Article 1
To standardize the trading behavior of directors and senior management of Zhejiang Kaineng Special Materials Co., Ltd. (hereinafter referred to as "the Company") regarding the Company's securities, this system is formulated in accordance with the "Company Law of the People's Republic of China," "Securities Law of the People's Republic of China," "Regulations on the Shareholding and Changes of Shares Held by Directors and Senior Management of Listed Companies," "Self-Regulatory Guidelines for Listed Companies on the Shenzhen Stock Exchange No. 1 - Standardized Operations of Main Board Listed Companies," "Self-Regulatory Guidelines for Listed Companies on the Shenzhen Stock Exchange No. 10 - Management of Share Changes," and relevant provisions of the "Articles of Association of Zhejiang Kaineng Special Materials Co., Ltd." (hereinafter referred to as "the Articles of Association"), combined with the actual situation of the Company.
Article 2
This system applies to the management of shares held and changes thereof by the Company's directors and senior management.
Article 3
Shares held by the Company's directors and senior management refer to all shares registered in their names and all shares held in the Company's name through others' accounts. If directors and senior management engage in margin trading, the shares held also include those recorded in their margin accounts.
Article 4
If directors and senior management plan to trade the Company's securities, they must fill out the "Inquiry Letter for Trading the Company's Securities" (Attachment 1) and submit it to the Board of Directors three trading days prior to the transaction. The Board Secretary is responsible for confirmation. Upon receiving the "Inquiry Letter for Trading the Company's Securities," the Board Secretary shall verify the Company's information disclosure and the progress of significant matters, forming a clear opinion of agreement or disagreement, and fill out the "Confirmation Letter Regarding Inquiry on Trading the Company's Securities" (Attachment 2), which must be delivered to the inquirer before the planned transaction time. If the trading behavior may violate laws, regulations, relevant provisions of the Shenzhen Stock Exchange, or the Articles of Association, the Board Secretary shall promptly notify the relevant directors and senior management in writing. Directors and senior management shall not engage in trading of the Company's securities without the confirmation letter from the Board Secretary. If the Board Secretary trades the Company's securities, the Chairman shall confirm it according to the above requirements.
Article 5
Directors and senior management may not trade the Company's shares during the following periods:
- Within fifteen days prior to the announcement of the Company's annual report or semi-annual report; if the announcement date is postponed for special reasons, this period is calculated from fifteen days before the originally scheduled announcement date.
- Within five days prior to the announcement of the Company's quarterly report, performance forecast, or performance brief.
- From the occurrence date of significant matters that may have a major impact on the trading price of the Company's stock and its derivatives, until the date of legal disclosure.
- Within six months after purchasing the Company's stock, or within six months after selling.
- Other periods as stipulated by national laws and regulations, the China Securities Regulatory Commission, and the Shenzhen Stock Exchange.
The above items (1)-(3) include the spouses of the securities affairs representatives and the aforementioned personnel.