for the suspension or exemption of disclosure have been eliminated and the time limit has expired, and the relevant information is not disclosed in a timely manner, the company will take corresponding disciplinary measures against the relevant personnel directly responsible, etc., as appropriate, with specific reference to the penalty provisions in the relevant laws, regulations, normative documents and the company's information disclosure management system.
Article 17 If this system conflicts with the laws, regulations, normative documents promulgated by the state in the future or the Articles of Association after being modified through legal procedures, the relevant laws, regulations, normative documents and the Articles of Association of the Company shall be followed.
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Implement the provisions of the "Courtesy", revise them in a timely manner, and submit them to the Board of Directors for review and approval.
Article 18 This system shall be interpreted and revised by the company's board of directors.
Article 19 This system will come into effect on the date it is reviewed and approved by the board of directors.
Board of Directors of Zhejiang Chengyi Pharmaceutical Co., Ltd. August 25, 2025
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