/Lepu Medical: Information Disclosure Management System (October 2025)

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Lepu Medical: Information Disclosure Management System (October 2025)

Shenzhen Stock Exchange

2025/10/25

Lepu (Beijing) Medical Equipment Co., Ltd. Information Disclosure Management System Lepu (Beijing) Medical Equipment Co., Ltd. Information Disclosure Management System

October 2025

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

Chapter 1 General Provisions

Article 1 In order to standardize the information disclosure behavior of Lepu (Beijing) Medical Devices Co., Ltd. (hereinafter referred to as the "Company"), strengthen the management of information disclosure affairs, and protect the legitimate rights and interests of investors, in accordance with the "Company Law of the People's Republic of China", the "Securities Law of the People's Republic of China" and the "Measures for the Administration of Information Disclosure of Listed Companies" issued by the China Securities Regulatory Commission, This system is formulated based on laws, regulations, normative documents such as the "Regulations on the Suspension and Exemption of Information Disclosure of Listed Companies" and other laws, regulations, normative documents, the relevant provisions of the Shenzhen Stock Exchange (hereinafter referred to as the "Shenzhen Stock Exchange") and the provisions of the Articles of Association of Lepu (Beijing) Medical Devices Co., Ltd. (hereinafter referred to as the "Articles of Association"), taking into account the actual situation of the company.

Article 2 This system applies to the following persons and institutions:

(1) Secretary of the company’s board of directors and office of the board of directors;

(2) Company directors and board of directors;

(3) Senior managers of the company;

(4) The company’s controlling shareholders, actual controllers, shareholders holding more than 5% of the shares and persons acting in concert;

(5) Other persons and institutions with information disclosure obligations.

The above persons and institutions are collectively referred to as “information disclosure obligors”.

Article 3 The term "information" as used in this system refers to all information that may have a significant impact on the trading price or investment decision-making of the company's stocks and derivatives, as well as the information required to be disclosed by the securities regulatory authorities; the term "disclosure" as used in this system refers to the information announced by the company and the relevant information disclosure obligors on qualified media in accordance with laws and regulations, the "Shenzhen Stock Exchange GEM Stock Listing Rules", the "Shenzhen Stock Exchange Listed Companies Self-Regulatory Guidelines No. 2 - Standardized Operation of GEM Listed Companies" and other relevant regulations of the Shenzhen Stock Exchange.

Chapter 2 Basic Principles of Information Disclosure

Article 4 Persons with information disclosure obligations shall perform their information disclosure obligations in a timely manner and in accordance with the law. The information disclosed shall be true, accurate, complete, concise, clear, and easy to understand, and shall not contain false records, misleading statements, or major omissions.

Article 5 Information disclosure obligors shall publicly disclose information to all investors at the same time and shall not disclose information to any unit or individual in advance. However, unless otherwise provided by laws and administrative regulations. Company information disclosure must reflect the principles of openness, fairness, and fair treatment of all shareholders.

Information disclosure is the company's ongoing responsibility, and the company should faithfully and honestly fulfill its obligations of continuous information disclosure.

Article 6 The company’s directors and senior managers shall perform their duties faithfully and diligently and ensure that the disclosed information is true, accurate, complete, timely and fair. If the report content cannot be guaranteed to be true, accurate, complete, timely, and fair, a corresponding statement shall be made in the announcement and the reasons shall be explained.

Article 7 When a company discloses information, it shall use descriptive language to explain the true circumstances of the incident in a concise and easy-to-understand manner. Information disclosure documents shall not contain words of a propaganda, advertising, complimentary or slanderous nature.

Article 8 If an event that occurs in or related to a company does not meet the disclosure standards stipulated in the Shenzhen Stock Exchange's stock listing rules, or there are no relevant regulations, but the company's board of directors or the Shenzhen Stock Exchange believes that the event may have a greater impact on the company's stock trading price, the company shall promptly disclose it in accordance with this system.

Chapter 3 Information that should be disclosed and disclosure standards

Section 1 General Provisions

Article 9 Information disclosure documents mainly include prospectuses, prospectuses, listing announcements, acquisition reports, regular reports and temporary reports, etc.

Article 10 Information disclosed in accordance with the law shall be published on the website of the Shenzhen Stock Exchange and media that meet the conditions specified by the China Securities Regulatory Commission, and shall be placed at the company's domicile and the Shenzhen Stock Exchange for public review.

The information disclosure obligor shall submit the information disclosure announcement draft and relevant reference documents to the Securities Regulatory Bureau at the place where the company is registered.

Information disclosure obligors shall not replace the reporting and announcement obligations that should be performed in any form such as press releases or answering reporters' questions, and may not replace the temporary reporting obligations that should be performed in the form of regular reports.

During non-trading hours, if the company and relevant information disclosure obligors really need it, they may release significant information to the outside world, but relevant announcements must be made before the start of the next trading period.

Article 11 Information disclosure documents shall be in Chinese. If a foreign language text is used at the same time, the disclosure obligor shall ensure that the contents of the two texts are consistent. In the event of any discrepancy between the two texts, the Chinese text shall prevail.

Section 2 Prospectus, Prospectus and Listing Announcement

Article 12 The company's preparation of prospectus shall comply with the relevant regulations of the China Securities Regulatory Commission. All information that has a significant impact on investors' investment decisions should be disclosed in the prospectus.

Article 13 After the application for public issuance of securities is accepted by the Shenzhen Stock Exchange, the issuer shall publish the full text of the prospectus on the Shenzhen Stock Exchange website and the website designated by the China Securities Regulatory Commission before the stock issuance. At the same time, an indicative announcement shall be published in the newspapers and periodicals designated by the China Securities Regulatory Commission to inform investors of the address for online publication and the method of obtaining documents.

Article 14 The company’s directors and senior managers shall sign a written confirmation of the prospectus to ensure that the disclosed information is true, accurate and complete.

The prospectus shall be stamped with the company's official seal.

Article 15 If an important event occurs between the time the securities issuance application is reviewed and approved by the Shenzhen Stock Exchange and the China Securities Regulatory Commission approves the registration and before the issuance is completed, the company shall provide a written explanation to the China Securities Regulatory Commission (or the Shenzhen Stock Exchange) and, with the consent of the China Securities Regulatory Commission (or the Shenzhen Stock Exchange), modify the prospectus or make a corresponding supplementary announcement.

Article 16 To apply for the listing and trading of securities, a listing announcement shall be prepared in accordance with the regulations of the Shenzhen Stock Exchange, and shall be announced after review and approval by the Shenzhen Stock Exchange. If the prospectus or listing announcement cites the professional opinions or reports of securities companies or securities service institutions, the relevant content shall be consistent with the content of the documents issued by the securities companies or securities service institutions to ensure that quoting the opinions of securities companies or securities service institutions will not be misleading.

Article 17 The above provisions on prospectuses shall apply to corporate bond prospectuses.

Article 18 After a company issues new shares in a non-public manner, it shall disclose an issuance report in accordance with the law.

Section 3 Periodic Report

Article 19 The periodic reports that a company should disclose include annual reports, interim reports and quarterly reports. All information that has a significant impact on investors' investment decisions must be disclosed.

The financial accounting report in the annual report shall be audited by an accounting firm that complies with the provisions of the Securities Law. Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

Article 20 The annual report shall be prepared within 4 months from the end of each fiscal year, the interim report shall be within 2 months from the end of the first half of each fiscal year, and the quarterly report shall be prepared and disclosed within 1 month from the end of the third and ninth months of each fiscal year.

The disclosure time of the first quarter quarterly report shall not be earlier than the disclosure time of the previous year's annual report. If a company expects to be unable to disclose a periodic report within the prescribed period, it shall report to the exchange in a timely manner and announce the reasons for the inability to disclose the periodic report, the solution and the deadline for delayed disclosure.

Article 21 The annual report shall record the following contents:

(1) Basic information of the company;

(2) Main accounting data and financial indicators;

(3) The issuance and changes of the company’s stocks and bonds, the total number of stocks and bonds, the total number of shareholders at the end of the reporting period, and the shareholding status of the company’s top 10 shareholders;

(4) Information about shareholders holding more than 5% of the shares, controlling shareholders and actual controllers;

(5) The employment status, shareholding changes, and annual remuneration of directors and senior managers;

(6) Board of Directors report;

(7) Management discussion and analysis;

(8) Major events during the reporting period and their impact on the company;

(9) The full text of the financial accounting report and audit report;

(10) Other matters that need to be disclosed in the annual report.

Article 22 The mid-term report shall record the following contents:

(1) Basic information of the company;

(2) Main accounting data and financial indicators;

(3) The issuance and changes of the company’s stocks and bonds, the total number of shareholders, the shareholdings of the company’s top 10 shareholders, and changes in controlling shareholders and actual controllers;

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

(4) Management discussion and analysis;

(5) Major litigation, arbitration and other major events during the reporting period and their impact on the company;

(6) Financial accounting reports;

(7) Other matters that need to be disclosed in the interim report.

Article 23 The quarterly report shall record the following contents:

(1) Basic information of the company;

(2) Main accounting data and financial indicators;

(3) Other matters that need to be disclosed in quarterly reports.

Article 24 The contents of periodic reports shall be reviewed and approved by the company’s board of directors. Periodic reports shall not be disclosed without review and approval by the Board of Directors. The financial information in the periodic reports shall be reviewed by the Audit Committee and submitted to the Board of Directors for review after approval by a majority of all members of the Audit Committee.

If a director cannot guarantee the authenticity, accuracy, completeness or objection of the contents of the periodic report, he shall vote against or abstain from voting when the board of directors considers the periodic report.

If a member of the audit committee cannot guarantee the authenticity, accuracy, completeness or objection of the financial information in the periodic report, he or she shall vote against or abstain from voting when the audit committee reviews the periodic report.

The company's directors and senior managers should sign written confirmation opinions on the periodic reports, and the audit committee should provide written review opinions to explain whether the preparation and review procedures of the board of directors comply with laws, administrative regulations and the provisions of the China Securities Regulatory Commission, and whether the content of the report can truly, accurately and completely reflect the actual situation of the company.

If directors and senior managers cannot guarantee or have objections to the authenticity, accuracy, and completeness of the contents of periodic reports, they shall state their reasons and opinions in written confirmation opinions and disclose them. Directors and senior managers shall abide by the principle of prudence when expressing opinions in accordance with the provisions of the preceding paragraph. Their responsibility to ensure the authenticity, accuracy and completeness of the contents of periodic reports is not only exempted by expressing opinions.

Article 25 If a company expects losses or significant changes in its operating results, it shall make a performance forecast in a timely manner.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

Article 26 If performance leaks occur before the disclosure of periodic reports, or performance rumors arise and the company's securities and derivatives transactions experience abnormal fluctuations, the company shall promptly disclose relevant financial data for the reporting period.

Article 27 If a non-standard audit report is issued on the financial accounting report in the periodic report, the company's board of directors shall make a special explanation on the matters involved in the audit opinion.

Section 4 Interim Report

Article 28 If a major event occurs that may have a greater impact on the trading price of the company's securities and its derivatives and investors have not yet learned of it, the company shall immediately disclose it and explain the cause, current status and possible impact of the event.

The major events mentioned in the preceding paragraph include:

(1) Major events specified in paragraph 2 of Article 80 of the Securities Law;

(2) The company is liable for large amounts of compensation;

(3) The company accrues large asset impairment provisions;

(4) The company’s shareholders’ equity is negative;

(5) The company’s main debtor becomes insolvent or enters bankruptcy proceedings, and the company fails to withdraw sufficient bad debt provisions for the corresponding claims;

(6) Newly announced laws, administrative regulations, rules, and industry policies may have a significant impact on the company;

(7) The company carries out equity incentives, share repurchases, major asset restructuring, asset spin-offs or listings;

(8) 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, or there is a risk of forced transfer;

(9) The main assets are sealed, detained or frozen; the main bank account is frozen;

(10) The company expects losses or significant changes in operating results;

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

(11) Main or all business comes to a standstill;

(12) 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;

(13) Appoint or dismiss the accounting firm that audits the company;

(14) Major independent changes in accounting policies and accounting estimates;

(15) Being ordered to make corrections by relevant authorities or making corrections as decided by the board of directors due to errors in previously disclosed information, failure to disclose in accordance with regulations or false records;

(16) The company or its controlling shareholders, actual controllers, directors, and senior managers are subject to criminal penalties, are investigated by the China Securities Regulatory Commission for suspected violations of laws and regulations, or are subject to administrative penalties by the China Securities Regulatory Commission, or are subject to major administrative penalties by other competent authorities;

(17) The company’s controlling shareholders, actual controllers, directors, and senior managers are suspected of serious violations of disciplines and laws or job crimes and are detained by the disciplinary inspection and supervision agencies, which affects their performance of duties;

(18) Except for the chairman or manager, other directors and senior managers of the company are unable to perform their duties normally for more than three months due to physical, work arrangements or other reasons, or are subject to compulsory measures by the competent authorities for suspected violations of laws and regulations, which affect their performance of duties;

(19) Other circumstances specified by the China Securities Regulatory Commission and Shenzhen Stock Exchange.

If a company's controlling shareholder or actual controller has a greater impact on the occurrence or progress of a major event, it shall promptly notify the company in writing of the relevant information it is aware of and cooperate with the company in fulfilling its information disclosure obligations.

Article 29 If a company changes its name, stock abbreviation, articles of association, registered capital, registered address, main office address, contact number, etc., it shall disclose it immediately.

Article 30 A company shall promptly perform its information disclosure obligations for major events at any of the following time points that first occur:

(1) When the board of directors forms a resolution on the major event;

(2) When the relevant parties sign a letter of intent or agreement regarding the major event;

(3) When directors and senior managers know or should know that the major event occurs.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

If one of the following situations occurs before the time specified in the preceding paragraph, the company shall promptly disclose the current status of relevant matters and risk factors that may affect the progress of the event:

(1) It is difficult to keep the major incident confidential;

(2) The major event has been leaked or there are rumors in the market;

(3) Abnormal transactions in the company’s securities and their derivatives.

Article 31 After a company discloses a major event, if there are developments or changes in the disclosed major events that may have a greater impact on the trading prices of the company's securities and derivatives, it shall promptly disclose the progress or changes and possible impacts.

Article 32 If a major event stipulated in Article 28 of this system occurs in a company's controlled subsidiary, which may have a greater impact on the trading price of the company's securities and derivatives, the company shall fulfill its information disclosure obligations. If an event occurs in a company in which the company holds shares that may have a greater impact on the trading prices of the company's securities and derivatives, the company shall fulfill its information disclosure obligations.

Article 33 If acquisitions, mergers, divisions, issuance of shares, repurchases of shares, etc. involving a company result in significant changes in the company's total share capital, shareholders, actual controllers, etc., the information disclosure obligor shall perform reporting and announcement obligations in accordance with the law and disclose changes in equity.

Article 34 A company shall pay attention to abnormal transactions in its securities and derivatives and media reports about the company.

When abnormal transactions occur in securities and their derivatives or news appears in the media that may have a significant impact on the trading of the company's securities and its derivatives, the company shall promptly learn the true situation from relevant parties, and when necessary, shall inquire in writing and provide public clarification.

The company's controlling shareholders, actual controllers and persons acting in concert shall promptly and accurately inform the company of any proposed equity transfer, asset reorganization or other major events, and cooperate with the company in information disclosure.

Article 35 If a company's securities and derivatives transactions are deemed to be abnormal transactions by the China Securities Regulatory Commission or the Shenzhen Stock Exchange, the company shall promptly understand the factors that cause abnormal fluctuations in securities and derivatives transactions and disclose them in a timely manner.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

Chapter 4 Responsibilities of Information Disclosure Obligors

Article 36 Directors and senior managers of a company shall be diligent and responsible, pay attention to the preparation of information disclosure documents, ensure that regular reports and temporary reports are disclosed within the prescribed time limit, and cooperate with the company and other information disclosure obligors in fulfilling their information disclosure obligations.

Except for securities companies and securities service institutions that can prepare and review information disclosure documents in accordance with regulations, companies may not entrust other companies or institutions to prepare or review information disclosure documents on their behalf. Companies are not allowed to consult companies or institutions other than securities companies and securities service institutions on matters such as the preparation and announcement of information disclosure documents.

Article 37 The general manager, financial controller, board secretary and other senior management personnel of the company shall prepare drafts of periodic reports in a timely manner and submit them to the board of directors for review; the audit committee shall conduct a prior review of the financial information in the periodic reports and submit them to the board of directors for review after being approved by more than half of all members; the board secretary is responsible for delivering them to the directors for review; the chairman is responsible for convening and presiding over the board of directors meetings to review the periodic reports; the board secretary is responsible for organizing the disclosure of periodic reports.

Article 38 When directors and senior managers become aware of the occurrence of a major event, they shall immediately perform their reporting obligations in accordance with the following provisions:

(1) When encountering information matters that may affect the company's stock price or will have an important impact on the company's operation and management (see the major events listed in Article 28) that they know of, they should inform the secretary of the board of directors as soon as possible, and promptly notify the company's board of directors office at the following points:

The day or the next day when the relevant matter occurs;
When there is substantive contact with the relevant parties (such as negotiation) or there is substantial progress in the matter (such as reaching a memorandum or signing a letter of intent);
The day after the agreement is significantly changed, suspended, terminated, or terminated;
When major matters are approved by relevant government departments or when major matters that have been disclosed are rejected by relevant government departments;
When the implementation of relevant matters is completed.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

(2) When the company studies and decides on matters involving information disclosure, it should notify the secretary of the board of directors to attend the meeting and provide him with the information required for information disclosure;

(3) When encountering information disclosure matters that require coordination, the secretary of the board of directors should be assisted in completing the task in a timely manner.

The board secretary should analyze and make judgments on reported internal material information. If it is necessary to fulfill information disclosure obligations as required by regulations, the secretary of the board of directors shall promptly report to the chairman of the board of directors. After receiving the report, the chairman of the board of directors shall immediately report to the board of directors and urge the secretary of the board of directors to organize the disclosure of temporary reports.

Article 39 The company shall not provide inside information when communicating with any unit or individual on the company’s operating conditions, financial status and other events through performance briefings, analyst meetings, road shows, accepting investor surveys, etc.

Article 40 Directors shall understand and continue to pay attention to the company's production and operation status, financial status, major events that have occurred or may occur in the company and their impact, and proactively investigate and obtain information needed for decision-making.

Article 41 The audit committee shall supervise the performance of information disclosure responsibilities by the company's directors and senior managers; pay attention to the company's information disclosure and discover that there are any illegal or illegal issues in information disclosure, it shall conduct an investigation and make suggestions for handling.

Article 42 Senior managers shall report to the board of directors in a timely manner major events in the company's operations or finances, the progress or changes in disclosed events, and other relevant information.

Article 43 The secretary of the board of directors is responsible for organizing and coordinating the company's information disclosure affairs, collecting information that the company should disclose and reporting to the board of directors, continuously paying attention to media reports on the company, and proactively verifying the true situation of the reports. The secretary of the board of directors has the right to participate in shareholders' meetings, board meetings, audit committee meetings and senior management-related meetings, and has the right to understand the company's financial and operating conditions, and to review all documents involving information disclosure matters.

The secretary of the board of directors is responsible for handling matters related to the disclosure of company information to the outside world. The information disclosed by the company shall be released in the form of board announcement. Directors and senior managers shall not release undisclosed information of the company to the outside world without the written authorization of the board of directors.

The company shall provide convenient conditions for the board secretary to perform his duties, and the financial person in charge shall cooperate with the board secretary in the relevant work of financial information disclosure.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

Article 44 Information disclosure obligors shall provide all information related to their practice to the securities companies and securities service institutions they employ, and ensure that the information is true, accurate, and complete, and shall not refuse, conceal, or make false reports.

When securities companies and securities service agencies issue special documents for information disclosure, if they discover that the materials provided by the company and other information disclosure obligors contain false records, misleading statements, major omissions, or other major violations, they shall require them to supplement and correct them.

Article 45 If a company dismisses an accounting firm, it shall promptly notify the accounting firm after the board of directors makes a resolution. When the company's shareholders' meeting votes on the dismissal of the accounting firm, the accounting firm shall be allowed to state its opinions. If the shareholders' meeting makes a resolution to dismiss or replace an accounting firm, the company shall explain the specific reasons for the dismissal or replacement and the accounting firm's statement of opinions when disclosing the decision.

Chapter 5 Transmission, review procedures and disclosure process of information disclosure

Article 46 The preparation, review and disclosure process of periodic reports:

(1) The secretary of the company's board of directors shall convene a meeting of relevant personnel to determine the time for disclosure of regular reports and formulate a preparation plan;

(2) All relevant departments draft relevant documents according to the regular report preparation plan, and submit them to the board of directors office after review by the leaders in charge;

(3) The Board of Directors Office prepares draft periodic reports;

(4) The draft periodic report shall be reviewed by the secretary of the board of directors;

(5) The general manager, financial director and other senior managers of the company discuss the draft periodic report;

(6) The secretary of the board of directors will submit the draft periodic report revised after discussion and revision by the general manager, financial controller and other senior managers to the audit committee of the board of directors for review;

(7) The audit committee shall submit the revised draft of the periodic report to the company’s board of directors for review;

(8) The chairman convenes and presides over board meetings to review regular reports;

(9) The Audit Committee reviews the regular reports prepared by the Board of Directors;

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

(10) The chairman of the board issues regular reports;

(11) The secretary of the board of directors organizes the disclosure of regular reports.

Article 47 The preparation, review and disclosure process of interim reports:

(1) The company’s board of directors, shareholders’ meeting resolutions, and information disclosure of independent directors’ opinions follow the following procedures:

The board of directors office prepares temporary reports based on the status of the board of directors and shareholders’ meetings and the content of resolutions;
If the opinions of independent directors are involved, they should be disclosed together;
Reviewed by the secretary of the board of directors and signed by the chairman of the board;
The board secretary organizes the disclosure of interim reports.

(2) The company’s information disclosure involving major events listed in this system and not subject to approval by the board of directors and shareholders’ meeting shall follow the following procedures:

The company’s functional departments shall promptly report the incident to the secretary of the board of directors and report to the board of directors as required.

The office submits relevant documents;

The Board of Directors Office prepares interim reports;
Reviewed by the secretary of the board of directors and signed by the chairman of the board;
The board secretary organizes the disclosure of interim reports.

Article 48 The disclosure of information related to major unprecedented matters shall follow the following procedures:

Major unprecedented matters refer to major matters that have no precedent, involve significant uncertainty, and require window guidance. Before communicating on unprecedented matters, the company should proactively apply to the Shenzhen Stock Exchange for a trading suspension and make an announcement, and submit an application to the Shenzhen Stock Exchange signed and confirmed by the secretary of the board of directors.

Article 49 After a company discloses an unprecedented matter in accordance with the above provisions, it shall timely disclose the progress in accordance with the following provisions:

(1) If a company suspends and withdraws an unprecedented matter, it should apply to the Shenzhen Stock Exchange for resumption of trading and make an announcement as soon as possible;

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

(2) If there is no precedent for the matter and the conditions for implementation are not met after communication, an application for resumption of trading should be made to the Shenzhen Stock Exchange as soon as possible and an announcement should be made;

(3) If there is no precedent for the matter to enter the reporting and announcement process after communication, it should apply to the Shenzhen Stock Exchange for resumption of trading as soon as possible and disclose the preliminary plan in the form of "Board Announcement".

Article 50 Information disclosure of the company’s holding subsidiaries shall follow the following procedures:

(1) When a company's controlled subsidiaries hold meetings of the board of directors, board of supervisors, or shareholders, they should submit the meeting resolutions and a complete set of documents to the company's board of directors office within two working days after the meeting; the controlled subsidiaries should promptly report to the company's board secretary after the occurrence of events listed in Article 28 of this system that do not require approval by the board of directors, board of supervisors, or shareholders' meeting, and submit relevant documents to the company's board of directors' office as required. The submitted documents must be signed by the chairman of the subsidiary (or his designated authorizer);

(2) The board of directors office prepares interim reports;

(3) Reviewed by the secretary of the board of directors and signed by the chairman of the board;

(4) The secretary of the board of directors organizes the disclosure of interim reports.

Article 51 If the company submits a report to the regulatory authorities or the Shenzhen Stock Exchange or the company publishes relevant information in the media designated for information disclosure, the secretary of the board of directors shall prepare or organize the preparation based on the information and materials provided by the company's relevant business departments, and submit or publish it after approval by the chairman of the board.

Article 52 When the company discovers that the disclosed information (including announcements issued by the company and information about the company reprinted in the media) is errors, omissions or misleading, it shall issue correction announcements, supplementary announcements or clarification announcements in a timely manner.

Article 53 When the following events occur to the company’s shareholders and actual controllers, they shall proactively inform the company’s board of directors and cooperate with the company in fulfilling its information disclosure obligations.

(1) A shareholder or actual controller who holds more than 5% of the company’s shares has a major change in the situation of holding shares or controlling the company, and a major change in the situation of the company’s actual controller and other companies it controls engaging in the same or similar business as the company;

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

(2) A court ruling prohibits the controlling shareholder from transferring its shares, and 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, or there is a risk of forced transfer;

(3) Planning to carry out major asset or business reorganization of the company;

(4) Other circumstances specified by the China Securities Regulatory Commission.

Before the information that should be disclosed is disclosed in accordance with the law, the relevant information has been disseminated in the media or there are abnormal transactions in the company's securities and derivatives, the shareholders or actual controllers shall make a timely and accurate written report to the company, and cooperate with the company to make timely and accurate announcements.

Shareholders and actual controllers of a company shall not abuse their shareholder rights and dominant position, or require the company to provide them with inside information.

Article 54 If a company and its actual controllers, shareholders, related parties, directors, senior managers, acquirers, asset transaction counterparties, bankruptcy reorganization investors and other relevant parties make public commitments, the company shall designate a dedicated person to track the implementation of the commitments, pay attention to changes in the performance conditions of the commitments, promptly report event developments to the company's board of directors, promptly disclose relevant matters in accordance with regulations, and fully implement them.

Article 55 When a company issues stocks to specific objects, its controlling shareholders, actual controllers and issuing objects shall provide relevant information to the company in a timely manner and cooperate with the company in fulfilling its information disclosure obligations.

Article 56 The company's directors, senior managers, shareholders holding more than 5% of the shares, and persons acting in concert and actual controllers shall promptly submit to the company's board of directors a list of the company's related persons and an explanation of the related relationships. The company shall perform the review procedures for related-party transactions and strictly implement the voting avoidance system for related-party transactions. The parties to the transaction shall not conceal the related relationship or use other means to circumvent the company's related transaction review procedures and information disclosure obligations.

Article 57 Shareholders or actual controllers who hold more than 5% of the company's shares through entrustment or trust shall promptly inform the company of the entrustment and cooperate with the company in fulfilling its information disclosure obligations.

Chapter 6 Storage of Information Disclosure Documents

Article 58 The performance of duties by the company's directors and senior managers shall be recorded and preserved by the company's board of directors office, and shall be archived and kept as company files.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

Article 59 The company’s secretary to the board of directors is responsible for the file management of the company’s information disclosure documents (including regular reports, interim reports, prospectuses, prospectuses, listing announcements, acquisition reports, etc., as well as newspaper pages and copies of information disclosed in designated media). Shareholders’ meeting documents, board of directors documents and other information disclosure documents are classified and archived in special volumes.

Article 60: If formal documents are issued to regulatory agencies, Shenzhen Stock Exchange and other units in the name of the company, the board of directors office shall also keep relevant documents for safekeeping.

Chapter 7 Confidentiality Measures

Article 61 Directors, senior managers and other persons who come into contact with information that should be disclosed due to work relationships have the responsibility and obligation to strictly keep confidential.

Article 62 The company's board of directors shall take necessary measures to limit the number of persons with knowledge of the information to the minimum before the information is publicly disclosed. Directors, senior managers or other personnel of the company shall not publish or disclose to shareholders and the media in any form, on behalf of the company or the board of directors, information that has not been made public by the company.

Article 63: In business cooperation with various intermediary agencies, various departments of the company shall only exchange information within this system and shall not leak or illegally obtain other inside information unrelated to the work.

Article 64: Relevant departments of the company should carefully review the reports, speeches, written materials and other contents at large and important internal meetings of the company; if it involves public information but has not been disclosed in the designated media and cannot be avoided, the scope of communication should be limited and confidentiality requirements should be imposed on the report drafters and participants. During the company's normal working meetings, participants have the responsibility to keep confidential the relevant important information stipulated in this system.

Article 65 When the board of directors learns that the relevant undisclosed information is difficult to keep confidential or has been leaked, or the company's stock price has obviously experienced abnormal fluctuations, the company shall immediately disclose the information.

Article 66: Before insider information is disclosed in accordance with the law, any insider or person who illegally obtains inside information shall not disclose or leak the information, or use the information to conduct insider trading. No unit or individual may illegally require the company to provide information that needs to be disclosed in accordance with the law but has not yet been disclosed.

If securities and their derivatives are publicly issued and traded domestically and overseas at the same time, the information disclosed in the overseas market shall be disclosed in the domestic market at the same time.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

If an information disclosure obligor suspends or exempts information from disclosure, it shall comply with laws, administrative regulations and the provisions of the China Securities Regulatory Commission.

Chapter 8 Internal Control and Supervision Mechanism of Financial Management and Accounting

Article 67 Before a company discloses financial information, it shall implement the company's internal control system for financial management and accounting and the relevant provisions of the financial management system of its subsidiaries and branches to ensure the authenticity and accuracy of financial information and prevent the leakage of financial information.

Article 68 The company’s board of directors and management shall be responsible for inspecting and supervising the establishment and implementation of internal controls to ensure the effective implementation of relevant control specifications.

Chapter 9 Information Disclosure Exemptions and Suspensions

Article 69 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 70 Companies and other information disclosure obligors shall prudently determine information disclosure suspensions and exemptions, and implement them after completing the company's internal review procedures. Companies should take effective measures to prevent the leakage of information that has been suspended or exempted from disclosure.

Article 71 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 shall be exempted from disclosure.

Companies and relevant information disclosure obligors shall abide by the national confidentiality legal system and perform confidentiality obligations. They shall not disclose state secrets through information disclosure, investor interactive Q&A, press releases, interviews, etc., 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.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

Article 72 If the information to be disclosed by the company and the relevant information disclosure obligors involves trade secrets or confidential business information (hereinafter collectively referred to as "trade 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 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.

After the company and relevant information disclosure obligors suspend or exempt from disclosure of trade secrets, if one 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 company stocks 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.

Article 73 If the relevant information in the periodic report that the company intends to disclose 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 above method is used, the interim report can be exempted from disclosure.

Article 74 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 promptly disclose it 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 75 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. Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

Article 76 The information disclosure suspension and exemption business is under the unified leadership and management of the company's board of directors. The company's board secretary is responsible for organizing and coordinating information disclosure suspension and exemption matters. The company's board of directors office assists the board secretary in handling the specific matters of information disclosure suspension and exemption.

The application and approval process for information disclosure suspension or exemption is as follows:

(1) Relevant departments or subsidiaries of the company or other information disclosure obligors should promptly fill in the "Registration Approval Form for Information Disclosure Suspended or Exempted Matters" (hereinafter referred to as the "Approval Form"), submit the aforementioned "Approval Form" signed by the head of the department or subsidiary and other information disclosure obligors, and relevant written materials on suspended or exempted disclosure matters to the company's board of directors office, and be responsible for their authenticity, accuracy, completeness and timeliness;

(2) The company's board of directors office is responsible for reviewing whether the information to be suspended or exempted from disclosure meets the conditions for suspension or exemption from disclosure. If necessary, it can be submitted to the secretary of the company's board of directors after countersigning and approval by the relevant departments;

(3) The secretary of the company's board of directors shall review the matters to be suspended or exempted from disclosure and sign his opinions on the "Approval Form";

(4) The chairman of the company shall make the final decision on the handling of matters to be suspended or exempted from disclosure, and shall sign and confirm on the Approval Form.

Article 77 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, interim 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.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

If disclosure is suspended or exempted due to the involvement of trade secrets, 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 78 Companies and other information disclosure obligors shall, within ten days after the announcement of annual reports, interim 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 Shenzhen Stock Exchange where the company is registered.

Chapter 10 Fair Information Disclosure

Article 79 When companies and relevant information disclosure obligors release undisclosed major information, they must disclose it publicly to all investors so that all investors can learn the same information at the same time. They must not disclose, reveal or leak privately in advance to specific objects such as institutional investors, analysts, news media and other specific objects. The company does not make selective disclosures during investor relations activities such as external receptions, performance briefings, and online roadshows, and treats all investors fairly.

Specific objects include but are not limited to:

(1) Institutions, individuals and their affiliates engaged in securities analysis, consulting and other securities services;

(2) Institutions, individuals and their affiliates engaged in securities investment;

(3) News media and news practitioners and their affiliates;

(4) The company or other institutions or individuals recognized by the Shenzhen Stock Exchange.

Article 80 Before the company communicates directly with a specific object, it shall require the specific object to sign a letter of commitment, which shall at least include the following contents:

(1) Promise not to intentionally inquire about the company’s undisclosed material information, and not to communicate or inquire with anyone other than the company’s designated personnel without the company’s permission;

(2) Commitment not to leak any undisclosed major information obtained inadvertently, and not to use the undisclosed major information obtained to buy or sell the company's securities or recommend others to buy or sell the company's securities;

(3) Commitment to indicate the source of the information when it involves profit forecasts and stock price forecasts in investment value analysis reports, press releases and other documents, and not to use subjective assumptions and information lacking factual basis;

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

(4) Commit to inform the company before releasing or using investment value analysis reports, press releases and other documents;

(5) Clarify the responsibilities for breach of commitments.

Article 81 Companies should carefully check investment value analysis reports, press releases and other documents notified by specific parties. If any wrong or misleading records are found, the company should be required to make corrections; if it refuses to make corrections, the company should promptly issue a clarification announcement to explain. If it is discovered that any undisclosed material information is involved, the company should immediately report it to the Shenzhen Stock Exchange and make an announcement.

Article 82 If a company provides materials related to disclosed information to specific targets such as institutional investors, analysts or news media, and if other investors also make the same request, the company shall provide it equally.

Article 83 The company may expand the scope of information dissemination by holding press conferences, investor talks, online briefings, etc., so that more investors can promptly know and understand the company’s major information that has been disclosed.

Article 84 When a company implements a refinancing plan (including non-public issuance), it shall pay special attention to the fairness of information disclosure when conducting price inquiry, promotion and other activities to specific individuals or institutions, and shall not provide undisclosed major information to them to attract them to subscribe for company securities.

Article 85 The company shall not disclose or leak undisclosed major information at the shareholders’ meeting. If an event reported to shareholders is undisclosed major information, the reported event should be disclosed simultaneously with the announcement of the resolution of the shareholders' meeting.

Article 86 The company shall perform its information disclosure obligations in strict accordance with relevant laws, administrative regulations, departmental rules, normative documents and relevant regulations of the Shenzhen Stock Exchange. In addition, companies can voluntarily disclose information relevant to investors' value judgments and investment decisions, but it must not conflict with the information disclosed in accordance with the law or mislead investors.

Article 87 The information voluntarily disclosed by the company must be true, accurate and complete. Voluntary information disclosure shall comply with the principle of fairness, maintain the continuity and consistency of information disclosure, and shall not make selective disclosure. Companies shall not use voluntarily disclosed information to improperly influence the trading prices of the company's securities and derivatives, and shall not use voluntary information disclosure to engage in market manipulation and other illegal activities. Company directors and senior managers should inform the board secretary before accepting interviews and surveys with specific targets, and the board secretary should properly arrange the interview or survey process and participate in the entire process. The person being interviewed or researched should form a written record of the research process and the content of the interview, and sign and confirm it with the interviewer or researcher. The secretary of the board of directors should sign and confirm at the same time.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

Article 88 The Shenzhen Stock Exchange encourages companies to place relevant information on communications with specific objects or acceptance of surveys and interviews with specific objects on the company's website or disclose it in the form of announcements.

Chapter 11 Media for Information Disclosure

Article 89 The company shall designate 1 to 3 newspapers recognized by the China Securities Regulatory Commission to publish company announcements and other information that needs to be disclosed.

Article 90 In addition to being published in the above-mentioned newspapers, the company's periodic reports, temporary announcements, company articles of association, prospectus, allotment prospectus and other relevant information disclosure documents should also be published on the website of the Shenzhen Stock Exchange and the company's website (www.lepumedical.com).

Article 91 The company shall not release information in other media before the designated media, shall not replace the reporting and announcement obligations that must be fulfilled in any form such as press releases or answering questions from reporters, and shall not replace the temporary reporting obligations that shall be fulfilled in the form of regular reports. When publishing major information on the company's website or other internal publications, it shall obtain the consent of the board secretary in advance from the perspective of information disclosure. When there is information that is not suitable for release, the board secretary has the right to stop it.

Chapter 12 Related Responsibilities

Article 92 If the information disclosure obligor fails to perform the information disclosure obligation within the prescribed time limit, or the disclosed information contains false records, misleading statements or major omissions, it shall be dealt with in the following manner:

(1) If the company's board of directors commits the above-mentioned behavior, the audit committee shall instruct it to make corrections; if losses are caused to the company, the relevant responsible directors shall compensate and bear joint and several liability; if the circumstances are serious, the audit committee shall request the shareholders' meeting to remove the relevant responsible directors from their posts.

(2) If a senior manager of the company commits the above-mentioned conduct, the board of directors shall instruct him to make corrections; if any loss is caused to the company, the relevant senior manager shall compensate him; if the circumstances are serious, the board of directors shall remove the relevant responsible senior manager from his position.

(3) If other persons with information disclosure obligations commit the above-mentioned behaviors, the company shall require them to make corrections; if they cause losses to the company, the company may require them to bear corresponding legal liabilities depending on the circumstances.

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

Article 93 If the information disclosure obligor under this system leaks inside information and causes losses to the company, he shall compensate for the losses. The company may require it to bear corresponding legal responsibilities depending on the circumstances.

Article 94 Persons with information disclosure obligations under this system who use inside information to buy and sell securities and their derivatives shall proactively dispose of their illegally held stocks. If it causes losses to the company, it shall also bear corresponding liability for compensation. If the circumstances are serious or the illegally held stocks are not dealt with, the person shall be removed from his position, as follows:

(1) The directors of the company shall be proposed by the board of directors to the shareholders' meeting to remove the corresponding director from his or her duties.

(2) The senior managers of the company shall be removed from their posts by the board of directors.

(3) Except for company directors and other internal personnel of the company, the company may remove these responsible personnel from their posts or dismiss them as appropriate.

Article 95 If consultants, intermediary staff, related persons, etc. hired by the company disclose company information without authorization and cause losses to the company, the company reserves the right to pursue their liability.

Chapter 13 Supplementary Provisions

Article 96 In this system, "above" includes the original number, and "below" does not include the original number.

Article 97 The meanings of the following terms in this system:

(1) Securities companies and securities service agencies that issue special documents for information disclosure obligors to fulfill their information disclosure obligations refer to securities companies, accounting firms, asset appraisal agencies, law firms, financial advisory agencies, credit rating agencies, etc. that prepare and issue sponsorship letters, audit reports, asset assessment reports, valuation reports, legal opinions, financial advisory reports, credit rating reports and other documents for securities issuance, listing, trading and other securities business activities.

(2) Timely means within two trading days from the calculation date or the disclosure time point.

(3) The company's related transactions refer to the transfer of resources or obligations between the company or its controlled subsidiaries and the company's related parties.

(4) Related parties include related legal persons and related natural persons.

A legal person with one of the following circumstances is a related legal person of the company:

Lepu (Beijing) Medical Devices Co., Ltd. Information Disclosure Management System

(1) A legal person that directly or indirectly controls the company;

(2) Legal persons other than the company and its holding subsidiaries that are directly or indirectly controlled by the legal persons mentioned in the preceding paragraph;

(3) Legal persons other than the company and its holding subsidiaries that are directly or indirectly controlled by related natural persons, or serve as directors or senior managers;

(4) Legal persons or persons acting in concert holding more than 5% of the company’s shares;

(5) One of the above situations has existed in the past 12 months or in the next 12 months according to relevant agreements;

(6) Other legal persons determined by the China Securities Regulatory Commission, the Shenzhen Stock Exchange or the company based on the principle of substance over form to have a special relationship with the company and that may or have caused the company to tilt its interests.

A natural person who has one of the following circumstances is an associated natural person of the company:

(1) A natural person who directly or indirectly holds more than 5% of the company's shares;

(2) Company directors and senior managers;

(3) Directors, supervisors and senior managers of legal persons that directly or indirectly control the company;

(4) Close family members of the persons mentioned in items 1 and 2 above, including spouse, parents, children over 18 years old and their spouses, brothers and sisters and their spouses, spouse’s parents, brothers and sisters, and children’s spouse’s parents;

(5) One of the above situations has existed in the past 12 months or in the next 12 months according to relevant agreements;

(6) Other natural persons identified by the China Securities Regulatory Commission, the Shenzhen Stock Exchange or the company based on the principle of substance over form that have a special relationship with the company and may or have caused the company to tilt its interests.

(5) Designated media refers to newspapers, periodicals and websites designated by the China Securities Regulatory Commission.

Article 98 Matters not covered by this system shall be handled in accordance with the Securities Law, the Measures for the Administration of Information Disclosure of Listed Companies, the Shenzhen Stock Exchange GEM Stock Listing Rules, and the Information Disclosure Management System of Shenzhen Stock Exchange Listed Gonglepu (Beijing) Medical Devices Co., Ltd.

Implementation of relevant laws, regulations and normative documents such as the "Self-Regulation Guidelines No. 2 - Standardized Operations of GEM Listed Companies".

Article 99 The board of directors is responsible for interpreting this system.

Article 100 This system will take effect after being reviewed and approved by the company's board of directors. If the relevant provisions of this system conflict with the relevant laws, regulations, rules and the Articles of Association that have been revised in accordance with legal procedures in the future, they shall be implemented in accordance with the provisions of the relevant laws, regulations, rules and the Articles of Association. The board of directors shall revise this system in a timely manner.