Primeton Information Technologies Inc(688118) information disclosure suspension and exemption management system
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Chapter I General Provisions Chapter II Scope of information disclosure suspension and exemption Chapter III internal management 4 chapter IV Supplementary Provisions five
Primeton Information Technologies Inc(688118)
Information disclosure suspension and exemption management system
Chapter I General Provisions
Article 1 in order to regulate the suspension and exemption of information disclosure of Primeton Information Technologies Inc(688118) (hereinafter referred to as the “company”), urge the company and relevant information disclosure obligors (hereinafter referred to as the “information disclosure obligors”) to perform their information disclosure obligations in accordance with the law and regulations, and protect the legitimate rights and interests of investors, in accordance with the securities law of the people’s Republic of China (hereinafter referred to as the “Securities Law”) The Listing Rules of Shanghai Stock Exchange’s Kechuang board (hereinafter referred to as the “Listing Rules”), the self regulatory guidelines of Shanghai Stock Exchange’s Kechuang board listed companies No. 1 – standardized operation (hereinafter referred to as the “standardized operation guidelines”) and other laws, regulations and departmental rules This system is formulated in accordance with the relevant provisions of normative documents, Primeton Information Technologies Inc(688118) articles of Association (hereinafter referred to as the “articles of association”) and Primeton Information Technologies Inc(688118) information disclosure management system, and in combination with the actual situation of the company.
Article 2 this system is applicable to the information disclosure obligors who handle the business of information disclosure suspension and exemption in accordance with the listing rules, guidelines for standardized operation and other relevant laws, regulations, departmental rules and normative documents.
Article 3 where the information to be disclosed by the information disclosure obligor is subject to the circumstances that the information disclosure can be suspended or exempted as stipulated in the listing rules, the guidelines for standardized operation and other relevant business rules of Shanghai Stock Exchange, it is not necessary to apply to Shanghai Stock Exchange. The information disclosure obligor shall make its own prudent judgment and accept the suspension and exemption of relevant information disclosure by Shanghai Stock Exchange Ex post facto supervision of exemption matters.
Chapter II Scope of suspension and exemption of information disclosure
Article 4 where the information to be disclosed by the information disclosure obligor is uncertain and belongs to temporary trade secrets, and timely disclosure may harm the interests of the company or mislead investors, the disclosure may be postponed.
Article 5 where the information to be disclosed by the information disclosure obligor belongs to trade secrets and business sensitive information, and the disclosure or performance of relevant obligations in accordance with the Listing Rules may lead to improper competition, damage the interests of the company and investors or mislead investors, the disclosure may be exempted.
If the information to be disclosed is recognized as a state secret according to law, and the disclosure or performance of relevant obligations in accordance with the Listing Rules may lead to its violation of domestic laws and regulations or endanger national security, it may be exempted from disclosure.
Article 6 the trade secrets mentioned in this system refer to the technical information and business information that are not known to the public, can bring economic benefits to the obligee, practical and confidential by the obligee, as stipulated in the relevant national anti unfair competition laws and regulations and departmental rules.
The term “state secrets” as mentioned in this system refers to the information that is related to national security and interests, determined in accordance with legal procedures and limited to a certain range of personnel within a certain period of time, and may damage the national security and interests in the fields of politics, economy, national defense, diplomacy and so on.
Article 7 the information to be suspended or exempted from disclosure shall meet the following conditions:
(I) relevant information has not been leaked;
(II) the insider of the relevant inside information has made a written commitment to confidentiality;
(III) there is no abnormal fluctuation in the trading of the company’s shares and their derivatives.
Chapter III internal management
Article 8 the information disclosure obligor shall carefully determine the suspension and exemption of information disclosure and take measures
Effective measures shall be taken to prevent the disclosure of information delayed or exempted from disclosure, and the suspension or exemption shall not be abused
Procedures to avoid the obligation of information disclosure that should be performed.
Article 9 Where the information disclosure obligor intends to suspend or exempt the disclosure of specific information, the relevant departments or subsidiaries shall fill in the approval form for the handling of information disclosure suspension and exemption business (Annex I) and the registration form for insiders of information disclosure suspension and exemption (Annex II), and submit the relevant information to the office of the board of directors of the company, which shall be registered by the Secretary of the board of directors of the company, After being signed and confirmed by the chairman of the company, it shall be properly filed and kept by the office of the board of directors of the company.
Relevant departments or subsidiaries shall fill in the confidentiality commitment letter for insiders of information disclosure suspension and exemption (Annex III) and submit it to the office of the board of directors for safekeeping. The storage period is ten years. The contents of registration and archiving generally include:
(I) contents of matters to be suspended or exempted from disclosure;
(II) reasons and basis for suspending or exempting disclosure;
(III) the period for delaying disclosure;
(IV) list of insiders of suspended or exempted matters;
(V) written confidentiality commitment of relevant insiders on matters to be suspended or exempted from disclosure; (VI) internal approval process of suspended or exempted items, etc.
Article 10 Where any of the following circumstances occurs to the information that has been suspended or exempted from disclosure, the company shall timely verify the relevant information and disclose it to the public:
(I) the information that is suspended or exempted from disclosure is leaked or there are market rumors;
(II) the reasons for the suspension or exemption of disclosure have been eliminated or the time limit has expired;
(III) abnormal fluctuations in the trading of the company’s shares and their derivatives.
If the reasons for the suspension or exemption of disclosure have been eliminated or the period has expired, the company shall timely announce the relevant information and disclose the reasons for the suspension or exemption of disclosure of the information, the internal registration review of the company, etc.
Article 11 the company establishes the accountability mechanism for the suspension and exemption of information disclosure, suspends and exempts the suspension and exemption of information disclosure that do not comply with the above provisions, or does not handle the suspension and exemption of disclosure in accordance with relevant laws and regulations and the provisions of this system, which has brought adverse effects or losses to the company and investors, The company will take corresponding disciplinary measures against relevant personnel and persons in charge who are directly responsible according to relevant laws and regulations and the provisions of the company’s management system.
Chapter IV supplementary provisions
Article 12 other matters concerning the suspension and exemption of the company’s information disclosure shall comply with the listing rules, the guidelines for standardized operation and other relevant business rules of Shanghai Stock Exchange.
Article 13 matters not covered in this system shall be implemented in accordance with relevant national laws, regulations, departmental rules, normative documents and the articles of Association; In case of any conflict between this system and relevant national laws, regulations, departmental rules, normative documents or the revised articles of association, the provisions of relevant national laws, administrative regulations, normative documents and the articles of association shall prevail.
Article 14 the system shall be interpreted and revised by the board of directors of the company. Article 15 this system shall come into force and come into force as of the date of deliberation and approval by the board of directors of the company, and the same shall apply when amending Primeton Information Technologies Inc(688118) April 2022 Annex I:
Primeton Information Technologies Inc(688118)
Approval form for information disclosure suspension and exemption business
Application department / unit applicant application time
Items to be suspended or exempted from disclosure describe the types of suspended or exempted disclosure and □ suspended disclosure (period of suspended disclosure:)
Period □ exempt from disclosure
□ it belongs to temporary trade secret and business sensitive information, so the reasons for applying for suspension or exemption of disclosure and
□ it belongs to state secrets and legal trade secrets, so it is applied for exemption from disclosure
basis
□ others (please specify):
Whether the insider registration form of information disclosure suspension and exemption has been filled in: □ yes □ no whether the relevant insider has made a written confidentiality commitment: □ yes □ no
Pre condition review and confirmation
Whether relevant information has not been disclosed: □ yes □ no
Whether there is no abnormal fluctuation in the trading of the company’s shares and their derivatives: □ yes □ no
Reviewed by the person in charge of the application department / unit
Nuclear opinion
Review opinions of the Secretary of the board of directors
Chairman’s approval opinions
remarks
Annex II:
Primeton Information Technologies Inc(688118)
Information disclosure suspension and exemption insider registration form
The ID number of the surname, the ID / ID card number or other personal information, the insider information of the information party, the insider name, the name of the unit, the relationship between the unit and the Department, and the time period (Note 2) of the position number (Note 5) (Note 1). (Note 3) (Note 4)
Note: 1. If the insider is a unit, the shareholders, actual controllers, related parties, acquirers, counterparties, etc. of the listed company shall be filled in; If the insider is a natural person, the Department and position of the affiliated unit shall also be filled in. 2. The ways of filling in the information, including but not limited to meeting, telephone, fax, written report, e-mail, etc. 3. Fill in the contents of the insider information obtained by each insider, and add additional pages for detailed description as needed. 4. The stage of inside information includes negotiation and planning, demonstration and consultation, contract conclusion, internal report, transmission, preparation, resolution, etc. 5. In case of company registration, fill in the name of the company registrant; In case of company summary, keep the name of the original registrant in the summary form.
Annex III:
Primeton Information Technologies Inc(688118)
Information disclosure suspension and exemption insider confidentiality commitment letter
I (the unit) Name:, ID card / unified social credit Code:, as the insider of the information disclosure suspension or exemption of Primeton Information Technologies Inc(688118) (hereinafter referred to as “the company”), I (the unit) declare and promise as follows:
1. I (the unit) clearly know the contents of the company’s management system for information disclosure suspension and exemption;
2. As the insider of the company’s suspension and exemption from disclosure, I (the unit) have the obligation of information confidentiality. Before the reasons for the suspension and exemption from disclosure are eliminated and the time limit expires, I promise not to disclose the information, not to buy and sell the company’s shares and their derivatives, and not to recommend others to buy and sell the company’s shares and their derivatives; 3. As the insider of the company’s suspension and exemption of disclosure, I (the unit) have the obligation to actively fill in the registration form of insider of information disclosure suspension and exemption of the company and file it with the office of the board of directors of the company from the date of learning of the company’s suspension and exemption of disclosure;
4. In case of disclosure of the company’s suspension or exemption from disclosure due to improper confidentiality, I (the unit) is willing to bear corresponding legal liabilities.
Committed by (signature / seal):
