Measures for the Suspension and Exemption of Information Disclosure of Capital Pharmaceutical Holdings (Beijing) Co., Ltd. (August 2025)
Beijing Capital Pharmaceutical Holdings (Beijing) Co., Ltd. Information Disclosure Suspension and Exemption Management Measures
Capital Pharmaceutical Holdings (Beijing) Co., Ltd.
Information Disclosure Suspension and Exemption Management Measures
Chapter 1 General Provisions
Article 1 In order to strengthen the management of the information disclosure of Capital Pharmaceutical Holdings (Beijing) Co., Ltd. (hereinafter referred to as the "Company" or the "Company"), further standardize the company's information disclosure suspension and exemption procedures, and protect the legitimate rights and interests of the company, shareholders and other stakeholders, in accordance with the "Securities Law of the People's Republic of China", "Listed Companies Information Disclosure Management Measures", "Listed Companies Information Disclosure Suspension and Exemption Management Regulations" and "Self-discipline Supervision Guidelines for Companies Listed on the Science and Technology Innovation Board of the Shanghai Stock Exchange No. 1" No. - Standardized Operation" (hereinafter referred to as the "Standardized Operation Guidelines") and the "Shanghai Stock Exchange Science and Technology Innovation Board Stock Listing Rules" (hereinafter referred to as the "Listing Rules") and other laws, regulations, normative documents and the relevant provisions of the "Articles of Association of Capital Pharmaceutical Holdings (Beijing) Co., Ltd." (hereinafter referred to as the "Articles of Association") and the "Information Disclosure Management Measures of Capital Pharmaceutical Holdings (Beijing) Co., Ltd." (hereinafter referred to as the "Information Disclosure Measures"), and based on the actual situation of the company, these Measures are formulated.
Article 2 These Measures shall apply when the company handles information disclosure suspension or exemption business in accordance with the provisions of the "Listing Rules", "Standardized Operation Guidelines" and other relevant business rules of the Shanghai Stock Exchange.
Article 3 If the information that a company should disclose is subject to suspension or exemption stipulated in the Listing Rules, Standardized Operation Guidelines and other relevant rules of the Shanghai Stock Exchange, the company shall make its own prudent judgment and may suspend or exempt the disclosure after internal approval of the company in accordance with these Measures, and accept the Shanghai Stock Exchange's supervision of relevant information disclosure suspensions and exemptions.
Chapter 2 Scope of Suspension and Exemption from Disclosure of Information
Article 4 If the company and the relevant information disclosure obligors 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"), they are exempt from disclosure in accordance with the law.
Companies and relevant information disclosure obligors shall earnestly fulfill their obligations to keep state secrets and shall not disclose state secrets through information disclosure, investor interactive Q&A, press releases, interviews, or any other form, and shall not 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.
Beijing Capital Pharmaceutical Holdings (Beijing) Co., Ltd. Information Disclosure Suspension and Exemption Management Measures
Article 5 If the information to be disclosed by the company and the relevant 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 6 After the company and the relevant 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 stocks of listed companies 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.
Chapter 3 Management Process
Article 7 Persons with information disclosure obligations shall prudently determine the matters that are suspended or exempted from information disclosure, and take effective measures to prevent the leakage of information that is suspended or exempted from disclosure. They shall not arbitrarily expand the scope of suspended or exempted matters, and shall not abuse the suspension or exemption procedures to avoid the information disclosure obligations that should be fulfilled.
Article 8 Relevant departments or subsidiaries of the company, the company’s controlling shareholders, actual controllers and shareholding If more than 5% of shareholders, directors, senior managers and other relevant personnel report major information or other information that should be disclosed to the company's board of directors office in accordance with the company's "Information Disclosure Measures" and believe that such information needs to be suspended or exempted from disclosure, they should submit a written application to the company's board of directors office. The application materials include but are not limited to: "Internal Registration Approval Form for Information Disclosure Suspension and Exemption Matters" and "Confidentiality Commitment Letter from Insiders of Suspension and Exemption Matters". They are responsible for the authenticity, accuracy and completeness of the submitted materials.
Article 9 After receiving the application, the Office of the Board of Directors shall immediately review whether the relevant information complies with the suspension or exemption from disclosure stipulated in the securities regulatory rules, and report the review opinions to the chairman of the company for confirmation.
Article 10 Companies shall prudently determine matters that are suspended or exempted from disclosure of information, and take effective measures to prevent the leakage of information that is suspended or exempted from disclosure.
If the company decides to suspend or exempt specific information from disclosure, the secretary of the company’s board of directors shall be responsible for the Management Measures for the Suspension and Exemption of Information Disclosure of Capital Pharmaceutical Holdings (Beijing) Co., Ltd.
After registration, and signature and confirmation by the chairman of the company, it shall be properly filed and kept for a period of not less than ten years. Companies and other information disclosure obligors that suspend or exempt relevant information from disclosure should 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 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 11 Companies and other information disclosure obligors shall, within ten days after the announcement of annual reports, semi-annual reports, and quarterly reports, submit relevant registration materials that are suspended or exempted from disclosure during the reporting period to the Securities Regulatory Bureau and the Shanghai Stock Exchange where the company is registered.
Article 12 If information that has been suspended or exempted from disclosure is leaked or market rumors appear, causing significant fluctuations in the trading prices of the company's stocks and their derivatives, the company shall promptly verify the relevant information and disclose it to the public.
If the reasons for the suspension or exemption of disclosure have been eliminated or the time limit has expired, the company shall promptly announce the relevant information and disclose the reasons for the suspension or exemption of disclosure of the information, the company's internal registration review, etc.
Article 13 The company has established a liability investigation mechanism for the suspension or exemption of information disclosure. If the suspension or exemption does not meet the above provisions, or the reasons for the suspension or exemption have been eliminated and the time limit has expired, and the relevant information is not disclosed in a timely manner, corresponding disciplinary measures will be taken against the relevant personnel who are directly responsible and the person in charge. Specifically, refer to the accountability clauses in the "Information Disclosure Measures".
Chapter 4 Supplementary Provisions
Article 14 Matters not covered in these Measures shall be implemented in accordance with relevant laws, regulations, departmental rules, the Articles of Association and the Information Disclosure Measures.
Beijing Capital Pharmaceutical Holdings (Beijing) Co., Ltd. Information Disclosure Suspension and Exemption Management Measures
Article 15 The Board of Directors is responsible for the interpretation and revision of these Measures.
Article 16 These Measures shall come into effect on the day they are reviewed and approved by the Board of Directors.
Capital Pharmaceutical Holdings (Beijing) Co., Ltd.
August 2025