Lisheng Pharmaceutical: Management Measures for External Information Users of Tianjin Lisheng Pharmaceutical Co., Ltd. (revised in January 2026)
Tianjin Lisheng Pharmaceutical Co., Ltd. Management Measures for External Information Users
Tianjin Lisheng Pharmaceutical Co., Ltd.
Measures for the Management of External Information Users
(Revised in year and month)
2026 1
Chapter 1 General Principles
Article 1 In order to further strengthen the management of information disclosure of Tianjin Lisheng Pharmaceutical Co., Ltd. (hereinafter referred to as the "Company" or "the Company"), standardize the reporting and use management of external information, ensure fair information disclosure, and avoid insider trading. These Measures are formulated in accordance with the Company Law of the People's Republic of China, the Securities Law of the People's Republic of China, the Stock Listing Rules of the Shenzhen Stock Exchange, the Articles of Association and other relevant laws and regulations, and in light of the company's actual situation.
Article 2 The scope of application of these Measures includes the company and its departments, branches, wholly-owned and controlled subsidiaries, as well as the company’s directors, senior managers and other relevant personnel.
Article 3 "Information" referred to in these Measures refers to all information that may have a greater impact on the company's stock trading price, including but not limited to regular reports, temporary reports, financial data, major matters that are being planned or need to be submitted for approval, etc.
Article 4 The company’s external information submission shall be subject to hierarchical and classified management. The company's board of directors is the highest management body for external submission of information. The secretary of the company's board of directors is responsible for the supervision of external submission of information. The company's securities affairs department is responsible for assisting the secretary of the board of directors in the daily management of external submission of information. Each responsible unit or relevant personnel of the company shall perform the procedures for external submission of information in accordance with the provisions of these Measures.
Chapter 2 Management and Process of External Information Submission
Article 5 The company’s directors and senior managers shall abide by the requirements of the information disclosure internal control system and perform necessary transmission, review and disclosure processes for the company’s regular reports, major events and other information.
Article 6 The company’s directors, senior managers and other relevant confidential personnel have the obligation to keep confidential during the preparation of periodic reports and the planning of major company events. Before the release of periodic reports, temporary announcements and relevant major event information, the contents of periodic reports, temporary announcements shall not be leaked to the outside world or specific persons in any form or by any means, including but not limited to performance symposiums, analyst meetings, investor surveys, discussions, media interviews and other external reporting methods.
Article 7 Before the annual report is disclosed, the company shall not submit annual statistical statements and other materials in advance to external units without legal and regulatory basis, and shall reject submission requests from external units without legal and regulatory basis.
Tianjin Lisheng Pharmaceutical Co., Ltd. Management Measures for External Information Users
Article 8 When a company submits annual statistical statements and other information to relevant government departments or other external units in accordance with laws and regulations on statistics, tax collection and administration, the time of submission shall not be earlier than the disclosure time of the company's performance forecast or performance bulletin.
Article 9 When a company is conducting business negotiations, bank loans, etc., and it is really necessary to provide undisclosed major information to the other party due to special circumstances, the company should require the other party to sign a confidentiality agreement to ensure that the relevant information will not be leaked to the public, and promise not to buy or sell the company's securities before the relevant information is announced.
Article 10 Before all departments, branches, wholly-owned and controlled subsidiaries of the company and their staff submit information to the outside world in accordance with the provisions of laws and regulations, the handling personnel shall, in accordance with internal office procedures, obtain the review and approval of the head of the department (or the person in charge of the branch company, wholly-owned/holding subsidiary company), the leader in charge of the company's department, and the approval of the secretary of the board of directors before submitting the information to the outside world. If necessary, the information must be approved by the chairman of the board. The person in charge of the external submission of information, department heads, and company department leaders are responsible for the authenticity, accuracy, and completeness of the submitted information, and the board secretary is responsible for the compliance of the submission procedures.
Article 11 When the company's departments, branches, wholly-owned and controlled subsidiaries and their staff provide external units or individuals with the company's undisclosed material information in accordance with the above provisions, they must register the reporting external units and relevant personnel as insiders of the company's inside information in accordance with the company's "Insider Information Insider Registration and Management Measures" and must require the other party to provide external information. Information related to the user of the information (including but not limited to: name, unit/department, position/position, and the time when the company first learned the inside information), the external unit and relevant personnel who reported the information shall be reminded in writing in the format of Annex 1 of these Measures to fulfill their confidentiality obligations, and the relevant personnel of the external unit shall be required to sign a receipt in accordance with Annex 2 of these Measures and promptly report the above information to the Securities Affairs Department of the Company.
Article 12 The confidentiality agreement and letter of commitment signed by the external information user and the relevant information on the external information user provided by the company shall be kept by the company's Securities Affairs Department for a period of 10 years.
Article 13 External units or individuals who receive and/or use the company’s undisclosed information shall not leak in any way the company’s undisclosed material information they know, nor use the inside information they know to buy or sell the company’s securities or recommend others to buy or sell the company’s securities.
Article 14 All departments, branches, wholly-owned and controlled subsidiaries of the company and their staff shall strictly implement these Measures, and shall require and urge external units or individuals to take effective confidentiality measures for the important undisclosed information of the company involved/used in their internally transmitted documents, materials, reports and other materials, and strictly limit the scope of information insiders.
Chapter 3 Responsibility Mechanism and Handling Measures
Article 15 All departments, branches, wholly-owned and controlled subsidiaries of the company and their staff shall urge external units or individuals and their staff to immediately notify the company when the aforementioned major information is disclosed or leaked due to improper confidentiality. The company shall also report and announce to the Shenzhen Stock Exchange as soon as possible after becoming aware of it.
Tianjin Lisheng Pharmaceutical Co., Ltd. Management Measures for External Information Users
Article 16 External units or individuals who receive and/or use the company’s undisclosed information should strictly abide by the above terms. If they violate the company’s undisclosed material information and cause the company to suffer economic losses, the company will require them to bear compensation liability in accordance with the law; if they use the information they know to buy or sell the company’s securities or recommend others to buy or sell the company’s securities, the company should immediately submit relevant materials to the securities regulatory agency or judicial authority.
Chapter 4 Supplementary Provisions
Article 17 The term “external units and individuals” as mentioned in these Measures refers to units and individuals other than the Company, its branches, wholly-owned and controlled subsidiaries.
Article 18 Matters not covered in these Measures shall be implemented in accordance with laws, regulations, relevant provisions of the Shenzhen Stock Exchange and other systems of the company.
Article 19 The company's board of directors is responsible for the interpretation and revision of these Measures.
Article 20 These Measures shall come into effect from the date of review and approval by the company's board of directors, and the same shall apply when revised.
Tianjin Lisheng Pharmaceutical Co., Ltd.
board of directors
January 2026
Tianjin Lisheng Pharmaceutical Co., Ltd. Management Measures for External Information Users
Attachment 1:
Confidentiality reminder letter
____________________________：
According to the requirements of the Securities Law of the People's Republic of China, the Measures for the Administration of Information Disclosure of Listed Companies and other relevant laws, administrative regulations, rules and normative documents, information that has not been publicly disclosed by listed companies should be classified as inside information, and listed companies should strictly manage the submission and use of inside information.
The relevant materials reported by our company to you this time are insider information that has not been publicly disclosed. In accordance with the requirements of the securities regulatory authorities, the key points are as follows:
Your organization/you should strictly control the scope of use of materials submitted by the company and the scope of insiders.
Your organization/you and all relevant personnel who receive and use the materials submitted by our company are insiders of inside information and have the obligation to keep the information confidential. Before the company announces relevant information in accordance with legal procedures, all insiders shall not disclose the information involved in the relevant materials, nor shall they use the undisclosed information of the company to buy or sell the company's securities or recommend others to buy or sell the company's securities.
Your organization/you and those who are aware of the company's relevant undisclosed information are not allowed to use the company's undisclosed information in externally submitted or publicly disclosed documents, unless the company simultaneously announces or has announced the disclosure of the information.
Your organization/you and those who know the company's relevant undisclosed information should notify the company immediately if the company's undisclosed information is leaked due to improper confidentiality.
If your organization/you and those who know the company's relevant undisclosed information violate the rules and cause the company to suffer economic losses, the company will require them to bear compensation liability in accordance with the law; if they use the company's undisclosed information they are aware of to buy or sell the company's securities or recommend others to buy or sell the company's securities, the company will report to the securities regulatory agency and pursue their legal responsibility; if it is suspected of constituting a crime, the company will transfer it to judicial authorities for handling.
In accordance with the requirements of the securities regulatory authorities, our company needs to register your organization/you and those who know the company's relevant information for investigation purposes.
We sincerely hope that your organization/you can provide active cooperation and assistance!
We hereby inform you
Tianjin Lisheng Pharmaceutical Co., Ltd.
year month day
Attachment 2 of the Management Measures for External Information Users of Tianjin Lisheng Pharmaceutical Co., Ltd.:
Confidentiality Commitment Letter
Tianjin Lisheng Pharmaceutical Co., Ltd.:
We have now received the following materials and confidentiality reminder letter submitted by your company:
____________________________;
____________________________;
____________________________;
This unit (or I) hereby confirms that the relevant personnel who receive or use the materials submitted by your company are as follows: Name Unit or department Position or position ID number Securities account number
This organization (or myself) hereby solemnly declares and commits to the following:
This unit (or I) guarantees to strictly control the scope of use and the scope of insiders of the materials submitted by your company.
This unit (or myself) and relevant personnel who receive and use the materials submitted by your company will strictly abide by confidentiality obligations. Before your company announces relevant information in accordance with legal procedures, this unit (or myself) and the relevant personnel who receive and use the materials submitted by your company shall not disclose relevant undisclosed information, nor use the undisclosed information they know to buy or sell your company's securities or recommend others to buy or sell your company's securities.
This unit (or myself) and those who know the relevant undisclosed information of your company will not use the undisclosed information submitted by your company in the documents submitted to the outside or publicly disclosed, unless your company announces the disclosure at the same time or has already announced the disclosure of the information.
This unit (or myself) and the personnel who know the relevant undisclosed information of your company, if the undisclosed information of your company is leaked due to improper confidentiality, this unit (or me) will notify your company immediately.
This unit (or myself) and those who know the relevant undisclosed information of your company shall bear corresponding legal responsibilities in accordance with the law if any illegal behavior occurs.
This is confirmed!
Recipient (signature):
Unit (stamped):
Signing date: year month day