DaAn Gene: Insider Information Registration and Management System (October 2025)
Guangzhou Da'an Gene Co., Ltd.
Insider information insider registration and management system
Chapter 1 General Provisions
Article 1 In order to further standardize the management of inside information of Guangzhou Da'an Gene Co., Ltd. (hereinafter referred to as the "Company"), strengthen the confidentiality of the company's inside information, avoid insider trading, maintain the principles of openness, fairness and impartiality in information disclosure, and protect the interests of investors, in accordance with the "Company Law of the People's Republic of China", "Securities Law of the People's Republic of China", "Measures for the Administration of Information Disclosure of Listed Companies" and "Supervisory Guidelines for Listed Companies No. 5 - - The relevant provisions of laws, administrative regulations, normative documents such as the Insider Registration and Management System for Listed Companies, the Stock Listing Rules of the Shenzhen Stock Exchange, and the Articles of Association of Guangzhou Da'an Gene Co., Ltd. and the Information Disclosure Management System of Guangzhou Da'an Gene Co., Ltd., combined with the actual situation of the company, are formulated.
Article 2 The company's board of directors is responsible for the management of the company's inside information and ensuring the authenticity, accuracy and completeness of insider files. The chairman of the board is the main responsible person. The secretary of the board of directors is responsible for the registration of insiders of the company’s inside information.
Article 3 The Securities Department is the company’s only information disclosure agency. Without the approval of the board of directors, no department or individual of the company may leak, report or transmit to the outside world any content involving the company’s inside information and information disclosure. External reports, transmitted documents, floppy (magnetic) disks, audio (video) tapes, CD-ROMs and other materials involving inside information and information disclosure must be reviewed and approved by the secretary of the board of directors (and reported to the board of directors for review depending on the importance) before they can be reported or transmitted to the outside world.
Article 4 The company’s directors, senior managers and all departments and branches (subsidiaries) of the company should do a good job in keeping the inside information confidential. You are not allowed to leak inside information, engage in insider trading or cooperate with others to manipulate securities trading prices.
Article 5 The secretary of the board of directors is the person in charge of the confidentiality of the company’s inside information, and the securities department is the daily work department responsible for the management, registration, disclosure and filing of the company’s inside information.
Chapter 2 Insider Information and Insider Information
Article 6 Insider information referred to in this system refers to undisclosed information known to insiders that involves the company's operations and finance or has a significant impact on the trading prices of the company's stocks and derivatives. The above-mentioned undisclosed information refers to matters that the company has not yet formally disclosed in the designated newspapers "Securities Times" and cninfo.com.
Article 7 The major events listed in paragraph 2 of Article 80 and paragraph 2 of Article 81 of the Securities Law belong to inside information. The scope of inside information referred to in this system includes but is not limited to:
(1) Major changes in the company’s business policy and business scope;
(2) The company’s major investment behavior or major decision to purchase property;
(3) The company enters into important contracts or engages in related transactions, which may have a significant impact on the company's assets, liabilities, equity and operating results;
(4) The company incurs major debts and fails to pay off major debts that are due, or is liable for large amounts of compensation;
(5) The company suffers significant losses or losses;
(6) Major changes occur in the external conditions of the company’s production and operation;
(7) The company’s directors or general manager change; the chairman or general manager is unable to perform their duties;
(8) The circumstances in which shareholders or actual controllers holding more than 5% of the company's shares hold shares or control the company have undergone major changes, and the company's actual controllers and other enterprises they control engage in the same or similar business as the company have undergone major changes;
(9) The company’s decision to reduce capital, merge, split, dissolve, or apply for bankruptcy; or enter bankruptcy proceedings in accordance with the law or be ordered to close down;
(10) Major lawsuits and arbitrations involving the company, resolutions of the shareholders’ meeting and the board of directors are revoked or declared invalid in accordance with the law;
(11) The company is suspected of violating laws and regulations and is investigated by the competent authorities, or is subject to criminal penalties or major administrative penalties; the company's directors and senior managers are suspected of violating laws and regulations and are investigated by the competent authorities or take compulsory measures;
(12) Newly announced laws, regulations, rules and industry policies may have a significant impact on the company;
(13) The board of directors forms relevant resolutions on the issuance of new shares or other refinancing plans and equity incentive plans;
(14) A court ruling prohibits the controlling shareholder from transferring its shares; more than 5% of the company's shares held by any shareholder are pledged, frozen, judicially auctioned, placed in custody, established as a trust, or have voting rights restricted in accordance with the law;
(15) The main assets are sealed, detained, frozen or mortgaged or pledged;
(16) Main or all business has come to a standstill;
(17) Provision of major external guarantees; major changes in the company’s debt guarantees;
(18) Obtaining large government subsidies and other additional income that may have a significant impact on the company's assets, liabilities, equity or operating results;
(19) Change accounting policies and accounting estimates;
(20) Because the information previously disclosed contains errors, is not disclosed in accordance with regulations, or is falsely recorded, it is ordered to make corrections by relevant authorities or is corrected as decided by the board of directors;
(21) The company’s undisclosed quarterly report, semi-annual report, annual report and dividend distribution plan
(22) The company’s undisclosed mergers and acquisitions, reorganizations, private placements and other activities;
(23) The mortgage, sale or scrapping of the company’s main assets for business purposes exceeds 30% of the assets at one time;
(24) Major changes in the company’s equity structure;
(25) The actions of the company’s directors and senior managers may bear significant liability for damages in accordance with the law;
(26) Other matters stipulated by the China Securities Regulatory Commission and the Shenzhen Stock Exchange.
Article 8 Insiders of inside information refer to the relevant persons specified in Article 51 of the Securities Law. The scope of insiders referred to in this system includes but is not limited to:
(1) The company’s directors and senior managers;
(2) Shareholders holding more than 5% of the company’s shares and their directors, supervisors, and senior managers, the company’s actual controllers and their directors, supervisors, and senior managers;
(3) Companies controlled by the company and its directors, supervisors and senior managers;
(4) Persons who can obtain relevant inside information of the company due to their position in the company;
(5) External units and individuals who obtain inside information of the company due to the performance of work duties;
(6) Relevant personnel of various securities service institutions who prepare and issue securities issuance sponsorship letters, audit reports, asset evaluation reports, legal opinions, financial advisory reports, credit rating reports and other documents for major events, as well as relevant personnel involved in the consultation, formulation, demonstration and other aspects of major events;
(7) Other insider information stipulated in laws, regulations, rules and normative documents.
Chapter 3 Insider Information Confidentiality System
Article 9 Insiders of the company's inside information need to sign a confidentiality agreement with the company, and are obliged to keep the inside information they know confidential, and are not allowed to leak the inside information to the outside world in any form without authorization.
Article 10 Company directors, senior managers and other insiders of inside information should control the scope of information to a minimum before the company's information is publicly disclosed, and designated personnel should be assigned to submit and keep important information documents.
Article 11 Before the inside information is released, insiders shall not leak, report or transmit the content of the inside information to the outside world, or disseminate it in any form.
Article 12 Before the public disclosure of inside information, the insider of the inside information shall properly keep the documents, disks, audio tapes, meeting minutes, resolutions and other materials containing the inside information, and shall not lend them to others for reading or copying, or allow others to carry or keep them on their behalf. Insiders of insider information should take corresponding measures to ensure that the relevant inside information stored on the computer is not accessed or copied.
Article 13 When discussing matters that may have a significant impact on the company's stock price, the company's shareholders and actual controllers should control the scope of information to a minimum. If the matter has been circulated in the market and caused changes in the company's stock price, the company's shareholders and actual controllers should immediately inform the secretary of the board of directors so that timely clarification can be provided.
Article 14 If a company needs to provide undisclosed information to insiders other than shareholders or actual controllers, it should confirm that it has signed a confidentiality agreement with them or obtained their commitment to keep the relevant information confidential before providing it.
Chapter 4 Insider Information Registration and Filing System
Article 15 Before the public disclosure of inside information in accordance with the law, the company shall fill in the files of insiders in accordance with relevant regulations, and promptly record the list of insiders in the stages of negotiation and planning, argumentation and consultation, contract conclusion, and reporting, transmission, preparation, resolution, disclosure, etc., as well as the time, location, basis, method, content and other information of knowing the inside information, for the company's self-examination and inquiries by relevant regulatory agencies.
When a company carries out major events such as acquisitions, major asset reorganizations, issuance of securities, mergers, divisions, share repurchases, equity incentives, etc., or discloses other matters that may have a significant impact on the company's securities trading prices, in addition to filling in the company's insider information files, it must also prepare a memorandum on the progress of major events, including but not limited to the time of each key time in the planning and decision-making process, the list of people participating in the planning and decision-making, the planning and decision-making methods, etc. The company should urge the relevant personnel involved in the memorandum to sign and confirm the memorandum, and within five trading days after the public disclosure of the inside information, file the insider information files and the memorandum on the progress of major events to the Guangdong Securities Regulatory Bureau and the Shenzhen Stock Exchange. Relevant entities such as the company's shareholders, actual controllers and their related parties should cooperate in preparing a process memorandum of major events.
After the company discloses major matters, if relevant matters change significantly, the company shall promptly submit additional insider information files and major event progress memorandums.
Article 16 Procedures for registration and filing of insiders of inside information:
(1) When inside information occurs, insiders who know the information (mainly the heads of departments, institutions, branches, and subsidiaries) should inform the company's board secretary as soon as possible. The secretary of the board of directors should promptly inform relevant insiders of various confidential matters and responsibilities, and control the transmission of inside information and the scope of knowledge in accordance with various laws and regulations;
(2) The secretary of the board of directors immediately organizes relevant insiders to fill in the "Insider Information Insider Registration Form" (see attachment) and verifies the inside information in a timely manner to ensure the authenticity and accuracy of the contents filled in the "Insider Information Insider Registration Form";
(3) After the secretary of the board of directors has verified that the information is correct, it will be reported to the Guangdong Securities Regulatory Bureau and the Shenzhen Stock Exchange in accordance with regulations.
(4) The company's board of directors shall ensure that the insider information files are true, accurate and complete, and the chairman of the board shall be the main responsible person. The secretary of the board of directors is responsible for the registration and submission of insider information of the company. The chairman of the board of directors and the secretary of the board of directors shall sign a written confirmation of the authenticity, accuracy and completeness of the insider information file.
Article 17 If a company needs to regularly submit information to the relevant administrative departments in accordance with the requirements of relevant laws, regulations and policies before information disclosure, provided there are no major changes in the reporting department, content, etc., it may be regarded as the same inside information matter, and the name of the administrative department shall be registered in the same form, and the time for submitting information shall continue to be registered. Except for the above circumstances, when the transfer of inside information involves the administrative department, the company shall register the name of the administrative department, the reason for contact with the inside information, and the time when the inside information was known in the insider file on a one-by-one basis.
Article 18 The directors, senior managers of the company and the principal persons in charge of each functional department and subsidiary (branch) company shall actively cooperate with the company in the registration and filing of insiders of inside information, and promptly inform the company of the status of insiders of major events that have occurred or are about to occur, as well as the changes in relevant insiders of inside information.
Article 19 When a company's shareholders, actual controllers and their related parties study or initiate major matters involving the company, or when other matters that have a significant impact on the company's stock price occur, they shall promptly fill in the insider information form;
Securities companies, securities service agencies, law firms and other intermediaries that accept entrustment to engage in securities services business and the entrusted matter has a significant impact on the company's stock price should promptly fill in the insider information form; acquirers, counterparties to major asset restructuring transactions, and other initiators of matters involving the company that have a significant impact on the company's stock price should fill in the insider information form in a timely manner.
The above-mentioned entities shall ensure the authenticity, accuracy and completeness of the insider information files, and deliver the insider information files to the company in stages according to the progress of the matter, but the delivery time of the complete insider information files shall not be later than the time when the company's insider information is publicly disclosed. Insider information insider files shall be in accordance with this system
The requirements in Article 15 must be filled in and confirmed by insiders.
Article 20 The secretary of the board of directors shall register and report the insider information at the same time as the insider becomes aware of the inside information, and promptly supplement the file information of the insider. Insider information files shall be kept for at least ten years from the date of recording (including supplements and improvements).
Chapter 5 Accountability
Article 21 When an insider violates this system by leaking inside information without authorization, or due to dereliction of duty, resulting in violation of regulations and causing serious impact or losses to the company, the company will, depending on the severity of the case, impose sanctions such as criticism, warning, demotion and salary reduction, termination of the labor contract, and appropriate compensation requirements. The above sanctions can be imposed individually or concurrently. If there are other penalties imposed by regulatory authorities such as the China Securities Regulatory Commission and Shenzhen Stock Exchange, the penalties can be combined.
Article 22 The company shall, in accordance with the provisions of the China Securities Regulatory Commission, conduct self-examination on the trading of the company's stocks and their derivatives by insiders. If it is discovered that an insider of insider information has disclosed illegally, conducted insider trading, leaked inside information, or suggested that others use the inside information to conduct transactions, the company shall conduct verification, hold the relevant personnel accountable, and submit the relevant situation and handling results to the Guangdong Securities Regulatory Bureau and the Shenzhen Stock Exchange for filing within 2 working days.
Article 23 If an insider of inside information violates the provisions of this system, causing heavy losses or serious consequences to the company, and constituting a crime, he or she will be transferred to judicial authorities for criminal liability in accordance with the law.
Chapter 6 Supplementary Provisions
Article 24 If matters are not covered in this system or are inconsistent with relevant national laws and regulations, the relevant national laws and regulations shall prevail.
Article 25 If this system conflicts with the laws and regulations promulgated by the country in the future or the Articles of Association after legal procedures, it shall be implemented in accordance with the relevant national laws, regulations and the Articles of Association, and this system shall be revised in a timely manner and submitted to the board of directors for review and approval.
Article 26 This system shall come into effect from the date of review and approval by the board of directors.
Article 27 The board of directors is responsible for interpreting this system.
Guangzhou Da'an Gene Co., Ltd.
Attachment to the Board of Directors meeting on October 30, 2025:
Guangzhou Da'an Gene Co., Ltd. Insider Information File
Insider Information Matters:
Serial number Name Affiliated unit ID number Notice of inside information Notice of inside information Know of inside information Inside information Insider information office Registration time Registrant
Notification time Notification location Information method note ① Capacity note ② Processing stage note ③
Company abbreviation:
Company code:
Signature of legal representative:
Company seal:
Note: ① Fill in the methods of obtaining inside information, including but not limited to interviews, phone calls, faxes, written reports, emails, etc. ② Fill in the content of the inside information learned by each insider, and add additional pages for detailed explanation as needed. ③ Fill in the stage of reporting the inside information, including discussion and planning, argumentation and consultation, contract conclusion, internal company reporting, transmission, preparation, resolution, etc.