Shanxi Lu’An Environmental Energydev.Co.Ltd(601699)
Management system for users of external information
Article 1 in order to strengthen the management of the submission and use of external information during the preparation, deliberation and disclosure of the company’s periodic reports and major events, ensure the fair disclosure of information and eliminate illegal acts such as insider trading, in accordance with the company law, the securities law, the measures for the Administration of information disclosure of listed companies, the stock listing rules of Shanghai Stock Exchange and other laws, regulations, normative documents and the articles of association This system is hereby formulated in accordance with the relevant provisions of the relevant systems of the company, such as the information disclosure management system, the insider registration system and so on. Article 2 the scope of application of this system includes all departments of the company, holding subsidiaries, directors, supervisors, senior managers, senior managers of holding subsidiaries and other relevant personnel.
Article 3 the internal information of the company shall be submitted to the outside, including but not limited to the submission of annual statistical statements and other materials to relevant government departments or other external units in accordance with the provisions of laws and regulations on state-owned assets supervision, national statistics, tax collection and management, or when the company applies for credit extension, loan, financing, business negotiation, application for product patent projects and application for relevant qualifications, It is really necessary to provide the other party with the company’s undisclosed material information due to special circumstances.
Article 4 the directors, supervisors, senior managers and other insiders of the company shall abide by the requirements of laws, regulations and systems related to information disclosure and bear the obligation of confidentiality during the preparation of regular reports and interim reports and the planning of major events of the company. Before the publication of the periodic report and interim report, the contents of the periodic report and interim report shall not be disclosed to the outside world or specific personnel in any form or by any means, including but not limited to performance symposium, analyst meeting, investor Research Symposium, social media platform, etc.
Article 5 when the relevant departments of the company submit information to the outside, the handling personnel shall provide the receiving personnel with the letter of tips on confidentiality of inside information (Annex I) and require the receiving personnel of the other party to sign the receipt (Annex II). The receipt shall list the personnel using the submitted information. Article 6 before the disclosure of periodic reports, the company shall not submit periodic reports, statistical statements and other materials to external units without laws and regulations in advance, and shall refuse the submission requirements put forward by external units without laws and regulations.
Article 7 where the company submits information related to regular reports to specific external information users in accordance with laws and regulations, the provision time shall not be earlier than the disclosure time of the company’s performance express, and the disclosure content of the performance express shall not be less than the information provided to external information users. Article 8 when the company needs to provide the other party with unpublished material information due to special circumstances during business negotiations, bank loans and other matters, the company shall require the other party to sign a confidentiality commitment (see Annex 1) to ensure that it will not disclose relevant information, and promise not to buy or sell the company’s securities before the relevant information is announced.
Article 7 when all departments, subsidiaries, branches and their staff of the company provide important information that has not been disclosed to external units or individuals in accordance with the above provisions, they must require the other party to register and record in accordance with the requirements of the insider information registration system.
Article 9 all departments, subsidiaries, branches and their staff of the company shall register and record the information that needs to be reported to the outside world or published on websites and journals in accordance with the requirements of the company’s sensitive information management system, and copy it to the company’s information disclosure management department at the same time to determine whether it needs to be disclosed in time; When publishing information on the website, it shall be approved by the information disclosure management department and signed and issued by the Secretary of the board of directors.
Article 10 the confidentiality agreement, letter of commitment, receipt of external submission and other materials signed by the user of external information shall be kept by the information disclosure management department of the company for a period of more than 10 years.
Article 11 external units or individuals shall not disclose the company’s undisclosed material information they know in any way, nor use the insider information they know to buy and sell the company’s securities or suggest others to buy and sell the company’s securities.
Article 12 If the documents, materials, reports and other materials disseminated internally by external units or individuals involve the known material information that has not been disclosed by the company, effective measures shall be taken to limit the scope of information insiders.
Article 13 if the above-mentioned major information is leaked due to improper confidentiality of external units or individuals and their staff, they shall immediately notify the company, and the company shall report to the Shanghai Stock Exchange and make an announcement at the first time. External units or individuals shall strictly abide by the above provisions. If the company suffers economic losses due to the illegal use of the company’s undisclosed material information they know, or uses the information they know to buy and sell the company’s securities or suggest others to buy and sell the company’s securities, the company will investigate their responsibilities in accordance with the insider registration system and relevant laws and regulations. If the criminal law is involved, it will be handed over to the judicial organ for handling.
Article 14 matters not covered in this system shall be implemented in accordance with laws, regulations, relevant provisions of Shanghai Stock Exchange and other systems of the company.
Article 15 the system shall be interpreted and revised by the board of directors of the company.
Article 16 this system shall be implemented from the date of deliberation and approval by the board of directors of the company.
Annex I
Tips on confidentiality of inside information
The report materials and other information submitted by the company to your company belong to the undisclosed inside information of the company. Now, in accordance with the criminal law of the people’s Republic of China, the securities law of the people’s Republic of China and the relevant provisions of the China Securities Regulatory Commission and Shanghai Stock Exchange on inside information, your company and the insiders who know the above materials and information shall strictly abide by the above laws Perform confidentiality and related obligations in accordance with relevant regulations and departmental rules:
1. Your company shall strictly control the scope of use and knowledge of the above materials submitted by the company.
2. The relevant personnel of your company who receive, submit and use the above materials are insiders and have the obligation of information confidentiality. The relevant personnel shall not disclose the relevant information before the relevant information of the company is disclosed, and shall not use the obtained information to buy or sell or suggest others to buy or sell the shares and derivatives of the company.
3. The personnel of your company who obtain the above submitted materials of the company shall immediately notify the company if the above major information is leaked due to improper confidentiality.
4. The company will investigate the compensation liability and legal liability of the person who divulges the material information without authorization if it causes economic losses or adverse effects to the company.
5. In addition to the administrative punishment given by the CSRC, the violators of insider trading and those who disclose insider information may also bear criminal liability and civil compensation liability according to the provisions of the current law.
6. Our company registers the relevant personnel of your company as the insider of the company. Please cooperate.
Here’s a reminder.
Shanxi Lu’An Environmental Energydev.Co.Ltd(601699)
Mm / DD / yy
Annex II
Return execution
Shanxi Lu’An Environmental Energydev.Co.Ltd(601699)
We have received the following documents submitted by your company and the relevant insider information confidentiality prompt letter: 1
2、
3、
4、
The personnel of our company who use the above documents and information are as follows:
Name unit / Department Post / post ID number
We hereby reply and confirm.
Signed by (signature or seal):
contact information:
Annex III
Confidentiality commitment
Shanxi Lu’An Environmental Energydev.Co.Ltd(601699)
I (unit) will make the following confidentiality commitments for all unpublished information submitted by your company according to relevant regulations:
I (the unit) promise not to disclose all the unpublished information legally submitted during the regular preparation, review and disclosure of your company and during the review and disclosure of other interim reports and major events in any form (unpublished information includes but is not limited to: financial information, business secrets, major events, business opportunities and all information affecting the fluctuation of the company’s share price);
I (unit) promise to keep the insiders of such information to a minimum before accepting the non-public disclosure of various statistical statements and financial data submitted by your company according to law, and not to submit and disclose the insider information submitted by your company to newspapers, radio and other social public media; I (unit) promise that I (unit) will not inadvertently obtain your company’s undisclosed material information, disclose undisclosed material information, buy or recommend others to buy and sell your company’s shares and their derivatives, and will not cooperate with others to manipulate the trading price of shares and their derivatives;
I (unit) promise not to use the undisclosed material information of your company to any third party after obtaining the relevant information submitted by your company according to law, unless your company has disclosed the information; I (the unit) promise to indicate the source of data and not use the data without factual basis if the information submitted by your company according to law involves financial information;
If I (unit) violates the above commitments, I am willing to bear the legal responsibility for the consequences.
Information recipient:
full name:
Work department:
Title:
ID number:
Securities account No.:
contact number:
Confidential Party (seal):
