Internal reporting system for major information (revised in September 2025)
Chongqing Zhengchuan Pharmaceutical Packaging Materials Co., Ltd.
Important information internal reporting system
Chapter 1 General Provisions
Article 1 In order to standardize the internal reporting of major information of Chongqing Zhengchuan Pharmaceutical Packaging Materials Co., Ltd. (hereinafter referred to as the "Company" or the "Company"), ensure the rapid transmission, collection and effective management of major information within the company, disclose information in a timely, accurate, comprehensive and complete manner, and safeguard the legitimate rights and interests of investors, in accordance with the "Chinese This system is formulated based on the Company Law of the People's Republic of China, the Securities Law of the People's Republic of China, the Measures for the Administration of Information Disclosure of Listed Companies, the Stock Listing Rules of the Shanghai Stock Exchange, the Articles of Association of Chongqing Zhengchuan Pharmaceutical Packaging Materials Co., Ltd. (hereinafter referred to as the "Articles of Association"), and based on the actual situation of the company.
Article 2 The company's internal reporting system for major information refers to a system that when a situation or event occurs, occurs or is about to occur that may have a greater impact on the trading price of the company's stocks and its derivatives, units, departments and personnel with reporting obligations in accordance with the provisions of this system shall report the relevant information to the chairman and board secretary as soon as possible.
Article 3 The “internal information reporting obligors” referred to in this system include:
(1) Directors and senior managers of the company;
(2) The heads and designated contact persons of various departments, branches and subsidiaries of the company;
(3) Directors, supervisors and senior managers assigned by the company to joint-stock companies;
(4) The company’s controlling shareholders and actual controllers;
(5) Other shareholders holding more than 5% of the company’s shares and related persons of the company (including related legal persons and related natural persons);
(6) Other relevant personnel who may be exposed to significant information.
Article 4 This system applies to companies, wholly-owned subsidiaries, holding subsidiaries and joint-stock companies.
Chapter 2 Scope of Material Information
Article 5 "Major information" as mentioned in this system refers to situations or events that have a greater impact on the trading prices of the company's stocks and their derivatives, including the following:
(1) Matters that the company, wholly-owned subsidiaries and controlled subsidiaries need to submit to the company’s board of directors and shareholders’ meeting (including notices of changes to the date of the shareholders’ meeting) for consideration;
(2) Resolutions of the board of directors, board of supervisors and shareholders’ meeting of the company, wholly-owned subsidiaries and controlled subsidiaries;
(3) The following major transactions have occurred or are expected to occur in various departments or subsidiaries of the company, including:
Purchase or sell assets;
External investment (including entrusted financial management, investment in subsidiaries, etc.);
Provide financial assistance (including interest or interest-free loans, entrusted loans, etc.);
Provide guarantees (including guarantees for holding subsidiaries, etc.);
Lease or lease assets;
Entrust or entrust management of assets and business;
Donate or receive assets;
Creditor's rights and debt restructuring;
Transfer or transfer of research and development projects;
Sign a license agreement;
Waiver of rights (including waiving the right of first refusal, the right to first subscribe for capital contribution, etc.);
Other transaction matters recognized by the Shanghai Stock Exchange.
The above-mentioned purchases and sales of assets do not include the purchase of raw materials, fuel and power, and the sale of products, commodities and other assets related to daily operations. However, the purchase and sale of such assets in the asset replacement are still included.
(4) Among the above-mentioned transactions, items 2 to 4, regardless of the amount, the information reporting obligor must perform reporting obligations. If the remaining transactions meet one of the following standards, they must report in a timely manner:
The total assets involved in the transaction (if there are both book value and appraisal value, whichever is higher) account for more than 10% of the company's latest audited total assets;
The net assets involved in the transaction target (such as equity) (if there are both book value and appraisal value, whichever is higher) account for more than 10% of the company's latest audited net assets, and the absolute amount exceeds 10 million yuan;
The transaction amount (including debts and expenses assumed) accounts for more than 10% of the company's latest audited net assets, and the absolute amount exceeds 10 million yuan;
The profit generated from the transaction accounts for more than 10% of the company's audited net profit in the most recent fiscal year, and the absolute amount exceeds 1 million yuan;
The operating income related to the transaction target (such as equity) in the most recent fiscal year accounts for more than 10% of the company's audited operating income in the most recent fiscal year, and the absolute amount exceeds 10 million yuan;
The net profit related to the transaction object (such as equity) in the most recent fiscal year accounts for more than 10% of the company's audited net profit in the most recent fiscal year, and the absolute amount exceeds 1 million yuan.
If the data involved in the calculation of the above indicators is negative, its absolute value will be used for calculation.
(5) Related transactions (related transactions refer to the transfer of resources or obligations between the company, its holding subsidiaries and other controlled entities and the company’s related parties, including the following transactions):
Transaction matters specified in paragraph (3) of this article;
Purchase raw materials, fuel, and power;
Selling products and commodities;
Providing or accepting labor services;
Entrusted or entrusted sales;
Joint investment with related parties;
Deposit and loan business;
Other matters that may result in the transfer of resources or obligations through agreement;
(6) If any related-party transactions occur that meet one of the following standards, they must be reported in a timely manner:
Related transactions involving a transaction amount of more than 300,000 yuan between the company and related natural persons;
The transaction amount between the company and related legal persons is more than 3 million yuan, and the related transactions account for more than 0.5% of the absolute value of the company’s latest audited net assets;
If a guarantee is provided to a related party, regardless of the amount, the information reporting obligor must report it in advance.
(7) Litigation and arbitration matters:
Major litigation or arbitration matters in which the amount involved accounts for more than 10% of the absolute value of the company's latest audited net assets, and the absolute amount exceeds 10 million yuan;
If the cumulative amount involved in litigation and arbitration matters occurring within twelve consecutive months reaches the above standards, this provision shall apply.
(8) Other major events:
Change the investment project of raised funds;
Revision of performance forecast and profit forecast;
Profit distribution and conversion of capital reserve funds into share capital;
Abnormal stock trading fluctuations and clarification matters;
Major matters involved in convertible corporate bonds;
Company securities issuance, repurchase, equity incentive plan and other related matters;
The company and its shareholders have commitment matters.
(9) Major risk matters:
Incur a major loss or suffer a major loss, with a single loss exceeding 1 million yuan;
The occurrence of major debts and defaults on major unpaid major debts that are due, amounting to more than 1 million yuan;
Possible legal liability for major breach of contract or large compensation liability, amounting to more than 1 million yuan;
Provision for large asset impairment;
The resolutions of the shareholders’ meeting and the board of directors are revoked by the court in accordance with the law;
The company decides to dissolve or is ordered to close down by the competent authorities in accordance with the law;
The company is expected to be insolvent (generally refers to negative net assets);
Major debts have not been paid off when due, or the main debtor becomes insolvent or enters bankruptcy proceedings;
The company’s main assets used for business operations have been sealed up, detained, frozen or mortgaged, pledged or scrapped, accounting for more than 30% of the total assets;
The company’s main bank account is frozen;
Main or all business has come to a standstill;
The company is investigated by competent authorities for suspected violations of laws and regulations, or is subject to major administrative or criminal penalties;
The company’s directors and senior managers are investigated or taken compulsory measures by the competent authorities due to suspected violations of laws and regulations, or are otherwise unable to perform their duties;
Other major risk situations identified by the Shanghai Stock Exchange or the company.
(10) Major changes:
Change the company name, stock abbreviation, company articles of association, registered capital, registered address, main office address and contact number, etc.;
Major changes occur in business policies and business scope;
Change accounting policies and accounting estimates;
The board of directors forms relevant resolutions on domestic and overseas financing plans such as the issuance of new shares, convertible corporate bonds, preferred shares, corporate bonds, etc.;
The company receives corresponding review opinions on its issuance of new shares or other domestic and overseas issuance and financing applications, major asset restructuring matters, etc.;
The shareholding status or control of the company by shareholders or actual controllers who hold more than 5% of the company's shares has or is expected to change significantly; the company's actual controller and other companies it controls engage in the same or similar business as the company have major changes;
There are changes in the company’s directors, general manager, board secretary or financial controller;
Major changes in production and operation conditions, external conditions or production environment (including major changes in industry policies, product prices, raw material procurement, sales methods, major suppliers or customers, etc.);
Entering into important contracts may have a significant impact on the company's assets, liabilities, equity and operating results;
Research and development of new products or approval for production;
New inventions and new patents are approved by the government;
Newly promulgated laws, administrative regulations, departmental rules, and policies may have a significant impact on the company's operations;
Appoint and dismiss accounting firms that audit the company;
The court ruled that the controlling shareholder is prohibited from transferring its shares in the company;
Obtaining additional income that has a significant impact on current profits and losses may have a significant impact on the company's assets, liabilities, equity or operating results;
Other circumstances determined by the Shanghai Stock Exchange or the company.
Article 6 If the company's controlling shareholder or actual controller changes or is expected to change, the company's controlling shareholder shall promptly report the information to the company's chairman and board secretary after reaching an intention on the matter, and continue to report the progress of the change. If a court rules to prohibit the company's controlling shareholder from transferring the company's shares, the company's controlling shareholder should promptly report the information to the company's chairman and board secretary after receiving the court's ruling.
Article 7 If a shareholder holding more than 5% of the company's shares is pledged, frozen, judicially auctioned, placed in custody or set up as a trust, or has his voting rights restricted in accordance with the law, or there is a risk of forced transfer, the shareholder shall report the relevant information to the company's chairman and board secretary in a timely manner.
Chapter 3 Internal Reporting Procedures for Major Information
Article 8 All departments of the company and each subsidiary company shall promptly report to the secretary of the company's board of directors any major information that may occur within the scope of responsibility of the department or the subsidiary company after a major event first touches any of the following points:
(1) When the department or subsidiary company plans to submit the major matter to the board of directors for review;
(2) When the relevant parties plan to conduct consultations or negotiations on the major matter;
(3) When the person in charge of the department, branch, or director, supervisor, or senior manager of the subsidiary knows or should know about the major matter.
Article 9 All departments and subsidiaries of the company shall report to the secretary of the company's board of directors or securities affairs representative the progress of major information matters within the scope of the department's responsibility or the company's in accordance with the following provisions;
(1) If the board of directors or shareholders’ meeting makes a resolution on a major event, the resolution shall be reported in a timely manner;
(2) If the company signs a letter of intent or agreement with the relevant parties regarding a disclosed major event, it shall report the main contents of the letter of intent or agreement in a timely manner; if the content or performance of the above-mentioned letter of intent or agreement undergoes major changes or is terminated or terminated, it shall promptly report the circumstances and reasons for the change or termination;
(3) If a major event is approved or rejected by the relevant department, the approval or rejection should be reported in a timely manner;
(4) If overdue payment occurs in a major event, the reasons for overdue payment and related payment arrangements should be reported in a timely manner;
(5) If a major event involves a main subject matter that is yet to be delivered or transferred, the relevant delivery or transfer matters shall be reported in a timely manner; if the delivery or transfer has not been completed for three months beyond the agreed delivery or transfer period, the reasons, progress and estimated completion time shall be reported in a timely manner, and the progress shall be reported every thirty days thereafter until the delivery or transfer is completed;
(6) If there are other developments or changes in major events that may have a greater impact on the trading prices of the company's stocks and their derivatives, the progress or changes in the events should be reported in a timely manner.
Article 10 Relevant personnel who have the obligation to report major information in accordance with the provisions of this system shall
The major information mentioned in Chapter 2 shall be immediately reported to the company's chairman and board secretary in person or by phone as soon as possible, and written documents related to the major information shall be directly submitted or faxed to the company's board secretary within 24 hours. If necessary, the original shall be delivered by express mail.
Article 11 The secretary to the board of directors shall analyze and judge the reported major information in accordance with relevant laws, regulations, departmental rules, normative documents, the "Shanghai Stock Exchange Stock Listing Rules" and the "Articles of Association". If information disclosure obligations need to be fulfilled, the secretary to the board of directors shall immediately report to the company's board of directors, request the company's board of directors to perform corresponding procedures, and make public disclosures in accordance with relevant regulations.
Article 12 In accordance with the provisions of this system, relevant materials of major information shall be submitted in written form, including but not limited to:
(1) The reasons for the occurrence of important events, the basic situation of all parties, the content of important events, the impact on the company's operations, etc.;
(2) The involved agreements, letters of intent, agreements, contracts, etc.;
(3) Involved government approvals, laws, regulations, court judgments and situation introductions, etc.;
(4) Opinions issued by intermediaries on important matters;
(5) The company’s internal opinions on the approval of major matters.
Chapter 4 Management and Responsibilities of Internal Reporting of Major Information
Article 13 The company implements a real-time reporting system for major information. When situations in Chapter 2 occur, occur, or are about to occur in various departments, branches, holding subsidiaries, and joint-stock companies of the company, those with reporting obligations should report the relevant information to the company’s chairman and board secretary to ensure that it is timely, true, accurate, complete, and free of false or seriously misleading statements or major omissions.
Article 14 The secretary to the company's board of directors and the securities department are specifically responsible for the periodic reports that the company should disclose, including annual reports, interim reports, and quarterly reports. All departments and subsidiaries of the company should submit the content and information involved in the annual report, interim report, and quarterly report to the Securities Department in a timely, accurate, truthful, and complete manner.
Article 15 The company's internal information reporting obligor, who is also the first person responsible for internal information reporting obligations, should formulate a corresponding internal information reporting system based on the actual situation of the unit or department where he or she works, and designate a person who is familiar with the relevant business and regulations as the information reporting liaison person (the liaison person of each department is preferably the department head, and the liaison person for subordinate companies is the financial person in charge or other appropriate personnel according to the actual situation), who is responsible for the collection and arrangement of major information of the department or the company and liaison with the company's board secretary and securities affairs representative. The corresponding internal information reporting system and designated information reporting contact person should be reported to the company's securities department for filing. Important information submission materials must be signed by the first responsible person before being submitted to the chairman of the board and the secretary of the board of directors.
Article 16 The general manager and other senior managers of the company have the responsibility of loyalty and diligence, and should always urge the company's departments, subordinate branches, company holding companies, and joint stock companies to collect, organize, and report important information.
Article 17 Directors, senior managers of a company and other persons who learn about the company's information that should be disclosed due to work relationships, before the relevant information has been publicly disclosed, should limit the number of insiders of the information to the minimum range, keep the relevant information strictly confidential, and are not allowed to leak the company's inside information, engage in insider trading or cooperate with others to manipulate the trading prices of stocks and their derivatives.
Article 18 The secretary of the company's board of directors shall, based on the actual situation of the company, regularly or irregularly conduct communication and training on corporate governance and information disclosure with relevant personnel of the company who have the obligation to report major information, so as to ensure the timely and accurate reporting of major information within the company.
Article 19 If major information mentioned in this system should be reported but is not reported in time, the first person responsible, the contact person and other persons with reporting obligations shall be held accountable; if information disclosure violations result, the relevant persons with reporting obligations shall bear the responsibility; if it causes serious impact or loss to the company, relevant persons with reporting obligations may be given sanctions, including but not limited to criticism, warnings, fines, and even dismissal of their duties, and may be required to bear liability for damages.
Chapter 5 Supplementary Provisions
Article 20 The term "above" in this system includes the original number; the term "more than" does not include the original number.
Article 21 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", the relevant laws, administrative regulations and normative documents of the state and the "Articles of Association" will be implemented, and this system will be revised in a timely manner and submitted to the board of directors for review and approval.
Article 22 The company’s board of directors is responsible for formulating, revising and interpreting this system.
Article 23 This system will come into effect and be implemented on the date it is reviewed and approved by the board of directors. From the date this system comes into effect, the original "Chongqing Zhengchuan Pharmaceutical Packaging Materials Co., Ltd. Major Information Internal Reporting System" will be automatically abolished, and the same will apply when it is revised.
Board of Directors of Chongqing Zhengchuan Pharmaceutical Packaging Materials Co., Ltd.
September 2025